On January 24, 2020 a
Party Discovery
was filed
involving a dispute between
Williams, Barbara,
and
Maldonado, Mariclare,
Wilson, Troy,
for Personal Injury Motor Vehicle Unlimited
in the District Court of San Bernardino County.
Preview
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ifm; 5‘
THE LAW OFFICE OF JONATHAN M. KASHANI, P.L.C.
JONATHAN M. KASHANI, State Bar N0. 266610
ionathan@kashlegal.com
BRIGITTE M. MAYO, State Bar N0. 173584
brigitte.mavo@kashlegal.com
GARY GUILLEN, State Bar No. 337780
gary.2uillen@kashlegal.com
Kash Legal Building
2839 South Robertson Boulevard
Los Angeles, California 90034
Telephone: (3 0) 272-7157
1
Facsimile: (3 10) 272-7746
\OOONON
litigationteam®kashlegal.com
Attorneys for Plaintiff, BARBARA WILLIAMS
10
SUPERIOR COURT OF THE STATE OF CALIFORNIA
11
12
COUNTY OF SAN BERNARDINO
13 BARBARA WILLIAMS, CASE NO. CIVD82002655
14
Plaintiff, DECLARATION OF GARY GUILLEN, ESQ.
15 IN SUPPORT OF PLAINTIFF’S
vs. OPPOSITION TO DEFENDANT TROY
16 WILSON’S MOTION TO QUASH THE
TROY WILSON; and DOES 1 to 100, inclusive, VIDEOTAPED DEPOSITION OF
17 DEFENDANT’S PHYSICIAN, JAMES I.
18
Defendant. RHO, M.D., AND REQUEST FOR
PRODUCTION OF DOCUMENTS 0R, IN
19 THE ALTERNATIVE, MOTION FOR A
PROTECTIVE ORDER
20
[served andfiled concurrently with Plaintiff’s Opposition
21 t0 Motion; [Proposed] Order]
22 Date: November 2022
9,
Time: 8:30 a.m.
23
Dept: S30
24
Trial Readiness Conference: March 9, 2023
25 Trial Date: March 13, 2023
26 ///
27 ///
28 ///
DECLARATION OF GARY GUILLEN, SUPPORT OF PLATNTIFF’S OPPOSITION TO DEFENDANT TROY
ESQ. TN
WILSON’S MOTION TO QUASH
l
DECLARATION OF GARY GUILLEN, ES! 2.
l, Gary Guillen, declare as follows:
DJ
. I am an attorney at law, duly qualified to practice before all 0fthe courts ofthe State of California.
. I am an attorney at the LAW OFFICES OF JONATHAN M. KASHANI, attorneys for Plaintiff,
BARBARA WILLIAMS, in this action.
. I make this Declaration of my own personal knowledge in that capacity. The facts stated herein
“a
are true based upon my own knowledge, except as to those facts which I believe to be true, and if
called upon t0 testify, I could and would testify competently thereto.
. At the time of the incident, Defendant Troy Wilson (“Defendant Wilson”), was taking the
10 following medications:
11 Dilaudid (Hydromorphone) — Schedule II opioid analgesic — according to the DEA drug fact
sheet: “It has an analgesic potency of two to eight times greater than that 0f morphine and
12 has a rapid onset 0f action.”
13
Morphine, extended release — Schedule II narcotic derived from opium
14
Lyrica (Pregabalin) fl Schedule V — nerve pain medication/antiepileptic
15
Tizanidine (muscle relaxer)
16
Celebrex — nonsteroidal anti-inflammatory drug (NSAID)
17
18 Attached hereto as Exhibit “A” is a true and correct copy 0f the relevant deposition transcript
excerpt of Defendant Wilson (p.32: l -l 6) dated February 23, 2021. Attached hereto as Exhibit
19
“B” are true and correct copies of the Department of Justice Drug Enforcement Administration
20
21 online Drug Fact Sheet regarding Hydromorphone (Dilaudid) and Morphine.
Dr. James I. Rho was Defendant Wilson’s pain management doctor and the prescribing doctor
22 .
for all ofthe medications set forth above. Attached hereto as Exhibit “A” is a true and correct
23
copy 0f the relevant deposition transcript excerpt 0f Defendant Wilson (pp.34:20-35: 1) dated
24
25 February 23, 2021.
26 . On July 29, 2022, my office properly issued a Deposition Subpoena for Personal Appearance and
27 Production 0f Documents and Things t0 Defendant Wilson’s prescribing physician, Dr. Rho.
28
DECLARATION OF GARY GUILLEN, ESQ. INSUPPORT OF PLAINTIFF’S OPPOSITION TO DEFENDANT TROY
WILSON’S MOTION TO QUASH
2
Document Filed Date
October 27, 2022
Case Filing Date
January 24, 2020
Category
Personal Injury Motor Vehicle Unlimited
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’ ifm; 5‘ THE LAW OFFICE OF JONATHAN M. KASHANI, P.L.C. JONATHAN M. KASHANI, State Bar N0. 266610 ionathan@kashlegal.com BRIGITTE M. MAYO, State Bar N0. 173584 brigitte.mavo@kashlegal.com GARY GUILLEN, State Bar No. 337780 gary.2uillen@kashlegal.com Kash Legal Building 2839 South Robertson Boulevard Los Angeles, California 90034 Telephone: (3 0) 272-7157 1 Facsimile: (3 10) 272-7746 \OOONON litigationteam®kashlegal.com Attorneys for Plaintiff, BARBARA WILLIAMS 10 SUPERIOR COURT OF THE STATE OF CALIFORNIA 11 12 COUNTY OF SAN BERNARDINO 13 BARBARA WILLIAMS, CASE NO. CIVD82002655 14 Plaintiff, DECLARATION OF GARY GUILLEN, ESQ. 15 IN SUPPORT OF PLAINTIFF’S vs. OPPOSITION TO DEFENDANT TROY 16 WILSON’S MOTION TO QUASH THE TROY WILSON; and DOES 1 to 100, inclusive, VIDEOTAPED DEPOSITION OF 17 DEFENDANT’S PHYSICIAN, JAMES I. 18 Defendant. RHO, M.D., AND REQUEST FOR PRODUCTION OF DOCUMENTS 0R, IN 19 THE ALTERNATIVE, MOTION FOR A PROTECTIVE ORDER 20 [served andfiled concurrently with Plaintiff’s Opposition 21 t0 Motion; [Proposed] Order] 22 Date: November 2022 9, Time: 8:30 a.m. 23 Dept: S30 24 Trial Readiness Conference: March 9, 2023 25 Trial Date: March 13, 2023 26 /// 27 /// 28 /// DECLARATION OF GARY GUILLEN, SUPPORT OF PLATNTIFF’S OPPOSITION TO DEFENDANT TROY ESQ. TN WILSON’S MOTION TO QUASH l DECLARATION OF GARY GUILLEN, ES! 2. l, Gary Guillen, declare as follows: DJ . I am an attorney at law, duly qualified to practice before all 0fthe courts ofthe State of California. . I am an attorney at the LAW OFFICES OF JONATHAN M. KASHANI, attorneys for Plaintiff, BARBARA WILLIAMS, in this action. . I make this Declaration of my own personal knowledge in that capacity. The facts stated herein “a are true based upon my own knowledge, except as to those facts which I believe to be true, and if called upon t0 testify, I could and would testify competently thereto. . At the time of the incident, Defendant Troy Wilson (“Defendant Wilson”), was taking the 10 following medications: 11 Dilaudid (Hydromorphone) — Schedule II opioid analgesic — according to the DEA drug fact sheet: “It has an analgesic potency of two to eight times greater than that 0f morphine and 12 has a rapid onset 0f action.” 13 Morphine, extended release — Schedule II narcotic derived from opium 14 Lyrica (Pregabalin) fl Schedule V — nerve pain medication/antiepileptic 15 Tizanidine (muscle relaxer) 16 Celebrex — nonsteroidal anti-inflammatory drug (NSAID) 17 18 Attached hereto as Exhibit “A” is a true and correct copy 0f the relevant deposition transcript excerpt of Defendant Wilson (p.32: l -l 6) dated February 23, 2021. Attached hereto as Exhibit 19 “B” are true and correct copies of the Department of Justice Drug Enforcement Administration 20 21 online Drug Fact Sheet regarding Hydromorphone (Dilaudid) and Morphine. Dr. James I. Rho was Defendant Wilson’s pain management doctor and the prescribing doctor 22 . for all ofthe medications set forth above. Attached hereto as Exhibit “A” is a true and correct 23 copy 0f the relevant deposition transcript excerpt 0f Defendant Wilson (pp.34:20-35: 1) dated 24 25 February 23, 2021. 26 . On July 29, 2022, my office properly issued a Deposition Subpoena for Personal Appearance and 27 Production 0f Documents and Things t0 Defendant Wilson’s prescribing physician, Dr. Rho. 28 DECLARATION OF GARY GUILLEN, ESQ. INSUPPORT OF PLAINTIFF’S OPPOSITION TO DEFENDANT TROY WILSON’S MOTION TO QUASH 2