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.
Preview
LAW OFFICES 0F MICHAEL J. LIBMAN, APC
MICHAEL J. LIBMAN (SBN 222353)
ZHANNA SANAMYAN (SBN 337133)
18321 Ventura Boulevard, Suite 700
Tarzana, California 91356
Telephone: (81 8) 995—7300
Facsimile: (866) 644—6764
'
SUPOERIORFco'UlfiTEFRCDALIFORNm
mil@libmanlaw.com C&figgfiAwNBg ”NcAm'cfiro
GARY BERKOVICH (SBN 192731)
A PROFESSIONAL CORPORATION FEB 14 2022
14900 Ventura Boulevard, Suite 220
Sherman Oaks, California 91403
Telephone: (8 1 8) 465-9505
Facsimile: (818) 358-2829
10 Attorneys for Plaintiff, LORI BUSH
ll-
SUPERIOR COURT OF THE STATE OF CALIFORNIA
12
FOR THE COUNTY OF SAN BERNARDINO
13
LORI BUSH, an individual; CASE NUMBER: CIVDSl613161
l4
Hon. John M. Pacheco
15 Plaintiff,
Dept: S31
vs.
l6
MOTION IN LIMINE No.
PLAINTIFF’S
17
1FOR AN ORDER PRECLUDING
ST. BERNARDINE MEDICAL CENTER, a REFERENCE T0 PLAINTIFF’S
18 business entity form unknown; DIGNITY RETAINED EXPERT SERGE
HEALTH, a California Corporation; and OBUKHOFF, M.D.’s MEDICAL
l9 DOES 1 through 200, inclusive
VVVVVVVVVVVVVVVVV
MALPRACTICE ACTIONS; [PROPOSED
ORDER]
20
Defendants. DECLARATION 0F MICHAEL J.
21 LIBMAN, ESQ. FILED CONCURENTLY
22 Trial Date: February 7, 2022
23
24
25
TO THE HONORABLE COURT, DEFENDANTS AND THEIR RESPECTIVE
26
ATTORNEYS OF RECORD:
27 PLEASE TAKE NOTICE that on the above date and time in Dept. S31 of San
28 Bemardino Superior Court located at 247 w. 3rd Street, San Bemardino, CA 92415, Plaintiff
LORI BUSH hereby moves this court for an Order In Limine No. 1 for an order excluding any
1
PLAINTIFF’S MOTION IN LIMINE NO. FOR AN ORDER PRECLUDING REFERENCE TO PLAINTIFF’S
l
RETAINED EXPERT SERGE OBUKHOFF, M.D.’S MEDICAL MALPRACTICE ACTIONS
and all evidence, references to evidence, testimony and argument relating Plaintiff‘s retained
expert witness Serge Obukhoff, M.D.’s medical malpractice incidents of approximately
Melt!
years ago. Plaintiff fixrther moves for an order instructing all other counsel in this action, and
requiring counsel to advise all witness: (1) not to mention, refer to or contempt to the jury in any
manner, either directly or indirectly, any of the facts mentioned in this action; (2) not to make
any reference to the fact that this motion has been filed, and (3) to warn each and every witness
to strictly follow the same instructions.
This motion is based upon the grounds that such evidence or reference is speculative,
irrelevant, and prejudicial to Plaintiff. The motion is further based upon the supporting
lO Memorandum of Points and Authorities, the pleadings and papers on file in this action, and upon
ll such argument and evidence
12
13
l4
15
DATED: January 25, 2022
By:
W MM
LAW OFFICES OF MICHAEL LIBMAN, APC
fl
J.
[E-Signature]
l6
MICHAEL J. LIBMAN
l7 BUSH
Attorneys for Plaintiff LORI
18
l9
20
21
22
23
24
25
26
27
28
2
PLAINTIFF’S MOTION IN LIMINE NO. FOR AN ORDER PRECLUDING REFERENCE TO PLAINTIFF’S
l
RETAINED EXPERT SERGE OBUKHOFF, M.D.’S MEDICAL MALPRACTICE ACTIONS
Document Filed Date
February 14, 2022
Case Filing Date
August 10, 2016
Category
Medical Malpractice Unlimited
For full print and download access, please subscribe at https://www.trellis.law/.