On August 10, 2016 a
Motion,Ex Parte
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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\a
ORIGINAL
THOMPSON & COLEGATE LLP
3610 Fourteenth Street
P. O. Box 1299 F I LE D
Riverside, California 92502 SUPERIOR COURT 0F CAUFORNIA
COUNTY 0F SAN BERNARDINO
Tel: (951) 682-5550 SAN BERNARowo DISTRICT
Fax: (951) 781-4012
JUL 12 2022
DIANE MAR WIESMANN (SBN
dwicsmaam®talawnet
SUSAN KNOCK BECK (SBN 230948)
slacckamclawnct
JUSTIN J. JANZEN (SBN 242556)
124409)
BY -—%—
PAO E AN Z. DEPUTY
iianzcngr’iflclawnc:
Attorneys for Defendant/Cross—Complainant, DIGNITY HEALTH
(erroneously sued and served as ST. BERNARDINE MEDICAL CENTER)
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO, SAN BERNARDINO DISTRICT GE‘IH
LORI BUSH, an individual; CASE NO. CIVDSl613161
A8
Plaintiff, Hon. John M. Pacheco
Dept: 83 1
v.
EX PARTE APPLICATION FOR XVfl
ST. BERNARDINE MEDICAL CENTER, a TEMPORARY STAY OF
business entity form unknown; DIGNITY ENFORCEMENT OF JUDGMENT (CODE
HEALTH, a California Corporation; and DOES OF CIVIL PROCEDURE SECTION 918);
1 through 200, inclusive, DECLARATIONS OF SUSAN KNOCK
BECK AND CORYNTHIA WINCN
Defendants.
DATE: July l3, 2022
TIME: 8:30 a.m.
DIGNITY HEALTH, DEPT: S31
Cross-Complainant, TRIAL DATE: 02/14/2022
ACTION FILED: 11/08/2016 (FAC)
V‘
TOTAL PROFESSIONAL NETWORK, INC.,
and ROES 1-100, inclusive,
Cross-Defendants.
///
1
EX PARTE APPLICATION FOR TEMPORARY STAY OF ENFORCEMENT OF JUDGMENT (CODE OF CIVIL
PROCEDURE SECTION 918, SUBDIVISION (A); DECLARATIONS OF SUSAN KNOCK BECK AND
CORYNTHIA WINCN THEREOF
TO THIS HONORABLE COURT, TO PLAINTIFF LORI BUSH AND TO HER
ATTORNEY OF RECORD:
Defendant DIGNITY HEALTH (“Defendant”) hereby requests that this Court stay the
enforcement of the judgment filed May 23, 2022 in this case pursuant to Code of Civil Procedure
section 91 8. Defendant has now filed a Motion for Judgment Notwithstanding the Verdict
(“JNOV”) pursuant to Code 0f Civil Procedure sections 629 and 660, subdivision (c). Pursuant t0
Code of Civil Procedure section 918, subdivision (b), Defendant requests that the stay remain in
effect until 10 days after the time to appeal under Rule 8.1 08(d) 0f the California Rules 0f Court.
The stay is necessary to permit Defendant to obtain meaningful judicial review 0f this Court’s
10 judgment by way of its JNOV motion and, possibly, in the appellate courts.
ll This application is based on this Ex Part6 Application, the attached declaration of Susan
12 Knock Beck, and all of the files and records in this case.
13 DATED: July 7, 2022 THOMPSON & COLEGATE LLP
n
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Bv.
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DIANE MAR WIESMANN
V» ,
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SUSAN KNOCK BECK
JUSTINJ. JANZEN
Attorneys for Defendant/Cross—Complainant,
DIGNITY HEALTH (erroneously sued and
served as ST. BERNARDINE MEDICAL
CENTER)
20
21
22
23
24
25
26
27
28
2
EX PARTE APPLICATION FOR TEMPORARY STAY OF ENFORCEMENT OF JUDGMENT (CODE OF CIVIL
PROCEDURE SECTION 918, SUBDIVISION (A); DECLARATIONS OF SUSAN KNOCK BECK AND
CORYNTHIA WINCN THEREOF
Document Filed Date
July 12, 2022
Case Filing Date
August 10, 2016
Category
Medical Malpractice Unlimited
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\a ORIGINAL THOMPSON & COLEGATE LLP 3610 Fourteenth Street P. O. Box 1299 F I LE D Riverside, California 92502 SUPERIOR COURT 0F CAUFORNIA COUNTY 0F SAN BERNARDINO Tel: (951) 682-5550 SAN BERNARowo DISTRICT Fax: (951) 781-4012 JUL 12 2022 DIANE MAR WIESMANN (SBN dwicsmaam®talawnet SUSAN KNOCK BECK (SBN 230948) slacckamclawnct JUSTIN J. JANZEN (SBN 242556) 124409) BY -—%— PAO E AN Z. DEPUTY iianzcngr’iflclawnc: Attorneys for Defendant/Cross—Complainant, DIGNITY HEALTH (erroneously sued and served as ST. BERNARDINE MEDICAL CENTER) SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO, SAN BERNARDINO DISTRICT GE‘IH LORI BUSH, an individual; CASE NO. CIVDSl613161 A8 Plaintiff, Hon. John M. Pacheco Dept: 83 1 v. EX PARTE APPLICATION FOR XVfl ST. BERNARDINE MEDICAL CENTER, a TEMPORARY STAY OF business entity form unknown; DIGNITY ENFORCEMENT OF JUDGMENT (CODE HEALTH, a California Corporation; and DOES OF CIVIL PROCEDURE SECTION 918); 1 through 200, inclusive, DECLARATIONS OF SUSAN KNOCK BECK AND CORYNTHIA WINCN Defendants. DATE: July l3, 2022 TIME: 8:30 a.m. DIGNITY HEALTH, DEPT: S31 Cross-Complainant, TRIAL DATE: 02/14/2022 ACTION FILED: 11/08/2016 (FAC) V‘ TOTAL PROFESSIONAL NETWORK, INC., and ROES 1-100, inclusive, Cross-Defendants. /// 1 EX PARTE APPLICATION FOR TEMPORARY STAY OF ENFORCEMENT OF JUDGMENT (CODE OF CIVIL PROCEDURE SECTION 918, SUBDIVISION (A); DECLARATIONS OF SUSAN KNOCK BECK AND CORYNTHIA WINCN THEREOF TO THIS HONORABLE COURT, TO PLAINTIFF LORI BUSH AND TO HER ATTORNEY OF RECORD: Defendant DIGNITY HEALTH (“Defendant”) hereby requests that this Court stay the enforcement of the judgment filed May 23, 2022 in this case pursuant to Code of Civil Procedure section 91 8. Defendant has now filed a Motion for Judgment Notwithstanding the Verdict (“JNOV”) pursuant to Code 0f Civil Procedure sections 629 and 660, subdivision (c). Pursuant t0 Code of Civil Procedure section 918, subdivision (b), Defendant requests that the stay remain in effect until 10 days after the time to appeal under Rule 8.1 08(d) 0f the California Rules 0f Court. The stay is necessary to permit Defendant to obtain meaningful judicial review 0f this Court’s 10 judgment by way of its JNOV motion and, possibly, in the appellate courts. ll This application is based on this Ex Part6 Application, the attached declaration of Susan 12 Knock Beck, and all of the files and records in this case. 13 DATED: July 7, 2022 THOMPSON & COLEGATE LLP n ”WJ'WW Bv. _'{ r - / r» >//’%'5“-~ DIANE MAR WIESMANN V» , g. . '2 ,«,-,...—-m- ~ SUSAN KNOCK BECK JUSTINJ. JANZEN Attorneys for Defendant/Cross—Complainant, DIGNITY HEALTH (erroneously sued and served as ST. BERNARDINE MEDICAL CENTER) 20 21 22 23 24 25 26 27 28 2 EX PARTE APPLICATION FOR TEMPORARY STAY OF ENFORCEMENT OF JUDGMENT (CODE OF CIVIL PROCEDURE SECTION 918, SUBDIVISION (A); DECLARATIONS OF SUSAN KNOCK BECK AND CORYNTHIA WINCN THEREOF