On April 19, 2018 a
Party Discovery
was filed
involving a dispute between
Garvey, Peter Alan,
and
Bohlman, Jeri Lynne,
Does 1-25,
Liebherr, Fred,
for PI Motor Vehicle
in the District Court of San Bernardino County.
Preview
DISC 030
ATTORNEY flR PARTY WITHDUT ATTORNEY Nama State Sarnurnber arsd acfOrass FOR COURT USE QAtY
Scott B Spri gs S N 11 71
Kinkle Radi er andSpri s
3333 14th St Riverside A 92SQ1
TELEPHONE NO S C 53 241 O n No o ro 951 6 3 7759
E MAIL ADORESS Uj fiotl9n
ATTflRNEYPOR Narre
Defendants JERI LYhINE BOHGMAN and FRED LIE SUPERIOR C U T OF CALIFQRNI
COlJIVTY O
AhI t3EIZNARDINO
SUPERiOR CfliJRT 4F GAI iFORNfA courtrr oF SAN BERNARDINO SAN 6ERNRR4 INO plSTF21CT
S7REETApDRESS 2t Yy 3rd Street
MA0 1NG ADDRESS
c TrANoz PcooE n Bet nardino CA 92415
BRANCM NAME 7
SH 3RT Tl7LE
ANDR IA EP
Garvey v Bolhman
CkSE NUMBER
CQMMISSIC N TO TAK DEPOSITIOlV OUTSIDE CALIFORNIA
CIVI3S18094fi2
Q ORDERED BY COURT ISSUED BY THE CLERK OF THE COURT
1 The Supenar Caurt of Galifornia hereby authorizes the deposition upon oral examinatlon of identlty of deponent
Krasimir Hristov DG
The depnsitian is ta be taken in state afthe United Sfates territor ori sularpassessian subject to its jurisdlctlon
New Mexico USA
3 The deposition will be conducted check one
a Q Under the supervision of a persan who is authorized to administer oaths by the laws af the United States or those af the
pface where the examination is to be held and whca is not otherwise disqualified under Caiifornia Code pf Civii Proc dure
sectians 2025 320 and 2425 3d0 b if or
b Q Before name of appoinfee
who is appointed to administer aafhs and fa take testimony
4 The documents or things to be produced at the time and place of the deposition are
described in Attachment 4 none
5 Additional terms required by the foreign jurisdiction to initiate the process are contained in Attachment 5 FJumber of pages
attached
6 Under California Code of Civil Procedure section 2026 d10 Califamia authorizes that a commission to take an out of state
deposition may be issued by the cierk af the court or if the foreign juriscfiction requires it by order a fhe caurt
7 7he Su aeriar Gourt of the State of California hereby requests tha process issua in the above referenced place where the
examin tion is ta be held r equiring the attendance and eniorcing the obligatians of the d panent to produt documents and
answer questions
SEP 0 4 02
ace
Judge
oR
i
Glerk Deputy
by
CnUrt Seel
Pa e t af t
F a to o use
m nva o
Ct r os Gv P oc g zozs arar
MMtSSit tJ Tfl TAKE u y
Q
DI NoewJanuary 4 r2008 DEPC SITION OUTSID CALIFORNlA
PRQDUCTIQN OF DOCUMENTS
1 ATTACHMENT
Plaintiff l eter Alan Garvey
D te af I3irth January 22 1974
3
1 Any and all documents paper and digitai records pertaining to care treatment and
4
examinatian inclu ing but not limited to all office raorn inpatient outpatient charts
emergency
5
eitl er in harci copy or electronic andlor faxed Any and a l x ray films to include MRI films CAT
6
scans myelograms radiological images ultrasounds and any other films specific tc PETER ALAN
7
GARVEY Please provide breakdown of filrns and or studies reflecting body parts dates taken
8
nurnber of filrns and or studies with associated cast for appraval prior to production Any and all
9
records of payment andlor disco int cegar ding any tnedtcal bi ing as wel as the bills themselves
1Q
billing infartnatian inclt t ing but not limited to proced re and diagnosis codes statements
ir
cornputer printouts itemized breakdown of all charges payments adjustments write offs or
12
balance due including but not lirnited to al charges credits payments adjustments and or write
13
affs and the sources of each such as all EQBs from any insurance carrier reflecting any and all
14
credits and adjustments and write offs to the bills by virtue of any payrnents and or contractual
1S
agreementsladjustments inc udin fees etc for professianal services including Medicare
16
Medicaid etc pertaining to PETER ALAN GARVEY born an January 22 1974 with SS Ut 1K
17
RECORDS FROM Septernber S 2012 TO PRESENT To include all electronic communications
I8
from and to the patient Patient treated at Reinecke Chiropractic at 1210 Narth Main Street
19
Roswell New Mexico 88201
20
2
Zz
as
26
27
28
KINKLE ROOIGER
tNQ SPRIGGS
ProtessirnalCaWretian
Document Filed Date
September 04, 2020
Case Filing Date
April 19, 2018
Category
PI Motor Vehicle
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DISC 030 ATTORNEY flR PARTY WITHDUT ATTORNEY Nama State Sarnurnber arsd acfOrass FOR COURT USE QAtY Scott B Spri gs S N 11 71 Kinkle Radi er andSpri s 3333 14th St Riverside A 92SQ1 TELEPHONE NO S C 53 241 O n No o ro 951 6 3 7759 E MAIL ADORESS Uj fiotl9n ATTflRNEYPOR Narre Defendants JERI LYhINE BOHGMAN and FRED LIE SUPERIOR C U T OF CALIFQRNI COlJIVTY O AhI t3EIZNARDINO SUPERiOR CfliJRT 4F GAI iFORNfA courtrr oF SAN BERNARDINO SAN 6ERNRR4 INO plSTF21CT S7REETApDRESS 2t Yy 3rd Street MA0 1NG ADDRESS c TrANoz PcooE n Bet nardino CA 92415 BRANCM NAME 7 SH 3RT Tl7LE ANDR IA EP Garvey v Bolhman CkSE NUMBER CQMMISSIC N TO TAK DEPOSITIOlV OUTSIDE CALIFORNIA CIVI3S18094fi2 Q ORDERED BY COURT ISSUED BY THE CLERK OF THE COURT 1 The Supenar Caurt of Galifornia hereby authorizes the deposition upon oral examinatlon of identlty of deponent Krasimir Hristov DG The depnsitian is ta be taken in state afthe United Sfates territor ori sularpassessian subject to its jurisdlctlon New Mexico USA 3 The deposition will be conducted check one a Q Under the supervision of a persan who is authorized to administer oaths by the laws af the United States or those af the pface where the examination is to be held and whca is not otherwise disqualified under Caiifornia Code pf Civii Proc dure sectians 2025 320 and 2425 3d0 b if or b Q Before name of appoinfee who is appointed to administer aafhs and fa take testimony 4 The documents or things to be produced at the time and place of the deposition are described in Attachment 4 none 5 Additional terms required by the foreign jurisdiction to initiate the process are contained in Attachment 5 FJumber of pages attached 6 Under California Code of Civil Procedure section 2026 d10 Califamia authorizes that a commission to take an out of state deposition may be issued by the cierk af the court or if the foreign juriscfiction requires it by order a fhe caurt 7 7he Su aeriar Gourt of the State of California hereby requests tha process issua in the above referenced place where the examin tion is ta be held r equiring the attendance and eniorcing the obligatians of the d panent to produt documents and answer questions SEP 0 4 02 ace Judge oR i Glerk Deputy by CnUrt Seel Pa e t af t F a to o use m nva o Ct r os Gv P oc g zozs arar MMtSSit tJ Tfl TAKE u y Q DI NoewJanuary 4 r2008 DEPC SITION OUTSID CALIFORNlA PRQDUCTIQN OF DOCUMENTS 1 ATTACHMENT Plaintiff l eter Alan Garvey D te af I3irth January 22 1974 3 1 Any and all documents paper and digitai records pertaining to care treatment and 4 examinatian inclu ing but not limited to all office raorn inpatient outpatient charts emergency 5 eitl er in harci copy or electronic andlor faxed Any and a l x ray films to include MRI films CAT 6 scans myelograms radiological images ultrasounds and any other films specific tc PETER ALAN 7 GARVEY Please provide breakdown of filrns and or studies reflecting body parts dates taken 8 nurnber of filrns and or studies with associated cast for appraval prior to production Any and all 9 records of payment andlor disco int cegar ding any tnedtcal bi ing as wel as the bills themselves 1Q billing infartnatian inclt t ing but not limited to proced re and diagnosis codes statements ir cornputer printouts itemized breakdown of all charges payments adjustments write offs or 12 balance due including but not lirnited to al charges credits payments adjustments and or write 13 affs and the sources of each such as all EQBs from any insurance carrier reflecting any and all 14 credits and adjustments and write offs to the bills by virtue of any payrnents and or contractual 1S agreementsladjustments inc udin fees etc for professianal services including Medicare 16 Medicaid etc pertaining to PETER ALAN GARVEY born an January 22 1974 with SS Ut 1K 17 RECORDS FROM Septernber S 2012 TO PRESENT To include all electronic communications I8 from and to the patient Patient treated at Reinecke Chiropractic at 1210 Narth Main Street 19 Roswell New Mexico 88201 20 2 Zz as 26 27 28 KINKLE ROOIGER tNQ SPRIGGS ProtessirnalCaWretian