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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THOMPSON & COLEGATE LLP
F L E D
3610 Fourteenth Street
P. O. Box 1299
mam count
I
wound
comm or 5m aenumomo
0F
Riverside, California 92502 IAN aemtmnn CML MON
Tel: (951) 682-5550
Fax: (951) 781—4012
FEB 1 0 2022
Y/
DIANE MAR WIESMANN (SBN
dwiesmann@tclaw.net
JUSTIN J. JANZEN (SBN 242556)
jjanzen@tclaw.net
124409)
P3013 Hemandez
m
Attorneys for Defendant/Cross-Complainant, DIGNITY HEALTH, erroneously sued and
served as ST. BERNARDINE MEDICAL CENTER
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10
FOR THE COUNTY OF SAN BERNARDINO, SAN BERNARDINO DISTRICT
ll
12
LORI BUSH, an individual; CASE NO. CIVDSl613161
13
Plaintiff, JUDGE: Hon. John M. Pacheco
14 Dept: S3 1
V.
15 MOTION IN LIMINE #5 FOR AN ORDER
ST. BERNARDINE MEDICAL CENTER, a PRECLUDING PLAINTIFF’S USE OF
16 business entity form unknown; DIGNITY IRRELEVANT AND PREJUDICIAL
HEALTH, a California Corporation; and DOES EVIDENCE OR ARGUMENT AT TRIAL
I7 1 through 200, inclusive, KNOWN AS THE “REPTILE THEORY”
18 Defendants.
19 TRIAL DATE: 02/14/2022
DIGNITY HEALTH, ACTION FILED: 11/08/2016 (PAC)
20
Cross—Complainant,
21
v.
22
TOTAL PROFESSIONAL NETWORK, INC.,
23 and ROES 1-100, inclusive,
24 Cross-Defendants.
25
26
Defendant, DIGNITY HEALTH, respectfully moves this court for an order precluding plaintiff
27
and her counsel’s use of irrelevant and prejudicial evidence 0r argument at trial known as the “Reptile
28
DEFENDANT DIGNITY HEALTH'S MOTION IN LIMINE #5
\4 V
Theory.” This would include any evidence, testimony, or reference during voir dire, opening statement,
witness examinations, or closing arguments, based on “Reptile Theory” arguments.
This motion is based upon all 0f the papers and records on file in this case, the attached
memorandum 0f points and authorities, and upon such further oral and documentary evidence as may
be presented at the time 0f the hearing on this motion.
DATED: February 7, 2022 THOMPSO E ATE LLP
By:
DIANEMAR WIESMANN
10 JUSTIN J. JANZEN
Attorneys for Defendant/Cross-Complainant,
11 DIGNITY HEALTH, erroneously sued and
served as ST. BERNARDINE MEDICAL
12 CENTER
13
14
15
I6
18
19
20
21
22
23
24
25
26
27
28
2
DEFENDANT DIGNITY HEALTH'S MOTION IN LIMINE #5
Document Filed Date
February 10, 2022
Case Filing Date
August 10, 2016
Category
Medical Malpractice Unlimited
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THOMPSON & COLEGATE LLP F L E D 3610 Fourteenth Street P. O. Box 1299 mam count I wound comm or 5m aenumomo 0F Riverside, California 92502 IAN aemtmnn CML MON Tel: (951) 682-5550 Fax: (951) 781—4012 FEB 1 0 2022 Y/ DIANE MAR WIESMANN (SBN dwiesmann@tclaw.net JUSTIN J. JANZEN (SBN 242556) jjanzen@tclaw.net 124409) P3013 Hemandez m Attorneys for Defendant/Cross-Complainant, DIGNITY HEALTH, erroneously sued and served as ST. BERNARDINE MEDICAL CENTER SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 FOR THE COUNTY OF SAN BERNARDINO, SAN BERNARDINO DISTRICT ll 12 LORI BUSH, an individual; CASE NO. CIVDSl613161 13 Plaintiff, JUDGE: Hon. John M. Pacheco 14 Dept: S3 1 V. 15 MOTION IN LIMINE #5 FOR AN ORDER ST. BERNARDINE MEDICAL CENTER, a PRECLUDING PLAINTIFF’S USE OF 16 business entity form unknown; DIGNITY IRRELEVANT AND PREJUDICIAL HEALTH, a California Corporation; and DOES EVIDENCE OR ARGUMENT AT TRIAL I7 1 through 200, inclusive, KNOWN AS THE “REPTILE THEORY” 18 Defendants. 19 TRIAL DATE: 02/14/2022 DIGNITY HEALTH, ACTION FILED: 11/08/2016 (PAC) 20 Cross—Complainant, 21 v. 22 TOTAL PROFESSIONAL NETWORK, INC., 23 and ROES 1-100, inclusive, 24 Cross-Defendants. 25 26 Defendant, DIGNITY HEALTH, respectfully moves this court for an order precluding plaintiff 27 and her counsel’s use of irrelevant and prejudicial evidence 0r argument at trial known as the “Reptile 28 DEFENDANT DIGNITY HEALTH'S MOTION IN LIMINE #5 \4 V Theory.” This would include any evidence, testimony, or reference during voir dire, opening statement, witness examinations, or closing arguments, based on “Reptile Theory” arguments. This motion is based upon all 0f the papers and records on file in this case, the attached memorandum 0f points and authorities, and upon such further oral and documentary evidence as may be presented at the time 0f the hearing on this motion. DATED: February 7, 2022 THOMPSO E ATE LLP By: DIANEMAR WIESMANN 10 JUSTIN J. JANZEN Attorneys for Defendant/Cross-Complainant, 11 DIGNITY HEALTH, erroneously sued and served as ST. BERNARDINE MEDICAL 12 CENTER 13 14 15 I6 18 19 20 21 22 23 24 25 26 27 28 2 DEFENDANT DIGNITY HEALTH'S MOTION IN LIMINE #5