On June 08, 2020 a
Party Discovery
was filed
involving a dispute between
Meredith, Katherine,
Meredith, Larry,
and
Apocada M.D M.D., Lorenzo,
Pure Gold Medical Center,
for Medical Malpractice Unlimited
in the District Court of San Bernardino County.
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19099862100 \
\ 0:04 p.m. 11—23—2020 5/34
F LF E
SLCJZERIOR COURT
UNTY 0F SAN
6"; RI" wow1A
X \
SAN BERNARDINO BE R N l‘ °
CIVIL [??figrgN
Patricia A. Law (SBN 163661)
LAW OFFICES OF PATRICIA A. LAW NOV 23
N A PROFESSIONAL CORPORATION 2320
10837 Laurel Street, Suite 101
Rancho Cucamonga, CA 91 730
(951) 683-8320 SY VIA
“qfi%mip
GUAJAR'
(951) 683-8321 fax EfiEPUTy
Attorneys for Plaintiffs
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
KATHERINE MEREDITH, LARRY Case N0.: CIVDS 2012210
MEREDITH
Plaintiffs, PLAINTIFF’S NOTICE OF
MOTION AND MOTION TO FAX
v. QUASH AND/OR MODIFY
SUBPOENA DUCES TECUM;
LORENZO APODACA, M.D.; PURE GOLD MEMORANDUM OF POINTS AND
MEDICAL CENTER AND DOES 1-100, AUTHORITIES; DECLARATION BY
INCLUSIVE OF PATRICIA A. LAW;
[PROPOSED] ORDER
Defendants.
(Filed concurrently with Plaintiff’s
Separate Statement)
DATE: January 21, 2021
OOQQM-hWN—‘OOOOQQMAUJNH
TIME: 9:00 a.m.
DEPT: S~23
TO ALL PARTIES, THEIR ATTORNEYS OF RECORD, PACIFIC PREMIER BANK AND
CUSTODIAN OF RECORDS FOR PACIFIC PREMIER BANK:
PLEASE TAKE NOTICE that on January 21, 2021 at 9:00 a.m., 0r as soon
thereafter as the matter may be heard, in Dept. “S-23"of the above-entitled Court, Plaintiff,
Katherine Meredith, will move for an order quashing or modifying the subpoenas duces tecum
issued and served on or about September 20, 2020 on the Custodian of Records for Pacific
Premier Bank c/o CT Corporation, the witness, requiring making the original business records
PLAINTIFF’S NOTICE OF MOTION AND MOTION TO QUASH AND/OR MODIFY
SUBPOENA DUCES TECUM
19099862100
x J:30 p.m. 11—23-2020
\ 6/34
._n
available for inspection on October 22, 2020 and the production of ceflain records.
This motion is made on the grounds that (1) the production 0f the requested
records
be limited to documents reflecting compensation and earnings and W-2 forms from
June 21,
2019 to the present only. Any other documents concerning Plaintiff’s employment are not
relevant to the subject matter of the instant litigation; and
\OOOQONM-DUJN
(2) that the production of said records
other than those reflecting compensation and earnings are
an invasion of privacy, violates
HIPPA protections, are overbroad, burdensome, oppressive and harassing t0 Plaintiff, Katherine
Meredith.
This motion is based 0n this Notice of Motion, the Memorandum 0f Points and
Authorities, the attached Declaration of Patricia A. Law, the Separate Statement of Disputed
Matters filed concurrently herewith, 0n the pleadings and papers on file in
this matter, and on
such oral and documentary evidence as may be presented to this Court.
Dated:
///g'/2&o,w
NNNNNNHHHflHy—IHHHp—a
PATRICIA A. LAW
STACY K. BRIGHAM
Attorneys for Plaintiffs
PLAINTIFF’S NOTICE OF MOTION AND MOTION TO QUASH AND/OR MODIFY
SUBPOENA DECES TECUM
Document Filed Date
November 23, 2020
Case Filing Date
June 08, 2020
Category
Medical Malpractice Unlimited
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‘ 19099862100 \ \ 0:04 p.m. 11—23—2020 5/34 F LF E SLCJZERIOR COURT UNTY 0F SAN 6"; RI" wow1A X \ SAN BERNARDINO BE R N l‘ ° CIVIL [??figrgN Patricia A. Law (SBN 163661) LAW OFFICES OF PATRICIA A. LAW NOV 23 N A PROFESSIONAL CORPORATION 2320 10837 Laurel Street, Suite 101 Rancho Cucamonga, CA 91 730 (951) 683-8320 SY VIA “qfi%mip GUAJAR' (951) 683-8321 fax EfiEPUTy Attorneys for Plaintiffs OOOOQO‘MbU) SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO KATHERINE MEREDITH, LARRY Case N0.: CIVDS 2012210 MEREDITH Plaintiffs, PLAINTIFF’S NOTICE OF MOTION AND MOTION TO FAX v. QUASH AND/OR MODIFY SUBPOENA DUCES TECUM; LORENZO APODACA, M.D.; PURE GOLD MEMORANDUM OF POINTS AND MEDICAL CENTER AND DOES 1-100, AUTHORITIES; DECLARATION BY INCLUSIVE OF PATRICIA A. LAW; [PROPOSED] ORDER Defendants. (Filed concurrently with Plaintiff’s Separate Statement) DATE: January 21, 2021 OOQQM-hWN—‘OOOOQQMAUJNH TIME: 9:00 a.m. DEPT: S~23 TO ALL PARTIES, THEIR ATTORNEYS OF RECORD, PACIFIC PREMIER BANK AND CUSTODIAN OF RECORDS FOR PACIFIC PREMIER BANK: PLEASE TAKE NOTICE that on January 21, 2021 at 9:00 a.m., 0r as soon thereafter as the matter may be heard, in Dept. “S-23"of the above-entitled Court, Plaintiff, Katherine Meredith, will move for an order quashing or modifying the subpoenas duces tecum issued and served on or about September 20, 2020 on the Custodian of Records for Pacific Premier Bank c/o CT Corporation, the witness, requiring making the original business records PLAINTIFF’S NOTICE OF MOTION AND MOTION TO QUASH AND/OR MODIFY SUBPOENA DUCES TECUM 19099862100 x J:30 p.m. 11—23-2020 \ 6/34 ._n available for inspection on October 22, 2020 and the production of ceflain records. This motion is made on the grounds that (1) the production 0f the requested records be limited to documents reflecting compensation and earnings and W-2 forms from June 21, 2019 to the present only. Any other documents concerning Plaintiff’s employment are not relevant to the subject matter of the instant litigation; and \OOOQONM-DUJN (2) that the production of said records other than those reflecting compensation and earnings are an invasion of privacy, violates HIPPA protections, are overbroad, burdensome, oppressive and harassing t0 Plaintiff, Katherine Meredith. This motion is based 0n this Notice of Motion, the Memorandum 0f Points and Authorities, the attached Declaration of Patricia A. Law, the Separate Statement of Disputed Matters filed concurrently herewith, 0n the pleadings and papers on file in this matter, and on such oral and documentary evidence as may be presented to this Court. Dated: ///g'/2&o,w NNNNNNHHHflHy—IHHHp—a PATRICIA A. LAW STACY K. BRIGHAM Attorneys for Plaintiffs PLAINTIFF’S NOTICE OF MOTION AND MOTION TO QUASH AND/OR MODIFY SUBPOENA DECES TECUM