On August 10, 2016 a
Motion-Secondary
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
361 0 Fourteenth Street
P.O.Box1299
Riverside, California 92502
FILED
SUPERIOR COURT 0F CALIFORNIA
m: (951) 6826550
Fax: (951) 781-4012
SAME“;
NOV 14 2022
DIANE MAR WIESMANN (SBN 124409)
gwiesmanngbtclawnet
JUSTIN J. JANZEN (SBN 242556) 3y
jianzenKaZtclawnet PAO AN Z, DEPUTY
Attorneys for Defendant/Cross-Complainant,
DIGNITY HEALTH ‘8
(erroneously sued and served as ST. BBRNARDINE MEDICAL CENTER) x93
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY 0F SAN BERNARDINO, SAN BERNARDINO DISTRICT
LORI BUSH, an individual; CASE NO. CIVDS l 61 3 1 61
Plaintiff, Hon. John M. Pacheco
Dept: S31
v‘
ST. BERNARDINE MEDICAL CENTER, a OBJECTION TO PLAINTIFF'S
business entity f01m unknown; DIGNITY [PROPOSED] CORRECTED ORDER ON
HEALTH, a. California Corporation; and DOES REQUEST FOR COSTS 0F PROOF
1 through 200, inclusive, PURSUANT T0 THE COURT‘S MINUTE
ORDER OF OCTOBER 14, 2022
Defendants.
DIGNITY HEALTH, TRIAL DATE: 02/14/2022
ACTION FILED: 1 1/08/201 6 (FAC)
2O Cross—Complainant,
v.
21
TOTAL PROFESSIONAL NETWORK, INC.,
22 and ROES 1-100, inclusive,
23 Cross-Defendants.
24
25 Defendant, DIGNITY HEALTH herein objects to plaintiff‘s Proposed Corrected Order based
26 upon this court's ruling on submitted matter dated October 14, 2022, on the grounds that it refers to
27 the recoverable amount of $125,981 .25 as a "cost" item to be added to the judgment. In fact, the
28 court's calculations in its minute order on submitted matter refer only to the amount of time spent by
1
OBJECTION TO PROPOSED CORRECTED ORDER
11/34/202? MQN 15:23 FAx" w» SBsc Central I003/005
the attorneys in various aspects of their work up and at trial, and the court expressly declined t0
"costs"
order any additional "costs" in its ruling, by stating that plaintiffs request to again recover
via her cost bill, already subject 10 a Motion to Tax, is improper. The court's minute order addresses
the amount of attorney time that is recoverable by plaintiff, thus referring to attorney fees, and not
hard "costs," which were denied.
Therefore, defendant objects to the statement in the Corrected Order directing the Clerk to
add this ”cost" item t0 the judgment, and requests that the court strike the term "cost" from the last
line of the Corrected Order.
Defendant has no objection to the amount of $125,981 .25 as set forth in the Corrected Order.
DATED: November 14, 2022 TH ON & COLEGATE LLP
I3 gmMUM
DIANE MAR" WIE'SMANN
r
Attomeys for Defendant/Cross-Complainant,
DIGNITY HEALTH dba ST. BERNARDINB
MEDICAL CENTER
20
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22
23
24
25
26
27
28
2
OBJECT!ON TO PROPOSED CORRECTED ORDER
Document Filed Date
November 14, 2022
Case Filing Date
August 10, 2016
Category
Medical Malpractice Unlimited
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11414/3m2 Mpn 15:21 FAx" «a rsasc Central ' Iooz/oos \r \r THOMPSON & COLEGATE LLP 361 0 Fourteenth Street P.O.Box1299 Riverside, California 92502 FILED SUPERIOR COURT 0F CALIFORNIA m: (951) 6826550 Fax: (951) 781-4012 SAME“; NOV 14 2022 DIANE MAR WIESMANN (SBN 124409) gwiesmanngbtclawnet JUSTIN J. JANZEN (SBN 242556) 3y jianzenKaZtclawnet PAO AN Z, DEPUTY Attorneys for Defendant/Cross-Complainant, DIGNITY HEALTH ‘8 (erroneously sued and served as ST. BBRNARDINE MEDICAL CENTER) x93 SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY 0F SAN BERNARDINO, SAN BERNARDINO DISTRICT LORI BUSH, an individual; CASE NO. CIVDS l 61 3 1 61 Plaintiff, Hon. John M. Pacheco Dept: S31 v‘ ST. BERNARDINE MEDICAL CENTER, a OBJECTION TO PLAINTIFF'S business entity f01m unknown; DIGNITY [PROPOSED] CORRECTED ORDER ON HEALTH, a. California Corporation; and DOES REQUEST FOR COSTS 0F PROOF 1 through 200, inclusive, PURSUANT T0 THE COURT‘S MINUTE ORDER OF OCTOBER 14, 2022 Defendants. DIGNITY HEALTH, TRIAL DATE: 02/14/2022 ACTION FILED: 1 1/08/201 6 (FAC) 2O Cross—Complainant, v. 21 TOTAL PROFESSIONAL NETWORK, INC., 22 and ROES 1-100, inclusive, 23 Cross-Defendants. 24 25 Defendant, DIGNITY HEALTH herein objects to plaintiff‘s Proposed Corrected Order based 26 upon this court's ruling on submitted matter dated October 14, 2022, on the grounds that it refers to 27 the recoverable amount of $125,981 .25 as a "cost" item to be added to the judgment. In fact, the 28 court's calculations in its minute order on submitted matter refer only to the amount of time spent by 1 OBJECTION TO PROPOSED CORRECTED ORDER 11/34/202? MQN 15:23 FAx" w» SBsc Central I003/005 the attorneys in various aspects of their work up and at trial, and the court expressly declined t0 "costs" order any additional "costs" in its ruling, by stating that plaintiffs request to again recover via her cost bill, already subject 10 a Motion to Tax, is improper. The court's minute order addresses the amount of attorney time that is recoverable by plaintiff, thus referring to attorney fees, and not hard "costs," which were denied. Therefore, defendant objects to the statement in the Corrected Order directing the Clerk to add this ”cost" item t0 the judgment, and requests that the court strike the term "cost" from the last line of the Corrected Order. Defendant has no objection to the amount of $125,981 .25 as set forth in the Corrected Order. DATED: November 14, 2022 TH ON & COLEGATE LLP I3 gmMUM DIANE MAR" WIE'SMANN r Attomeys for Defendant/Cross-Complainant, DIGNITY HEALTH dba ST. BERNARDINB MEDICAL CENTER 20 21 22 23 24 25 26 27 28 2 OBJECT!ON TO PROPOSED CORRECTED ORDER