On March 12, 2019 a
Party Discovery
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
\r
I L E D
SUPERIOR COURT 0F CALIFORNIA
COUNTY 0F SAN BERNARDINO
SAN BERNARDINO DlSTRICT
KJAR,McKENNA & STOCKALPER, LLP JUL -3 2023
ROBERT L. McKENNA III (SBN 166650)
MICHAEL R. PITTMAN (SBN 260737)
7711 Center Avenue, Suite 350
BY OM A. me
JEs§ICA GAfibEZ. ‘DEPUTY
Huntington Beach, CA 92647
Telephone No. (657) 237-7533 / Facsimile N0. (657) 237-7534
rmckenna@kmslegal.com / mpittman@kmslegal.com
Attorneys for Defendant, STEVEN ERNST, M.D.
00\IO\
SUPERIOR COURT OF THE STATE OF CALIFORNIA
“
\O COUNTY 0F SAN BERNARDINO «z;
10
11 ALEXANDER RUIZ, CASE NO.: CIVDS 1 907976
12 Plaintiff, PUBLIC-REDA CTS MA TERIAL FROM
CONDITIONALL Y SEALED RECORD
13 vs.
DEFENDANT STEVEN ERNST, M.DJS
14 SAN ANTONIO REGIONAL HOSPITAL, REDACTED NOTICE 0F
15
LOMA LINDA UNIVERSITY MEDICAL SETTLEMENT/RESOLUTION
CENTER, STEVEN ERNST, M.D., NABIL PURSUANT T0 CALIFORNIA CODE 0F
16 KOUDSI, M.D., and DOES through 100,
1
CIVIL PROCEDURE § 877.6(a)(2)
Inclusive,
17 [Filed concurrently with Unredacted Notice of
Defendants. Settlement; Redacted Application for Good Faith
18 Settlement; Unredacted Notice of Settlement Lodged
Conditionally Under Seal; and Unredacted Application
for Good Faith Settlement Lodged Conditionally Under
19
Seal; Notice of Motion and Motion to File Under Seal the
Settlement Amount in Defendant’s Application for
20
Redacted Application for Good Faith Settlement; and
[Proposed] Order]
21
ASSIGNED FOR ALL PURPOSES TO:
22 JUDGE: HON. JOSEPH T. ORTIZ
DEPARTMENT: S17
23
Complaint Filed: March 12. 2019
Trial Date: July 31, 2023
24
///
25
///
26
///
27
///
28
1
DEFENDANT’S REDACTED NOTICE OF SETTLEMENT/RESOLUTION PURSUANT TO
CALIFORNIA CODE OF CIVIL PROCEDURE § 877.6(A)(2)
TO THE HONOMBLE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that Plaintiff ALEXANDER RUIZ (“Plaintiff”) and Defendant
STEVEN ERNST, M.D., have entered into a settlement wherein Plaintiffwill accept a confidential
sum in the amount of-, in exchange for a dismissal with prejudice as a full and final
will apply to this Court for
resolution ofhis claims against Steven Ernst, M.D., and that Defendant
provision of California
determination 0f “good faith” of such resolution in accordance with the
Code of Civil Procedure § 877.6(a)(2).
good of this
OGOOflfi PLEASE TAKE FURTHER NOTICE that if you wish to contest the faith
this notice, the attached
settlement, you must, within twenty-five (25) days of the mailing of
application for determination of good faith settlement, and proposed order, file a notice of motion
11 t0 contest the good faith of the settlement in a manner provided by Code of Civil Procedure §
do so, the Court may approve the settlement in accordance with the attached
12 1005(b). Ifyou fail to
13 application and proposed order
14 DATED: June 21, 2023 KJAR, MCKENNA & STOCKALPER, LLP
15
16 By: yM/(m
ROBERT L. McKENNA III
17 MICHAEL R. PITTMAN
Attorneys for Defendant
18
STEVEN ERNST, MD.
19
20
21
22
23
24
25
26
27
28
2
DEFENDANT’S REDACTED NOTICE OF SETTLEMENT/RESOLUTION PURSUANT TO
CALIFORNIA CODE OF CIVIL PROCEDURE § 877.6(A)(2)
Document Filed Date
July 03, 2023
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
\r I L E D SUPERIOR COURT 0F CALIFORNIA COUNTY 0F SAN BERNARDINO SAN BERNARDINO DlSTRICT KJAR,McKENNA & STOCKALPER, LLP JUL -3 2023 ROBERT L. McKENNA III (SBN 166650) MICHAEL R. PITTMAN (SBN 260737) 7711 Center Avenue, Suite 350 BY OM A. me JEs§ICA GAfibEZ. ‘DEPUTY Huntington Beach, CA 92647 Telephone No. (657) 237-7533 / Facsimile N0. (657) 237-7534 rmckenna@kmslegal.com / mpittman@kmslegal.com Attorneys for Defendant, STEVEN ERNST, M.D. 00\IO\ SUPERIOR COURT OF THE STATE OF CALIFORNIA “ \O COUNTY 0F SAN BERNARDINO «z; 10 11 ALEXANDER RUIZ, CASE NO.: CIVDS 1 907976 12 Plaintiff, PUBLIC-REDA CTS MA TERIAL FROM CONDITIONALL Y SEALED RECORD 13 vs. DEFENDANT STEVEN ERNST, M.DJS 14 SAN ANTONIO REGIONAL HOSPITAL, REDACTED NOTICE 0F 15 LOMA LINDA UNIVERSITY MEDICAL SETTLEMENT/RESOLUTION CENTER, STEVEN ERNST, M.D., NABIL PURSUANT T0 CALIFORNIA CODE 0F 16 KOUDSI, M.D., and DOES through 100, 1 CIVIL PROCEDURE § 877.6(a)(2) Inclusive, 17 [Filed concurrently with Unredacted Notice of Defendants. Settlement; Redacted Application for Good Faith 18 Settlement; Unredacted Notice of Settlement Lodged Conditionally Under Seal; and Unredacted Application for Good Faith Settlement Lodged Conditionally Under 19 Seal; Notice of Motion and Motion to File Under Seal the Settlement Amount in Defendant’s Application for 20 Redacted Application for Good Faith Settlement; and [Proposed] Order] 21 ASSIGNED FOR ALL PURPOSES TO: 22 JUDGE: HON. JOSEPH T. ORTIZ DEPARTMENT: S17 23 Complaint Filed: March 12. 2019 Trial Date: July 31, 2023 24 /// 25 /// 26 /// 27 /// 28 1 DEFENDANT’S REDACTED NOTICE OF SETTLEMENT/RESOLUTION PURSUANT TO CALIFORNIA CODE OF CIVIL PROCEDURE § 877.6(A)(2) TO THE HONOMBLE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that Plaintiff ALEXANDER RUIZ (“Plaintiff”) and Defendant STEVEN ERNST, M.D., have entered into a settlement wherein Plaintiffwill accept a confidential sum in the amount of-, in exchange for a dismissal with prejudice as a full and final will apply to this Court for resolution ofhis claims against Steven Ernst, M.D., and that Defendant provision of California determination 0f “good faith” of such resolution in accordance with the Code of Civil Procedure § 877.6(a)(2). good of this OGOOflfi PLEASE TAKE FURTHER NOTICE that if you wish to contest the faith this notice, the attached settlement, you must, within twenty-five (25) days of the mailing of application for determination of good faith settlement, and proposed order, file a notice of motion 11 t0 contest the good faith of the settlement in a manner provided by Code of Civil Procedure § do so, the Court may approve the settlement in accordance with the attached 12 1005(b). Ifyou fail to 13 application and proposed order 14 DATED: June 21, 2023 KJAR, MCKENNA & STOCKALPER, LLP 15 16 By: yM/(m ROBERT L. McKENNA III 17 MICHAEL R. PITTMAN Attorneys for Defendant 18 STEVEN ERNST, MD. 19 20 21 22 23 24 25 26 27 28 2 DEFENDANT’S REDACTED NOTICE OF SETTLEMENT/RESOLUTION PURSUANT TO CALIFORNIA CODE OF CIVIL PROCEDURE § 877.6(A)(2)