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
o oc o a
1 Thomas R Bradfortl Esq Bar No 110230
Sherry M Gregorio Esq Bar No 263856
2 Alexa L Halloran Esq Bar No 315470
F
PETERSON BRADFORD BURKWITZ p
3 100 North First Street Suite 300 SUPERi
CUUNTYR pp
C01SqNT Or
gErCALiFORNIA
N RDINO
Burbank California 91502 SAN 6ERPIARDItJO D STftICT
4 818 562 5800
N 8 20 0
5 Attorneys for Defendant
W
RINGO BANGALAN D D S y
C
K
6 C Y
a
7
g SUPERIOR COURT OF THE STATE OF CALIFORNIA
g COUNTY OF SAN BERNARDINO
10
11 ALI ODEH Case No CIVDS1823772
Assigned to the Honorable Wilfred J Schneider Jr
Plaintiff Dept S32
12
13 vs DEFENDANT RINGO BANGALAN D D S AMICUS
Y g
o CURIE BRIEF IN SUPPORT OF CO
m
14 LYNGADLEN FERNANDEZ DDS SUAREZ DEFENDANT S OPPOSITION TO PLAINTIFF S
m o FE R NAND EZ D EN TI STR Y an tl R I N GO BA NGA LA N M OTI ON TO DI S QUALIFY CO DEFENDANT S
DDS COUNSEL JERRY AKITA ESQ AND IN
N 15
SUPPORT OF MR AKITA AND DECLARATION
L Defendants OF THOMAS R BRADFORD ESQ
16
Z
oZ
Date June 10 2020
w g
Time 8 30 a m
g Dept S32
19
Complaint Filetl September 11 2018
20
21 TO THE HONORABLE COURT ALL PARTIES AND THEIR ATTORNEYS OF RECORD
22 Defense counsel for Dr Bangalan submits this Amicus Curiae Brief in support of Co tlefendant
23 LYNGADLEN FERNANDEZ D D S Opposition to Plaintiff s Motion to Disqualify Co defentlanYs counsei
24 JERRY AKITA ESQ
25 I INTRODUCTION
26 This Amicus Brief is submitted to provitle relevant antl helpful atltlitional information to this Honorable
27 Court regartling the subject matter at issue in Plaintiff s Motion to Disqualify Co defendanYs counsel Jerry
2 1
DEFENDANT RINGO BANGALAN D D S BRIEF IN SUPPORT OF CO DEFENDANT S OPPOSITION TO PLAINTIFF S
MOTION TO DISQUALIFY CO DEFENDANT S COUNSEL JERRY AKITA ESQ AND IN SUPPORT OF MR AKITA AMICUS
CURIAE BRIEF
n files12214 odeh tdic pleadingslamicus
brieflp amicus brief docx
1 Akita Esq Plaintiff s Motion from this case Plaintiff s counsel Vasu Vijayraghavan Esq has continuously
2 harassed antl threatened defense counsel including counsel for Dr Bangalan in an attempt to force the
3 Defendants into an unwantetl settlement Her conduct violates California Rules of Professional Conduct Rule
4 3 10 a
5 The allegations forth in Plaintiff s pentling Motions were also matle against Dr Bangalan s counsei
6 antl atltlressetl by the Court at the hearing on Dr Bangalan s Motions on March 10 2020 As the Court will
7 recali Plaintiff and or her counsel alleged that our Firm was compiicit in the alleged hacking into of the Plaintiff s
8 Yelp account an action that allegedly occurretl months and months before our office had any idea who the
9 Plaintiff antl her attorney were let alone our client antl the co tlefendant forging and or covering up the forging
10 of plaintiff s signature on a consent form and contlucting illegal surveillance Plaintiff andlor her counsel have
11 admitted in Court tlocuments to having filetl complaints with the police the District Attorney s office the Dental
12 Board of California and the State Bar as a last resort to compel the tlefense to settle the case Actions of
F
N
Yo 13 this type as citable to the State Bar Califomia Rules of Professional Contluct Rule 3 10 a In fact this Court
MO
t
14 cautioned Ms Vijayraghavan against making these types of accusations and threats and taking the actions
o @o
N 15
o she and her client hatl done against defense counsel Yet in her reply to the opposition to the pending motions
Q U n
L 16 she misrepresented to this Court that it was defense counsel who was atlmonished and or chastisetl at the
Z
oZ s
w 17 March 10 2020 hearing
w
18 Notably immetliately afterthe March 10 2020 hearing Mr Bradford did speak with Ms Vijayraghavan
19 just outside the courtroom Despite having been cautionetl as to her contluct she atltletl to her unfountletl
20 allegations claiming that the tlentist Defendants conspiretl to addict the Plaintiff to pain medications She
21 clearly did not listen to a word that this Court had to say
22 Obviously undeterred Ms Vijayraghavan continues with her accusations against Mr Akita again
23 violating California Rules of Professional Conduct Rule 3 10 a and asserting baseless claims in Plaintiff s
24 Motion accusing Mr Akita of criminal conduct antl seeking to tlisqualify him basetl on unfountled allegations
25
On March 10 2020 this Court specifically cautioned antl atlmonished Plaintiffs counsel on her contluct moving
26 forward in this lawsuit Any reasonable attorney hereby the comments from the bench on March 10 2020
27 woultl have withdrawn the pending motion Still Ms Vijayraghavan chose to move forwartl with the present
28
2
DEFENDANT RINGO BANGALAN D D S BRIEF IN SUPPORT OF CO DEFENDANT S OPPOSITION TO PLAINTIFF S
MOTION TO DISQUALIFY CO DEFENDANT S COUNSEL JERRY AKITA ESQ AND IN SUPPORT OF MR AKITA AMICUS
CURIAE BRIEF
n fles12214 odeh tdic lpleadings amicus bneil ramicus brief docx
Document Filed Date
June 08, 2020
Case Filing Date
September 11, 2018
Category
Medical Malpractice Unlimited
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Preview
o oc o a 1 Thomas R Bradfortl Esq Bar No 110230 Sherry M Gregorio Esq Bar No 263856 2 Alexa L Halloran Esq Bar No 315470 F PETERSON BRADFORD BURKWITZ p 3 100 North First Street Suite 300 SUPERi CUUNTYR pp C01SqNT Or gErCALiFORNIA N RDINO Burbank California 91502 SAN 6ERPIARDItJO D STftICT 4 818 562 5800 N 8 20 0 5 Attorneys for Defendant W RINGO BANGALAN D D S y C K 6 C Y a 7 g SUPERIOR COURT OF THE STATE OF CALIFORNIA g COUNTY OF SAN BERNARDINO 10 11 ALI ODEH Case No CIVDS1823772 Assigned to the Honorable Wilfred J Schneider Jr Plaintiff Dept S32 12 13 vs DEFENDANT RINGO BANGALAN D D S AMICUS Y g o CURIE BRIEF IN SUPPORT OF CO m 14 LYNGADLEN FERNANDEZ DDS SUAREZ DEFENDANT S OPPOSITION TO PLAINTIFF S m o FE R NAND EZ D EN TI STR Y an tl R I N GO BA NGA LA N M OTI ON TO DI S QUALIFY CO DEFENDANT S DDS COUNSEL JERRY AKITA ESQ AND IN N 15 SUPPORT OF MR AKITA AND DECLARATION L Defendants OF THOMAS R BRADFORD ESQ 16 Z oZ Date June 10 2020 w g Time 8 30 a m g Dept S32 19 Complaint Filetl September 11 2018 20 21 TO THE HONORABLE COURT ALL PARTIES AND THEIR ATTORNEYS OF RECORD 22 Defense counsel for Dr Bangalan submits this Amicus Curiae Brief in support of Co tlefendant 23 LYNGADLEN FERNANDEZ D D S Opposition to Plaintiff s Motion to Disqualify Co defentlanYs counsei 24 JERRY AKITA ESQ 25 I INTRODUCTION 26 This Amicus Brief is submitted to provitle relevant antl helpful atltlitional information to this Honorable 27 Court regartling the subject matter at issue in Plaintiff s Motion to Disqualify Co defendanYs counsel Jerry 2 1 DEFENDANT RINGO BANGALAN D D S BRIEF IN SUPPORT OF CO DEFENDANT S OPPOSITION TO PLAINTIFF S MOTION TO DISQUALIFY CO DEFENDANT S COUNSEL JERRY AKITA ESQ AND IN SUPPORT OF MR AKITA AMICUS CURIAE BRIEF n files12214 odeh tdic pleadingslamicus brieflp amicus brief docx 1 Akita Esq Plaintiff s Motion from this case Plaintiff s counsel Vasu Vijayraghavan Esq has continuously 2 harassed antl threatened defense counsel including counsel for Dr Bangalan in an attempt to force the 3 Defendants into an unwantetl settlement Her conduct violates California Rules of Professional Conduct Rule 4 3 10 a 5 The allegations forth in Plaintiff s pentling Motions were also matle against Dr Bangalan s counsei 6 antl atltlressetl by the Court at the hearing on Dr Bangalan s Motions on March 10 2020 As the Court will 7 recali Plaintiff and or her counsel alleged that our Firm was compiicit in the alleged hacking into of the Plaintiff s 8 Yelp account an action that allegedly occurretl months and months before our office had any idea who the 9 Plaintiff antl her attorney were let alone our client antl the co tlefendant forging and or covering up the forging 10 of plaintiff s signature on a consent form and contlucting illegal surveillance Plaintiff andlor her counsel have 11 admitted in Court tlocuments to having filetl complaints with the police the District Attorney s office the Dental 12 Board of California and the State Bar as a last resort to compel the tlefense to settle the case Actions of F N Yo 13 this type as citable to the State Bar Califomia Rules of Professional Contluct Rule 3 10 a In fact this Court MO t 14 cautioned Ms Vijayraghavan against making these types of accusations and threats and taking the actions o @o N 15 o she and her client hatl done against defense counsel Yet in her reply to the opposition to the pending motions Q U n L 16 she misrepresented to this Court that it was defense counsel who was atlmonished and or chastisetl at the Z oZ s w 17 March 10 2020 hearing w 18 Notably immetliately afterthe March 10 2020 hearing Mr Bradford did speak with Ms Vijayraghavan 19 just outside the courtroom Despite having been cautionetl as to her contluct she atltletl to her unfountletl 20 allegations claiming that the tlentist Defendants conspiretl to addict the Plaintiff to pain medications She 21 clearly did not listen to a word that this Court had to say 22 Obviously undeterred Ms Vijayraghavan continues with her accusations against Mr Akita again 23 violating California Rules of Professional Conduct Rule 3 10 a and asserting baseless claims in Plaintiff s 24 Motion accusing Mr Akita of criminal conduct antl seeking to tlisqualify him basetl on unfountled allegations 25 On March 10 2020 this Court specifically cautioned antl atlmonished Plaintiffs counsel on her contluct moving 26 forward in this lawsuit Any reasonable attorney hereby the comments from the bench on March 10 2020 27 woultl have withdrawn the pending motion Still Ms Vijayraghavan chose to move forwartl with the present 28 2 DEFENDANT RINGO BANGALAN D D S BRIEF IN SUPPORT OF CO DEFENDANT S OPPOSITION TO PLAINTIFF S MOTION TO DISQUALIFY CO DEFENDANT S COUNSEL JERRY AKITA ESQ AND IN SUPPORT OF MR AKITA AMICUS CURIAE BRIEF n fles12214 odeh tdic lpleadings amicus bneil ramicus brief docx