On August 10, 2016 a
Order to Show Cause
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 F L E D I
P. O. Box 1299 WROOURT 0F mu‘oaum‘
Riverside, California 92502 wc°”m"m"
253;? fig‘zfimgm
""m" '
Tel: (951) 682-5550
Fax: (951) 781-4012 FEB 1 0 2022
DIANE MAR WIESMANN (SBN 124409)
dwiesmann@tclaw.net h
JUSTIN J. JANZEN (SBN 242556) Paola Hernandez Danny
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. CIVDSl613 161
13
Plaintiff, JUDGE: Hon. John M. Pacheco
14 Dept: S31
V.
15 MOTION IN LIMINE #1 FOR AN ORDER
ST. BERNARDINE MEDICAL CENTER, a PROHIBITING PLAINTIFF FROM USING
16 business entity form unknown; DIGNITY OR SHOWING ANY EXHIBITS TO THE
HEALTH, a California Corporation; and DOES 1 JURY DURING OPENING STATEMENT
17 through 200, inclusive,
18 Defendants. TRIAL DATE: 02/ 14/2022
ACTION FILED: 11/08/2016 (FAC)
19
DIGNITY HEALTH,
20
Cross-Complainant,
21
v.
22
TOTAL PROFESSIONAL NETWORK, INC.,
23 and ROES 1—100, inclusive,
24 Cross—Defendants.
25
26 ///
27 ///
///
28
l
DEFENDANT DIGNITY HEALTH‘S MOTION IN LIMINE #1
\r \r
Defendant, DIGNITY HEALTH, respectfully moves this court for an order precluding
Plaintiff, LORI BUSH, from using or showing any exhibits to the jury during opening statements
without first showing the exhibits t0 the Defendants.
This motion is based upon all of the papers and records on file in this case, the attached
memorandum 0f points and authorities, and upon such further oral and documentary evidence as
may be presented at the time of the hearing on this motion.
DATED: February 7, 2022 THOMPSON E TE LLP
10 By:
D&QNKMAR WIESMANN
11 J T J. JANZEN
Attorneys for Defendant/Cross-Complainant,
12 DIGNITY HEALTH, erroneously sued and
served as ST. BERNARDINE MEDICAL
13 CENTER
14
15
I6
l7
18
19
20
21
22
23
24
25
26
27
28
2
DEFENDANT DIGNITY HEALTH'S MOTION IN LIMINE #1
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 F L E D I P. O. Box 1299 WROOURT 0F mu‘oaum‘ Riverside, California 92502 wc°”m"m" 253;? fig‘zfimgm ""m" ' Tel: (951) 682-5550 Fax: (951) 781-4012 FEB 1 0 2022 DIANE MAR WIESMANN (SBN 124409) dwiesmann@tclaw.net h JUSTIN J. JANZEN (SBN 242556) Paola Hernandez Danny 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. CIVDSl613 161 13 Plaintiff, JUDGE: Hon. John M. Pacheco 14 Dept: S31 V. 15 MOTION IN LIMINE #1 FOR AN ORDER ST. BERNARDINE MEDICAL CENTER, a PROHIBITING PLAINTIFF FROM USING 16 business entity form unknown; DIGNITY OR SHOWING ANY EXHIBITS TO THE HEALTH, a California Corporation; and DOES 1 JURY DURING OPENING STATEMENT 17 through 200, inclusive, 18 Defendants. TRIAL DATE: 02/ 14/2022 ACTION FILED: 11/08/2016 (FAC) 19 DIGNITY HEALTH, 20 Cross-Complainant, 21 v. 22 TOTAL PROFESSIONAL NETWORK, INC., 23 and ROES 1—100, inclusive, 24 Cross—Defendants. 25 26 /// 27 /// /// 28 l DEFENDANT DIGNITY HEALTH‘S MOTION IN LIMINE #1 \r \r Defendant, DIGNITY HEALTH, respectfully moves this court for an order precluding Plaintiff, LORI BUSH, from using or showing any exhibits to the jury during opening statements without first showing the exhibits t0 the Defendants. This motion is based upon all of the papers and records on file in this case, the attached memorandum 0f points and authorities, and upon such further oral and documentary evidence as may be presented at the time of the hearing on this motion. DATED: February 7, 2022 THOMPSON E TE LLP 10 By: D&QNKMAR WIESMANN 11 J T J. JANZEN Attorneys for Defendant/Cross-Complainant, 12 DIGNITY HEALTH, erroneously sued and served as ST. BERNARDINE MEDICAL 13 CENTER 14 15 I6 l7 18 19 20 21 22 23 24 25 26 27 28 2 DEFENDANT DIGNITY HEALTH'S MOTION IN LIMINE #1