MOVING PARTY: Defendant Pacific Alliance Medical Center

OPPOSITION: Plaintiff Lynda McMorries

Plaintiff Lynda McMorries (“Plaintiff”) brings suit on behalf of her deceased son, Gerald Victorino (“Decedent”), whom Plaintiff alleges died as a result of the medical malpractice of

Defendant Pacific Alliance Medical Center (“Defendant”) and others. Plaintiff is successor-in-interest and mother of Decedent. Plaintiff alleges that Defendant prematurely discharged her dependent adult from their hospital which resulted in his death on June 1, 2016.

On August 18, 2017, Plaintiff filed her original complaint. On December 4, 2018, Plaintiff filed the operative Third Amended Complaint (“TAC”) alleging:

1) Dependent Adult Abuse (pursuant to Welfare & Institutions Code §§ 15600, et seq.)

2) Professional Negligence against all Defendants

3) Wrongful Death against all Defendants

All thr........