On March 12, 2019 a
Party Notice
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
f ILEC
SUPERIOR COURT OF CAUFORNIA
OUNTY OF SAN BERNARDINO
SAN BERNARQIRIO DISTRIG
1 KJAR McKENNA STOCKALPER LLP
ROBERT L McKENNA III SBN 166650 9 20
2
ALESSA R JONAS SBN 299161
3 7711 Center Avenue Suite 350
BY
Huntington Beach CA 92647 DAISY AILON DEPUTt
4 Telephone No 657 237 7533 Facsimile No 657 237 7534
Attorneys for Defendant STEVEN ERNST M D
5
6
7
g SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT
10
11 ALEXANDER RUIZ CASE NO CIVDS1907976
12 Plaintiff DEFENDANT STEVEN ERNST M D S
NOTICE OF LODGING EVIDENCE IN
13 vs
SUPPORT OF MOTION FOR SUMMARY
14 NDGMENT
SAN ANTONIO REGIONAL HOSPITAL
LOMA LINDA iJNIVERSITY MEDICAL
15 Filed concurrently with Notice of Motion
CENTER STEVEN ERNST M D NABIL
MD
and Motion for Summary Judgment
16 KOUDSI and DOES 1 through 100
Separate Statement of Undisputed Material
Inclusive
Facts Proposed Order Proposed
1
Judgment
Defendants
18
Date September 22 2020
19 Time 1 30 PM s r x
Reservation Number
20
ASSIGNED FOR ALL PURPOSES TO
21 JUDGE HON THOMAS S GARZA
DEPARTMENT S27
22
Complaint Filed March 12 2019
Trial Date March 29 2021
23
24 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD
25 Pursuant to California Rules of Court rule 3 1350 g Defendant STEVEN ERNST
26
M D provide the following evidence in support of his concurrently filed Motion for Summary
27 Judgment
28
1
DEFENDANT STEVEN ERNST M D S NOTICE OF LODGING EVIDENCE IN SUPPORT OF MOTION FOR
SUMMARY NDGMENT
1 l Attached hereto Exhibit A
as
is a true and correct copy of Plaintiffls
2 Complaint
3 2 Attached hereto Exhibit B
as
is a true and correct copy of Plaintif s medical
4 records from San Antonio Regional Hospital
5 3 Attached hereto Exhibit C
as
is a true and correct copy of the pertinent
6 portions of Plaintiffls from Loma Linda Medical Center
medical records
University A CD
7
containing the complete set of records from which Exhibit C was extracted is attached to the
8 hereto as Exhibit D
9 4 Attached hereto Exhibit E
as
is a true and correct copy of Plaintiffls medical
10 records from American Medical Response
11 5 Attached hereto Exhibit F
as
is a certified copy of Plaintiff s deposition
12 transcript
13 6 Attached hereto Exhibit G
as
is a certified copy of Shirley Ruiz s deposition
14 transcript
15 7 Attached hereto as Exhibit H is a certified copy of Michael Ruiz s deposition
16 transcript
17 8 Attached hereto Exhibit I
as
is a certified copy of Nabil Koudsi M D s
18 deposition transcript
19 9 Attached hereto Exhibit J
as
is a certified copy of Steven Ernst M D s
20 deposition transcript
21 10 Attached hereto as Exhibit K is the Declaration of Raymond L Ricci M D
22
23
24
25
26
27
28
2
DEFENDANT STEVEN ERNST M D S NOTICE OF LODGING EVIDENCE IN SUPPORT OF MOTION FOR
SUMMARY JUDGMENT
Document Filed Date
July 09, 2020
Case Filing Date
March 12, 2019
Category
Complaint for Medical Malpractice
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
f ILEC SUPERIOR COURT OF CAUFORNIA OUNTY OF SAN BERNARDINO SAN BERNARQIRIO DISTRIG 1 KJAR McKENNA STOCKALPER LLP ROBERT L McKENNA III SBN 166650 9 20 2 ALESSA R JONAS SBN 299161 3 7711 Center Avenue Suite 350 BY Huntington Beach CA 92647 DAISY AILON DEPUTt 4 Telephone No 657 237 7533 Facsimile No 657 237 7534 Attorneys for Defendant STEVEN ERNST M D 5 6 7 g SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT 10 11 ALEXANDER RUIZ CASE NO CIVDS1907976 12 Plaintiff DEFENDANT STEVEN ERNST M D S NOTICE OF LODGING EVIDENCE IN 13 vs SUPPORT OF MOTION FOR SUMMARY 14 NDGMENT SAN ANTONIO REGIONAL HOSPITAL LOMA LINDA iJNIVERSITY MEDICAL 15 Filed concurrently with Notice of Motion CENTER STEVEN ERNST M D NABIL MD and Motion for Summary Judgment 16 KOUDSI and DOES 1 through 100 Separate Statement of Undisputed Material Inclusive Facts Proposed Order Proposed 1 Judgment Defendants 18 Date September 22 2020 19 Time 1 30 PM s r x Reservation Number 20 ASSIGNED FOR ALL PURPOSES TO 21 JUDGE HON THOMAS S GARZA DEPARTMENT S27 22 Complaint Filed March 12 2019 Trial Date March 29 2021 23 24 TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD 25 Pursuant to California Rules of Court rule 3 1350 g Defendant STEVEN ERNST 26 M D provide the following evidence in support of his concurrently filed Motion for Summary 27 Judgment 28 1 DEFENDANT STEVEN ERNST M D S NOTICE OF LODGING EVIDENCE IN SUPPORT OF MOTION FOR SUMMARY NDGMENT 1 l Attached hereto Exhibit A as is a true and correct copy of Plaintiffls 2 Complaint 3 2 Attached hereto Exhibit B as is a true and correct copy of Plaintif s medical 4 records from San Antonio Regional Hospital 5 3 Attached hereto Exhibit C as is a true and correct copy of the pertinent 6 portions of Plaintiffls from Loma Linda Medical Center medical records University A CD 7 containing the complete set of records from which Exhibit C was extracted is attached to the 8 hereto as Exhibit D 9 4 Attached hereto Exhibit E as is a true and correct copy of Plaintiffls medical 10 records from American Medical Response 11 5 Attached hereto Exhibit F as is a certified copy of Plaintiff s deposition 12 transcript 13 6 Attached hereto Exhibit G as is a certified copy of Shirley Ruiz s deposition 14 transcript 15 7 Attached hereto as Exhibit H is a certified copy of Michael Ruiz s deposition 16 transcript 17 8 Attached hereto Exhibit I as is a certified copy of Nabil Koudsi M D s 18 deposition transcript 19 9 Attached hereto Exhibit J as is a certified copy of Steven Ernst M D s 20 deposition transcript 21 10 Attached hereto as Exhibit K is the Declaration of Raymond L Ricci M D 22 23 24 25 26 27 28 2 DEFENDANT STEVEN ERNST M D S NOTICE OF LODGING EVIDENCE IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT