On September 11, 2018 a
Party Notice
was filed
involving a dispute between
Bradbury D.D.S., Michael G,
Bradbury, Rhonda,
Odeh, Ali,
and
Cohan, Kat,
Odeh, Ali,
Fernandez D.D.S, Lyngladen,
Fernandez Dds, Lyngladen,
Kingsley Dentistry,
Kingsly Dentistry,
Lyngadlen Fernandez Dds,
Lyngladen Fernandez D.D.S.,
Ringo Bangalan Dds,
Silagan-Fernandez D.D.S., Lyngadlen,
Suarez-Fernandez Dentistry,
Suarez Fernandez Dentistry And Ringo Bangalan, Dds,
for Medical Malpractice Unlimited
in the District Court of San Bernardino County.
Preview
OHHGMNW,
Thomas R. Bradford, Esq., Bar No.: 110230
Sherry Gregon'o, Esq., Bar No.: 263856
Irene A. Yousefi, Esq., Bar No.: 328432 F LED|
PETERSON, BRADFORD, BURKWITz “$3530" COURT OF cmrom
GREGORIO, BURKWITZ & SU, LLP
WOF SAN BERNARDONO
100 North First Street, Suite 300
Burbank, California 91502 OCT 2 6 2023
T: 818.562.5800
(DmVODWhOON—fi
F. 818.562.5810
BY
Attorneys for Defendant, MAR'AH MORA. DEPUTY
RINGO BANGALAN, D.D.S.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO ‘:I
C3317
Ali Odeh
Plaintiff,
Case
Assigned
No.:
[Dept. $31]
CIVDS1823772
to the Honorable: John M. Pacheco G
LLP
300
BURKWITZ,
vs.
SU.
Suite
91502 SPECIALLY APPEARING DEFENDANT RINGO
& Lyngadlen Femandez; DDS; Suarez-Femandez BANGALAN, D.D.S’S NOTICE OF INTENT TO
Dentistry and Ringo Bangalan, DDS FILE A MOTION FOR AN ORDER DECLARING
818.562.5800
Street.
BURKWITZ
California
PLAINTIFF ALI ODEH A VEXATIOUS LITIGANT
AND FOR AN ORDER REQUIRING PLAINTIFF TO
BRADFORD,
Defendants.
First
POST SECURITY IN AMOUNT 0F $20,000
Telephone
Burbank.
North
GREGORIO.
PETERSON.
100
mem#WNAo®mem#WN—¥O
Complaint Filed: September 11, 2018
NNNNNNNNN—L—LAAAAAAAA
Tn'al Date: January 9, 2024
T0 ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE that on January 25, 2024, at 8:30 a.m., or as soon thereafter as this matter
may be heard in Depanment $31 of the above-entitled court located at 247 West Third Street, 9‘“ Floor, San
Bemardino, CA 92415, Defendant Ringo Bangalan, D.D.S (“Dr. Bangalan”) will move for an orderdeclan‘ng Ali
Odeh (“Plaintiff”) a vexatious litigant should Plaintiff persist in filing unmen'torious and frivolous Motions/ Moving
papers against Dr. Bangalan.
Consistent with such a determination, Dr. Bangalan request that the Court issue a pre-filing order
prohibiting Plaintiff from filling any new litigation in the Courts of this State without first obtaining leave from the
presiding justice orjudge of the Court where the litigation is proposed to be filed. Dr. Bangalan contends that
1
SPECIALLY APPEARING DEFENDANT RINGO BANGALAN, D.D.S'S NOTICE 0F INTENT TO FILE A
MOTION FOR AN ORDER DECLARING PLAINTIFF ALI ODEH A VEXATIOUS LITIGANT AND FOR AN
ORDER REQUIRING PLAINTIFF TO POST SECURITY IN AMOUNT 0F $20,000
V \a
this litigation lacks men't and has been filed and/or sought to be maintained for the purposes of harassment
and/or improper purposes; accordingly, to the extent the action is not dismissed, Dr. Bangalan respectfully
requests that this Honorable Court issue an order requin'ng Plaintiffto post a bond in the amount of $20,000
pn'or to proceeding with the instant action.
(OQVODCDACDNA
Although the action against Dr. Bangalan has been finally determined, Plaintiff continues to file
frivolous and unmen'ton'ous Motions against Dr. Bangalan. At least three fn'volous and unmen'ton'ous motions
were filed on October 9, 2023 alone. Pursuant to California Rules of Court, “a ‘failure to oppose a motion’ may
be deemed a consenttothe granted of the motion.” (CRC 8.54: Advisory Committee Comment, Subdivision(c).)
Thus, Dr. Bangalan is left with no option but to continuously oppose Plaintiff‘s frivolous and unmen'ton'ous
Motions or n'sk consenting to the Motions themselves. Thus, Dr. Bangalan maintains standing to file a
Vexatious Litigant Motion. Dr. Bangalan makes this motion pursuant to Code of Civil Procedure Sectiors
391(b)(2), 391(b)(3), 391.3, and 391.7, 0n the following grounds:
LLP
300
BURKWITZ;
SU.
Suite
91502
1. Following an adverse determination of each pn'or litigation, Plaintiff has repeatedly relitigated or
&
818.562.5800
Street. attempted to relitigate in pmpn’a persona the (i) validity of the determination against the same Dr. Bangalan or
California
BURKWITZ
BRADFORD,
First
the other defendants; and/or, (ii) the cause of action, claims, or any of the issues of fact or law determined by
Telephone
whom
NNNNNNJ-s-L-s-s—x-n-L-L—s
North
Burbank,
the final determination against the same defendant/ defendants as to the litigation was finally
GREGORIO.
PETERSON.
100 determined; and
2. While acting in propn'a persona, Plaintiff repeatedly filed unmen'torious motions and engaged in
gNECflAMN—koomflmm#wN—IO
tactics that are fn'volous.
3. Plaintiff's pro per status: On July 31, 2020, Plaintiff‘s former counsel, Vasu Vijayraghavan's
Motion to Relieve herself as counsel was granted. On August 10, 2020, Plaintiff obtained new counsel,
Kathen'ne Cohan, Esq. On Segtember 30, 2020, Kathen'ne Cohan, Esq., withdrew as counsel. Since then,
Plaintiff maintained his status as pro per.
4. Frivolous Motions as to Dr. Bangalan’s Final Judgment: On Februag 24, 2021, following
a successful Motion forSummary Judgment, the Honorable Judge VWIfred J. Schneider, Jr., entered judgment
in favor of Dr. Bangalan and against Plaintiff, who was in pro per. On March 23 2022, the Appeal to Dr.
N
2
SPECIALLY APPEARING DEFENDANT RINGO BANGALAN, D.D.S'S NOTICE OF INTENT TO FILE A
MOTION FOR AN ORDER DECLARING PLAINTIFF ALI ODEH A VEXATIOUS LITIGANT AND FOR AN
ORDER REQUIRING PLAINTIFF TO POST SECURITY IN AMOUNT 0F $20,000
Preview
OHHGMNW, Thomas R. Bradford, Esq., Bar No.: 110230 Sherry Gregon'o, Esq., Bar No.: 263856 Irene A. Yousefi, Esq., Bar No.: 328432 F LED| PETERSON, BRADFORD, BURKWITz “$3530" COURT OF cmrom GREGORIO, BURKWITZ & SU, LLP WOF SAN BERNARDONO 100 North First Street, Suite 300 Burbank, California 91502 OCT 2 6 2023 T: 818.562.5800 (DmVODWhOON—fi F. 818.562.5810 BY Attorneys for Defendant, MAR'AH MORA. DEPUTY RINGO BANGALAN, D.D.S. SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO ‘:I C3317 Ali Odeh Plaintiff, Case Assigned No.: [Dept. $31] CIVDS1823772 to the Honorable: John M. Pacheco G LLP 300 BURKWITZ, vs. SU. Suite 91502 SPECIALLY APPEARING DEFENDANT RINGO & Lyngadlen Femandez; DDS; Suarez-Femandez BANGALAN, D.D.S’S NOTICE OF INTENT TO Dentistry and Ringo Bangalan, DDS FILE A MOTION FOR AN ORDER DECLARING 818.562.5800 Street. BURKWITZ California PLAINTIFF ALI ODEH A VEXATIOUS LITIGANT AND FOR AN ORDER REQUIRING PLAINTIFF TO BRADFORD, Defendants. First POST SECURITY IN AMOUNT 0F $20,000 Telephone Burbank. North GREGORIO. PETERSON. 100 mem#WNAo®mem#WN—¥O Complaint Filed: September 11, 2018 NNNNNNNNN—L—LAAAAAAAA Tn'al Date: January 9, 2024 T0 ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE that on January 25, 2024, at 8:30 a.m., or as soon thereafter as this matter may be heard in Depanment $31 of the above-entitled court located at 247 West Third Street, 9‘“ Floor, San Bemardino, CA 92415, Defendant Ringo Bangalan, D.D.S (“Dr. Bangalan”) will move for an orderdeclan‘ng Ali Odeh (“Plaintiff”) a vexatious litigant should Plaintiff persist in filing unmen'torious and frivolous Motions/ Moving papers against Dr. Bangalan. Consistent with such a determination, Dr. Bangalan request that the Court issue a pre-filing order prohibiting Plaintiff from filling any new litigation in the Courts of this State without first obtaining leave from the presiding justice orjudge of the Court where the litigation is proposed to be filed. Dr. Bangalan contends that 1 SPECIALLY APPEARING DEFENDANT RINGO BANGALAN, D.D.S'S NOTICE 0F INTENT TO FILE A MOTION FOR AN ORDER DECLARING PLAINTIFF ALI ODEH A VEXATIOUS LITIGANT AND FOR AN ORDER REQUIRING PLAINTIFF TO POST SECURITY IN AMOUNT 0F $20,000 V \a this litigation lacks men't and has been filed and/or sought to be maintained for the purposes of harassment and/or improper purposes; accordingly, to the extent the action is not dismissed, Dr. Bangalan respectfully requests that this Honorable Court issue an order requin'ng Plaintiffto post a bond in the amount of $20,000 pn'or to proceeding with the instant action. (OQVODCDACDNA Although the action against Dr. Bangalan has been finally determined, Plaintiff continues to file frivolous and unmen'ton'ous Motions against Dr. Bangalan. At least three fn'volous and unmen'ton'ous motions were filed on October 9, 2023 alone. Pursuant to California Rules of Court, “a ‘failure to oppose a motion’ may be deemed a consenttothe granted of the motion.” (CRC 8.54: Advisory Committee Comment, Subdivision(c).) Thus, Dr. Bangalan is left with no option but to continuously oppose Plaintiff‘s frivolous and unmen'ton'ous Motions or n'sk consenting to the Motions themselves. Thus, Dr. Bangalan maintains standing to file a Vexatious Litigant Motion. Dr. Bangalan makes this motion pursuant to Code of Civil Procedure Sectiors 391(b)(2), 391(b)(3), 391.3, and 391.7, 0n the following grounds: LLP 300 BURKWITZ; SU. Suite 91502 1. Following an adverse determination of each pn'or litigation, Plaintiff has repeatedly relitigated or & 818.562.5800 Street. attempted to relitigate in pmpn’a persona the (i) validity of the determination against the same Dr. Bangalan or California BURKWITZ BRADFORD, First the other defendants; and/or, (ii) the cause of action, claims, or any of the issues of fact or law determined by Telephone whom NNNNNNJ-s-L-s-s—x-n-L-L—s North Burbank, the final determination against the same defendant/ defendants as to the litigation was finally GREGORIO. PETERSON. 100 determined; and 2. While acting in propn'a persona, Plaintiff repeatedly filed unmen'torious motions and engaged in gNECflAMN—koomflmm#wN—IO tactics that are fn'volous. 3. Plaintiff's pro per status: On July 31, 2020, Plaintiff‘s former counsel, Vasu Vijayraghavan's Motion to Relieve herself as counsel was granted. On August 10, 2020, Plaintiff obtained new counsel, Kathen'ne Cohan, Esq. On Segtember 30, 2020, Kathen'ne Cohan, Esq., withdrew as counsel. Since then, Plaintiff maintained his status as pro per. 4. Frivolous Motions as to Dr. Bangalan’s Final Judgment: On Februag 24, 2021, following a successful Motion forSummary Judgment, the Honorable Judge VWIfred J. Schneider, Jr., entered judgment in favor of Dr. Bangalan and against Plaintiff, who was in pro per. On March 23 2022, the Appeal to Dr. N 2 SPECIALLY APPEARING DEFENDANT RINGO BANGALAN, D.D.S'S NOTICE OF INTENT TO FILE A MOTION FOR AN ORDER DECLARING PLAINTIFF ALI ODEH A VEXATIOUS LITIGANT AND FOR AN ORDER REQUIRING PLAINTIFF TO POST SECURITY IN AMOUNT 0F $20,000