On November 03, 2017 a
Motion-Secondary
was filed
involving a dispute between
Murphy Sherry,
and
Chadha M.D. Arinder,
Chang Pa Kenny,
Chung M.D. Robert,
Lakeview Terrace Skilled Nursing Facility Llc,
Medical Director M.D. Doe,
Skilled Wound Care,
for civil
in the District Court of Los Angeles County.
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Electronically FILED by Superior Court of California, County of Los Angeles on 09/09/2019 12:01 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Bolden,Deputy Clerk
1 Louis H. DeHaas, State Bar No. 39579
David J. Ozeran, State Bar No. 137452
2 LA FOLLETTE, JOHNSON, DeHAAS, FESLER & AMES
865 South Figueroa Street, 32nd Floor
3 Los Angeles, California 90017-5431
Telephone (213) 426-3600 • Facsimile (213) 426-3650
4
Attorneys for Defendants, ROBERT CHUNG, M.D., KENNY
5 CHANG, P.A. and SKILLED FACILITY HEALTH CARE
SOLUTIONS dba SKILLED WOUND CARE (erroneously sued as
6 SKILLED WOUND CARE)
7
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
Cl)
UJ
9 COUNTY OF LOS ANGELES - CENTRAL DISTRICT
2
j 10
�UJ 11 SHERRY MURPHY, CASE NO.: BC682249
LI. Assigned for All Purposes To:
0 12 Plaintiff, Hon. Susan Bryant-Deason
Dept. 52
r3 13 vs.
z
�
z 14 LAKEVIEW TERRACE SKILLED REPLY TO OPPOSITION TO MOTION IN
:c NURSING FACILITY LLC; DOE LIMINE NO. 1 TO LIMIT PLAINTIFF TO
�
UJ
15 MEDICAL DIRECTOR, M.D. LAKEVIEW RECOVERY OF $250,000 IN GENERAL
TERRACE SKILLED NURSING FACILITY DAMAGES
�
...J
16 LLC; ARINDER CHADHA, M.D.; KENNY
0 CHANG, P.A.; ROBERT CHUNG, M.D. and
� 17 DOES 1 through 100, Inclusive, FSC DATE: September 16, 2019
TRIAL DATE: September 25, 2019
18 Defendants. TIME: 8:30 a.m.
DEPT: 52
19
20
21
22 TO ALL PARTIES AND THEIR COUNSEL:
23 Defendants, ROBERT CHUNG, M.D., KENNY CHANG, P.A. and SKILLED FACILITY
24 HEALTH CARE SOLUTIONS dba SKILLED WOUND CARE (DOE 1) hereby reply to the plaintiffs
25 opposition to their Motion in Limine No. 1 to limit plaintiff to recovery of $250,000 in general
26 damages.
27 Ill
28 Ill
-1-
REPLY TO OPPOSITION TO MOTION IN LIMINE NO. 1
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 09/09/2019 12:01 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Bolden,Deputy Clerk 1 Louis H. DeHaas, State Bar No. 39579 David J. Ozeran, State Bar No. 137452 2 LA FOLLETTE, JOHNSON, DeHAAS, FESLER & AMES 865 South Figueroa Street, 32nd Floor 3 Los Angeles, California 90017-5431 Telephone (213) 426-3600 • Facsimile (213) 426-3650 4 Attorneys for Defendants, ROBERT CHUNG, M.D., KENNY 5 CHANG, P.A. and SKILLED FACILITY HEALTH CARE SOLUTIONS dba SKILLED WOUND CARE (erroneously sued as 6 SKILLED WOUND CARE) 7 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA Cl) UJ 9 COUNTY OF LOS ANGELES - CENTRAL DISTRICT 2 j 10 �UJ 11 SHERRY MURPHY, CASE NO.: BC682249 LI. Assigned for All Purposes To: 0 12 Plaintiff, Hon. Susan Bryant-Deason Dept. 52 r3 13 vs. z � z 14 LAKEVIEW TERRACE SKILLED REPLY TO OPPOSITION TO MOTION IN :c NURSING FACILITY LLC; DOE LIMINE NO. 1 TO LIMIT PLAINTIFF TO � UJ 15 MEDICAL DIRECTOR, M.D. LAKEVIEW RECOVERY OF $250,000 IN GENERAL TERRACE SKILLED NURSING FACILITY DAMAGES � ...J 16 LLC; ARINDER CHADHA, M.D.; KENNY 0 CHANG, P.A.; ROBERT CHUNG, M.D. and � 17 DOES 1 through 100, Inclusive, FSC DATE: September 16, 2019 TRIAL DATE: September 25, 2019 18 Defendants. TIME: 8:30 a.m. DEPT: 52 19 20 21 22 TO ALL PARTIES AND THEIR COUNSEL: 23 Defendants, ROBERT CHUNG, M.D., KENNY CHANG, P.A. and SKILLED FACILITY 24 HEALTH CARE SOLUTIONS dba SKILLED WOUND CARE (DOE 1) hereby reply to the plaintiffs 25 opposition to their Motion in Limine No. 1 to limit plaintiff to recovery of $250,000 in general 26 damages. 27 Ill 28 Ill -1- REPLY TO OPPOSITION TO MOTION IN LIMINE NO. 1