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OMINAL
BISNAR CHASE LLP
|
BRIAN D. CHASE, SBN 164109 L, E E»
‘
supmomccimmoe cw w. aw
I I
bchase@bisnarchase.com
TOM G. ANTUNOVICH, SBN 305216 co umvm smmaénnr‘xsqy
SAN WRN -\ l .
#UJN
tantunovich@bisnarchase.com
1301 Dove Street, Suite 120 JUL O 3 2023
Newport Beach, Califomia 92660
Telephone: (949) 752-2999 x ’3
h‘
“4—,.
NMA BEWY L&m/
Facsimile: (949) 752-2777 5v
Attorneysfor Plaintiffs
\OOO\IO'\UI
FAX
BY SUPERIOR COURT OF THE STATE OF CALIFORNIA
10 FOR THE COUNTY OF SAN BERNARDINO
11
MICHELLE VALENZUELA, a California CASE NO.: CIVSBZZ 1 7403
12
citizen; and ERNEST MICHAEL
13 VALENZUELA III, a California citizen, Judge: Hon. Gilbert Ochoa
Dept: $24
14 Plaintiffs,
PLAINTIFF MICHELLE
15
v. VALENZUELA’S SEPARATE
16 STATEMENT IN SUPPORT OF
ADA MCZEAL, a California citizen; and OPPOSITION TO DEFENDANT ADA
17 JULIUS MOORE, a California citizen; and MCZEAL’S MOTION TO COMPEL
DOES 1 to 10, inclusive, FURTHER RESPONSES TO REQUEST
18
FOR PRODUCTION OF DOCUMENTS,
19
Defendants. SET ONE
20
Motion to Compel Hearing Information:
21
Date: July 17, 2023
22 Time: 8:30 a.m.
Dept: $24
23
Filed: August 1, 2022
24
Trial: Not Set
25
26
27
28
1
PLAINTIFF MICHELLE VALENZUELA’S SEPARATE STATEMENT IN SUPPORT OF OPPOSITION OF MOTION TO
COMPEL REQUESTS FOR PRODUCTION, SET ONE
REQUEST FOR PRODUCTION OF DOCUMENTS NO. 2:
Please produce any and all reports by any HEALTH CARE PROVIDER who examined,
consulted and/or treated YOU in the five (5) years before of the INCIDENT.
I
HEALTH CARE PROVIDER includes any PERSON referred to in Code of Civil
Procedure section 667.7(e)(3).
\OOONQUIAUJNH
PERSON(S) includes a natural person, firm, association, organization, partnership,
business, trust, corporation or public entity.
YOU 0r YOUR includes you, your agents, your employees, your insurance companies,
their agents, their employees, your attorneys, your accountants, your investigators, and anyone else
acting on your behalf.
Hr—tp—A
NHO INCIDENT includes the circumstances and events surrounding the September 29, 2020
accident, damage, loss 0r other occurrence giving rise t0 this action or proceeding. Whenever the
term "INCIDENT" is used, it refers to the September 29, 2020 incident referred t0 in YOUR
14 Complaint.
15 RESPONSE TO DEMAND FOR PRODUCTION NO. 2:
16 Plaintiff objects to this interrogatory as vague, ambiguous and overbroad. Plaintiff further
17 objects t0 this interrogatory as seeking production of documents protected from disclosure by the
18 attorney client privilege, attorney work product doctrine, physician-patient privilege and/or
19 psychotherapist patient privilege. Finally, plaintiff objects t0 this request as harassing and
20 burdensome and seeking production of documents protected from disclosure by plaintiff’s right to
21 privacy. Subject to and without waiving these objections, plaintiff responds: I am producing (i)
22 my medical records relating to treatment for my injuries suffered as a result of the subject dog bite
23 incident from Community Hospital; (ii) 102 photos 0f Ernest’s injuries; (iii) 29 photos of my
24 injuries; (iv) medical records relating t0 treatment for Emest’s injuries suffered as a result of the
25 subject dog bite incident from Community Hospital, Inland Psychiatric and Arrowhead Regional;
26 and (v) San Bemardino County Sherist Department Crime Report DR#012002468.
27 ///
28 ///
2
PLAINTIFF MICHELLE VALENZUELA’S SEPARATE STATEMENT IN SUPPORT OF OPPOSITION OF MOTION TO
COMPEL REQUESTS FOR PRODUCTION, SET ONE
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OMINAL BISNAR CHASE LLP | BRIAN D. CHASE, SBN 164109 L, E E» ‘ supmomccimmoe cw w. aw I I bchase@bisnarchase.com TOM G. ANTUNOVICH, SBN 305216 co umvm smmaénnr‘xsqy SAN WRN -\ l . #UJN tantunovich@bisnarchase.com 1301 Dove Street, Suite 120 JUL O 3 2023 Newport Beach, Califomia 92660 Telephone: (949) 752-2999 x ’3 h‘ “4—,. NMA BEWY L&m/ Facsimile: (949) 752-2777 5v Attorneysfor Plaintiffs \OOO\IO'\UI FAX BY SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 FOR THE COUNTY OF SAN BERNARDINO 11 MICHELLE VALENZUELA, a California CASE NO.: CIVSBZZ 1 7403 12 citizen; and ERNEST MICHAEL 13 VALENZUELA III, a California citizen, Judge: Hon. Gilbert Ochoa Dept: $24 14 Plaintiffs, PLAINTIFF MICHELLE 15 v. VALENZUELA’S SEPARATE 16 STATEMENT IN SUPPORT OF ADA MCZEAL, a California citizen; and OPPOSITION TO DEFENDANT ADA 17 JULIUS MOORE, a California citizen; and MCZEAL’S MOTION TO COMPEL DOES 1 to 10, inclusive, FURTHER RESPONSES TO REQUEST 18 FOR PRODUCTION OF DOCUMENTS, 19 Defendants. SET ONE 20 Motion to Compel Hearing Information: 21 Date: July 17, 2023 22 Time: 8:30 a.m. Dept: $24 23 Filed: August 1, 2022 24 Trial: Not Set 25 26 27 28 1 PLAINTIFF MICHELLE VALENZUELA’S SEPARATE STATEMENT IN SUPPORT OF OPPOSITION OF MOTION TO COMPEL REQUESTS FOR PRODUCTION, SET ONE REQUEST FOR PRODUCTION OF DOCUMENTS NO. 2: Please produce any and all reports by any HEALTH CARE PROVIDER who examined, consulted and/or treated YOU in the five (5) years before of the INCIDENT. I HEALTH CARE PROVIDER includes any PERSON referred to in Code of Civil Procedure section 667.7(e)(3). \OOONQUIAUJNH PERSON(S) includes a natural person, firm, association, organization, partnership, business, trust, corporation or public entity. YOU 0r YOUR includes you, your agents, your employees, your insurance companies, their agents, their employees, your attorneys, your accountants, your investigators, and anyone else acting on your behalf. Hr—tp—A NHO INCIDENT includes the circumstances and events surrounding the September 29, 2020 accident, damage, loss 0r other occurrence giving rise t0 this action or proceeding. Whenever the term "INCIDENT" is used, it refers to the September 29, 2020 incident referred t0 in YOUR 14 Complaint. 15 RESPONSE TO DEMAND FOR PRODUCTION NO. 2: 16 Plaintiff objects to this interrogatory as vague, ambiguous and overbroad. Plaintiff further 17 objects t0 this interrogatory as seeking production of documents protected from disclosure by the 18 attorney client privilege, attorney work product doctrine, physician-patient privilege and/or 19 psychotherapist patient privilege. Finally, plaintiff objects t0 this request as harassing and 20 burdensome and seeking production of documents protected from disclosure by plaintiff’s right to 21 privacy. Subject to and without waiving these objections, plaintiff responds: I am producing (i) 22 my medical records relating to treatment for my injuries suffered as a result of the subject dog bite 23 incident from Community Hospital; (ii) 102 photos 0f Ernest’s injuries; (iii) 29 photos of my 24 injuries; (iv) medical records relating t0 treatment for Emest’s injuries suffered as a result of the 25 subject dog bite incident from Community Hospital, Inland Psychiatric and Arrowhead Regional; 26 and (v) San Bemardino County Sherist Department Crime Report DR#012002468. 27 /// 28 /// 2 PLAINTIFF MICHELLE VALENZUELA’S SEPARATE STATEMENT IN SUPPORT OF OPPOSITION OF MOTION TO COMPEL REQUESTS FOR PRODUCTION, SET ONE