Motion-Secondary: BAMBI CORTEZ, ET AL. VS RENAISSANCE IMAGING CENTER, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 06/16/2022 02:38 PM Sherri R. Carter, Executive Officer/Clerk of Court, by B. Shanbrom,Deputy Clerk



                 1      Raymond L. Blessey, Esq. (State Bar No. 176180)
                        Tracy D. Hughes, Esq. (State Bar No. 269187)
                 2      REBACK, MCANDREWS & BLESSEY, LLP
                        1230 Rosecrans Avenue, Suite 450
                 3      Manhattan Beach, CA 90266
                 4      T: (310) 297-9900
                        F: (310) 297-9800
                 5      rblessey@rmblawyer.com
                        thughes@rmblawyer.com
                 6
                 7      Attorneys for Defendant, ESTATE OF JOEL HERRIOTT THAYER, M.D. (erroneously sued and
                        served as JOEL HERRIOTT THAYER, M.D.)
                 8
                                                       SUPERIOR COURT OF THE STATE OF CALIFORNIA
                 9
                                                                    FOR THE COUNTY OF LOS ANGELES
                10
                11
                        BAMBI CORTEZ AND SUMMER              )                                   CASE NO. 20AVCV00282
                12      GREGORY,                             )
                                                             )                                   DECLARATION OF RICHARD OFSTEIN, M.D.,
                13
                                     Plaintiffs,             )                                   IN SUPPORT OF ESTATE OF JOEL HERRIOTT
                14                                           )                                   THAYER, M.D.’S MOTION FOR
                                     v.                      )                                   UNDERTAKING RE: SUMMAR GREGORY
                15                                           )
                        RENAISSANCE IMAGING CENTER,          )                                   [Filed concurrently with Notice of Motion and Motion
                16
                        PALMDALE REGIONAL MEDICAL            )                                   for an Undertaking re: Summer Gregory; [Proposed]
                17      CENTER, JOEL HERRIOTT THAYER,        )                                   Order]
                        M.D., HIGH DESERT MEDICAL GROUP, )
                18      QUARTZ HILL WALK-IN MEDICAL          )                                   RESERVATION ID: 243654085180
                        GROUP, INC., ERIC CARNEY DENLEY, )                                       Date: July 19, 2022
                19      M.D., CARLOS A. GUERRERO, FNP, and )                                     Time: 8:30 a.m.
                20      DOES 1 through 100, inclusive,       )                                   Dept: A14
                                                             )
                21                   Defendants.             )                                   Assigned to Hon. Judge Stephen Morgan
                                                             )                                   Dept. A14
                22                                           )
                23                                           )                                   Complaint Filed: 4/20/2020
                                                             )                                   Trial Date:   8/19/2022
                24      ____________________________________ )
                25
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                            DECLARATION OF RICHARD OFSTEIN, M.D., IN SUPPORT OF ESTATE OF JOEL HERRIOTT THAYER, M.D.’S MOTION FOR
                                                            UNDERTAKING RE: SUMMAR GREGORY
1                                 DECLARATION OF RICHARD OFSTEIN, M.D.
2           I, RICHARD OFSTEIN, M.D., declare and state as follows:
3
            1.      I am a physician licensed to practice medicine in the California, Utah, Nevada, and
4    Wyoming. I have personal knowledge of all facts contained within this declaration, and if called as a
5    witness, I could and would competently testify to the following:
6
            2.      I received my medical degree from Southern Illinois University, Springfield, Illinois. I
7    completed an internship in general surgery at UCLA Hospital and Clinics, Los Angeles, California in
8    June 1981. I completed my Residency in diagnostic radiology at UCLA Hospital and Clinics, Los
9    Angeles, California in June 1984. I participated in a radiology fellowship program at Memorial
10   Medical Center of Long Beach, Long Beach, California, from July 1984-June 1985. I am currently an

11   Adjunct Assistant Professor of Radiology and have hospital privileges at the University of Utah. I am
     board certified in diagnostic radiology and have a certificate of added qualifications in neuroradiology.
12
     My CV is attached hereto as Exhibit A.
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            3.      Based on my background, training, and experience, I am familiar with the standard of
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     care applicable to radiologist treating patients such as decedent Silvia Handley. I am qualified to
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     render an expert opinion in this case concerning the medical care and treatment provided by Joel
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     Thayer, M.D., to decedent. I am making this Declaration in support of Defendant Estate of Joel
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     Herriott Thayer, M.D.’s Motion to require non-resident plaintiff to file an undertaking.
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            4.      I reviewed Plaintiffs’ Complaint and decedent’s medical records, including imaging
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     studies from Antelope Valley Hospital, Palmdale Regional Medical Center, Renaissance Imaging, and
20   First Valley Medical Group (formally known as Quartz Hill). I relied on these materials as well as my
21   education, training, and experience in forming my opinions.
22          5.      On March 31, 2017, the patient Silvia Handley presented to Quartz Hill Medical Group
23   with complaints of cough and shortness of breath. A chest x-ray was ordered and performed at
24   Antelope Valley Hospital on April 2, 2017. Findings as interpreted by Renaissance Imaging indicate
25   cardiomediastinal silhouette appears normal, there is calcification in the thoracic aorta, pulmonary

26   vasculature appears normal, Lung fields appear clear, no pneumothorax, costophrenic angles are well
     defined, there are bilateral breast implants present, and the osseous elements appear intact.
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       DECLARATION OF RICHARD OFSTEIN, M.D., IN SUPPORT OF ESTATE OF JOEL HERRIOTT THAYER, M.D.’S MOTION FOR
                                       UNDERTAKING RE: SUMMAR GREGORY
1           6.      On April 4, 2017, the patient presented to the ED of Palmdale Regional Medical Center,
2    with a history of COPD and hypertension and a present complaint of labored breathing. Notes indicate

3    that she had finished a three-day course of a Z-pack for possible pneumonia. A chest x-ray was
     ordered. The x-ray was read by defendant Dr. Thayer who indicated that the cardiac size is within
4
     normal limits. The pulmonary vasculature is normal. The lung parenchyma is clear. Nodular density
5
     overlying the left the lower lung consistent with nipple shadow. The costophrenic sulci are clear. The
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     visualized skeletal structures are normal. Accordingly, the patient was discharged in stable condition.
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     She was to follow up with the primary care provider for reevaluation and further management within
8    1-2 days.
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            7.      On January 13, 2018, the patient presented via ambulance to the ED of Antelope Valley
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     Hospital with complaints of right flank and right elbow pain after a fall four days earlier. Notes
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     indicate that her breathing was unlabored and regular, but rales/crackles were noted to bilateral upper
12   lobes and bilateral lower lobes, with a cough. A chest x-ray showed: a spiculated mass measuring
13   roughly 4.6 cm in diameter in the mid lateral left lower lobe which appears to be new since the prior
14   examination. The lungs otherwise appear clear. Impression: probable 4.6 cm bronchogenic carcinoma
15   in the left lower lobe. Although less likely based on its appearance, this could represent pneumonia.

16   Additional imaging is recommended.

17          8.      On July 18, 2018, the patient presented to First Valley Medical Group (formally known
18   as Quartz Hill), for an annual wellness visit. Notes indicate that the patient had a couple of falls due to
19   dizziness, ambulates without assistance, has perceived memory issues, requires some assistance with

20   activities of daily living, and family members help care for the patient. She is not complaining of any
     pain now but does have intermittent pain. Examination of lungs shows wheezing, distant sounds. A
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     chest x-ray was ordered due to the patient’s COPD and shortness of breath.
22
23          9.      The chest x-ray showed a patchy density measuring approximately 6 x 4 x 7 cm in the

24   left lower lobe not seen on prior. The heart is enlarged. Calcification aortic arch. The lungs are
     otherwise clear and there is no pleural effusion or pneumothorax. The bones and soft tissues are
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     unremarkable. The Patient was notified.
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       DECLARATION OF RICHARD OFSTEIN, M.D., IN SUPPORT OF ESTATE OF JOEL HERRIOTT THAYER, M.D.’S MOTION FOR
                                       UNDERTAKING RE: SUMMAR GREGORY
1               10.    On November 27, 2018, the patient presented to the ED of Palmdale Regional Medical
2    Center complaining of increased shortness of breath and productive cough of yellowish phlegm. Notes

3    indicate history of COPD/CHF who does not have home oxygen. She was initially evaluated for
     shortness of breath which increased with exertion. Patient did respond well to fluids, breathing
4
     treatment and solumedrol. Today her chest x-ray showed left sided opacities which recommends CT
5
     Thorax which is pending. Diagnosis: Mass of lower lobe of left lung. Plan: admitted.
6
7               11.    The patient was admitted to Antelope Valley Hospital on January 1, 2019 and passed on

8    January 20, 2019. The cause of death acute was respiratory failure secondary to lung abscess.

9               12.    Based on my review of decedent’s medical records, including imaging studies and
10   reports,     as   well   as   my    education,   training,   and   experience,   it   is   my   opinion   that
11   Dr. Thayer’s care and treatment of decedent was at all times within the applicable standard of care.

12   My opinion is based on the following:

13              13.    Dr. Thayer’s interpretation of the April 4, 2017, chest x-ray (AP view only), was

14   reasonable and well within the standard of care, in part, because to a reasonable medical probability,

15   decedent did not have a lung mass visible on x-ray at that time.

16              14.    Dr. Thayer’s interpretation of the chest film is consistent with that of the radiologist

17   who read the April 2, 2017, imaging who had the added advantage of a lateral film as well as the AP
     imaging to examine.
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19              15.    This opinion is based on several factors. First, the subject film depicted a “distorted
     right breast” likely due to prior surgery which prevented Dr. Thayer and the other radiologists who
20
     read the chest films from comparing the location of the left breast nipple to that on the right.
21
22              16.    The x-ray on April 2, 2017, did not reveal the presence of a mass. To a reasonable
     medical probability, if a cancerous mass was present at the time of April 4, 2017, chest x-ray, the prior
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     study would have shown it.
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                17.    The standard of care did not require Dr. Thayer to recommend further imaging with
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     nipple markers. This type of request is only made when the radiologist has a high index of suspicion
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     that the patient has a concerning mass vs. nipple shadow.
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                                                             4
           DECLARATION OF RICHARD OFSTEIN, M.D., IN SUPPORT OF ESTATE OF JOEL HERRIOTT THAYER, M.D.’S MOTION FOR
                                           UNDERTAKING RE: SUMMAR GREGORY
1           18.     Even if Dr. Thayer had recommended further imaging with nipple markers, and a CT
2    scan was done at that time, to a reasonable medical probability the CT scan would not have revealed a

3    lung mass.

4           19.     The findings on the subsequent CT scan of the chest done in November 2018, reveals
5    further evidence that the nipple shadow referred by Dr. Thayer was indeed a shadow and not a mass.

6    The 2018 CT scan reveals a lung mass that is 8 cm from the center of the spine, whereas the nipple
     shadow on the April 4, 2017, is 12 cm from the center point.
7
8           20.     Further, because Dr. Thayer met the applicable standard of care at all times in his care
     and treatment of decedent, to a reasonable medical probability nothing Dr. Thayer did or failed to do
9
     caused or contributed to decedent’s death.
10
11          I declare under penalty of perjury under the laws of the State of California that the foregoing is
     true and correct.
12
13          Executed on June _____, 2022, in Las Vegas, Nevada.

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15                                                                       ___________________________
16
                                                                         Richard Ofstein, M.D.
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       DECLARATION OF RICHARD OFSTEIN, M.D., IN SUPPORT OF ESTATE OF JOEL HERRIOTT THAYER, M.D.’S MOTION FOR
                                       UNDERTAKING RE: SUMMAR GREGORY
EXHIBIT A
RICHARD ALAN OFSTEIN, M.D.

        Curriculum Vitae




       MAILING ADDRESS

           PO Box 370385
       Las Vegas Nevada 89137




       Last Revised June 2020




                 1
                          RICHARD ALAN OFSTEIN, M.D.
                          CURRICULUM VITAE (continued)

DATE/PLACE OF BIRTH:




LICENSE:

      California Medical License # G 44857 (Active)
      Utah Medical License # 10161123-1205 (Active)
      Nevada Medical License # 18022

      Drug Enforcement Administration # AO 1046259

EDUCATION:

      Undergraduate
      Southern Illinois University
      Carbondale, Illinois
      B.S. PHYSIOLOGY
      August 1975

      Graduate
      Southern Illinois University
      Carbondale, Illinois
      PHYSIOLOGY
      June 1976-June 1977

      Medical
      Southern Illinois University
      Springfield, Illinois
      MEDICAL DEGREE (M.D.)
      June 1980




                                         2
                         RICHARD ALAN OFSTEIN, M.D.
                         CURRICULUM VITAE (continued)

POST MEDICAL DEGREE TRAINING:

      Internship
      UCLA Hospital and Clinics
      Los Angeles, California
      GENERAL SURGERY
      July 1980-June 1981

      Residency
      UCLA Hospital and Clinics
      Los Angeles, California
      DIAGNOSTIC RADIOLOGY
      July 1981-June 1984

      Fellowship
      Memorial Medical Center of Long Beach
      Long Beach, California
      CT/MRI (8 months) & Interventional Radiology (4 months)
      July 1984-June 1985

WORK STATUS:

      CURRENT WORK STATUS:

      Adjunct Assistant Professor of Radiology University Utah
      June 2017-Present

      PRIOR WORK STATUS:

      Jackson Hole Medical Imaging, Inc.
      P.O. Box 1450
      Wilson, WY 83014
      February 2006-June 2016

      Memrad Medical Group, Inc.
      100 Oceangate, Suite 1000
      Long Beach, CA 90802
      562-590-7400
      July 1985-December 1998
      January 2000-January 2006




                                           3
                           RICHARD ALAN OFSTEIN, M.D.
                           CURRICULUM VITAE (continued)

      PRIOR WORK STATUS:

      Assistant Clinical Professor of Radiology 1988-2002
      UCLA School of Medicine
      Los Angeles, CA


STAFF PRIVILEGES:

      Hospital                                          Status

      University of Utah                                Active
      Salt Lake City UT

CERTIFICATION:

      American Board of Radiology
      Certification in Diagnostic Radiology, May 1984

      American Board of Radiology
      Certificate of Added Qualifications in Neuroradiology, November 2001, November
      2012

MEMBERSHIPS:

      American College of Radiology
      American Society of Neuroradiology
      Radiological Society of North America
      American Roentgen Ray Society

UNIVERSITY APPOINTMENTS:

      Adjunct Assistant Professor of Radiology University Utah
      June 2017-Present

      Assistant Clinical Professor of Radiology UCLA School of Medicine
      1988-2002

PUBLICATIONS:

      Magnetic Resonance Update
      Founding Publisher, Editor and Author
      Dates of Publication: 1989-2005


                                           4
                         RICHARD ALAN OFSTEIN, M.D.
                         CURRICULUM VITAE (continued)

PUBLICATIONS:

      Consultations in Radiology & Imaging
      Founding Publisher, Editor and Author
      Dates of Publication: 1990-1998

      Women’s Health Review
      Founding Publisher, Editor and Author
      Dates of Publication: 1995-1996

      Morrison, D.S., Ofstein, R. The Use of Magnetic Resonance Imaging in the Diagnosis
      of Rotator Cuff Tears. Orthopedics;13(6): 633-7 (1990)

      Berger, P.E., Ofstein, R. MRI Demonstration of Radiographically Occult Fractures:
      What Have We Been Missing? Radiographics; 9(3): 407-36 (1989)

      Low Back Pain in Adults, Magnetic Resonance Update, 1989

      Temporomandibular Joint Dysfunction, Magnetic Resonance Update, 1989

      Knee MRI-The Menisci, Ligaments, and Tendons, Magnetic Resonance Update, 1989

     Gadolinium and MRI: Information for the Referring Physician, Magnetic Resonance
     Update, 1989

      Unilateral Hearing Loss, Tinnitus, Dysequilibrium: Acoustic Neuromas, Magnetic
      Resonance Update, 1989

      Shoulder Pain: Rotator Cuff Tears, Magnetic Resonance Update, 1989

      Pituitary Adenomas, Magnetic Resonance Update, 1989

      Cerebral Metastases, Magnetic Resonance Update, 1989

      Hip Pain: Avascular Necrosis of the Femoral Head, Magnetic Resonance Update, 1989

      The Cervical Spine: Disc Herniation and Degenerative, Magnetic Resonance Update,
      1990

      Prostate Cancer: Staging with MRI, Magnetic Resonance Update, 1990

      Stress Fractures-Occult Osseous Injuries, Magnetic Resonance Update, 1990

      Wrist Pain, Magnetic Resonance Update, 1990

                                           5
                           RICHARD ALAN OFSTEIN, M.D.
                           CURRICULUM VITAE (continued)


PUBLICATIONS (Continued):

       Aortic Aneurysms, Magnetic Resonance Update, 1990

       Endometrial Carcinoma: Staging with MRI, Magnetic Resonance Update, 1990

       Neck Masses Including: Parathyroid and Thyroid Glands, Magnetic Resonance Update,
       1990

       Bone Metastases in Adults, Magnetic Resonance Update, 1990

       Head Trauma, Magnetic Resonance Update, 1990

       Ankle Injuries, Magnetic Resonance Update, 1990

       AIDS: Central Nervous System Involvement, Magnetic Resonance Update, 1990

       Adrenal Metastases and Other Masses, Magnetic Resonance Update, 1991

       Mediastinal Masses, Magnetic Resonance Update, 1991

       Vertebral Compression Fractures: Benign or Malignant?, Magnetic Resonance Update,
       1991

       Pediatric Abdominal Masses, Magnetic Resonance Update, 1991

       The Aging Brain, Magnetic Resonance Update, 1991

       Breast Cancer, Consultations in Radiology & Imaging, 1989

       Sinusitis: Imaging Evaluation, Consultations in Radiology & Imaging, 1990

       TIA and Stroke: Ultrasound Evaluation of Extracranial Carotid Arterial Disease,
       Consultations in Radiology & Imaging, 1990

       Claudication: Peripheral Angiography and Related Interventional Procedures,
       Consultations in Radiology & Imaging, 1990

       Cholecystolithiasis and Cholecystitis, Consultations in Radiology & Imaging, 1991

       Pregnancy and Related Complications: The Diagnostic Role Of Ultrasound,
       Consultations n Radiology & Imaging, 1991


                                            6
                            RICHARD ALAN OFSTEIN, M.D.
                            CURRICULUM VITAE (continued)

PUBLICATIONS (Continued):

        Interstitial Lung Disease: High-Resolution CT, Consultations in Radiology &
        Imaging, 1991

REFERENCES:

        Paul Berger, MD
        Past President, Memrad Medical Group
        Founder, NightHawk Radiology
        Scottsdale, Arizona

        Alyssa Watanabe, MD
        Vice President, Direct Access Imaging, Inc.
        2711 N Sepulveda Boulevard, # 284
        Manhattan Beach, CA 90266

        Barbara Kadell, M.D.
        UCLA Medical Center
        Professor of Radiology
        Vice Chair of Clinical Operations
        Los Angeles, CA

        Robert Jones, MD
        Jackson Hole Medical Imaging
        Radiology-St John’s Medical Center
        625 E Broadway
        Jackson WY 83001


PRESENTATIONS

Natural Background and Medical Radiation:               St. John’s Medical Center
What you need to know for your health and Safety        9 November 2010

Coronary CT Angiography                                 St. John’s Medical Center
                                                        30 October 2010

Breast Cancer Screening                                 St. John’s Medical Center
                                                        30 October 2010

MRI: Bone Pathology                                     Medical Staff Meeting, Los Alamitos
                                                        Medical Center
                                                        14 December 1998

                                             7
                             RICHARD ALAN OFSTEIN, M.D.
                             CURRICULUM VITAE (continued)

PRESENTATIONS (continued)

Medical Imaging from the Perspective of Litigation         Trial Attorney Group
                                                           Memrad Corporate Office
                                                           27 October 1998
CONTINUING MEDICAL EDUCATION

CONFERENCE/ACTIVITY                    DATES                       CME CREDITS

ASCR ER MSK Case Review –              Completed 5/19/2021         8.0 hours, Category 1
Upper Extremity

ACR CPI Gastrointestinal Tract         Completed 5/6/2021          8.0 hours, Category 1

Penn Radiology-Emergency Imaging: Completed 5/2/2020               15.75 hours, Category 1
Acute Diagnoses

RSNA Virtual Meeting                   2019/2020                   10.5 hours, Category 1

Penn Radiology’s Comprehensive         Completed 3/21/19           25.25 hours, Category 1
Neuroradiology: Best Practices

RSNA Virtual Meeting                   December 2018               9.0 hours, Category 1

ACR RADAR 2 – MSK                      February 2018               8.0 hours, Category 1

Radiological Society of North America December 2017                10.25 hours, Category 1
Annual Meeting
Chicago, Illinois

CPI Chest Radiology Module 2017        June 18, 2017               8.0 hours, Category 1
(ONLINE) ACR

Duke Radiology-                        May 30, 2017                18.25 hours, Category 1
Neuro and Musculoskeletal Imaging

Texas Jurispudence Prep                February 1, 2017            8.0 hours, Category 1

Radiological Society of North America 27 Nov-2 Dec 2016            17 hours, Category 1
Annual Meeting
Chicago, Illinois

Mammography Case Review                July 20, 2015               15 hours, Category 1


                                              8
                              RICHARD ALAN OFSTEIN, M.D.
                              CURRICULUM VITAE (continued)

CONTINUING MEDICAL EDUCATION (Continued)

CONFERENCE/ACTIVITY                  DATES                   CME CREDITS

Breast Tomosynthesis 2014            July 2, 2014            8.75 hours, Category 1
USF Health

Radiological Society of North America 30 Nov-6 Dec 2013      10.5 hours, Category 1
Annual Meeting
Chicago, Illinois

Radiological Society of North America 25-30 Nov 2012         12.75 hours, Category 1
Annual Meeting
Chicago, Illinois

Johns Hopkins Neuroradiology         12 Jan 2012             25 hours, Category 1
Review

Mayo Clinic Neuroradiology:          Nov-Dec 2011            21.5 hours, Category 1
Practice to Innovation

Radiological Society of North America 27 Nov -2 Dec 2011
Annual Meeting Chicago Illinois

Radiological Society of North America 28 Nov -3 Dec 2010     15.0 hours, Category 1
Annual Meeting
Chicago, Illinois

A Comprehensive Tutorial in          28-30 Oct 2010          17.5 hours, Category 1
Musculoskeletal Imaging

Coronary CT Angiography              19-21 February 2010     21.5 hours, Category 1
Reston, VA

Radiological Society of North America 29 Nov-4 Dec 2009      9.5 hours, Category 1
Annual Meeting

Advanced Radiology Life Support      7 April 09              4.5 hours, Category 1
Mayo Clinic

Radiological Society of North America 30 Nov-5 Dec 2008      8.25 hours, Category 1
Annual Meeting

Digital Mammography                  9/11/2008               8.8 hours, Category 1

                                            9
                            RICHARD ALAN OFSTEIN, M.D.
                            CURRICULUM VITAE (continued)

CONTINUING MEDICAL EDUCATION (Continued)

CONFERENCE/ACTIVITY                  DATES                 CME CREDITS

Radiological Society of North America 25-30 Nov 2007       8.5 hours, Category 1
Annual Meeting
Chicago, Illinois

UCSF in Africa                       24-29 June 2007       23.75 hours, Category 1
UCSF

Radiological Society of North America 26 Nov-1 Dec 06      7.75 hours, Category 1
Annual Meeting
Chicago, Illinois

Diagnostic Radiology Seminars: Back 29 Oct-3 Nov 06        23.75 hours, Category 1
UCSF
Lahaina, Hawaii

The Team Approach to Breast Imaging 26-28 Oct 2006         23 hours, Category 1
Harvard Medical School, Newport, Rhode Island

Radiological Society of North America 27 Nov- 2 Dec 2005   6.25 hours, Category 1
Annual Meeting
Chicago, Illinois

Visiting Fellowship-Nuclear          4-18 Nov 2005         40 hours, Category 1
Cardiology
Department of Radiology
Massachusetts General Hospital

Mammography: Advanced Diagnostic 9-12 Nov 2005             26 hours, Category 1
With Screening
Laszlo Tabar, MD
Indian Wells, CA
UCSF Breast Imaging Mini-Fellowship 31 Oct-4 Nov 2005      40 hours, Category 1

Breast Imaging and Intervention      21-23 Oct 2005        20 hours, Category 1
From A to Z
James Brenner, MD
Medical Education Resources


                                           10
                             RICHARD ALAN OFSTEIN, M.D.
                             CURRICULUM VITAE (continued)

CONTINUING MEDICAL EDUCATION (Continued)

CONFERENCE/ACTIVITY                   DATES                    CME CREDITS

Mammography Interpretive Skills       11 Sept 05               9 hours, Category 1
Assessment 3
American College of Radiology

Mammography Interpretive Skills       9 Sept 05                8 hours, Category 1
Assessment 2
American College of Radiology

Advanced Concepts in Body MRI         10-11 Sept 2005          12 hours, Category 1
American College of Radiology
Santa Monica, CA

Summer Seminar in Breast Imaging      16 July 2005             5.75 hours, Category 1
Los Angeles Radiological Society
Los Angeles, CA

Diagnostic Imaging Update             28 March-1 April, 2005   16 hours, Category 1
Stanford University

Cardiac MR Fellowship                 9-11 Dec 2004            17.5 hours, Category 1
University California San Francisco

Radiological Society of North America 28-30 Nov 2004           8.75 hours, Category 1
Annual Meeting
Chicago, Illinois

The Johns Hopkins University          1-8 Aug 2004             26.75 hours, Category 1
School of Medicine
Advanced Topics in Multidector
CT Scanning

Musculoskeletal MR Course             20-23 Oct 2003           9 hours, Category 1
University of California San Diego
School of Medicine

11th Annual Current Issues of         25-28 August 2002        25 hours, Category 1
Magnetic Resonance Imaging in
Orthopaedics and Sports Medicine




                                            11
                               RICHARD ALAN OFSTEIN, M.D.
                               CURRICULUM VITAE (continued)

CONTINUING MEDICAL EDUCATION (Continued)

CONFERENCE/ACTIVITY                     DATES                 CME CREDITS

CT Screening 2002:                      31 May-2 June 2002    13 hours, Category 1
National Symposium

International Spine Injection Society   4-5 May 2002          13 hours, Category 1
Phase 1 Lumbar Workshop

CT Screening: The Science,              14-16 Dec 2001        16 hours, Category 1
The Business, The Issues

Certificate of Added Qualifications     Nov 2001              100 hours, Category 1
in Neuroradiology, November 2001
American Board of Radiology

Johns Hopkins Neuroradiology Review 11-13 October 2001        17.25 hours, Category 1


Diagnostic Imaging Update               26-30 March 2001      23 hours, Category 1
Stanford University

Radiological Society of North America 25 Nov-1 Dec 2000       12.5 hours, Category 1

The Twenty-first Annual Symposium: 12-14 August 2000          15 hours, Category 1
Breast Imaging
Brown University School of Medicine

MRI 1999                                15-19 February 1999   25 hours, Category 1
Harvard Medical School

Radiological Society of North America 29 Nov-4 Dec 98         7.75 hours, Category 1

Diagnostic Imaging Update
Stanford University                     16-20 February 1998   20.50 hours, Category 1

Current Issues in Obstetrics            6-10 March 1996       20 hours, Category 1
and Gynecology

Radiological Society of North America 1-6 Dec 1996            9.25 hours, Category 1

Radiological Society of North America 28 Nov-1 Dec 1995       9.5 hours, Category 1


                                              12
                             RICHARD ALAN OFSTEIN, M.D.
                             CURRICULUM VITAE (continued)

CONTINUING MEDICAL EDUCATION (Continued)

CONFERENCE/ACTIVITY                   DATES                 CME CREDITS

Wilderness Medical Society            8-12 August 1995      31 hours, Category 1

Musculoskeletal MRI, Univ Penn        11-15 March 1995      25 hours, Category 1

American College of Cardiology        16-20 Jan 1995        21.5 hours, Category 1

Controversies in Women’s Health       8-9 Dec 1994          13.5 hours, Category 1
University California San Francisco

Radiological Society of North America 27 Nov-2 Dec 1994     15.75 hours, Category 1

National Conference on Obstetrics &   16-19 Nov 1994        18 hours, Category 1
Gynecology

American Heart Association            13-14 Jan 1994        16 hours, Category 1
ACLS Course




                                            13
1                   PROOF OF SERVICE -- §1013a CODE OF CIVIL PROCEDURE,
                      STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
2
3           I am employed in the County of Los Angeles, State of California; I am over the age of eighteen
     years and not a party to the within action; my business address is 1230 Rosecrans Avenue, Suite 450,
4    Manhattan Beach, California 90266.
5             On, June 16, 2022 I served the foregoing document described as DECLARATION OF
6    RICHARD OFSTEIN, M.D., IN SUPPORT OF ESTATE OF JOEL HERRIOTT THAYER,
     M.D.’S MOTION FOR UNDERTAKING RE: SUMMAR GREGORY on all interested parties in
7    this action by placing the original a true copy thereof in a sealed envelope addressed as follows:
8                                         SEE ATTACHED SERVICE LIST
9
            By Mail I caused such envelope to be deposited in the mail at Manhattan Beach, California.
10          The envelope was mailed with postage thereon fully prepaid. I am “readily familiar” with the
            firm’s practice of collection and processing correspondence for mailing. It is deposited with
11          U.S. postal service on that same day in the ordinary course of business. I am aware that on
12          motion of party served, service is presumed invalid if postal cancellation date or postage meter
            date is more than 1 day after date of deposit for mailing in affidavit.
13
            By E-mail The above-described document(s) were sent by e-mail transmission to the E-mail
14          addresses listed on the attached service list.
15
            By Express Mail I caused such envelope to be deposited in the mail at Manhattan Beach,
16          California. The envelope was mailed with Express Mail postage thereon fully prepaid.
17          By Overnight Delivery I caused such envelope to be sent via overnight delivery service. The
18          envelope was deposited in or with a facility regularly maintained by the express service carrier
            with delivery fees paid or provided for.
19
            By Personal Service I delivered such envelope by hand to the offices of the addressee(s).
20
            State I declare under penalty of perjury under the laws of the State of California that the
21
            foregoing is true and correct.
22
            Federal I declare that I am employed in the office of a member of the bar of this court at whose
23          direction this service was made.
24
            Executed on June 16, 2022 at Manhattan Beach, California.
25
26                                                ______________________________
                                                   /s/
                                                  ROXANNE OLIVA
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                                                         1                               6104-0406
1                        CORTEZ v. RENAISSANCE IMAGING CENTER, et al.
2                                       LASC Case No.: 20AVCV00282
3
4                                             SERVICE LIST
5
     Gary M. Schneider, Esq.                            ATTORNEYS FOR PLAINTIFFS
6    Nancy Siccama, Esq.
     LAW OFFICES OF GARY M SCHNEIDER
7    12100 Wilshire Blvd., Suite 1100
     Los Angeles, CA 90025
8
     Tel: 310-820-5544
9    Fax: 310-820-6024
     gary@gmsesq.com
10   nancy@gmsesq.com
     moui@gmsesq.com
11
12   Rodney G. Tomlinson, Esq.                          ATTORNEYS FOR DEFENDANTS
     Adam R. James, Esq.                                ERIC CARNEY DENLEY, M.D., CARLOS A.
13   SCHMID & VOILES                                    GUERRERO, FNP; and QUARTZ HILL
     333 South Hope Street, 8th Floor                   WALK-IN MEDICAL GROUP, INC.
14
     Los Angeles, CA 90071
15   Tel: (213) 473-8700
     Fax: (213) 473-8777
16   Rtomlinson@schmidvoiles.com
     ajames@schmidvoiles.com
17   Asanchez@schmidvoiles.com
18
     Janee M. Tomlinson, Esq.                           ATTORNEYS FOR DEFENDANTS HIGH
19   Christopher P. Wend, Esq.                          DESERT MEDICAL CORPORATION, A
     LA FOLLETTE, JOHNSON, DeHAAS, FESLER               MEDICAL GROUP
20   & AMES
21   701 North Brand Blvd., Suite 600
     Glendale, CA 91203
22   Tel: 213-426-3600
     Fax: 213-426-3650
23   jtomlinson@ljdfa.com
24   cwend@ljdfa.com
     zdavis@ljdfa.com
25   yblum@ljdfa.com
     ahernandez@ljdfa.com
26
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                                                    2                        6104-0406
1    Gregory G. Lynch                          ATTORNEYS FOR DEFENDANTS
     John D. Schumacher                        RENAISSANCE IMAGING MEDICAL
2    LEWIS BRISBOIS BISGAARD & SMITH LLP       ASSOCIATES (erroneously sued herein as
3    633 West 5th Street, Suite 4000           "Renaissance Imaging Medical Center)
     Los Angeles, California 90071
4    Tel: 213-250-1800
     Fax: 213-250-7900
5    Greg.Lynch@lewisbrisbois.com
6    John.Schumacher@lewisbrisbois.com
     Sherri.Norwood@lewisbrisbois.com
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                                           3                              6104-0406
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Make a Reservation
BAMBI CORTEZ, et al. vs RENAISSANCE IMAGING CENTER, et al.
Case Number: 20AVCV00282 Case Type: Civil Unlimited Category: Medical Malpractice - Physicians & Surgeons

Date Filed: 2020-04-20 Location: Michael Antonovich Antelope Valley Courthouse - Department A14



Reservation
Case Name:
BAMBI CORTEZ, et al. vs RENAISSANCE IMAGING           Case Number:
CENTER, et al.                                        20AVCV00282
Type:
Motion for Order (REQUIRING PLAINTIFF TO FILE AN      Status:
UNDERTAKING)                                          RESERVED
                                                      Location:
Filing Party:                                         Michael Antonovich Antelope Valley Courthouse -
Estate of Joel Herriot Thayer (Defendant)             Department A14
Date/Time:                                            Number of Motions:
07/19/2022 8:30 AM                                    1
Reservation ID:                                       Confirmation Code:
243654085180                                          CR-OCTRHXGRNCYKEBXQO


Fees
Description                                                                    Fee     Qty              Amount

Motion for Order (name extension)                                           60.00       1                60.00

Credit Card Percentage Fee (2.75%)                                           1.65       1                 1.65

TOTAL                                                                                                   $61.65


Payment
Amount:                                               Type:
$61.65                                                Visa
Account Number:                                       Authorization:
XXXX1052                                              23338G

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