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v ORIGINAL v
F LE l D
SUPERIORCOURT
”O ”3mm
THOMPSON & COLEGATE LLP
3610 Fourteenth Street OCT 0 5 2022
P. 0. Box 1299
Riverside, California 92502
Tel: (951) 682-5550
BY Q¥v> é”
c
Fax: (951) 781-4012 DEW
DIANE MAR WIESMANN (SBN 124409)
Samantha Becerra
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JUSTIN J. JANZEN (SBN 242556)
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Attorneys for Defendant/Cross—Complainant,
DIGNITY HEALTH
(erroneously sued and served as ST. BERNARDINE MEDICAL CENTER)
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO, SAN BERNARDINO DISTRICT
LORI BUSH, an individual; CASE NO. CIVDSI613161 0311::
Plaintiff, Hon. John M. Pacheco
Dept: S31
15 v,
16 ST. BERNARDINE MEDICAL CENTER, a NOTICE OF LIEN A9
business entity form unknown; DIGNITY
l7 HEALTH, a California Corporation; and DOES
1 through 200, inclusive, TRIAL DATE: 02/14/2022 xva
ACTION FILED: 11/08/2016 (FAC)
Defendants.
20 DIGNITY HEALTH,
21 Cross-Complainant,
22 V.
23 TOTAL PROFESSIONAL NETWORK, INC,
and ROES 1—100, inclusive,
24
Cross—Defendants.
25
26
27 ///
28 ///
1
NOTICE OF LIEN
TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:
{Q PLEASE TAKE NOTICE 0f the attached Order from the Los Angeles Superior Court in the
case ofAntwon Jones, et al., v. City ofLos Angeles, e! al., LEAD CASE NUMBER BC577267
[RELATED TO CASE NOS. BC536272, BC565618, BC568722, BC571664, BC594049, and
BC574690], granting the Jones Class Action’s Motion for an Assignment Order Against Judgment
Debtors Michael J. Libman and the Law Offices 0f Michael J. Libman, pursuant to Code 0f Civil
Procedure section 708.5 1 0. Said Order was received in the office of defense counsel 0n October 3,
2022, and is attached as Exhibit "A."
Based upon said Order, defendant DIGNITY HEALTH hereby requests that any amount
ordered by this court as a result of the pending motion for costs and fees set for further hearing on
October 12, 2022, be made payable as set forth in the attached order. In the alternative, defendant
DIGNITY HEALTH requests that the court allow it t0 deposit the funds ordered with the court and
disbursed through the Interpleader process.
On September 23, 2022, defendant DIGNITY HEALTH disbursed a check in the amount of
$2,329,373.48 made payable t0 Lori Bush, and the Law Office of Michael J. Libman, APC and Law
Offices 0f Gary Berkovich, APC. Said amount constituted a Partial Satisfaction 0f the Judgment
(inclusive ofjury award, net cost award, and interest) as follows:
Judgment Amount: $ l ,616,390.29
Daily Interest (from Judgment date 0f 4/27/1 8-9/23/22): $7125983.19
Total: $2,329,373.48
Said check has cleared the financial institutions and has been paid. Mr. Libman has declined
t0 sign a Notice OfPartial Satisfaction 0f Judgment at the time these funds were disbursed, stating he
would wait until the instant hearing. Then Mr. Libman stated that if the court ordered less than what
he requested in his pending motion, he would appeal said ruling.
Once the funds as ordered by this court are deposited 0r disbursed, defendant DIGNITY
HEALTH will request that this court provide a Judicial Satisfaction 0f Judgment for the full amount.
2
NOTICE 0F LIEN
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v ORIGINAL v F LE l D SUPERIORCOURT ”O ”3mm THOMPSON & COLEGATE LLP 3610 Fourteenth Street OCT 0 5 2022 P. 0. Box 1299 Riverside, California 92502 Tel: (951) 682-5550 BY Q¥v> é” c Fax: (951) 781-4012 DEW DIANE MAR WIESMANN (SBN 124409) Samantha Becerra dwiesnmnm‘rbtclawnct JUSTIN J. JANZEN (SBN 242556) iianzcngfimflgmflq Attorneys for Defendant/Cross—Complainant, DIGNITY HEALTH (erroneously sued and served as ST. BERNARDINE MEDICAL CENTER) SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO, SAN BERNARDINO DISTRICT LORI BUSH, an individual; CASE NO. CIVDSI613161 0311:: Plaintiff, Hon. John M. Pacheco Dept: S31 15 v, 16 ST. BERNARDINE MEDICAL CENTER, a NOTICE OF LIEN A9 business entity form unknown; DIGNITY l7 HEALTH, a California Corporation; and DOES 1 through 200, inclusive, TRIAL DATE: 02/14/2022 xva ACTION FILED: 11/08/2016 (FAC) Defendants. 20 DIGNITY HEALTH, 21 Cross-Complainant, 22 V. 23 TOTAL PROFESSIONAL NETWORK, INC, and ROES 1—100, inclusive, 24 Cross—Defendants. 25 26 27 /// 28 /// 1 NOTICE OF LIEN TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD: {Q PLEASE TAKE NOTICE 0f the attached Order from the Los Angeles Superior Court in the case ofAntwon Jones, et al., v. City ofLos Angeles, e! al., LEAD CASE NUMBER BC577267 [RELATED TO CASE NOS. BC536272, BC565618, BC568722, BC571664, BC594049, and BC574690], granting the Jones Class Action’s Motion for an Assignment Order Against Judgment Debtors Michael J. Libman and the Law Offices 0f Michael J. Libman, pursuant to Code 0f Civil Procedure section 708.5 1 0. Said Order was received in the office of defense counsel 0n October 3, 2022, and is attached as Exhibit "A." Based upon said Order, defendant DIGNITY HEALTH hereby requests that any amount ordered by this court as a result of the pending motion for costs and fees set for further hearing on October 12, 2022, be made payable as set forth in the attached order. In the alternative, defendant DIGNITY HEALTH requests that the court allow it t0 deposit the funds ordered with the court and disbursed through the Interpleader process. On September 23, 2022, defendant DIGNITY HEALTH disbursed a check in the amount of $2,329,373.48 made payable t0 Lori Bush, and the Law Office of Michael J. Libman, APC and Law Offices 0f Gary Berkovich, APC. Said amount constituted a Partial Satisfaction 0f the Judgment (inclusive ofjury award, net cost award, and interest) as follows: Judgment Amount: $ l ,616,390.29 Daily Interest (from Judgment date 0f 4/27/1 8-9/23/22): $7125983.19 Total: $2,329,373.48 Said check has cleared the financial institutions and has been paid. Mr. Libman has declined t0 sign a Notice OfPartial Satisfaction 0f Judgment at the time these funds were disbursed, stating he would wait until the instant hearing. Then Mr. Libman stated that if the court ordered less than what he requested in his pending motion, he would appeal said ruling. Once the funds as ordered by this court are deposited 0r disbursed, defendant DIGNITY HEALTH will request that this court provide a Judicial Satisfaction 0f Judgment for the full amount. 2 NOTICE 0F LIEN