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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LAW OFFICES OF MICHAEL J. LIBMAN, APC
MICHAEL J. LIBMAN (SBN 222353)
ZHANNA SANAMYAN (SBN 337133)
18321 Ventura Boulevard, Suite 700
Tarzana, California 91356
Telephone: (818) 995-7300
Facsimile: (866) 644-6764
mjl@libmanlaw.com
F I
SUPERIOR coulfirgrgwmaw
GARY BERKOVICH (SBN 192731)
A PROFESSIONAL CORPORATION
coumvopsm
sAN
mmm
35mm. m mam
14900 Ventura Boulevard, Suite 220 _
f
Sherman Oaks, California 91403 FEB l 4 2022
Telephone: (818) 465—9505
Facsimile: (818) 358-2829
10 Attorneys for Plaintiff, LORI BUSH
ll
12
SUPERIOR COURT OF THE STATE OF CALIFORNIA
13
FOR THE COUNTY OF SAN BERNARDINO — SAN BERNARDINO DISTRICT
l4
LORI BUSH, an individual. CASE NUMBER: CIVDSI613161
15
Hon. John M. Pacheco
Plaintiff,
16 Dept: S31
VS'
l7 PLAINTIFF’S OPPOSITION TO
18
DEFENDANT TOTAL PROFESSIONAL
NETWORK, INC’S MOTION IN LIMINE
19
ST. BERNARDINE MEDICAL CENTER, a
NO. 9 PRECLUDING 0R LIMITING
business entity form unknown; DIGNITY VVVVVVVVVVVVVVVVV PLAINTIFF’S EXPERTS FROM
20 HEALTH, a California Corporation; and
TESTIFYING AS TO MEDICARE
DOES 1 through 200, inclusive
“NEVER EVENTS”
21
DefendantS- Trial Date: February 7, 2021
22
Time: 10:00 A.M.
23 Dept. S31
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TO THE HONORABLE COURT AND DEFENDANTS BY AND THROUGH
28
THEIR COUNSEL OF RECORD:
Plaintiff LORI BUSH (“Plaintiff”) hereby opposes Defendant Total Professional
1
PLAINTIFF’S OPPOSITION TO DEFENDANT TOTAL PROFESSIONAL NETWORK, INC’S MOTION IN LIMINE NO. 9 PRECLUDING
OR LIMITING PLAINTIFF’S EXPERTS FROM TESTIFYING AS TO MEDICARE “NEVER EVENTS”
Network, Inc’s (“Defendant”) MOTION IN LIMINE NO. 7 0R LIMITING PLAINTIFF’S
EXPERTS FROM TESTIFYING AS T0 MEDICARE “NEVER EVENTS”.
This opposition shall be based on the attached memorandum of points and authorities,
all papers currently on file in this case, and any such further evidence or argument the Court
may allow at the hearing on this motion.
lO
DATED: January 25, 2022
By:
W MM
LAW OFFICE 0F MICHAEL J. LIBMAN, APC
fl [E-Signature]
Michael J. Libman
ll Attorneys for Plaintiff
LORI BUSH
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25
26
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PLAINTIFF’S OPPOSITION TO DEFENDANT TOTAL PROFESSIONAL NETWORK, INC’S MOTION IN LIMINE NO. 9 PRECLUDING
OR LIMITING PLAINTIFF’S EHERTS FROM TESTIFYING AS TO MEDICARE “NEVER EVENTS”
Document Filed Date
February 14, 2022
Case Filing Date
August 10, 2016
Category
Medical Malpractice Unlimited
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LAW OFFICES OF MICHAEL J. LIBMAN, APC MICHAEL J. LIBMAN (SBN 222353) ZHANNA SANAMYAN (SBN 337133) 18321 Ventura Boulevard, Suite 700 Tarzana, California 91356 Telephone: (818) 995-7300 Facsimile: (866) 644-6764 mjl@libmanlaw.com F I SUPERIOR coulfirgrgwmaw GARY BERKOVICH (SBN 192731) A PROFESSIONAL CORPORATION coumvopsm sAN mmm 35mm. m mam 14900 Ventura Boulevard, Suite 220 _ f Sherman Oaks, California 91403 FEB l 4 2022 Telephone: (818) 465—9505 Facsimile: (818) 358-2829 10 Attorneys for Plaintiff, LORI BUSH ll 12 SUPERIOR COURT OF THE STATE OF CALIFORNIA 13 FOR THE COUNTY OF SAN BERNARDINO — SAN BERNARDINO DISTRICT l4 LORI BUSH, an individual. CASE NUMBER: CIVDSI613161 15 Hon. John M. Pacheco Plaintiff, 16 Dept: S31 VS' l7 PLAINTIFF’S OPPOSITION TO 18 DEFENDANT TOTAL PROFESSIONAL NETWORK, INC’S MOTION IN LIMINE 19 ST. BERNARDINE MEDICAL CENTER, a NO. 9 PRECLUDING 0R LIMITING business entity form unknown; DIGNITY VVVVVVVVVVVVVVVVV PLAINTIFF’S EXPERTS FROM 20 HEALTH, a California Corporation; and TESTIFYING AS TO MEDICARE DOES 1 through 200, inclusive “NEVER EVENTS” 21 DefendantS- Trial Date: February 7, 2021 22 Time: 10:00 A.M. 23 Dept. S31 24 25 26 27 TO THE HONORABLE COURT AND DEFENDANTS BY AND THROUGH 28 THEIR COUNSEL OF RECORD: Plaintiff LORI BUSH (“Plaintiff”) hereby opposes Defendant Total Professional 1 PLAINTIFF’S OPPOSITION TO DEFENDANT TOTAL PROFESSIONAL NETWORK, INC’S MOTION IN LIMINE NO. 9 PRECLUDING OR LIMITING PLAINTIFF’S EXPERTS FROM TESTIFYING AS TO MEDICARE “NEVER EVENTS” Network, Inc’s (“Defendant”) MOTION IN LIMINE NO. 7 0R LIMITING PLAINTIFF’S EXPERTS FROM TESTIFYING AS T0 MEDICARE “NEVER EVENTS”. This opposition shall be based on the attached memorandum of points and authorities, all papers currently on file in this case, and any such further evidence or argument the Court may allow at the hearing on this motion. lO DATED: January 25, 2022 By: W MM LAW OFFICE 0F MICHAEL J. LIBMAN, APC fl [E-Signature] Michael J. Libman ll Attorneys for Plaintiff LORI BUSH 12 13 l4 15 16 l7 18 l9 20 21 22 23 24 25 26 27 28 2 PLAINTIFF’S OPPOSITION TO DEFENDANT TOTAL PROFESSIONAL NETWORK, INC’S MOTION IN LIMINE NO. 9 PRECLUDING OR LIMITING PLAINTIFF’S EHERTS FROM TESTIFYING AS TO MEDICARE “NEVER EVENTS”