On April 10, 2015 a
PLAINTIFF TODD LANMAN M.D.S OPPOSITION TO LNNOVATIVE CARE MANAGEMENT INC.'S MOTION TO STRIKE PUNITIVE DAMAGES FROM THESAC
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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®
THE CARREON FIRM
Patrick Carreon, Esq. State Bar No. 119576
444 W. Ocean Blvd., Suite $05 FILED
Sup erior Court of California
Telephone: (562) 432-9999 ounty of Los Angeles
Fax: (562) 432-9990 AUG 39 2016
carreon@mocalaw.com
Sherri Carter, Executive Officer/Clerk
By.aad Ney Deputy
Attomeys for Plaintiff Raul Sanchez
TODD LANMAN M.D.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES
10 TOPD LANMAN, M_LD., an Individual Case No. BC578420
11 Unlimited Civil Action
Plaintiff,
12 PLAINTIFF TODD LANMAN M.D.'S
Vs.
13 OPPOSITION TO INNOVATIVE CARE
PACIFIC MARITIME ASSOCIATION, in its MANAGEMENT INC.’S MOTION TO
14 STRIKE PUNITIVE DAMAGES FROM
capacity as Trustee of the Coastwise
15 Indemnity Plan; ZENITH AMERICAN THE SAC
SOLUTIONS, INC., a corporation; TC3
16
HEALTH, INC. a corporation; INNOVATIVE
17 CARE MANAGEMENT, INC., a corporation; Date: September 13, 2016
CIGNA INC., a corporation and DOES 1 Time: 8:30 a.m.
18 Dept: 52
through 100, inclusive,
19
Defendants,
20 By Fax
21
22
COMES NOW, Plaintiff Todd Lanman M.D., (hereinafter referred to as "Dr. Lanman")
23
and brings the following opposition to Defendant, INNOVATIVE CARE MANAGEMENT
es
24 INC.’S (hereinafter referred to as "[CM") Motion to Strike Portions of Plaintiff's Second
oe
cat 25 Amended Complaint (hereinafter referred to.as “SAC”) as follows:
ey
Pet 26
«Ey
27
L INTRODUCTION
a
28
In its Motion to Strike, ICM takes the position that plaintiff's SAC contains no factual
PLAINTIFF'S OPPOSITION TO ICM’S MOTION TO STRIKE PUNITIVES
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® THE CARREON FIRM Patrick Carreon, Esq. State Bar No. 119576 444 W. Ocean Blvd., Suite $05 FILED Sup erior Court of California Telephone: (562) 432-9999 ounty of Los Angeles Fax: (562) 432-9990 AUG 39 2016 carreon@mocalaw.com Sherri Carter, Executive Officer/Clerk By.aad Ney Deputy Attomeys for Plaintiff Raul Sanchez TODD LANMAN M.D. SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES 10 TOPD LANMAN, M_LD., an Individual Case No. BC578420 11 Unlimited Civil Action Plaintiff, 12 PLAINTIFF TODD LANMAN M.D.'S Vs. 13 OPPOSITION TO INNOVATIVE CARE PACIFIC MARITIME ASSOCIATION, in its MANAGEMENT INC.’S MOTION TO 14 STRIKE PUNITIVE DAMAGES FROM capacity as Trustee of the Coastwise 15 Indemnity Plan; ZENITH AMERICAN THE SAC SOLUTIONS, INC., a corporation; TC3 16 HEALTH, INC. a corporation; INNOVATIVE 17 CARE MANAGEMENT, INC., a corporation; Date: September 13, 2016 CIGNA INC., a corporation and DOES 1 Time: 8:30 a.m. 18 Dept: 52 through 100, inclusive, 19 Defendants, 20 By Fax 21 22 COMES NOW, Plaintiff Todd Lanman M.D., (hereinafter referred to as "Dr. Lanman") 23 and brings the following opposition to Defendant, INNOVATIVE CARE MANAGEMENT es 24 INC.’S (hereinafter referred to as "[CM") Motion to Strike Portions of Plaintiff's Second oe cat 25 Amended Complaint (hereinafter referred to.as “SAC”) as follows: ey Pet 26 «Ey 27 L INTRODUCTION a 28 In its Motion to Strike, ICM takes the position that plaintiff's SAC contains no factual PLAINTIFF'S OPPOSITION TO ICM’S MOTION TO STRIKE PUNITIVES