On April 10, 2015 a
PLAINTIFF 90210'S OPPOSITION TO ZENITH AMERICAN SOLUTIONS INC.'S MOTION TO STRIKE PUNITIVE DAMAGES FROM THE SAC
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 FIL
444 W. Ocean Blvd., Suite 505 Superior Court of California
‘ounty of Los Angeles
Telephone: (562) 432-9999
Fax: (562) 432-9990 AUG 30 2016
carreon@mocalaw.com r/Clerk
She eri Carter, Executive Office
By. odRaul Qe
Sanchez
Deputy
Attorneys for Plaintiff
90210 SURGERY MEDICAL CENTER, LLC
SUPERIOR COURT OF THE STATE OF CALIFORNIA
‘ COUNTY OF LOS ANGELES
10 90210 SURGERY MEDICAL CENTER, Case No..BC578420
11 LLC, a limited liability corporation Unlimited Civil Action
12 Plaintiff, PLAINTIFF 90210'S OPPOSITION TO
13 ZENITH AMERICAN SOLUTIONS
Vs.
INC.’S MOTION TO STRIKE PUNITIVE
14 DAMAGES FROM THE SAC
PACIFIC MARITIME ASSOCIATION, in its
15 capacity as Trustee of the Coastwise
Indemnity Plan; ZENITH AMERICAN
16 Date: September 13, 2016
SOLUTIONS, INC., a corporation; TC3
Time: 8:30 a.m.
17 HEALTH, INC. a corporation; INNOVATIVE
CARE MANAGEMENT, INC., a corporation; Dept: 52 By Fax
18
CIGNA INC., a corporation and DOES 1
19 through 100, inclusive,
20 Defendants,
21
22
23
e 24
A COMES NOW, Plaintiff 90210 SURGERY MEDICAL CENTER, LLC, (hereinafter
25 referred to as "90210") and brings the following opposition to Defendant, ZENITH AMERICAN
a
Ne 26 SOLUTIONS INC.’S (hereinafter referred toas "Zenith") Motion to Strike Portions of Plaintiff's
ee
27 Second Amended Complaint (hereinafter referred to. as “SAC”) as follows:
ee
28
PLAINTIFF'S OPPOSITION TO ZENITH’S MOTION TO STRIKE PUNITIVES
Preview
@ THE CARREON FIRM Patrick Carreon, Esq. State Bar No. 119576 FIL 444 W. Ocean Blvd., Suite 505 Superior Court of California ‘ounty of Los Angeles Telephone: (562) 432-9999 Fax: (562) 432-9990 AUG 30 2016 carreon@mocalaw.com r/Clerk She eri Carter, Executive Office By. odRaul Qe Sanchez Deputy Attorneys for Plaintiff 90210 SURGERY MEDICAL CENTER, LLC SUPERIOR COURT OF THE STATE OF CALIFORNIA ‘ COUNTY OF LOS ANGELES 10 90210 SURGERY MEDICAL CENTER, Case No..BC578420 11 LLC, a limited liability corporation Unlimited Civil Action 12 Plaintiff, PLAINTIFF 90210'S OPPOSITION TO 13 ZENITH AMERICAN SOLUTIONS Vs. INC.’S MOTION TO STRIKE PUNITIVE 14 DAMAGES FROM THE SAC PACIFIC MARITIME ASSOCIATION, in its 15 capacity as Trustee of the Coastwise Indemnity Plan; ZENITH AMERICAN 16 Date: September 13, 2016 SOLUTIONS, INC., a corporation; TC3 Time: 8:30 a.m. 17 HEALTH, INC. a corporation; INNOVATIVE CARE MANAGEMENT, INC., a corporation; Dept: 52 By Fax 18 CIGNA INC., a corporation and DOES 1 19 through 100, inclusive, 20 Defendants, 21 22 23 e 24 A COMES NOW, Plaintiff 90210 SURGERY MEDICAL CENTER, LLC, (hereinafter 25 referred to as "90210") and brings the following opposition to Defendant, ZENITH AMERICAN a Ne 26 SOLUTIONS INC.’S (hereinafter referred toas "Zenith") Motion to Strike Portions of Plaintiff's ee 27 Second Amended Complaint (hereinafter referred to. as “SAC”) as follows: ee 28 PLAINTIFF'S OPPOSITION TO ZENITH’S MOTION TO STRIKE PUNITIVES