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  • LORI BUSH -V- ST BERNADINE MEDICAL CENTER Print Medical Malpractice Unlimited  document preview
  • LORI BUSH -V- ST BERNADINE MEDICAL CENTER Print Medical Malpractice Unlimited  document preview
  • LORI BUSH -V- ST BERNADINE MEDICAL CENTER Print Medical Malpractice Unlimited  document preview
  • LORI BUSH -V- ST BERNADINE MEDICAL CENTER Print Medical Malpractice Unlimited  document preview
						
                                

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THOMPSON & COLEGATE LLP 3610 Fourteenth Street P. O. Box 1299 SUPERIOR golulfirgFgAuFORNlA Riverside, California 92502 COUNTY 0F SAN BERNARDINO Tel: (951) 682-5550 Fax: (951) 731-4012 APR 2O 2023 DIANE MAR WIESMANN (SBN 124409) . dwiesmann@tclaw.net BY: Rina JUSTIN J. JANZEN (SBN 242556) Phillips Deputy jjanzen@tclaw.net Attorneys for Defendant/Cross-Complainant, DIGNITY HEALTH, erroneously sued and served as ST. BERNARDINE MEDICAL CENTER and Examinee KURT WEINMIESTER SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO, SAN BERNARDINO DISTRICT LORI BUSH, an individual; CASE NO. CIVDSl613161 Plaintiff, Dept: S30 14 V. DIGNITY HEALTH AND KURT WEINMEISTER’S NOTICE OF 15 ST. BERNARDINE MEDICAL CENTER, a MOTION AND MOTION FOR business entity form unknown; DIGNITY PROTECTIVE ORDER RE ORDER 16 HEALTH, a California Corporation; and DOES TO APPEAR FOR EXAMINATION; 1 through 200, inclusive, MEMORANDUM 0F POINTS AND 17 AUTHORITIES; DECLARATION OF Defendants. JUSTIN J. JANZEN, ESQ. IN 18 SUPPORT THEREOF DIGNITY HEALTH, DATE: June 22, 2023 20 Cross-Complainant, TIME: 8:30 a.m. DEPT: S30 21 v. 22 TOTAL PROFESSIONAL NETWORK. INC, and ROES 1—100, inclusive, Cross—Defendants. 24 25 TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD: 26 PLEASE TAKE NOTICE that 0n June 22. 2023 at 8:30 a.m. in Department S30 0fthe above- 27 entitled Court, Defendant DIGNITY HEALTH and examinee KURT WEINMEISTER will and 28 hereby d0 move this Court for a protective order in regards to the Order 10 Appear for Examination on 1 DIGNITY HEALTH’S NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER RE ORDER TO APPEAR FOR EXAMINATION May 8, 2023, served 0n Kurt Weinmeister. This Motion is based upon the fact that the witnesses is not appropriately named and the examination is improper as Defendant has a complaint in interpleader pending, so a judgment debtor exam has n0 relevance 0r legitimate purpose. This Motion will be based upon this Notice, the pleadings, records and files herein, upon the Declaration 0f Justin J. Janzen, Esq., the Memorandum 0f Points and Authorities, and 0n such further and other evidence as may be presented at the hearing 0f this Motion. DATED: April M2023 THOMPSON TE LLP 10 By: DIAN M WIESMANN 11 JUS . JANZEN Attme s for Defendant/Cross-Complainant, 12 DIGNITY HEALTH, erroneously sued and BERNARDINE MEDICAL served as ST. 13 CENTER and Examinee KURT WEINMIESTER 14 15 16 20 21 22 23 24 25 26 27 28 2 DIGNITY HEALTH’S NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER RE ORDER TO APPEAR FOR EXAMINATION