On September 11, 2018 a
Motion-Secondary
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.
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Ali Odeh ELECTRONICALLY FILEE (Auto)
14167 Flamingo Bay Ln. SUPERIOR COURT OF C ALIFORNIA
COUNTY OF SAN BERNA RDINO
Moreno Valley, California 92553 11/6/2023 2:00 PM
Telephone: (815) 600—2550
E-Mail: AJ0275@vahoo.com
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN BERNARDINO
ALI ODEH Case No.2 CIVDS 1 823772
[Honorable Judge John Pacheco M
Plaintiff,
Department S3 I]
10
11 VS.
OPPOSITION TO DEFENDANT
LYNDGLADEN FERNANDEZ, D.D.S.,
12 AND KINGSLY DENTISTRY’S
LYNGLADEN SILAGAN—FERNANDEZ, DDS; JOINDER IN DEFENDANT RINGO
13
KINGSLY DENTISTRY, ET. AL BANGALAN’S OPPOSITION TO
14 MOTION TO SET ASIDE AND
Defendants.
VACATE SUMMARY JUDGMENT
15 AND TO SET NEW TRIAL
16
17
18 Date: November 17, 2023
Time: 8:30 am.
19
Dept: S31
20
21 Motion Aside and Vacate:
to Set
Date: November 17, 2023
22
Time: 8:30 am.
23 Dept: S3 1
24
25
26
27 Action Filed: September 11, 2018
Trial Date: January 9, 2024
28
1
DEFENDANT LYNGLADEN FERNANDEZ, D.D.S. DBA KINGSLY DENTISTRY JOINDER
PLAINTIFF ALI ODEH’S OPPOSITION TO
TO DEFENDANT RINGO BANGALAN’S OPPOSITION TO MOTION TO VACATE SUMMARY JUDGMENT
CASE NO. CIVDSI 823 772
ODEH, ETAL. V.LYNGLADEN FERNANDEZ, DDS, ET. AL
MEMORANDUM OF POINTS & AUTHORITIES
On October 11, 2023, Plaintiff Ali Odeh (“Odeh”) filed a motion t0 set aside and vacate
the summary judgment entered December 2, 2020, and t0 set a new trial date (“Motion t0
Vacate”).
On October 25, 2023, Defendant Ringo Bangalan filed opposition papers to the Motion to
Vacates, styled as, “Specially Appearing Defendant Rinto Bangalan, D.D.S.’s Opposition to
Plaintiff Ali Odeh’s Motion t0 Set Aside and Vacate Summary Judgment and To Set Aside New
Trial; Memorandum of Points and Authorities”.
On October 25, 2023, Odeh received by electronic message a document styled, as
“Defendant, Lyngladen Fernandez, D.D.S., and Kingsly Dentistry’s Joinder t0 Specially
10
Appearing Defendant, Ringo Bangalan, D.D.S.’ Opposition t0 Plaintiff’ s Motion t0 Set Aside
11 and Vacate Summary Judgment and t0 Set a New Trial” (the “Joinder”). The papers contained 2-
12 pages for the notice, 2-pages with service of process information, and n0 memorandum 0f points
13 and authorities was included in the documents. Although the proof 0f service attached indicates
the document was served 0n August 25, 2023, this is false, because the Motion t0 Vacate itself
14
was not served 0r filed until October 11, 2023. Additionally, 0n October 24, 2023, Defendant,
15
Lyngladen Fernandez, D.D.S. and Kingsly Dentistry (collectively, “Kingsly Dentistry”) filed a
16
separate opposition t0 the Motion t0 Vacate by electronic mail.
17
Plaintiff opposes the Joinder on the following grounds:
18
First, the request that the summary judgment be vacated that was entered solely for
19
Ringo Bangalan, Defendant Lyngladen Fernandez, D.D.S., and dba Kingsly Dentistry’s Joinder
20 in that portion 0f the opposition is improper. Further, Kingsly Dentistry’s separately filed
21 opposition does not contain any narrative whatsoever to support how its interests align with that
22 0f Ringo Bangalan, nor does it include any supporting statements to determine that it is entitled
t0 relief on any 0f the grounds stated in Bangalan’s opposition.
23
Second, Bangalan’s opposition fails to address the main ground 0f the Motion t0 Vacate
24
— namely, that the summary judgment was entered based on a phony consent form, 0n Which the
25
Defendants allegedly conspired t0 forge the Plaintiff” s signature. The overwhelming amount of
26
expert testimony that the consent used to support the Bangalan’s motion for summary judgment
27
is not rebutted whatsoever in either Defendants’ oppositions t0 the Motion to Vacate.
28
2
PLAINTIFF ALI ODEH’S OPPOSITION TODEFENDANT LYNGLADEN FERNANDEZ, D.D.S. DBA KINGSLY DENTISTRY JOINDER
TO DEFENDANT RINGO BANGALAN’S OPPOSITION TO MOTION TO VACATE SUMMARY JUDGMENT
CASE N0. CIVDS1823772
ODEH, ETAL. V. LYNGLADENFERNANDEZ, DDS, ET. AL
Preview
Ali Odeh ELECTRONICALLY FILEE (Auto) 14167 Flamingo Bay Ln. SUPERIOR COURT OF C ALIFORNIA COUNTY OF SAN BERNA RDINO Moreno Valley, California 92553 11/6/2023 2:00 PM Telephone: (815) 600—2550 E-Mail: AJ0275@vahoo.com SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO ALI ODEH Case No.2 CIVDS 1 823772 [Honorable Judge John Pacheco M Plaintiff, Department S3 I] 10 11 VS. OPPOSITION TO DEFENDANT LYNDGLADEN FERNANDEZ, D.D.S., 12 AND KINGSLY DENTISTRY’S LYNGLADEN SILAGAN—FERNANDEZ, DDS; JOINDER IN DEFENDANT RINGO 13 KINGSLY DENTISTRY, ET. AL BANGALAN’S OPPOSITION TO 14 MOTION TO SET ASIDE AND Defendants. VACATE SUMMARY JUDGMENT 15 AND TO SET NEW TRIAL 16 17 18 Date: November 17, 2023 Time: 8:30 am. 19 Dept: S31 20 21 Motion Aside and Vacate: to Set Date: November 17, 2023 22 Time: 8:30 am. 23 Dept: S3 1 24 25 26 27 Action Filed: September 11, 2018 Trial Date: January 9, 2024 28 1 DEFENDANT LYNGLADEN FERNANDEZ, D.D.S. DBA KINGSLY DENTISTRY JOINDER PLAINTIFF ALI ODEH’S OPPOSITION TO TO DEFENDANT RINGO BANGALAN’S OPPOSITION TO MOTION TO VACATE SUMMARY JUDGMENT CASE NO. CIVDSI 823 772 ODEH, ETAL. V.LYNGLADEN FERNANDEZ, DDS, ET. AL MEMORANDUM OF POINTS & AUTHORITIES On October 11, 2023, Plaintiff Ali Odeh (“Odeh”) filed a motion t0 set aside and vacate the summary judgment entered December 2, 2020, and t0 set a new trial date (“Motion t0 Vacate”). On October 25, 2023, Defendant Ringo Bangalan filed opposition papers to the Motion to Vacates, styled as, “Specially Appearing Defendant Rinto Bangalan, D.D.S.’s Opposition to Plaintiff Ali Odeh’s Motion t0 Set Aside and Vacate Summary Judgment and To Set Aside New Trial; Memorandum of Points and Authorities”. On October 25, 2023, Odeh received by electronic message a document styled, as “Defendant, Lyngladen Fernandez, D.D.S., and Kingsly Dentistry’s Joinder t0 Specially 10 Appearing Defendant, Ringo Bangalan, D.D.S.’ Opposition t0 Plaintiff’ s Motion t0 Set Aside 11 and Vacate Summary Judgment and t0 Set a New Trial” (the “Joinder”). The papers contained 2- 12 pages for the notice, 2-pages with service of process information, and n0 memorandum 0f points 13 and authorities was included in the documents. Although the proof 0f service attached indicates the document was served 0n August 25, 2023, this is false, because the Motion t0 Vacate itself 14 was not served 0r filed until October 11, 2023. Additionally, 0n October 24, 2023, Defendant, 15 Lyngladen Fernandez, D.D.S. and Kingsly Dentistry (collectively, “Kingsly Dentistry”) filed a 16 separate opposition t0 the Motion t0 Vacate by electronic mail. 17 Plaintiff opposes the Joinder on the following grounds: 18 First, the request that the summary judgment be vacated that was entered solely for 19 Ringo Bangalan, Defendant Lyngladen Fernandez, D.D.S., and dba Kingsly Dentistry’s Joinder 20 in that portion 0f the opposition is improper. Further, Kingsly Dentistry’s separately filed 21 opposition does not contain any narrative whatsoever to support how its interests align with that 22 0f Ringo Bangalan, nor does it include any supporting statements to determine that it is entitled t0 relief on any 0f the grounds stated in Bangalan’s opposition. 23 Second, Bangalan’s opposition fails to address the main ground 0f the Motion t0 Vacate 24 — namely, that the summary judgment was entered based on a phony consent form, 0n Which the 25 Defendants allegedly conspired t0 forge the Plaintiff” s signature. The overwhelming amount of 26 expert testimony that the consent used to support the Bangalan’s motion for summary judgment 27 is not rebutted whatsoever in either Defendants’ oppositions t0 the Motion to Vacate. 28 2 PLAINTIFF ALI ODEH’S OPPOSITION TODEFENDANT LYNGLADEN FERNANDEZ, D.D.S. DBA KINGSLY DENTISTRY JOINDER TO DEFENDANT RINGO BANGALAN’S OPPOSITION TO MOTION TO VACATE SUMMARY JUDGMENT CASE N0. CIVDS1823772 ODEH, ETAL. V. LYNGLADENFERNANDEZ, DDS, ET. AL