On April 10, 2015 a
DEFENDANT INNOVATIVE CARE MANAGEMENT'S SEPARATE STATEMENT IN SUPPORT OF MOTION FOR AN ORDER COMPELLING PLAINTIFF 90210 SURGERY MEDICAL CENTER, LLC TO PROVIDE FURTHER RESPONSES TO DEFENDANTS REQUESTS F
was filed
involving a dispute between
90210 Surgery Medical Center Llc,
Lanman Todd M.D.,
and
Cigna Inc.,
Innovative Care Management Inc.,
Pacific Maritime Association,
Tc3 Health Inc.,
Zenith American Solutions Inc.,
for Other Commercial/Business Tort (not fraud/ breach of contract) (General Jurisdiction)
in the District Court of Los Angeles County.
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@ @
PRINDLE, GOETZ, BARNES & REINHOLTZ LLP sO
Jack R, Reinholtz, Esq. (Bar No. 149884)
gS5
Cynthia A. Palin, Esq. (Bar No. 143486)
310 Golden Shore, Fourth Floor Sug aiiar Gauit of California
ounty of Los Angeles
Long Beach, California 90802
Telephone: (562) 436-3946
Facsimile: (562) 495-0564 AUG 10 2018
jreinholtz@prindlelaw.com
Sherri R. Carter, Exegutive Officer/Clerk
cpalin@prindlelaw.com
By. ess Deputy
lancy Alvarez
Attorneys for Defendant,
INNOVATIVE CARE MANAGEMENT, INC.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES, CENTRAL DISTRICT
10
11 TODD LANMAN, MD., CASE NO. BC578420
BY FAX
(Consolidated with 90210 Surgery Medical Center,
12 Plaintiff, LLC v. Pacific Maritime Association, Case No.
BC578421)
13 (Case assigned to Judge Susan Bryant-Deason —
Vv.
14 Dept. 52)
PACIFIC MARITIME ASSOCIATON, in its
15 capacity as Trustee of the Coastwise Indemnity DEFENDANT INNOVATIVE CARE
Plan; ZENITH AMERICAN SOLUTIONS, MANAGEMENT’S SEPARATE STATEMENT
16 INC., a corporation; TC3 HEALTH, INC., a IN SUPPORT OF MOTION FOR AN ORDER
corporation; INNOVATIVE CARE COMPELLING PLAINTIFF 90210 SURGERY
17
MANAGMENT, INC, a corporation; CIGNA, MEDICAL CENTER, LLC TO PROVIDE
18 INC., a corporation and DOES 1 through 100 FURTHER RESPONSES TO DEFENDANT'S
inclusive REQUESTS FOR PRODUCTION OF
19 DOCUMENTS, SET SIX AND TO PAY
Defendants. SANCTIONS
20
{Filed Concurrently With Defendant's Motion to Compel Further
21 Responses to Request for Production of Documents Set Six;
Declaration of Cynthia A. Palin; and Proposed Order}
22
Reservation ID: 180809338999
23 Date: October 9, 2018
Time: 8:30 a.m.
24 Dept.: 52
25 April 10, 2015
2 Complaint Filed:
Pe
26 ILWU-PMA WELFARE PLAN, Trial Date: October 24, 2018
27 Intervenor Plaintiff,
hm
2 28
re
SEPARATE STATEMENT IN SUPPORT OF DEFENDANT’S MOTION TO “ORIGINAL
Category
Other Commercial/Business Tort (not fraud/ breach of contract) (General Jurisdiction)
Status
Request for Dismissal - Before Trial not following ADR or more than 60 days since ADR 06/14/2019
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Preview
@ @ PRINDLE, GOETZ, BARNES & REINHOLTZ LLP sO Jack R, Reinholtz, Esq. (Bar No. 149884) gS5 Cynthia A. Palin, Esq. (Bar No. 143486) 310 Golden Shore, Fourth Floor Sug aiiar Gauit of California ounty of Los Angeles Long Beach, California 90802 Telephone: (562) 436-3946 Facsimile: (562) 495-0564 AUG 10 2018 jreinholtz@prindlelaw.com Sherri R. Carter, Exegutive Officer/Clerk cpalin@prindlelaw.com By. ess Deputy lancy Alvarez Attorneys for Defendant, INNOVATIVE CARE MANAGEMENT, INC. SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES, CENTRAL DISTRICT 10 11 TODD LANMAN, MD., CASE NO. BC578420 BY FAX (Consolidated with 90210 Surgery Medical Center, 12 Plaintiff, LLC v. Pacific Maritime Association, Case No. BC578421) 13 (Case assigned to Judge Susan Bryant-Deason — Vv. 14 Dept. 52) PACIFIC MARITIME ASSOCIATON, in its 15 capacity as Trustee of the Coastwise Indemnity DEFENDANT INNOVATIVE CARE Plan; ZENITH AMERICAN SOLUTIONS, MANAGEMENT’S SEPARATE STATEMENT 16 INC., a corporation; TC3 HEALTH, INC., a IN SUPPORT OF MOTION FOR AN ORDER corporation; INNOVATIVE CARE COMPELLING PLAINTIFF 90210 SURGERY 17 MANAGMENT, INC, a corporation; CIGNA, MEDICAL CENTER, LLC TO PROVIDE 18 INC., a corporation and DOES 1 through 100 FURTHER RESPONSES TO DEFENDANT'S inclusive REQUESTS FOR PRODUCTION OF 19 DOCUMENTS, SET SIX AND TO PAY Defendants. SANCTIONS 20 {Filed Concurrently With Defendant's Motion to Compel Further 21 Responses to Request for Production of Documents Set Six; Declaration of Cynthia A. Palin; and Proposed Order} 22 Reservation ID: 180809338999 23 Date: October 9, 2018 Time: 8:30 a.m. 24 Dept.: 52 25 April 10, 2015 2 Complaint Filed: Pe 26 ILWU-PMA WELFARE PLAN, Trial Date: October 24, 2018 27 Intervenor Plaintiff, hm 2 28 re SEPARATE STATEMENT IN SUPPORT OF DEFENDANT’S MOTION TO “ORIGINAL