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.
Preview
‘
THOMPSON & COLEGATE LLP V
§
3610 Fourteenth Street F L
r. 0. Box 1299 S UPERIOR com I
D
CfiLéFo‘m'A
Riverside, California 92502 CgfifiggggAggiFF
C D'STR'CT
Tex: (951) 682—5550
‘
.
Fax: (951) 781-4012 JUL 06 2022
DIANE MAR WIESMANN (SEN 124409)
BY
‘
dwjgg; mgmggighm gm
SUSAN KNOCK BECK; (SEN
I
230948) LETTE Roon‘ uez,
DEPUTY
fifitssigimécwwzxz
JUSTIN J. JANZEN (SEN 242556) ‘
15412123“me 1
Attorneys for Defendantx’Cross-Compiainant, DIGNITY HEALTH
i
;
(erroneously sued and served as STX BERNARDINE MEDICAL CENTER)
10
SUPERJOR COURT OF THE STATE OF CALIFORNIA
II
FOR THE COUNTY OF SAN BERNARDINO, SAN BERNARDINO PISTRICT
‘12 GE'IH
i
I3 \
LORI BUSH, an individual; CASE NO. CIVDSIéBIfiLj
14 ‘
Plaintiff, Hon. John M. Pacheco 1
A8
S31
3
Dept:
V. ‘
16 DECLARATION OF SU AN KNOCK XV:I
ST, BERNARDINE MEDICAL CENTER. a BECK 1N SUPPORT 0 HE MOTION
17 business entity form unknown; DIGNITY BY DEFENDANT DIG HEALTH
HEALTH, a California Corporation; and DOES FOR JUDGMENT NO ETHSTANDING
:3 I through 200, inclusive, THE VERDICT PURSU NT TO CODE
0F CIVIL PROCEDU SECTION 629
w Defendants.
i
?
20 TRIAL DATE: 02/1 72022
DIGNITY HEALTH ACTION FILED: 31f 2016 (FAG)
21 3
Cross—Complainang
22
v.
ORlGINAL
>3
TOTAL PROFESSIONAL NETWORK, INC, ‘
3
24 and ROES E400, inclusive, i
25 Cross—Defendants. 1
a
27
28 lff
I
DECLARATION OF SUSAN KNOCK BECK IN SUPPORT OF THE MOTION BY DEFENDANT DIGNITY
HEALTH FOR JUDGMENT NOTWITHSTANDING THE VERDiCT PURSUANT TO CODE OF CIVIL
PROCEDURE SECTION‘629 ‘
JLA
DECLARATION 0F SUSAN KNOCK BECK
1, SUSAN KNOCK BECK, deciare as follows:
1. I am Of Counsel m the law firm of Thompson 85 Colegate LLPJ attorneys of record
herein for Defendant DIGNITY HEALTH (cnoncously sued and scwcd as S'll‘. BERNARDINE
MEDICAL CENTER) (“Defendant”) I have been duly admitted to practice {lbw in the State of
California I am a Certified Specialist in Appellate Law, State Bar of Califorfjnjfia, Board of Legal
Specialization I make this declaration in support of Defendant’s MOTION‘FOR HJDGMENT
NOTWITHSTANDING THE VERDICT based on. my own persona} knowledgeflnd a review of the
10 file of this matter maintained in our ofii ces. If called upon to testify, I could midi Would competently
‘
II testify thereto,
12 2. Attached hereto as Exhibit A (“Defendant’s (Exhibits 004”) is a txfle and correct copy
13 ofthe Notice ofEntry oqudgment in this matter served by Plaintiff on June 2,1, M22,
14 3. Attached hereto as Exhibit B (“Defendant’s Exhibits 0] 6”) is a rifle and correct copy
of excerpts of a certified copy of the trial testimony ofplaintiffs expert, Eris Barihas who testified 0n
i
March 1, 20224
4. Attached hereto as Exhibit C (“Defendant’s Exhibits 029”) is a trfle and correct copy
0f excerpts of a certified copy of the triai testimony of Plaintiff’s expert, Brad AW: who testified on
March 1 2022 3
‘
5. Attached hereto as Exhibit D (“Defendant’s Exhibits 039”) is a trhe and correct copy
2! of‘excerpts of a certified copy of‘the trial testimony 0f Cory Don Cheffers, a formfit security guard for
22 Defendant, who testified on March E, 2022,
‘
‘
23 6x Attached hereto as Exhibit E (“Defendant’s Exhibits 061”) is a true and correct copy
24 0f excerpts 0f a certified copy 0f the triai testimony of Roberta Harris, RN, whqitestified on March
‘
25 2, 2022 and March 7, 2022? f
26 7A Attached hereto as Exhibit F (“Defendant’s Exhibits 083”) is at and correct copy
‘
’3
27 of excerpts of a certified copy of the trial testimony of’Carlos Rodriguez, Defend Senior Director
28 0f Facilities Management who testified 0n March 2022.
g
A
DECLARATION OF SUSAN KNGCK BECK IN SUPPORT OF THE MOTION BY DEFE! ANT DIGNITY
HEALTH FOR JUDGMENT NOTWITHSTANDING THE VERDICT PURSUANT TO C DE OF CIVXL
PROCEDURE SECTION 629
Document Filed Date
July 06, 2022
Case Filing Date
August 10, 2016
Category
Medical Malpractice Unlimited
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
‘ THOMPSON & COLEGATE LLP V § 3610 Fourteenth Street F L r. 0. Box 1299 S UPERIOR com I D CfiLéFo‘m'A Riverside, California 92502 CgfifiggggAggiFF C D'STR'CT Tex: (951) 682—5550 ‘ . Fax: (951) 781-4012 JUL 06 2022 DIANE MAR WIESMANN (SEN 124409) BY ‘ dwjgg; mgmggighm gm SUSAN KNOCK BECK; (SEN I 230948) LETTE Roon‘ uez, DEPUTY fifitssigimécwwzxz JUSTIN J. JANZEN (SEN 242556) ‘ 15412123“me 1 Attorneys for Defendantx’Cross-Compiainant, DIGNITY HEALTH i ; (erroneously sued and served as STX BERNARDINE MEDICAL CENTER) 10 SUPERJOR COURT OF THE STATE OF CALIFORNIA II FOR THE COUNTY OF SAN BERNARDINO, SAN BERNARDINO PISTRICT ‘12 GE'IH i I3 \ LORI BUSH, an individual; CASE NO. CIVDSIéBIfiLj 14 ‘ Plaintiff, Hon. John M. Pacheco 1 A8 S31 3 Dept: V. ‘ 16 DECLARATION OF SU AN KNOCK XV:I ST, BERNARDINE MEDICAL CENTER. a BECK 1N SUPPORT 0 HE MOTION 17 business entity form unknown; DIGNITY BY DEFENDANT DIG HEALTH HEALTH, a California Corporation; and DOES FOR JUDGMENT NO ETHSTANDING :3 I through 200, inclusive, THE VERDICT PURSU NT TO CODE 0F CIVIL PROCEDU SECTION 629 w Defendants. i ? 20 TRIAL DATE: 02/1 72022 DIGNITY HEALTH ACTION FILED: 31f 2016 (FAG) 21 3 Cross—Complainang 22 v. ORlGINAL >3 TOTAL PROFESSIONAL NETWORK, INC, ‘ 3 24 and ROES E400, inclusive, i 25 Cross—Defendants. 1 a 27 28 lff I DECLARATION OF SUSAN KNOCK BECK IN SUPPORT OF THE MOTION BY DEFENDANT DIGNITY HEALTH FOR JUDGMENT NOTWITHSTANDING THE VERDiCT PURSUANT TO CODE OF CIVIL PROCEDURE SECTION‘629 ‘ JLA DECLARATION 0F SUSAN KNOCK BECK 1, SUSAN KNOCK BECK, deciare as follows: 1. I am Of Counsel m the law firm of Thompson 85 Colegate LLPJ attorneys of record herein for Defendant DIGNITY HEALTH (cnoncously sued and scwcd as S'll‘. BERNARDINE MEDICAL CENTER) (“Defendant”) I have been duly admitted to practice {lbw in the State of California I am a Certified Specialist in Appellate Law, State Bar of Califorfjnjfia, Board of Legal Specialization I make this declaration in support of Defendant’s MOTION‘FOR HJDGMENT NOTWITHSTANDING THE VERDICT based on. my own persona} knowledgeflnd a review of the 10 file of this matter maintained in our ofii ces. If called upon to testify, I could midi Would competently ‘ II testify thereto, 12 2. Attached hereto as Exhibit A (“Defendant’s (Exhibits 004”) is a txfle and correct copy 13 ofthe Notice ofEntry oqudgment in this matter served by Plaintiff on June 2,1, M22, 14 3. Attached hereto as Exhibit B (“Defendant’s Exhibits 0] 6”) is a rifle and correct copy of excerpts of a certified copy of the trial testimony ofplaintiffs expert, Eris Barihas who testified 0n i March 1, 20224 4. Attached hereto as Exhibit C (“Defendant’s Exhibits 029”) is a trfle and correct copy 0f excerpts of a certified copy of the triai testimony of Plaintiff’s expert, Brad AW: who testified on March 1 2022 3 ‘ 5. Attached hereto as Exhibit D (“Defendant’s Exhibits 039”) is a trhe and correct copy 2! of‘excerpts of a certified copy of‘the trial testimony 0f Cory Don Cheffers, a formfit security guard for 22 Defendant, who testified on March E, 2022, ‘ ‘ 23 6x Attached hereto as Exhibit E (“Defendant’s Exhibits 061”) is a true and correct copy 24 0f excerpts 0f a certified copy 0f the triai testimony of Roberta Harris, RN, whqitestified on March ‘ 25 2, 2022 and March 7, 2022? f 26 7A Attached hereto as Exhibit F (“Defendant’s Exhibits 083”) is at and correct copy ‘ ’3 27 of excerpts of a certified copy of the trial testimony of’Carlos Rodriguez, Defend Senior Director 28 0f Facilities Management who testified 0n March 2022. g A DECLARATION OF SUSAN KNGCK BECK IN SUPPORT OF THE MOTION BY DEFE! ANT DIGNITY HEALTH FOR JUDGMENT NOTWITHSTANDING THE VERDICT PURSUANT TO C DE OF CIVXL PROCEDURE SECTION 629