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F I LE D
CALIFORNIA
SUPER'OR CEURT 0F DNO
BERNARD
Linda A. Chapman 022" BeguAgnAlg‘lNo DISTRICT
846 East Margarita Rd.
Rialto Califomia 92376 MAY O 3 2021
TELEPHONE (909) 820 0174 1
FAX (909) 907 0027
EMAIL: (Hsuu~, .
IN PR0 PER
\‘D-r
BY
DAIB NLDN DEPUTY
SUPERIOR COURT OF THE STATE OF CALIFORNIA
SAN BERNARDINO COUNTY, CIVIL DIVISION
LINDA A.CHAPMAN, Case No.:
CIV SB 2 1 1 0 7 5 S
Plaintifi‘,
10
vs. COMPLAINT FOR DAMAGES FOR:
ll
12 DR. FAITH LEE—JACKSON; and DOES ONE through l. NEGLIGENCE
ONE HUNDRED, inclusive 2. FRAUD
l3
Defendants. DEMAND FOR JURY TRIAL
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Plaintiff, Linda A. Chapman, a 73-year old female, brings this lawsuit against the
l6 Defendant, Dr. Faith Lee-Jackson, M.D. (Medical Board of California, license no. A63452); and Does 1
17
through 100, inclusive (Defendants). In support of the allegations, Plaintiff states:
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FACTS
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l. That the plaintiff is a resident of San Bemardino County, California and became a
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patient under the Defendant’s care for primary medical services on or about
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September of 20 1 0.
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2. That Defendant, Dr. Faith Lee—Jackson, M.D., is a licensed Physician providing
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medical care to the Citizens 0f the State of California. The Defendant provides
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25 medical services as part of the San Bemardino Medical Group, Inc., (California
26 Corporation Entity No. C4562966), with a principal place of business providing
27 medical services at 1700 No. Waterman Avenue, San Bemardino, California 92404-
28
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51 15. Additionally, Dr. Faith Lee—Jackson, M.D., provides medical services as part 01
North American Medical Management California, Inc., (California Corporation
Entity No. C21 84092), with a principal place 0f business located at 3990 Concours,
Suite 500, Ontario, California 91764.
That DOES l through 100, inclusive, all remaining Defendants at all times herein
mentioned were and are: (a) engaged in owning, operating, maintaining, managing
and doing business, in the State of California; (b) engaged in rendering medical,
surgical, clinical, diagnostic, nursing, and other services to the general public for
10 compensation; and (c) a corporation, partnership, sole proprietorship, joint venture,
11 unincorporated association, or some other entity doing business in the County of San
12 Bemardino, State of California and duly organized and existing under and by virtue
13 of the laws of the County of San Bemardino and the State of California.
14
Plaintiff is informed and believes that Defendant, Dr. Faith Lee-Jackson, M.D., and
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Does 1 through 100, inclusive, as owners, operators, managers and general service
l6
providers, participated in, authorized, directed and/or concealed the negligence and
17
errors; and are therefore liable for the acts and omissions 0fthe Defendants, its agents
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and employees.
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Since the true names and capacities, whether individual, corporate, associate, or
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21 otherwise, of the Defendants desiglated and sued as DOES 1 through 100, inclusive
22 are unknown to Plaintiff, those Defendants are designated by their fictitious names.
23 Plaintiff alleges on information and belief that each of the Defendants designated and
24 sued as a DOE failed to follow the applicable standard of care and is legally
25
responsible in some manner for the negligence and fraud referred t0 herein below,
26
and legally caused the injuxy and damages to Plaintiffherein alleged. Plaintiff will
27
ask leave of this Court to amend this pleading to insert the true names and capacities
28
Preview
\r \y F I LE D CALIFORNIA SUPER'OR CEURT 0F DNO BERNARD Linda A. Chapman 022" BeguAgnAlg‘lNo DISTRICT 846 East Margarita Rd. Rialto Califomia 92376 MAY O 3 2021 TELEPHONE (909) 820 0174 1 FAX (909) 907 0027 EMAIL: (Hsuu~, . IN PR0 PER \‘D-r BY DAIB NLDN DEPUTY SUPERIOR COURT OF THE STATE OF CALIFORNIA SAN BERNARDINO COUNTY, CIVIL DIVISION LINDA A.CHAPMAN, Case No.: CIV SB 2 1 1 0 7 5 S Plaintifi‘, 10 vs. COMPLAINT FOR DAMAGES FOR: ll 12 DR. FAITH LEE—JACKSON; and DOES ONE through l. NEGLIGENCE ONE HUNDRED, inclusive 2. FRAUD l3 Defendants. DEMAND FOR JURY TRIAL 14 Plaintiff, Linda A. Chapman, a 73-year old female, brings this lawsuit against the l6 Defendant, Dr. Faith Lee-Jackson, M.D. (Medical Board of California, license no. A63452); and Does 1 17 through 100, inclusive (Defendants). In support of the allegations, Plaintiff states: 18 FACTS 19 l. That the plaintiff is a resident of San Bemardino County, California and became a 20 patient under the Defendant’s care for primary medical services on or about 21 September of 20 1 0. 22 2. That Defendant, Dr. Faith Lee—Jackson, M.D., is a licensed Physician providing 23 medical care to the Citizens 0f the State of California. The Defendant provides 24 25 medical services as part of the San Bemardino Medical Group, Inc., (California 26 Corporation Entity No. C4562966), with a principal place of business providing 27 medical services at 1700 No. Waterman Avenue, San Bemardino, California 92404- 28 \a \u 51 15. Additionally, Dr. Faith Lee—Jackson, M.D., provides medical services as part 01 North American Medical Management California, Inc., (California Corporation Entity No. C21 84092), with a principal place 0f business located at 3990 Concours, Suite 500, Ontario, California 91764. That DOES l through 100, inclusive, all remaining Defendants at all times herein mentioned were and are: (a) engaged in owning, operating, maintaining, managing and doing business, in the State of California; (b) engaged in rendering medical, surgical, clinical, diagnostic, nursing, and other services to the general public for 10 compensation; and (c) a corporation, partnership, sole proprietorship, joint venture, 11 unincorporated association, or some other entity doing business in the County of San 12 Bemardino, State of California and duly organized and existing under and by virtue 13 of the laws of the County of San Bemardino and the State of California. 14 Plaintiff is informed and believes that Defendant, Dr. Faith Lee-Jackson, M.D., and 15 Does 1 through 100, inclusive, as owners, operators, managers and general service l6 providers, participated in, authorized, directed and/or concealed the negligence and 17 errors; and are therefore liable for the acts and omissions 0fthe Defendants, its agents 18 and employees. 19 Since the true names and capacities, whether individual, corporate, associate, or 20 21 otherwise, of the Defendants desiglated and sued as DOES 1 through 100, inclusive 22 are unknown to Plaintiff, those Defendants are designated by their fictitious names. 23 Plaintiff alleges on information and belief that each of the Defendants designated and 24 sued as a DOE failed to follow the applicable standard of care and is legally 25 responsible in some manner for the negligence and fraud referred t0 herein below, 26 and legally caused the injuxy and damages to Plaintiffherein alleged. Plaintiff will 27 ask leave of this Court to amend this pleading to insert the true names and capacities 28