Declaration of Kathy Cawthon in Support of Opposition to Plaintiff's Motion to Compel - Declaration

On February 13, 2018 a case was filed by O'Connell, John , and O'Connell, John, represented by Vetter, Jack , and Vetter, Jack, against Enloe Medical Center , Guster, Allison , Ludwig, Derron, Md et al. represented by Brown, John Quincy, Iii , Gallert, Michael Gordon , Zimmerman, Robert Harry et al. in the jurisdiction of Butte County.



oonaunr wn = RS) Ol RO RO ee CO ON Ne Oe Oo ROBERT H. ZIMMERMAN, BAR No. 84345, F —Supetior Court of California IAN A. SCHARG, BAR NO, 285304 County of Butte SCHUERING ZIMMERMAN & DOYLE, LLP I I 400 University Avenue L L Sacramento, California 95825-6502 (916) 567-0400 E E FAX: 568-0400 D Shyu Emalah, Clete D By f NN AA, Deputy Attorneys for Defendant ENLOE MEDICAL CENTER Electro SUPERIOR COURT OF CALIFORNIA, COUNTY OF BUTTE JOHN O’CONNELL, Plaintiff, vs. ENLOE MEDICAL CENTER; ALLISON GUSTER, RN; NORTH VALLEY SURGICAL pees: DERRON LUDWIG, M.D., etal., Defendants. NO. 18CV00806 Assigned to the Honorable Judge Tamara L. Mosbarger for All Purposes DECLARATION OF KATHY CAWTHON IN SUPPORT OF OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET 17 AND ee RESPONSES TO RFP SETS 6 1, KATHY CAWTHON, declare: Date: September 22, 2021 Time: 9:00 a.m. Dept: 1 Complaint filed: February 13, 2018 Trial Date: October 18, 2021 1, I know the facts set forth herein from my own personal knowledge. If called upon to testify in this action as to the matters set forth herein, | could and would competently testify thereto. 2. I am the Director of Quality & Safety/Medical Staff Services at Enloe Medical Center. Iam responsible for Enloe Medical Center's patient safety incident report process, peer review, and investigations. | refer reports to the appropriate regulatory and state agencies as defined by those regulatory bodi...

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