On September 11, 2018 a
Party Discovery
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.
Preview
ORIGiI L
1 Thomas R Bradford Es a Bar No 110230 F I L E D
SUPERIOR COURT OF CALIFORNiA
Sherry Gregorio Esq Bar No 263856 COUN7Y OF SAN BERNARDINO
SAN RFRNARf INO CIVIL D GI N
2 Alexa L Halloran Esq Bar No 315470
PETERSON BRADFORD BURKWITZ
3 100 North First Street Suite 300 Ap 2 0 2020
Burbank California 91502 f
4 818 562 5800
5 Attorneys for Defendant
RINGO BANGALAN D D S
i T4 6
7 SUPERIOR COURT OF THE STATE OF CALIFORNIA
g COUNTY OF SAN BERNARDINO
9
Ali Odeh Case No CIVDS1823772
10
Assigned to the Honorable Wilfred J Schneider Jr
Plaintiff Dept S32
11
vs DEFENDANT RINGO BANGALAN D D S
12
N SEPARATE STATEMENT IN SUPPORT OF
Lyngadlen Fernandez DDS Suarez Fernandez MOTION TO COMPEL PLAINTIFF S FURTHER
13
Dentistry and Ringo Bangalan DDS RESPONSES TO FORM INTERROGATORIES
m GENERAL SET ONE
14
o Defendants
15 Filed concurrently wifh Motion to Compel
o Responses to Form Inferrogatories General Set
m Y One Proposed Order
6
Zv D l 0 cx vrl
o Z Date To be s
o
m
17 by Court
Time To be se t by C ourt
w Dept S32
19
Complaint Filed September 11 2018
20
21
22 TO PLAINTIFF AND HIS ATTORNEY OF RECORD HEREIN
23 COMES NOW Defendant Ringo Bangalan D D S hereby submits the following Separate Statement
24 in support of the Motion to Compel Further Responses to Form Interrogatories Set One to Plaintiff Ali Odeh
25 FORM INTERROGATORIES GENERAL
26 FORM INTERRO ATORY N0 2 8
27 Have you ever been convicted of a felony If so for each conviction state
28 a the city and state where you were convicted
1
DEFENDANT S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL PLAINTIFF S FURTHER RESPONSES
TO FORM INTERROGATORIES SET ONE
n lfiles12214 odeh tdic lpleadingslmtc frog 2nd mtnlp sep stmt iso mtc docx
1 b the date of canviction
2 c the offense and
3 d the court and case number
4 RE PONSE TO FQRM INTERRQCATQRY N0 2 8
5 NlA Objection on the grounds of irrelevance
6 ARGUMEN7 FOR FURTHER RESPONSE
7 Plaintiff s response is evasive and incomplete in violation of Cal Civ Proc Code 2030 300 a
8
For the purpose af attacking the credibility af a witness it may be shawn by the examination of the witness
9 the the judgment that he has been
or by record af convicted of a felony See Cal Evid Code 788 A
1 felony c nviction is relevant as it may be admissible for impeachment purposes of a witness As such this
11
request is applicable to this lawsult and a response is required by Plaintiffi
12 F4RM INTERRQGATORY N0 6 2
H
N
Y m
13 Identify each injury you attribute to the INCIDENT and the area of your body affectgd
14 RESPONSE TO FORM INTERROGATORY N4 6 2
a Q
o
o 15
o Still under medical treatment I am still seeing a dentist on a regular basis as well as a psychiatrist
16 ARGUMENT FOR FURTHER RESPONSE
z
oz
g 17 Plaintiff s response is evasive and incomplete in violatian of Cal Civ Prac Code 2Q30 300 a
W
18 The request asks for Piaintiff ta identify each injury that he attributes to the INCIDENT Further the request
19 asks Plaintiff to identify the area of his body affected by the injury Instead of providing a complete answer
2Q
Plainti f has generally stated that he is under medical treatment and is treating with a der tist and
21 psychiatrist This respanse fails to answer the request
22 FORM INTERROGATORY N0 6 3
23 Do you still have any complaints that you attribute to the INCIDENT If sa for each camplaint state
24 a a description
25 b whether the complaint is subsiding remaining the same or becaming worse and
26 c the frequency and duration
27 RESPONSE T4 FORM INTERROGA70RY N0 6 3
28 Yes All are becoming worse I am dealing witl it all an a daily basis
2
QEfENDANT S SEPARATE STATEMENT IN SUPRORT OF Mt3Ti0N TO COMPEL PLAINTIFF S FURTHER RESPONSES
TO FORM INTERROGATORIES SET ONE
n lfilest2214 odeh tdic tpleadingslmfc frog 2nd mtn stmt iso mtc docx
p sep
Document Filed Date
April 20, 2020
Case Filing Date
September 11, 2018
Category
Medical Malpractice Unlimited
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ORIGiI L 1 Thomas R Bradford Es a Bar No 110230 F I L E D SUPERIOR COURT OF CALIFORNiA Sherry Gregorio Esq Bar No 263856 COUN7Y OF SAN BERNARDINO SAN RFRNARf INO CIVIL D GI N 2 Alexa L Halloran Esq Bar No 315470 PETERSON BRADFORD BURKWITZ 3 100 North First Street Suite 300 Ap 2 0 2020 Burbank California 91502 f 4 818 562 5800 5 Attorneys for Defendant RINGO BANGALAN D D S i T4 6 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA g COUNTY OF SAN BERNARDINO 9 Ali Odeh Case No CIVDS1823772 10 Assigned to the Honorable Wilfred J Schneider Jr Plaintiff Dept S32 11 vs DEFENDANT RINGO BANGALAN D D S 12 N SEPARATE STATEMENT IN SUPPORT OF Lyngadlen Fernandez DDS Suarez Fernandez MOTION TO COMPEL PLAINTIFF S FURTHER 13 Dentistry and Ringo Bangalan DDS RESPONSES TO FORM INTERROGATORIES m GENERAL SET ONE 14 o Defendants 15 Filed concurrently wifh Motion to Compel o Responses to Form Inferrogatories General Set m Y One Proposed Order 6 Zv D l 0 cx vrl o Z Date To be s o m 17 by Court Time To be se t by C ourt w Dept S32 19 Complaint Filed September 11 2018 20 21 22 TO PLAINTIFF AND HIS ATTORNEY OF RECORD HEREIN 23 COMES NOW Defendant Ringo Bangalan D D S hereby submits the following Separate Statement 24 in support of the Motion to Compel Further Responses to Form Interrogatories Set One to Plaintiff Ali Odeh 25 FORM INTERROGATORIES GENERAL 26 FORM INTERRO ATORY N0 2 8 27 Have you ever been convicted of a felony If so for each conviction state 28 a the city and state where you were convicted 1 DEFENDANT S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL PLAINTIFF S FURTHER RESPONSES TO FORM INTERROGATORIES SET ONE n lfiles12214 odeh tdic lpleadingslmtc frog 2nd mtnlp sep stmt iso mtc docx 1 b the date of canviction 2 c the offense and 3 d the court and case number 4 RE PONSE TO FQRM INTERRQCATQRY N0 2 8 5 NlA Objection on the grounds of irrelevance 6 ARGUMEN7 FOR FURTHER RESPONSE 7 Plaintiff s response is evasive and incomplete in violation of Cal Civ Proc Code 2030 300 a 8 For the purpose af attacking the credibility af a witness it may be shawn by the examination of the witness 9 the the judgment that he has been or by record af convicted of a felony See Cal Evid Code 788 A 1 felony c nviction is relevant as it may be admissible for impeachment purposes of a witness As such this 11 request is applicable to this lawsult and a response is required by Plaintiffi 12 F4RM INTERRQGATORY N0 6 2 H N Y m 13 Identify each injury you attribute to the INCIDENT and the area of your body affectgd 14 RESPONSE TO FORM INTERROGATORY N4 6 2 a Q o o 15 o Still under medical treatment I am still seeing a dentist on a regular basis as well as a psychiatrist 16 ARGUMENT FOR FURTHER RESPONSE z oz g 17 Plaintiff s response is evasive and incomplete in violatian of Cal Civ Prac Code 2Q30 300 a W 18 The request asks for Piaintiff ta identify each injury that he attributes to the INCIDENT Further the request 19 asks Plaintiff to identify the area of his body affected by the injury Instead of providing a complete answer 2Q Plainti f has generally stated that he is under medical treatment and is treating with a der tist and 21 psychiatrist This respanse fails to answer the request 22 FORM INTERROGATORY N0 6 3 23 Do you still have any complaints that you attribute to the INCIDENT If sa for each camplaint state 24 a a description 25 b whether the complaint is subsiding remaining the same or becaming worse and 26 c the frequency and duration 27 RESPONSE T4 FORM INTERROGA70RY N0 6 3 28 Yes All are becoming worse I am dealing witl it all an a daily basis 2 QEfENDANT S SEPARATE STATEMENT IN SUPRORT OF Mt3Ti0N TO COMPEL PLAINTIFF S FURTHER RESPONSES TO FORM INTERROGATORIES SET ONE n lfilest2214 odeh tdic tpleadingslmfc frog 2nd mtn stmt iso mtc docx p sep