On August 10, 2016 a
Order of Examination
was filed
involving a dispute between
Bush, Lori,
Dignity Health, A Califonia Corporation,
and
Dignity Health, A Califonia Corporation,
St. Bernadine Medical Center A Business Entity Unknown,
Total Professional Network, Inc,
for Medical Malpractice Unlimited
in the District Court of San Bernardino County.
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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
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DIGNITY HEALTH’S NOTICE OF MOTION AND MOTION FOR PROTECTIVE ORDER RE ORDER TO
APPEAR FOR EXAMINATION
Document Filed Date
April 20, 2023
Case Filing Date
August 10, 2016
Category
Medical Malpractice Unlimited
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