Answer: ODEH -V- FERNANDEZ Print

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                                SUPERIOR COIFRT OF    C   LIFORNIA
                                                                              COUNTY OF SAN BERNARpiNO
              S Akita   SBN 13Q643
 1    Jerry                                                                    SAN BERNARDINO DlS7RICT
      LAW OFFICE OF JERRY S AKITA
2     32158 Camino Capistrano Ste A 194                                             APR       9 2019
      San Juan Capistrano CA 92675
       949 248 1021
                                                                         Y                A    O       n      Q

4                                                                                 DANiELA VARGRS C PU Ty
      Attorneys for Defendant
 5    LYNGI ADF N FERNANDEZ D D S
      Individually and dba KINGSLY DENTISTRY
 6     Incorrectly named as L1 NGADI FN FERNANDEZ D D S
      SUAREZ FERNANDEL DENTISI RY
 7


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                          SUPERIOR COURT OF THE STATE OF CALIFORNIA
l0
                                    FOR THE COUNTY OF SAN BERNARD NO

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      Ali Odeh                                                   CASE NO        CIVDS1823772

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                                Plaintiff                        ASSIGNED FOR ALL PURPOSES TO
14                                                               JUDGE Wilfred J Schneider Jr
               v                                                 DEPARTMENT S32
15                                                               Ai swer to Amended Verified
      Lyngadlen Fernandez Kingsly Dentistry
16    and Does 1 through 10
                                                                 Compinint Filed 9 11 I S
                                    Defendants                    Tria Date      None



1 g            COMES NOW Defe ndants LYNGLADEN FERNANDE7 D D S                                  Individually and

19    doing business as KINGSLY DENTISTRY and for no other person firm or corporation

20    answers this VU iHY Verified Amended Complaint as follows


21       1     In   response   to    Paragraph   1   of   the   Amended Complaint       Defendant          admits   the


 2             allegations contained therein the allegations contained therein



23       2     In   response   to    Paragraph 2     of   the   Amended Complaint       Defendant          admits   the


24             allegations contained therein the al egations contained therein



25       3     ln response to Para raph 3 of the Amended Complaint                Defendant denies that there


26             was a consultation       and further denies that the plaintiff s initial consultation was on


27             March 13   2018
                                                                                                                          I

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      ANSWER TO VFRIPIED COMPLAINT

                                                                                                   RI        11 1AL
 1    4    ln response to Paragraph 4 of the Amended Complaint Defendant denies each and

2
           every allegation contained therein

3      5   In   response     to   Paragraph      5    of    the    Amended            Complaint        Defendant admits     the


4          allegatians contained therein


5      6   In response to Paragraph 6 of the Amended Complaint Defendant denies that on

6          March 19 2018 a surgical removal of an erupted tooth was performed and denies

7          there was a surgical removal of erupted                         teeth     Defendant denies that the procedure


8          site required closure        or   sutures       Defendant admits that no bone graft procedure was


 9         performed on March 19 2018

10     7   In response to Paragraph 7 of the Amended Complaint Defendant admits that D7210

11         is a code relating to a surgical removal of an erupted tooih Defendant admits that the
12         surgical procedure to remove an erupted tootll may require a mucoperiosteal flap and

l3         removal of      bone    and or section of        the tooth              Defendant has insufficient information


14         upon which to admit or deny that the procedure requires prior approval if done more
IS         than four times within one and on that basis denies each and every allegation therein

16         Defendant admits that generally the procedure can include cutting of gingiva and

17         bone    sectioning      of   teeth   removal       of   the       tooth structure       and    closure      Defendant


18         denies that the procedure always requires a bone graft mucoperiosteal flap or closure

19     8   In response to Paragraph 8 of the Amended Complaint Defendant denies that closing

20         and   stitching   of   the procedure        was required on              that   day    Defendant has insufficient


21         information upon which to either admit or deny the allegations contained therein and

22         on that basis denies the allegations contained therein

23     9   In response to Paragraph 9 of the Amended Complaint Defendant admits that plaintiff

24         had   an appointment         for March 28 2018 for fillings                      on   two   front   teeth   Defendant


25         denies each and every other allegation therein

26     10 In     response    to   Paragraph          0 of the Arnended Complaint                       Defendant admits that

27         Lyngladen Fernandez               D D S     was not        in    the office on March 28             2018    Defendant

28         denies that the individual who treated was not licensed to practice dentistry and
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     ANSWER TO VF RIFIGD AMENDI f               COMPLAINT