On September 11, 2018 a
Complaint,Petition
was filed
involving a dispute between
Bradbury D.D.S., Michael G,
Bradbury, Rhonda,
Odeh, Ali,
and
Cohan, Kat,
Odeh, Ali,
Fernandez D.D.S, Lyngladen,
Fernandez Dds, Lyngladen,
Kingsley Dentistry,
Kingsly Dentistry,
Lyngadlen Fernandez Dds,
Lyngladen Fernandez D.D.S.,
Ringo Bangalan Dds,
Silagan-Fernandez D.D.S., Lyngadlen,
Suarez-Fernandez Dentistry,
Suarez Fernandez Dentistry And Ringo Bangalan, Dds,
for Medical Malpractice Unlimited
in the District Court of San Bernardino County.
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G. Michael Bradbury, DDS Rhonda Bradbury
31525 Larga Vista 3 1 525 Larga Vista
Valley Center CA 92082 Valley Center CA 92082
760-751-1 155 760-751-1 155
mike@bhllc.us rhonda@bhllc.us
F I LE D
Intervenor in pro per Intervenor in pro per SUPERIOR COURT
BERNARDINO
CSEEE‘ESSASRASNO msmcr
BYW MAR 0 2
SANDRA ORTEG
2021
epuw
10
SUPERIOR COURT OF THE STATE OF CALIFORNIA
ll
FOR THE COUNTY OF SAN BERNARDINO
12
l3
UNLIMITED CIVIL CASE
Ali Odeh
l4 Plaintiff, No. CIVDS 1823772
15 Vs
AMENDED VERIFIED COWLAINT FOR
16
Lyngadlen Silagan-Femandez, DDS;
Kingsly Dentistry and Ringo Bangalan,
1) FORGERY
17 FRAUD
2)
DDS
18
3) FRAUDULENT CONCEALMENT
Defendants 4) INTENTIONAL INTERFERENCE
19 WITH PROSPECTIVE ECONOMIC
G. Michael Bradbury, DDS, Rhonda
ADVANTAGE
20 5) NEGLIGENT INTERFERENCE WITH
Bradbury,
21
PROSPECTIVE ECONOMIC
Intervenors
ADVANTAGE
22 Vs.
6) VIOLATION OF CALIFORNIA
PENAL CODE 115
23
Ali Odeh; Kat Cohan,
7) DEFAMATION PER SE
24
8) INTENTIONAL INFLICTION 0F
Intervenees
EMOTIONAL DISTRESS
25 9) IDENTITY THEFT
10) INTRUSION INTO SECLUSION
26
27
28
VERIFIED PLEADING BRADBURY
COME NOW INTERVENORS G. MICHAEL BRADBURY, DDS AND RHONDA BRADBURY,
IN PRO PER, FILING THE PRESENT COMPLAINT AGAINST INTERVENEES ALI ODEH
AND KAT COHAN AND STATE THE FOLLOWING.
PARTIES
10
1. Intervenors G. Michael Bradbury, DDS and Rhonda Bradbury are married individuals residing
ll
in San Diego County.
12
Intervenee Ali Odeh, Plaintifl' in the present matter is an individual residing in Riverside County
13
Intervenee Kat Cohan is a licensed attorney whose principal place of business is in Los Angelest
l4
County.
15
l6
II. COMMON OPERATIVE FACTS
Intervenor G. Michael Bradbury (“Mike”) is a semi-retired dentist with omce in Northern
l7
18
San Diego County. He has been in practice for forty—five years. His current practice consists oi
l9 approximately one thousand patients.
20 Intervenor Rhonda Bradbury (“Rhonda”) is the ofiice manager of Mike’s practice.
21 Despite the fact of the semi-rural are in which Mike’s practice is located, he has a constant
22 stream of patients everyday-patients who rely on his expertise, his strong ethical standards, his
23 compassionate care and the hos overall sterling reputation.
24 In his long and storied career he has never been sued and, conversely, he has not sued himsele
25 The events that occurred to him and the acts committed against him by intervenes Odeh and
26 Cohan are therefore unprecedented in nature for him.
27
28
2
VERIFIED PLEADING BRADBURY
000003
Document Filed Date
March 02, 2021
Case Filing Date
September 11, 2018
Category
Medical Malpractice Unlimited
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G. Michael Bradbury, DDS Rhonda Bradbury 31525 Larga Vista 3 1 525 Larga Vista Valley Center CA 92082 Valley Center CA 92082 760-751-1 155 760-751-1 155 mike@bhllc.us rhonda@bhllc.us F I LE D Intervenor in pro per Intervenor in pro per SUPERIOR COURT BERNARDINO CSEEE‘ESSASRASNO msmcr BYW MAR 0 2 SANDRA ORTEG 2021 epuw 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA ll FOR THE COUNTY OF SAN BERNARDINO 12 l3 UNLIMITED CIVIL CASE Ali Odeh l4 Plaintiff, No. CIVDS 1823772 15 Vs AMENDED VERIFIED COWLAINT FOR 16 Lyngadlen Silagan-Femandez, DDS; Kingsly Dentistry and Ringo Bangalan, 1) FORGERY 17 FRAUD 2) DDS 18 3) FRAUDULENT CONCEALMENT Defendants 4) INTENTIONAL INTERFERENCE 19 WITH PROSPECTIVE ECONOMIC G. Michael Bradbury, DDS, Rhonda ADVANTAGE 20 5) NEGLIGENT INTERFERENCE WITH Bradbury, 21 PROSPECTIVE ECONOMIC Intervenors ADVANTAGE 22 Vs. 6) VIOLATION OF CALIFORNIA PENAL CODE 115 23 Ali Odeh; Kat Cohan, 7) DEFAMATION PER SE 24 8) INTENTIONAL INFLICTION 0F Intervenees EMOTIONAL DISTRESS 25 9) IDENTITY THEFT 10) INTRUSION INTO SECLUSION 26 27 28 VERIFIED PLEADING BRADBURY COME NOW INTERVENORS G. MICHAEL BRADBURY, DDS AND RHONDA BRADBURY, IN PRO PER, FILING THE PRESENT COMPLAINT AGAINST INTERVENEES ALI ODEH AND KAT COHAN AND STATE THE FOLLOWING. PARTIES 10 1. Intervenors G. Michael Bradbury, DDS and Rhonda Bradbury are married individuals residing ll in San Diego County. 12 Intervenee Ali Odeh, Plaintifl' in the present matter is an individual residing in Riverside County 13 Intervenee Kat Cohan is a licensed attorney whose principal place of business is in Los Angelest l4 County. 15 l6 II. COMMON OPERATIVE FACTS Intervenor G. Michael Bradbury (“Mike”) is a semi-retired dentist with omce in Northern l7 18 San Diego County. He has been in practice for forty—five years. His current practice consists oi l9 approximately one thousand patients. 20 Intervenor Rhonda Bradbury (“Rhonda”) is the ofiice manager of Mike’s practice. 21 Despite the fact of the semi-rural are in which Mike’s practice is located, he has a constant 22 stream of patients everyday-patients who rely on his expertise, his strong ethical standards, his 23 compassionate care and the hos overall sterling reputation. 24 In his long and storied career he has never been sued and, conversely, he has not sued himsele 25 The events that occurred to him and the acts committed against him by intervenes Odeh and 26 Cohan are therefore unprecedented in nature for him. 27 28 2 VERIFIED PLEADING BRADBURY 000003