Motion-Secondary: PEREZ -V- LOMA LINDA UNIVERSITY, ET AL Print

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                                Gordon L. Dayton, Esq., (SBN: 208379)                                             ELECTRONICALLY FILED (Auto)
     LAW OFFICES OF GORDON L. DAYTON                                                   SUPERIOR COURT OF CALIFORNIA
                                                                                       COUNTY OF SAN BERNARDINO
     41856 Ivy Street, Suite 214
                                                                                       1/4/2024 7:57 PM
     Murrieta, CA 92562
     Telephone (951) 296-5303 * Facsimile (951) 296-5319

     Attorney for Plaintiffs, ANTHONY L. PEREZ
             and SANDRA L. PEREZ




                       IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA

                                       COUNTY OF SAN BERNARDINO

     ANTHONY L. PEREZ, an individual, SANDRA L.                   Case No. CIVDS1913814
10   PEREZ, an individual, ANTHONY L. PEREZ,
     Successor-in-Interest to the ESTATE OF JORDAN                DECLARATION OF JUDITH A. SHEININ,
1]   LEE PEREZ, and SANDRA L. PEREZ, Successor-                   R.N., BSH, MSN IN SUPPORT OF PLAIN-
     in-Interest to the ESTATE OF JORDAN LEE                      TIFFS’ OPPOSITION TO DEFENDANTS’
12   PEREZ                                                        LOMA LINDA UNIVERSITY HEALTH,
                                                                  CHELSEA L. COLLINS M.D., ALBERT
13                                        Plaintiffs,             KHERADPOUR M.D., CHENUE ABONGWA
                                                                  M.D., AND BATUL SUTERWALA M.D.’S MO-
14                                                                TION FOR SUMMARY JUDGMENT OR
                           VS.                                    SUMMARY ADJUDICATION OR BOTH
15
                                                                  ACTION FILED: May 6, 2019
16   LOMA LINDA UNIVERSITY HEALTH, a non-                         FAC FILED: July 31, 2019
     profit corporation; LOMA LINDA UNIVERSITY                    SAC FILED: January 8, 2020
17   MEDICAL CENTER, a nonprofit corporation;                     TAC: June 2, 2020
     LOMA LINDA UNIVERSITY CHILDREN'S                             FRAC FILED: November         19, 2020
18   HOSPITAL a nonprofit corporation; ALBERT                     TRIAL DATE: None Set
     KHERADPOUR M.D.., an individual; and DOES 2-
19   200, inclusive,

20                                        Defendants.

21

22           I, Judith A. Sheinin, R.N., BSH, MSN       declare and state, that if called upon to testify and

23   sworn, I could and would testify to the following facts of my own personal knowledge.

24   //
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                      DECLARATION OF JUDITH A. SHEININ IN SUPPORT OF OPPOSITION TO
                             DEFENDANTS’ MOTION FOR SUMMARY JUDGEMENT
     Qualifications and Credentials

         1. I, I Judith A. Sheinin, declare as follows:

        2.1 am a Registered Nurse, with Master's degree in Science-Emphasis in Healthcare Systems

     Management-Loyola University of New Orleans. I have an Bachelors degree in Healthcare Manage-

     ment- University of LaVerne and Associate Science Degree-Compton Community College.

        3. I have 40 years work experience and education. I am a Utilization Manager/Case Manager of

     15 years. I perform comprehensive analytic review of medical records, clinical documentation of

     Healthplan Insurer's and depositions.

        4. In Utilization/Case I am proficient in utilizing the Mckesson-Interqual guidelines in the Epic

10   system. I assisted in the development of Case Management processes at Riverside University Health

1]   Systems Emergency Department and Denials and Appeals in patient accounts.

12      5. In overturning many Denials and providing Riverside University Health Systems with return

13   revenue from my appeal letters utilizing evidence-based criteria, clinical and regulatory knowledge. I

14   was promoted to the highest status of the Nursing Department- RN V. In the position of RN V I was

15   recruited to teach 1st and 2nd year medical residents to document in the medical record clearly and

16   concisely to prevent denials of hospital admissions from the payor of patient's healthplan.

17      6. I have participated in Utilization, Case Management committee's at Riverside University

18   Health System, Arrowhead Regional Medical Center, Kaiser Permanente- Riverside, Inland Faculty

19   Medical Group, Concentra Managed Care, Inc.

20      7. | have performed Legal Nurse reviews for the Board of Registered Nursing, I have performed

21   clinical reviews and expert witness for Private-Attorney Practice: Dickman & Holt Riverside Ca.,

22   Yoshi Kubota-Anaheim Ca.

23      8. | am mobile intensive certified, advanced cardio life support certified as well as Basic life sup-

24   port. I have worked in direct patient care as an ICU Nurse- St. Bernadine, ER trauma Nurse-River-
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                      DECLARATION OF JUDITH A. SHEININ IN SUPPORT OF OPPOSITION TO
                             DEFENDANTS’ MOTION FOR SUMMARY JUDGEMENT