On August 10, 2016 a
Party Discovery
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
F L
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Riverside, California 92502 SUPERIOR COURTEF EDALIFORNIA
Tel: (951) 682-5550
COUNTY 0F SAN BERNARDINO
SAN BERMARDINQ DISTRICT
Fax: (951) 781-4012
FEB 1 7 2022
DIANE MAR WIESMANN (SBN 124409)
dwiesmann@tclaw.net
JUSTIN J. JANZEN (SBN 242556)
jjanzen@tclaw.net PAO AN Z. DEPUTY
Attorneys for Defendant/Cross-Complainant,
DIGNITY HEALTH
(erroneously sued and served as ST. BERNARDINE MEDICAL CENTER)
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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FOR THE COUNTY OF SAN BERNARDINO, SAN BERNARDINO DISTRICT
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LORI BUSH, an individual; CASE NO. CIVDSl613161
Plaintiff, Hon. John M. Pacheco
Dept: S3 1
V.
AMENDED NOTICE OF LODGMENT OF
ST. BERNARDINE MEDICAL CENTER, a DEPOSITIONS FOR TRIAL FROM
business entity form unknown; DIGNITY DEFENDANT/CROSS-COMPLAINANT
HEALTH, a California Corporation; and DOES DIGNITY HEALTH
1 through 200, inclusive,
Defendants. TRIAL DATE: 02/14/2022
ACTION FILED: 11/08/2016 (FAC)
20 DIGNITY HEALTH,
21 Cross—Complainant,
22 V.
23 TOTAL PROFESSIONAL NETWORK, INC.,
and ROES 1-100, inclusive,
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Cross—Defendants.
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27
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AMENDED NOTICE OF LODGMENT OF EXHIBITS FOR TRIAL FROM DEFENDANT/CROSS-COMPLAINANT DIGNITY
HEALTH
\a \a
TO ALL PARTIES AND TO THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE THAT Defendant/Cross-Complainant, DIGNITY HEALTH (“Dignity”)
hereby lodges true and correct copies of the deposition transcripts and exhibits With the Court in
M
support t0 Dignity’s defense during
Exhibit 234:
Exhibit 235:
trial:
Full transcript Lori
Full transcript of Lori
Bush Session One.
Full transcript of Carlos
Bush Session Two and Exhibits
Bush and Exhibits A through D.
1 through 8.
Exhibit 236: Full transcript of Brad Avrit, PE and Exhibit 1.
Exhibit 237: Full transcript of Eris Barillas, CXLT, CPSI.
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Exhibit 238: Full transcript of Sharyn Brekhus, MD and Exhibits 1 through 5.
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Exhibit 239: Full transcript 0f Lawrence Lievense
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Exhibit 240: Full transcript of Timothy P. Luckett, BS, RN, CNOR, CRNFA, CIC, LNC
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and Exhibits A and B.
16 Exhibit 241: Full transcript of Lawrence Miller, MD and Exhibits A through C.
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Exhibit 242: Full transcript of Serge Obukhoff, MD Session One and Exhibits 1through 4.
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Exhibit 243: Full transcript 0f Maurice Espinoza and Exhibit 1 through 6.
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Exhibit 252: Full transcript of Thomas Parco and Exhibits 1 through 8.
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Exhibit 257: Full transcript 0f Serge Obukhoff, MD Session Two and Exhibit 3.
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Exhibit 47: Full transcript of Cory J. Cheffers and Exhibits 1 through 3.
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DATED: February 17, 2022
THCZ PSON & COLEGATE LLP
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26 Diane Mar Wiesmann, Esq.
Attorneys for Defendant/Cross-Complainant,
27 DIGNITY HEALTH
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AMENDED NOTICE OF LODGM ENT OF EXHIBITS FOR TRIAL FROM DEFENDANT/CROSS-COMPLAINANT DIGNITY
HEALTH
Document Filed Date
February 17, 2022
Case Filing Date
August 10, 2016
Category
Medical Malpractice Unlimited
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