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
3610 Fourteenth Street
P. O. Box 1299
Riverside, California 92502
Tel: (951) 682-5550
Fax: (951) 781-4012
DIANE MAR WIESMANN (SBN 124409)
dwiesmann@tclaw.net
JUSTIN J. JANZEN (SBN 242556)
jjanzen@tclaw.net
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
11
12
LORI BUSH, an individual; CASE NO. CIVDSI613161
l3
Plaintiff, JUDGE: Hon. John M. Pacheco
14 Dept: S3 1
v.
15 MOTION IN LIMINE #7 FOR
ST. BERNARDINE MEDICAL CENTER, a AN ORDER PRECLUDING PLAINTIFF
16 business entity form unknown; DIGNITY FROM INTRODUCING INTO EVIDENCE
HEALTH, a California Corporation; and DOES THE FULL, UNDISCOUNTED AMOUNT
17 1 through 200, inclusive, OF PLAINTIFF’S MEDICAL BILLS
18 Defendants.
TRIAL DATE: 02/14/2022
19 ACTION FILED: 11/08/2016 (FAC)
DIGNITY HEALTH,
20
Cross-Complainant,
21
v.
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TOTAL PROFESSIONAL NETWORK, INC.,
23 andROES 1-100, inclusive,
24 Cross—Defendants.
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Defendant, DIGNITY HEALTH, respectfully moves this court for an order precluding plaintiff
27
or plaintiffs witnesses from offering testimony, evidence or argument concerning amounts 0f any
28
DEFENDANT DIGNITY HEALTH‘S MOTION IN LIMINE #7
\r \r
medical damages other than the amounts actually paid and/or accepted as payment in full by plaintiff s
health care providers.
This motion is based upon the grounds that the billed amounts are irrelevant and inadmissible,
and damages are limited t0 the amount actually paid.
This motion is based on the Memorandum of Points and Authorities, records on file herein,
and upon any and all such further oral evidence and/or documentary evidence which may be presented
at or before the hearing in this matter.
DATED: February 7, 2022 THOMPSON & TE LLP
10
ll
12
By:
DIAN
JUST
M
J.
WIESMANN
JANZEN
Attorneys for Defendant/Cross—Complainant,
13
DIGNITY HEALTH, erroneously sued and
served as ST. BERNARDINE MEDICAL
14
CENTER
15
17
18
19
20
21
22
23
24
25
26
27
28
2
DEFENDANT DIGNITY HEALTH'S MOTION IN LIMINE #7
Document Filed Date
February 10, 2022
Case Filing Date
August 10, 2016
Category
Medical Malpractice Unlimited
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THOMPSON & COLEGATE LLP 3610 Fourteenth Street P. O. Box 1299 Riverside, California 92502 Tel: (951) 682-5550 Fax: (951) 781-4012 DIANE MAR WIESMANN (SBN 124409) dwiesmann@tclaw.net JUSTIN J. JANZEN (SBN 242556) jjanzen@tclaw.net 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 11 12 LORI BUSH, an individual; CASE NO. CIVDSI613161 l3 Plaintiff, JUDGE: Hon. John M. Pacheco 14 Dept: S3 1 v. 15 MOTION IN LIMINE #7 FOR ST. BERNARDINE MEDICAL CENTER, a AN ORDER PRECLUDING PLAINTIFF 16 business entity form unknown; DIGNITY FROM INTRODUCING INTO EVIDENCE HEALTH, a California Corporation; and DOES THE FULL, UNDISCOUNTED AMOUNT 17 1 through 200, inclusive, OF PLAINTIFF’S MEDICAL BILLS 18 Defendants. TRIAL DATE: 02/14/2022 19 ACTION FILED: 11/08/2016 (FAC) DIGNITY HEALTH, 20 Cross-Complainant, 21 v. 22 TOTAL PROFESSIONAL NETWORK, INC., 23 andROES 1-100, inclusive, 24 Cross—Defendants. 25 26 Defendant, DIGNITY HEALTH, respectfully moves this court for an order precluding plaintiff 27 or plaintiffs witnesses from offering testimony, evidence or argument concerning amounts 0f any 28 DEFENDANT DIGNITY HEALTH‘S MOTION IN LIMINE #7 \r \r medical damages other than the amounts actually paid and/or accepted as payment in full by plaintiff s health care providers. This motion is based upon the grounds that the billed amounts are irrelevant and inadmissible, and damages are limited t0 the amount actually paid. This motion is based on the Memorandum of Points and Authorities, records on file herein, and upon any and all such further oral evidence and/or documentary evidence which may be presented at or before the hearing in this matter. DATED: February 7, 2022 THOMPSON & TE LLP 10 ll 12 By: DIAN JUST M J. WIESMANN JANZEN Attorneys for Defendant/Cross—Complainant, 13 DIGNITY HEALTH, erroneously sued and served as ST. BERNARDINE MEDICAL 14 CENTER 15 17 18 19 20 21 22 23 24 25 26 27 28 2 DEFENDANT DIGNITY HEALTH'S MOTION IN LIMINE #7