On June 02, 2021 a
Clerk Notice
was filed
involving a dispute between
Raul Saldana And Eric Saldana,
and
Brett Clement, Do,
Dignity Health,
Dignity Health - St. Bernardine Medical Center,
Does 4 To100,
Omar Saleh, M.D.,
Saldana, Jason,
Saldana, Jessica,
Saldana, Kady,
Simpledeep Kaur Banipal,
for Medical Malpractice Unlimited
in the District Court of San Bernardino County.
Preview
\v V
Randall S. Schiavone, SBN: 148021
KAMPF, SCHIAVONE & ASSOCIATES, A.P.C.
290 N. D Street, Suite 901
Mailing Address: P.O. Box 1061 .755; 157‘33333} gunmwu
AWN
San Bernardino, CA 92402-1061 $333355gégiggygggfi;x"
-' ‘
Phone: 909.885.1522 ’
I'
Facsimile: 909.384.0673 +1 .t {r 202?
Rschiavon.e@ksa—atty.com . '
;
1' I
‘
'
Byuégawzgu
Attorney for Plaintiff chfii‘b‘ {@363
wififififgggn
\OOONOUI
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO — SAN BERNARDINO JUSTICE CENTER
10
11 RAUL SALDANA and ERIC SALDANA, CASE NO.: CIVSB21 15525
12 Plaintiff, DECLARATION OF MATTHEW
SINNER, R.N. IN SUPPORT OF
13
v. PLAINTIFFS’ OPPOSITION TO
14 DEFENDANT DIGNITY HEALTH dba
DIGNITY HEALTH — ST. BERNARDINE ST. BERNARDINE MEDICAL
15 MEDICAL CENTER, KADY SALDANA, CENTER’S NOTICE OF MOTION
JASON SALDANA, JESSICA SALDANA, AND MOTION FOR SUMMARY
16
and DOES 1 TO 100, INCLUSIVE, JUDGEMENT/ADJUDICATION
17
Defendants. (Filed concurrently with Plaintiffs’ Opposition to
Defendant Dignity Health dba St. Bemardine
18
Medical Center’s Motion for Summary
Judgement/Adjudication; Memorandum of Points
19
and Authorities in Support Thereof; Plaintiffs’
VVVVVVvVVVVVVVVVVVVVVVVVVVVVVV
Separate Statement of Disputed and Undisputed
20
Material Facts in Opposition to Defendant
Dignity Health dba St. Bemardine Medical
21 Center’s Motion for Summary
Judgement/Adjudication; Declaration of Randall
22 S. Schiavone, Esq.; Declaration of Matthew
Sinner, R.N.; Objection to Evidence in
23 Opposition; Notice of Lodging; [Proposed] Order)
24
Date: October 18, 2022
25 Time: 8:30 am.
Dept: S-25
26
Action Filed: June 02, 2021
27
Trial Date: None Set
28
\r V
DECLARATION OF MATTHEW SINNER, RN
N
I, MATTHEW SINNER, declare and state as follows:
a witness at trial
1. I am a nurse duly licensed in the State of California. If called as
\OOONONU‘l-bw 0r hearing, I could and would competently testify t0 each of the matters set forth below based 0n
my personal knowledge.
2. I obtained my Bachelor of Science in Nursing at Azusa Pacific University
was issued my nursing license for the State 0f California on
graduating in December 2012. I
10’ March 11, 2013. I provided nursing services at Huntington Hospital from February 2013 to
11 December 2017, which included critical care nursing services in the Intensive Care Unit as well
From December 201 7 t0 October 2020, I provided nursing services at
12 as a reliefCharge nurse.
Loma Linda University Medical Center as a critical care transport nurse. From October 2020 to
13
14 the present I have served as a Clinical Nurse educator at Lorna Linda University Medical Center.
cardiac life support, pediatric
15 I currently hold a provider card for basic life support, advanced
support, and Trauma Nursing Core Course (TNCC). I have completed additional
16 advanced life
17 training to obtain certificates such as NIHSS Certification from NIHSS.org and Sedation
18 Certified Registered Nurse from
“A Healthy Visions Company.”
reviewed medical records of decedent Debra Saldana from St. Bemardine
19 3. I
20 Medical Center and the autopsy report and death certificate. Based on my review of these
21 medical records, and based on my training, education, background and experience, as well as my
22 familiarity with the applicable standard 0f care, I have reached opinions as t0 the nursing services
Bernardine Medical Center’s treatment of Debra Saldana on April 3, 2020 and
23 regarding St.
24 April 4, 2020.
25 ///
26
1
27
28 DECLARATION OF MATTHEW SINNER, RN
Document Filed Date
September 30, 2022
Case Filing Date
June 02, 2021
Category
Medical Malpractice Unlimited
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\v V Randall S. Schiavone, SBN: 148021 KAMPF, SCHIAVONE & ASSOCIATES, A.P.C. 290 N. D Street, Suite 901 Mailing Address: P.O. Box 1061 .755; 157‘33333} gunmwu AWN San Bernardino, CA 92402-1061 $333355gégiggygggfi;x" -' ‘ Phone: 909.885.1522 ’ I' Facsimile: 909.384.0673 +1 .t {r 202? Rschiavon.e@ksa—atty.com . ' ; 1' I ‘ ' Byuégawzgu Attorney for Plaintiff chfii‘b‘ {@363 wififififgggn \OOONOUI SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO — SAN BERNARDINO JUSTICE CENTER 10 11 RAUL SALDANA and ERIC SALDANA, CASE NO.: CIVSB21 15525 12 Plaintiff, DECLARATION OF MATTHEW SINNER, R.N. IN SUPPORT OF 13 v. PLAINTIFFS’ OPPOSITION TO 14 DEFENDANT DIGNITY HEALTH dba DIGNITY HEALTH — ST. BERNARDINE ST. BERNARDINE MEDICAL 15 MEDICAL CENTER, KADY SALDANA, CENTER’S NOTICE OF MOTION JASON SALDANA, JESSICA SALDANA, AND MOTION FOR SUMMARY 16 and DOES 1 TO 100, INCLUSIVE, JUDGEMENT/ADJUDICATION 17 Defendants. (Filed concurrently with Plaintiffs’ Opposition to Defendant Dignity Health dba St. Bemardine 18 Medical Center’s Motion for Summary Judgement/Adjudication; Memorandum of Points 19 and Authorities in Support Thereof; Plaintiffs’ VVVVVVvVVVVVVVVVVVVVVVVVVVVVVV Separate Statement of Disputed and Undisputed 20 Material Facts in Opposition to Defendant Dignity Health dba St. Bemardine Medical 21 Center’s Motion for Summary Judgement/Adjudication; Declaration of Randall 22 S. Schiavone, Esq.; Declaration of Matthew Sinner, R.N.; Objection to Evidence in 23 Opposition; Notice of Lodging; [Proposed] Order) 24 Date: October 18, 2022 25 Time: 8:30 am. Dept: S-25 26 Action Filed: June 02, 2021 27 Trial Date: None Set 28 \r V DECLARATION OF MATTHEW SINNER, RN N I, MATTHEW SINNER, declare and state as follows: a witness at trial 1. I am a nurse duly licensed in the State of California. If called as \OOONONU‘l-bw 0r hearing, I could and would competently testify t0 each of the matters set forth below based 0n my personal knowledge. 2. I obtained my Bachelor of Science in Nursing at Azusa Pacific University was issued my nursing license for the State 0f California on graduating in December 2012. I 10’ March 11, 2013. I provided nursing services at Huntington Hospital from February 2013 to 11 December 2017, which included critical care nursing services in the Intensive Care Unit as well From December 201 7 t0 October 2020, I provided nursing services at 12 as a reliefCharge nurse. Loma Linda University Medical Center as a critical care transport nurse. From October 2020 to 13 14 the present I have served as a Clinical Nurse educator at Lorna Linda University Medical Center. cardiac life support, pediatric 15 I currently hold a provider card for basic life support, advanced support, and Trauma Nursing Core Course (TNCC). I have completed additional 16 advanced life 17 training to obtain certificates such as NIHSS Certification from NIHSS.org and Sedation 18 Certified Registered Nurse from “A Healthy Visions Company.” reviewed medical records of decedent Debra Saldana from St. Bemardine 19 3. I 20 Medical Center and the autopsy report and death certificate. Based on my review of these 21 medical records, and based on my training, education, background and experience, as well as my 22 familiarity with the applicable standard 0f care, I have reached opinions as t0 the nursing services Bernardine Medical Center’s treatment of Debra Saldana on April 3, 2020 and 23 regarding St. 24 April 4, 2020. 25 /// 26 1 27 28 DECLARATION OF MATTHEW SINNER, RN