Preview
Lawrence D. Murray (SBN 077536)
Murray k Associates ELECTRONICALLY
650 5'" Street, Suite 514 FILED
San Francisco, CA 94107 Superior Court of California,
County of San Francisco
Tel: (415) 673-0555
05/02/2024
Clerk of the Court
Attorney for Plaintiff BY: RONNIE OTERO
ALEXANDER JACQUES NOUAUX Deputy Clerk
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SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
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ALEXANDER JACQUES NOUAUX Case No. CGC-22-60284 1
MEMORANDUM OF POINTS AND AUTHORITIKS IN
13 Plaintiff, SUPPORT OF MOTION FOR ISSUANCE OF ORDER TO
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SHOW CAUSE AND APPLICATION FOR ORDER TO
Vs. STRIKE LIENS, OR ALTERNATIVELY, SET LIEN
AMOUNTS FOR ALL LIEN CLAIMANTS
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xxxxxx xxxxx xxxxxx, et al.
Hearing: MAY 28, 2024
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Time: 9:30 a.m.
Defendants. Dept: 302
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Plaintiff is in need of the powers of and orders of the Court to compel non parties to appear and
then, with the aid of an Order To Show Cause, have the court specify the medical liens to be paid and
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those to be strick given the limited amount of funds available from the recovery and settlement of the
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underlying case, and the limitations on such liens as specified in the Civil Code. Therefore, this motion
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is presented for the form of the Order to Show Cause, a copy of which is attached to the Declaration of
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Lawrence D. Murray.
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's I BACKGROUND
26 A. The Collision: Auto v. Bicvcle
27 On the morning of Tuesday, January 19, 2021, Plaintiff Alexander Nouaux was riding his bike to
work as usual going through downtown San Francisco. Around 9:30 am. he went through Mechanics
Monument Plaza and approach the intersection of Bush and Battery Street. As he neared the intersection,
Aiouaux vs. xxxxxx; San Francisco County Superior Court No. CGC-22-602841 PAGE I
Memo. Of Points & Authorities ISO of Motion for Issuance of Order to Show Cause and Application to Strike Liens
he had a green light with 10 seconds left on the countdown clock, so he proceeded to start to cross the
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intersection. At the time he could not see any vehicles coming into the intersection.
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As he entered the intersection he was hit by a mid-sized BMW sedan running the red light in excess
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of 25 mph. He had no time to avoid a collision. He crashed into the front and side of the vehicle on the
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driver's side view mirror and door. He ricochetted off the vehicle and was thrown from the bike to the
pavement. He was tossed through the air before landing on the street. He used his right arm to break the
fall. Upon landing, he struggle up on his knees and hands to crawl and stagger to the curb. He had a wide
2 gash on the palm ofhis right hand and felt pain radiating from his right wrist. He has a wave of immense
8 pain on the right side of his chest and back. It was immediately difficult to breath. He was helplessly
9 wailing in pain and shock. Moving was very difficult. His breathing was shallow and he felt a sharp
pain in his right lung. His glasses are completely shattered. He ask for an ambulance. It took a while.
(Nouaux Declaration )A[2 — 6 as part of the Order To Show Cause Declaration)
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The driver, Defendant xxxxxxxxxxxxx, screeched his BMW to a halt and got out. The eye witnesses
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informed him the BMW ran the red light. People from the plaza came over to help collect the bike and
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other items from the street. Plaintiff Nouaux crawled and stagger to the curb in complete disbelief and
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shock. The entire right side of his body was in pain, (See Nouaux Dec. SF Police Report, Exhibit I as
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part of the Order To Show Cause Declaration)
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17 B. Medical Treatment and Claims Based On Treatment
i. San Francisco Health Network's Claims Have Been Compromised and Satisfied
19 As a result of the collision, plaintiff underwent emergency room treatment and later hospitalization
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for about I 0 days. San Francisco Health Networkm for the City and County of San Francisco, claims
$ 137,459.23 as and for total "reasonable'* expenses, with creditsof payments and ajustments from
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United Healthcare, plaintiff's HMO provider, of $ 132,010.18, as well as payments by plaintiff of
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$ 649.05, leaving an outstanding balance, according to the City's billing, of $ 4800.00. (Nouaux
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Declaration $ 13, Exhibit 4, as part of the Order To Show Cause Declaration)
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After the payments for services by Nouaux's HMO on June 7, 2021,and plaintiff, and contrary to the
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compromise it accepting from United Healhcare and plaintiff, the City and County contradicted the
compromise reduction to $ 4800 they had agreed upon, by adding, on August 4, 2022, a new lien amount
of $ 74,999.59 and issuing a lien notice. (Nouaux Declaration $ 14 Exhibit 5 as part of the Order To
28 Show Cause Declaration)
It had already acknowledged payment, adjustments, and a credit of $ 132,010.18, (see Exhibit 4 as
IVouaux vs. xxxxxx; San Francisco County Superior Court No. CGC-22-602841 PAGE 2
Memo. Of Points & Authorities ISO of Motion for Issuance of Order to Show Cause and Application to Strike Liens
part of the Order To Show Cause Declaration) in order to secure payment from United Healthcare and
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plaintiff, reducing their demand to $ 4800.00. Now they seek double dipping and a breach of the terms
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by which they took the payment from United Healthcare. If the San Francisco Health Network is
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entitled to anything, which it is not, it would be no more than $ 4800.00. (Nouaux Declaration $ 14
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Exhibits 4 & 5 as part of the Order To Show Cause Declaration)
Then the City and County issued its letter on August 15, 2022, claiming it would accept $ 26,615.86
as full satisfaction of its lien. (Nouaux Declaration $ 12 Exhibit 5 page 2 as part of the Order To Show
Cause Declaration) Its lien should be stricken.
9 ii. King-American Ambulance Billings Have Been Compromised and Paid
King-American Ambulance billed $ 3277.98 for services rendered driving plaintiff to the
emergency rooom. On February 24, 2021, it accepted from the plaintiff s HMO, United Health Care,
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payment of $ 698.02 for their services. That should have been the end of it, but instead, in an effort at
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"balanced billing," in violation of the accord and satisfaction with United Health Care, it claimed
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$ 3277.98 to collect what it waived from the HMO, and when that was not paid, sent it to its collection
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agency, "Grant Mercantile Agency, Inc." (Nouaux Declaration $ 10 Exhibit 7 as part of the Order To
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Show Cause Declaration) Balanced billing is prohibited in California. Prospect Medical Group, Inc, v.
Northridge Emergency Medical Group 45 Cal.4th 497 (2009)
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18 iii. SF General Hospital Medical Group Billings Have Been Compromised and Paid
19 The SFGH Medical Group listed charges of $ 7877.00 and then accepted insurance payments of
20 $ 93 3 . 56. Somehow they arrived at a "Total Balance" of $ 1,802.92. (Nouaux Declaration f[ I 6 Exhibit
6) Once the medical group accepts the negotiated accord and satisfaction, it cannot attempt to collect the
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amount negotiated from the patient, here plaintiff. Balanced billing is prohibited in California. Prospect
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Medical Group, Inc. v. Northridge Emergency Medical Group 45 Cal.41h 497 (2009)
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iv. Plaintiff Paid Medical Expensse nnd had Wage Loss
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Plaintifi'was on his way to work when he was run down. He was off work 1'or 9 days and v'ould
have made $ 2165.63 during that lime. I-le has a total wage loss of $ 2165.63.
27 Additionally, plaintiff has paid his own out of pocket medical expenses which were not paid by
28 anyone else in the amount of $ 1082.41. (Nouaux Dec $ 17, 18 as part of the Order To Show Cause
Declaration)
IVouaux vs. Sferler San Francisco County Superior Court No. CGC-22-602841 PAGE 3
Memo. Of Points & Authorities ISO of Motion for Issuance of Order to Show Cause and Application to Strike Liens
C. Less Fees and Costs For Securing A Recovery Resulting Net Recovery For Distribution
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Liability has not been disputed once the eye witness statements were revealed. Based on the
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severity of the injuries, and after representation by Murray & Associates, Allstate Insurance Company,
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insurance carrier for Defendant xxxxxx, offered plaintiff s law firm the full amount of the policy limit for
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their insured, totaling $ 50,000.00, for settlement of all claims. (Nouaux Dec $ Exhibits 2 and 3 as part
of the Order To Show Cause Declaration). Settlement has been put on hold pending the resolution of the
lien claims set out related to medical expenses and billings.
8 D. Gross /Net Settlement Funds
9 From Allstate Insurane Comoanv: Policv Limits (Exhibit 2) $ 50,000.00
Costs (initial filing fee and service) $ 587.93
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Subtotal $ 49,412.07
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Attorney Fees (contract is 40% for fees at this point) '19,764.83
Subtotal $ 29,647.24
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Net Settlement Available for distribution by Court: $ 29,647.24
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Since plaintiff's injuries far exceed the amount remaining, plaintiff requests that the amount
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subject to distribution by Court order be ordered released to him and the said liens and claims denied.
The liens and claims total far exceed the amount and if paid would diminish or eliminate money to
17 plaintiff.
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II. THIS COURT SHOULD SET RECOVERY AND LIEN AMOUNTS
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The case requires the court to set lien amounts and otherwise order payments from the settlement
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proceeds. It will not happen without the assistance of the court.
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'n attorney lien for fees and costs in thc action has priority over a contractual medical lien regardless
of which lien was first in time. Without the attorney's efforts, there may be no judgment or settlement
and the medical lien could be worthless. [(~i/ntmt v. Dtd/ty 176 Cal.App.4th 606, 618-619 (2009)
/Vouaux vs. Sfer/e; San Francisco County Superior Court No. CGC-22-602841 PAGE 4
Memo. Of Points k. Authorities ISO of Motion for Issuance of Order to Show Cause and Application to Strike Liens
III. CONCLUSION
2 It is respectfully requested that the Court issue it's Order To Show Cause to permit this matter to
come to conclusion and a dismissal issue.
Respectfully submitted,
MURRAY & ASSOCIATES
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April 23, 2024
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Nouaux vs. Sferie; San Francisco County Superior Court No. CGC-22-602841 PAGE 5
Memo. Of Points & Authorities ISO of Motion for Issuance of Order to Show Cause and Application to Strike Liens
PROOF OF SERVICE
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I am employed in the City and County of San Francisco, State of California. I am over the age of
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18 and not a party to the within action. My business address is 650 5th Street, Suite 514, San Francisco,
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California 94107; (415) 673-0555. On this date, I served the following document(s):
4
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION FOR
ISSANCE OF ORDER TO SHOW CAUSE AND APPLICATION FOR ORDER TO STRIKE
LIENS, OR ALTERNATIVELY, SET LIEN AMOUNTS FOR ALL LIEN CLAIMANTS on the
interested parties in this action as follows:
8 Anthony F. Pinelli
Gina D. Huettel
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Williams, Pinelli & Cullen
10 1960 The Alameda, Suite 195
San Jose, CA 95126
Tel: (408) 288-3686
Fax: (408) 288-3860
12
aoinelliPa.,woclaw.corn
13 uhuettei wnclaw.com
'4 [ ] [BY PERSONAL SERVICE] I caused such envelope(s) to be delivered by hand to the above
address(es).
16 [XX] [BY EMAIL] I caused such document(s) to be served on the parties listed in this action via
email to the email addresses shown above.
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8 [ ] [BY MAIL] I caused envelope(s) with postage thereon fully prepaid to be placed in the United
States mail at San Francisco, California, addressed as shown above.
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[ ] [BY E-SERVICE] I caused such document(s) to be served via e-service on the parties listed
above.
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[ ] [BY PERSONAL SERVICE BY FAX] I caused the above entitled document(s) to be
22 personally served on the above shown parties by facsimile transmission on the date shown below
by confirming the fax phone number with the law office shown above then (a) transmitting it via
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the fax machine within this office, and (b) receiving a receipt from the machine within this office
24 confirming all documents sent were in fact properly received.
23 I declare under penalty of perjury under the laws of the State of California that the above is true and
correct. Executed in San Francisco, California, on April 23, 2024.
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Nnu~MA
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Nouaur vs. Sferler San Francisco County Superior Court No. CGC-22-602841 PAGE 6
Memo. Of Points & Authorities ISO of Motion for Issuance of Order to Show Cause and Application to Strike Liens
Preview
Lawrence D. Murray (SBN 077536) Murray k Associates ELECTRONICALLY 650 5'" Street, Suite 514 FILED San Francisco, CA 94107 Superior Court of California, County of San Francisco Tel: (415) 673-0555 05/02/2024 Clerk of the Court Attorney for Plaintiff BY: RONNIE OTERO ALEXANDER JACQUES NOUAUX Deputy Clerk 6 SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN FRANCISCO 10 ALEXANDER JACQUES NOUAUX Case No. CGC-22-60284 1 MEMORANDUM OF POINTS AND AUTHORITIKS IN 13 Plaintiff, SUPPORT OF MOTION FOR ISSUANCE OF ORDER TO 14 SHOW CAUSE AND APPLICATION FOR ORDER TO Vs. STRIKE LIENS, OR ALTERNATIVELY, SET LIEN AMOUNTS FOR ALL LIEN CLAIMANTS 15 xxxxxx xxxxx xxxxxx, et al. Hearing: MAY 28, 2024 16 Time: 9:30 a.m. Defendants. Dept: 302 17 19 Plaintiff is in need of the powers of and orders of the Court to compel non parties to appear and then, with the aid of an Order To Show Cause, have the court specify the medical liens to be paid and 20 those to be strick given the limited amount of funds available from the recovery and settlement of the 21 underlying case, and the limitations on such liens as specified in the Civil Code. Therefore, this motion 22 is presented for the form of the Order to Show Cause, a copy of which is attached to the Declaration of 23 Lawrence D. Murray. 24 's I BACKGROUND 26 A. The Collision: Auto v. Bicvcle 27 On the morning of Tuesday, January 19, 2021, Plaintiff Alexander Nouaux was riding his bike to work as usual going through downtown San Francisco. Around 9:30 am. he went through Mechanics Monument Plaza and approach the intersection of Bush and Battery Street. As he neared the intersection, Aiouaux vs. xxxxxx; San Francisco County Superior Court No. CGC-22-602841 PAGE I Memo. Of Points & Authorities ISO of Motion for Issuance of Order to Show Cause and Application to Strike Liens he had a green light with 10 seconds left on the countdown clock, so he proceeded to start to cross the I intersection. At the time he could not see any vehicles coming into the intersection. 2 As he entered the intersection he was hit by a mid-sized BMW sedan running the red light in excess 3 of 25 mph. He had no time to avoid a collision. He crashed into the front and side of the vehicle on the 4 driver's side view mirror and door. He ricochetted off the vehicle and was thrown from the bike to the pavement. He was tossed through the air before landing on the street. He used his right arm to break the fall. Upon landing, he struggle up on his knees and hands to crawl and stagger to the curb. He had a wide 2 gash on the palm ofhis right hand and felt pain radiating from his right wrist. He has a wave of immense 8 pain on the right side of his chest and back. It was immediately difficult to breath. He was helplessly 9 wailing in pain and shock. Moving was very difficult. His breathing was shallow and he felt a sharp pain in his right lung. His glasses are completely shattered. He ask for an ambulance. It took a while. (Nouaux Declaration )A[2 — 6 as part of the Order To Show Cause Declaration) ll The driver, Defendant xxxxxxxxxxxxx, screeched his BMW to a halt and got out. The eye witnesses 12 informed him the BMW ran the red light. People from the plaza came over to help collect the bike and 13 other items from the street. Plaintiff Nouaux crawled and stagger to the curb in complete disbelief and 14 shock. The entire right side of his body was in pain, (See Nouaux Dec. SF Police Report, Exhibit I as 13 part of the Order To Show Cause Declaration) 16 17 B. Medical Treatment and Claims Based On Treatment i. San Francisco Health Network's Claims Have Been Compromised and Satisfied 19 As a result of the collision, plaintiff underwent emergency room treatment and later hospitalization 20 for about I 0 days. San Francisco Health Networkm for the City and County of San Francisco, claims $ 137,459.23 as and for total "reasonable'* expenses, with creditsof payments and ajustments from 21 United Healthcare, plaintiff's HMO provider, of $ 132,010.18, as well as payments by plaintiff of 22 $ 649.05, leaving an outstanding balance, according to the City's billing, of $ 4800.00. (Nouaux 23 Declaration $ 13, Exhibit 4, as part of the Order To Show Cause Declaration) 24 After the payments for services by Nouaux's HMO on June 7, 2021,and plaintiff, and contrary to the 23 compromise it accepting from United Healhcare and plaintiff, the City and County contradicted the compromise reduction to $ 4800 they had agreed upon, by adding, on August 4, 2022, a new lien amount of $ 74,999.59 and issuing a lien notice. (Nouaux Declaration $ 14 Exhibit 5 as part of the Order To 28 Show Cause Declaration) It had already acknowledged payment, adjustments, and a credit of $ 132,010.18, (see Exhibit 4 as IVouaux vs. xxxxxx; San Francisco County Superior Court No. CGC-22-602841 PAGE 2 Memo. Of Points & Authorities ISO of Motion for Issuance of Order to Show Cause and Application to Strike Liens part of the Order To Show Cause Declaration) in order to secure payment from United Healthcare and I plaintiff, reducing their demand to $ 4800.00. Now they seek double dipping and a breach of the terms 2 by which they took the payment from United Healthcare. If the San Francisco Health Network is 3 entitled to anything, which it is not, it would be no more than $ 4800.00. (Nouaux Declaration $ 14 4 Exhibits 4 & 5 as part of the Order To Show Cause Declaration) Then the City and County issued its letter on August 15, 2022, claiming it would accept $ 26,615.86 as full satisfaction of its lien. (Nouaux Declaration $ 12 Exhibit 5 page 2 as part of the Order To Show Cause Declaration) Its lien should be stricken. 9 ii. King-American Ambulance Billings Have Been Compromised and Paid King-American Ambulance billed $ 3277.98 for services rendered driving plaintiff to the emergency rooom. On February 24, 2021, it accepted from the plaintiff s HMO, United Health Care, ll payment of $ 698.02 for their services. That should have been the end of it, but instead, in an effort at 12 "balanced billing," in violation of the accord and satisfaction with United Health Care, it claimed 13 $ 3277.98 to collect what it waived from the HMO, and when that was not paid, sent it to its collection 14 agency, "Grant Mercantile Agency, Inc." (Nouaux Declaration $ 10 Exhibit 7 as part of the Order To IS Show Cause Declaration) Balanced billing is prohibited in California. Prospect Medical Group, Inc, v. Northridge Emergency Medical Group 45 Cal.4th 497 (2009) 17 18 iii. SF General Hospital Medical Group Billings Have Been Compromised and Paid 19 The SFGH Medical Group listed charges of $ 7877.00 and then accepted insurance payments of 20 $ 93 3 . 56. Somehow they arrived at a "Total Balance" of $ 1,802.92. (Nouaux Declaration f[ I 6 Exhibit 6) Once the medical group accepts the negotiated accord and satisfaction, it cannot attempt to collect the 21 amount negotiated from the patient, here plaintiff. Balanced billing is prohibited in California. Prospect 22 Medical Group, Inc. v. Northridge Emergency Medical Group 45 Cal.41h 497 (2009) 23 24 iv. Plaintiff Paid Medical Expensse nnd had Wage Loss 23 Plaintifi'was on his way to work when he was run down. He was off work 1'or 9 days and v'ould have made $ 2165.63 during that lime. I-le has a total wage loss of $ 2165.63. 27 Additionally, plaintiff has paid his own out of pocket medical expenses which were not paid by 28 anyone else in the amount of $ 1082.41. (Nouaux Dec $ 17, 18 as part of the Order To Show Cause Declaration) IVouaux vs. Sferler San Francisco County Superior Court No. CGC-22-602841 PAGE 3 Memo. Of Points & Authorities ISO of Motion for Issuance of Order to Show Cause and Application to Strike Liens C. Less Fees and Costs For Securing A Recovery Resulting Net Recovery For Distribution I Liability has not been disputed once the eye witness statements were revealed. Based on the 2 severity of the injuries, and after representation by Murray & Associates, Allstate Insurance Company, 3 insurance carrier for Defendant xxxxxx, offered plaintiff s law firm the full amount of the policy limit for 4 their insured, totaling $ 50,000.00, for settlement of all claims. (Nouaux Dec $ Exhibits 2 and 3 as part of the Order To Show Cause Declaration). Settlement has been put on hold pending the resolution of the lien claims set out related to medical expenses and billings. 8 D. Gross /Net Settlement Funds 9 From Allstate Insurane Comoanv: Policv Limits (Exhibit 2) $ 50,000.00 Costs (initial filing fee and service) $ 587.93 10 Subtotal $ 49,412.07 11 12 Attorney Fees (contract is 40% for fees at this point) '19,764.83 Subtotal $ 29,647.24 13 Net Settlement Available for distribution by Court: $ 29,647.24 14 Since plaintiff's injuries far exceed the amount remaining, plaintiff requests that the amount ts subject to distribution by Court order be ordered released to him and the said liens and claims denied. The liens and claims total far exceed the amount and if paid would diminish or eliminate money to 17 plaintiff. 18 II. THIS COURT SHOULD SET RECOVERY AND LIEN AMOUNTS 20 The case requires the court to set lien amounts and otherwise order payments from the settlement 21 proceeds. It will not happen without the assistance of the court. /// /// /// /// /// 27 28 'n attorney lien for fees and costs in thc action has priority over a contractual medical lien regardless of which lien was first in time. Without the attorney's efforts, there may be no judgment or settlement and the medical lien could be worthless. [(~i/ntmt v. Dtd/ty 176 Cal.App.4th 606, 618-619 (2009) /Vouaux vs. Sfer/e; San Francisco County Superior Court No. CGC-22-602841 PAGE 4 Memo. Of Points k. Authorities ISO of Motion for Issuance of Order to Show Cause and Application to Strike Liens III. CONCLUSION 2 It is respectfully requested that the Court issue it's Order To Show Cause to permit this matter to come to conclusion and a dismissal issue. Respectfully submitted, MURRAY & ASSOCIATES 9 April 23, 2024 10 ux 12 13 14 16 17 18 19 20 21 22 23 24 26 26 27 Nouaux vs. Sferie; San Francisco County Superior Court No. CGC-22-602841 PAGE 5 Memo. Of Points & Authorities ISO of Motion for Issuance of Order to Show Cause and Application to Strike Liens PROOF OF SERVICE 1 I am employed in the City and County of San Francisco, State of California. I am over the age of 2 18 and not a party to the within action. My business address is 650 5th Street, Suite 514, San Francisco, 3 California 94107; (415) 673-0555. On this date, I served the following document(s): 4 MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION FOR ISSANCE OF ORDER TO SHOW CAUSE AND APPLICATION FOR ORDER TO STRIKE LIENS, OR ALTERNATIVELY, SET LIEN AMOUNTS FOR ALL LIEN CLAIMANTS on the interested parties in this action as follows: 8 Anthony F. Pinelli Gina D. Huettel 9 Williams, Pinelli & Cullen 10 1960 The Alameda, Suite 195 San Jose, CA 95126 Tel: (408) 288-3686 Fax: (408) 288-3860 12 aoinelliPa.,woclaw.corn 13 uhuettei wnclaw.com '4 [ ] [BY PERSONAL SERVICE] I caused such envelope(s) to be delivered by hand to the above address(es). 16 [XX] [BY EMAIL] I caused such document(s) to be served on the parties listed in this action via email to the email addresses shown above. 17 8 [ ] [BY MAIL] I caused envelope(s) with postage thereon fully prepaid to be placed in the United States mail at San Francisco, California, addressed as shown above. 19 [ ] [BY E-SERVICE] I caused such document(s) to be served via e-service on the parties listed above. 21 [ ] [BY PERSONAL SERVICE BY FAX] I caused the above entitled document(s) to be 22 personally served on the above shown parties by facsimile transmission on the date shown below by confirming the fax phone number with the law office shown above then (a) transmitting it via 23 the fax machine within this office, and (b) receiving a receipt from the machine within this office 24 confirming all documents sent were in fact properly received. 23 I declare under penalty of perjury under the laws of the State of California that the above is true and correct. Executed in San Francisco, California, on April 23, 2024. 27 Nnu~MA 28 0 Nouaur vs. Sferler San Francisco County Superior Court No. CGC-22-602841 PAGE 6 Memo. Of Points & Authorities ISO of Motion for Issuance of Order to Show Cause and Application to Strike Liens