On March 12, 2019 a
Party Statement
was filed
involving a dispute between
Ruiz, Alexander,
and
Loma Linda University Medical Center,
Nabil Koudsi, M.D.,
San Antonio Regional Hospital,
Steven Ernst, M.D.,
for Complaint for Medical Malpractice
in the District Court of San Bernardino County.
Preview
1 Gary M Schneider Esq SBN 72553
Nancy Siccama Esq SBN 285800
2 lAW OFFICES OF GARY M SCHNEIDER
3
121aQ Wilshire Boulevard Suite 1100
Los Angeles CA 80025 7111
Scouti
5q y
ro
1y coupTE
Telephane 310 820 5544
N pM1 q y
NAR INo
4 Facsimile 310 820 6024 S p iSroN
Attomeys for Plaintiff
0
5
F
6
7
8
SUPERIOR COURT FOR THE STATE OF CALIFORNIA
9
IN THE COUN tY OF SAN BERNARDINO
10
11
12 ALEXANDER RUIZ CASE NO CIVDS 1907976
13 Assigned for all purposes to Honorable
Plaintiff Judge Thomas S Garza in Depf S27
14
vs DECLARATION OF GARY M
15 SCHNEIDER SUBMiTTED IN
SAN ANTONIO REGIONAL HOSPITAL OPPOS TION TC MOTION FOR
16 LOMA UNDA UNIVERSITY MEDICAL SUMMARY JUDGMENT OF DEFENDANT
CENTER STEVEN ERNST M D NABIL STEVEN ERNST M D
1 KDUDSi M D and DOES 1 through 100
inclusive D te September 22 2020
18 Time 1 30 p m
Qefendants Dept S27
19
Filed Concurrentiy with Plaintiffs
20 Memorandum of Points and Authorities in
Opposition to Motion for Summary
21 Judgment of Defendant Steven Emst
M D P aintifPs Separate Statement of
22 Disputed and Undisputed Materiai Facts
and Supporting Evidence Submitted in
23 Oppositicm to Motion for Summary
Judgment of Defendant Steven Emst
24 M D and Declaration of Richard Sonner
t
M D
25
Triaf Date March 29 2021
26 Complaint Filed March 12 2019
27
28
1
DECLARATION OF iARY M 9CHNEI R SUBM2TTED IN OPPOSROON TO AbOl10N FOR SUMNlARY JUO iMBdT OF OEFENDANT
S7EVEN ERNST M D
1 DECLARATION OF GARY M SCHNEIDER
2 i Gary M Sr neider decla e and state as follows
3 1 I am one of the attomeys of record for p aintiff in this action I am submitting this
4 declaration in opposition to the Motion for Summary Judgment of defendant Steven Emst
5 MD Dr EmsY I have persanal knowledge of the facts set forth herein and could if
6 calied upon to do so competen y testify thereto as a witness under oath
7 2 With Plainfiff s opposition to the motion for summary judgment we are submitting
8 the declara on of Richard Sonner M D Dr Sonner tn his declaration Dr Sonner
9 makes reference to records he reviewed in the case alt of which have already been
10 authenticated and filed with the Court by Dr Emst with his motion For the Court s
li convenient reference I am attaching to this declaration specif c pertinent records that are
12 included in the large volume of records already filed with the court by Dr Emst I am also
3 attaching relevant portions of deposition testimony
14 3 Attached hereto as Exhibit 1 are pages 1 2 of the American Medicai Respanse
15 AMR Pa ent Care Report pertaining to the care and transport of Mr Ruiz from tha
16 footbakl field where he was injured to San Antonio Regional Hospital San Antonio
1 These pages show that the AMR team arrived at Mr Ruiz s side at 7 29 p m departed
18 the scene with Mr Ruiz at 7 41 p m and arrived at San Antonio at 8 02 p m Ths record
19 also shows in the narrative portion that when Mr Ruiz was examined whlle still at the
2o football field he had a dorsal pedis pulse present
21 4 Attached hereto as Exhibit 2 are pages from the San Antonio Record numbered 1
22 11 The rapid triage assessment of 8 11 p m is on page 5 of 11 The nurse noted there
23 that Mr Ruiz s right lower extremity was cool to touch that there was an inability ta
2 9 palpate a right dorsalis pedis pulse that the capiltary refill equaled 3 seconds and that the
25 M D was aware Dr EmsYs assessment of Mr Ruiz at 8 26 p m is on pages 1 2 of 11 It
2 6 was noted there that Mr Ruiz could not feel his right foot that his right knee was rnarkediy
2 deformed that the right dorsalis pedis pulse was absent and that the right foot and tower
28 distal eg were cQol to touch The record of the joint reduction at 9 p m is on page 4 of 11
2
DECLARATtON OF f3ARY M SCHNEIOER SUBMf1 I ED tN OPPOSITION TO NE 7SON FOR 8UMMARY JUOCiMFJ T OF DEPENpANT
srEVEN sr n o
Document Filed Date
September 08, 2020
Case Filing Date
March 12, 2019
Category
Complaint for Medical Malpractice
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1 Gary M Schneider Esq SBN 72553 Nancy Siccama Esq SBN 285800 2 lAW OFFICES OF GARY M SCHNEIDER 3 121aQ Wilshire Boulevard Suite 1100 Los Angeles CA 80025 7111 Scouti 5q y ro 1y coupTE Telephane 310 820 5544 N pM1 q y NAR INo 4 Facsimile 310 820 6024 S p iSroN Attomeys for Plaintiff 0 5 F 6 7 8 SUPERIOR COURT FOR THE STATE OF CALIFORNIA 9 IN THE COUN tY OF SAN BERNARDINO 10 11 12 ALEXANDER RUIZ CASE NO CIVDS 1907976 13 Assigned for all purposes to Honorable Plaintiff Judge Thomas S Garza in Depf S27 14 vs DECLARATION OF GARY M 15 SCHNEIDER SUBMiTTED IN SAN ANTONIO REGIONAL HOSPITAL OPPOS TION TC MOTION FOR 16 LOMA UNDA UNIVERSITY MEDICAL SUMMARY JUDGMENT OF DEFENDANT CENTER STEVEN ERNST M D NABIL STEVEN ERNST M D 1 KDUDSi M D and DOES 1 through 100 inclusive D te September 22 2020 18 Time 1 30 p m Qefendants Dept S27 19 Filed Concurrentiy with Plaintiffs 20 Memorandum of Points and Authorities in Opposition to Motion for Summary 21 Judgment of Defendant Steven Emst M D P aintifPs Separate Statement of 22 Disputed and Undisputed Materiai Facts and Supporting Evidence Submitted in 23 Oppositicm to Motion for Summary Judgment of Defendant Steven Emst 24 M D and Declaration of Richard Sonner t M D 25 Triaf Date March 29 2021 26 Complaint Filed March 12 2019 27 28 1 DECLARATION OF iARY M 9CHNEI R SUBM2TTED IN OPPOSROON TO AbOl10N FOR SUMNlARY JUO iMBdT OF OEFENDANT S7EVEN ERNST M D 1 DECLARATION OF GARY M SCHNEIDER 2 i Gary M Sr neider decla e and state as follows 3 1 I am one of the attomeys of record for p aintiff in this action I am submitting this 4 declaration in opposition to the Motion for Summary Judgment of defendant Steven Emst 5 MD Dr EmsY I have persanal knowledge of the facts set forth herein and could if 6 calied upon to do so competen y testify thereto as a witness under oath 7 2 With Plainfiff s opposition to the motion for summary judgment we are submitting 8 the declara on of Richard Sonner M D Dr Sonner tn his declaration Dr Sonner 9 makes reference to records he reviewed in the case alt of which have already been 10 authenticated and filed with the Court by Dr Emst with his motion For the Court s li convenient reference I am attaching to this declaration specif c pertinent records that are 12 included in the large volume of records already filed with the court by Dr Emst I am also 3 attaching relevant portions of deposition testimony 14 3 Attached hereto as Exhibit 1 are pages 1 2 of the American Medicai Respanse 15 AMR Pa ent Care Report pertaining to the care and transport of Mr Ruiz from tha 16 footbakl field where he was injured to San Antonio Regional Hospital San Antonio 1 These pages show that the AMR team arrived at Mr Ruiz s side at 7 29 p m departed 18 the scene with Mr Ruiz at 7 41 p m and arrived at San Antonio at 8 02 p m Ths record 19 also shows in the narrative portion that when Mr Ruiz was examined whlle still at the 2o football field he had a dorsal pedis pulse present 21 4 Attached hereto as Exhibit 2 are pages from the San Antonio Record numbered 1 22 11 The rapid triage assessment of 8 11 p m is on page 5 of 11 The nurse noted there 23 that Mr Ruiz s right lower extremity was cool to touch that there was an inability ta 2 9 palpate a right dorsalis pedis pulse that the capiltary refill equaled 3 seconds and that the 25 M D was aware Dr EmsYs assessment of Mr Ruiz at 8 26 p m is on pages 1 2 of 11 It 2 6 was noted there that Mr Ruiz could not feel his right foot that his right knee was rnarkediy 2 deformed that the right dorsalis pedis pulse was absent and that the right foot and tower 28 distal eg were cQol to touch The record of the joint reduction at 9 p m is on page 4 of 11 2 DECLARATtON OF f3ARY M SCHNEIOER SUBMf1 I ED tN OPPOSITION TO NE 7SON FOR 8UMMARY JUOCiMFJ T OF DEPENpANT srEVEN sr n o