Preview
Richard S. Salinas, #154959
Lindsey R. Fries, PL#554357
SALINAS LAW GROUP
8405 North Fresno Street, Suite 150
Fresno, California 93720
Telephone: (559) 438-2080
Facsimile: (559) 438-8363
rsalinas@salinaslg.com |fries@salinaslg.com
Attomeys for Defendants, EUNICE SUHR, M.D., BRYCE BECKER, P.A. and
PAUL MROZ, M.D.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF KERN
10
11 LINDA SPENCER and HARVEY SPENCER, ) Case No. BCV-24-100724
12 Plaintiff, DEFENDANTS, EUNICE SUHR, M.D.,
BRYCE BECKER, P.A. AND PAUL
13
vs. MROZ, M.D.’S ANSWER TO
14 COMPLAINT
DIGNITY HEALTH; ARROYO GRANDE
15 COMMUNITY HOSPITAL; DIGNITY
HEALTH WOMEN’S CENTER-
16
SOUTHWEST; HALL AMBULANCE
17 SERVICE, INC.; KEVIN MCCLENAHAN
EMT/PARAMEDIC; EUNICE SUHR, M.D.;
18 BRYCE BECKER, P.A.; KL FERGUSON,
M.D.; PAUL MROZ, M.D.; BOB FUKANO,
19
RP.H.; JUSTIN T. LEE, M.D.; and DOES 1
20 through 30, inclusive, Action Filed: February 29, 2024
Trial Date:
21 Defendants.
22
23
Defendants, EUNICE SUHR, M.D., BRYCE BECKER, P.A. AND PAUL MROZ, M.D
24
(hereinafter “Defendants”), for Answer to Plaintiffs unverified Complaint, alleges as follows:
25
1 By virtue of the provisions of Section 431.30(d) of the Code of Civil Procedure,
26
Defendants generally deny the unverified Complaint and each and every allegation therein.
27
WW
28
Mt
1
DEFENDANTS, EUNICE SUHR, M.D., BRYCE BECKER, P.A. AND PAUL MROZ, M.D.’S ANSWER TO COMPLAINT
FIRST AFFIRMATIVE DEFENSE
2 Defendants allege that the damages, if any, complained of by Plaintiffs were
proximately caused by the negligence of firms, persons, corporations and/or entities other than
Defendants, and that said negligence comparatively reduces the percentage of any negligence by
Defendants, if any be found, which negligence Defendants expressly deny.
SECOND AFFIRMATIVE DEFENSE
3 Defendants allege that in the event Defendants are found to be negligent, which is
expressly herein denied, Defendants may elect to introduce evidence of any amounts paid or
payable, if any, as a benefit to Plaintiffs pursuant to Civil Code section 3333.1.
10 THIRD AFFIRMATIVE DEFENSE
11 4 Defendants allege that in the event Defendants are found to be negligent, which is
12 expressly herein denied, the damages for non-economic losses shall not exceed the amounts
13 specified in Civil Code section 3333.2.
14 FOURTH AFFIRMATIVE DEFENSE
is 5 Defendants allege that in the event Defendants are found to be negligent, which is
16 expressly herein denied, Defendants may elect to have future damages, if in excess of the amount
17 specified in Code of Civil Procedure section 667.7, paid in whole or in part as specified in Code
18 of Civil Procedure section 667.7.
19 FIFTH AFFIRMATIVE DEFENSE
20 6 Defendants allege that Plaintiffs did not exercise ordinary care, caution or
21 prudence to avoid the happening of the incident complained of herein, and said incident and the
22 injuries and damages, if any, sustained by Plaintiff were directly and proximately caused and
23 contributed to by the negligence of said Plaintiff.
24 SIXTH AFFIRMATIVE DEFENSE
25 7. Defendants allege that the action is barred by the appropriate statute of limitations
26 as set forth in Code of Civil Procedure sections 335.1 and 340.5, and Defendants request a
27 separate trial in regard to this defense pursuant to Code of Civil Procedure section 597.5.
28 Ml
2
DEFENDANTS, EUNICE SUHR, M.D., BRYCE BECKER, P.A. AND PAUL MROZ, M.D.’S ANSWER TO COMPLAINT
SEVENTH AFFIRMATIVE DEFENSE
8 Defendants allege that the Complaint on file herein fails to state facts sufficient to
constitute a cause of action against Defendants.
EIGHTH AFFIRMATIVE DEFENSE
9 Defendants allege that in the event Defendants are found to be negligent, which is
expressly herein denied, the liability of Defendant is limited by reason of California Civil Code
section 1431.2.
NINTH AFFIRMATIVE DEFENSE
10. Defendants allege that Plaintiffs acted with full knowledge of all the facts and
10 circumstances surrounding Plaintiffs’ injuries, and that said matters of which Plaintiffs assumed
11 the risk proximately contributed to and proximately caused Plaintiff's injuries, if any.
12 TENTH AFFIRMATIVE DEFENSE
13 11. In the event it is found that Defendants failed to disclose all material information
14 to Plaintiffs, a reasonably prudent person would have consented to the medical treatment or
15 operation had there been full disclosure of the risks and benefits.
16 ELEVENTH AFFIRMATIVE DEFENSE
17 12. Defendants allege that he is not liable for any of the alleged damages pursuant to
18 Civil Code section 1714.8 “for any occurrence or result solely on the basis that the occurrence or
19 result was caused by the natural course of a disease or condition, or was the natural or expected
20 result of reasonable treatment rendered for the disease or condition.”
21 TWELFTH AFFIRMATIVE DEFENSE
22 13. Defendants allege that the complaint, and the allegations contained therein, is
23 barred by §1317(c) and (f) of the Health and Safety Code.
24 THIRTEENTH AFFIRMATIVE DEFENSE
25 14. As a separate and distinct affirmative defense, Defendants contend that even if a
26 reasonable person in Plaintiffs’ position might not have consented to the procedure(s) or
aa treatment performed on her by Defendants if she had been given enough information about its
28 risks, Plaintiff still would have consented to the procedure or treatment.
3
DEFENDANTS, EUNICE SUHR, M.D., BRYCE BECKER, P.A. AND PAUL MROZ, M.D.’S ANSWER TO COMPLAINT
FOURTEENTH AFFIRMATIVE DEFENSE
15. As a separate and distinct affirmative defense, Defendants contend that they had
no duty to disclose to Plaintiffs the likelihood of success or risks associated with procedure(s) or
treatment they performed on the Plaintiff, because Plaintiff asked not to be informed of the
likelihood of success or risks of the procedure or treatment.
FIFTEENTH AFFIRMATIVE DEFENSE
16. As a separate and distinct affirmative defense, Defendants contend that they were
not required to inform Plaintiffs of the likelihood of success or risks of the procedure(s) or
treatment they performed on the Plaintiff as the treatment or procedure is a simple procedure and
10 it is understood that the risks are minor and not likely to occur.
il SIXTEENTH AFFIRMATIVE DEFENSE
12 17. As a separate and distinct affirmative defense, Defendants contend that they were
13 not required to inform Plaintiffs of the likelihood of success or risks of the procedure(s) or
14 treatment they performed on the Plaintiff as the information would have so seriously upset
15 Plaintiff that Plaintiff would not have been able to reasonably consider the risks of refusing to
16 have the medical procedure.
17 SEVENTEENTH AFFIRMATIVE DEFENSE
18 18. As a separate and distinct affirmative defense, Defendants contend that they were
19 not required to inform Plaintiff of the likelihood of success or risks of the procedure(s) or
20 treatment they performed on the Plaintiff because an emergency existed.
21 EIGHTEENTH AFFIRMATIVE DEFENSE
22 19. Defendants allege that liability for damages, if any, is further limited by the recent
aan decisions of Cabrera v. E. Rojas Properties, Inc. (2011) 192 Cal.App.4th 1319, and Howell v.
24 Hamilton Meats & Provisions (2011) 52 Cal.4th 541, which in conjunction hold that a plaintiff
aaa may not recover for “phantom” damages in the form of medical expenses billed yet not actually
26 paid and related principles set forth in each case and their progeny.”
27 M
28 M
4
DEFENDANTS, EUNICE SUHR, M.D., BRYCE BECKER, P.A. AND PAUL MROZ, M.D.’S ANSWER TO COMPLAINT
WHEREFORE, Defendants pray that Plaintiffs take nothing by reason of their Complaint
and that Defendants have and recover judgment for costs of suit and for such other relief as the
Court deems proper.
D
Dated: May _['f_, 2024 S. LAW GROUP
C7
6
B
Richard S-Salitas
Lindsey R. Fries
Attorneys for Defendants, EUNICE
SUHR, M.D., BRYCE BECKER, P.A.
10 and PAUL MROZ, M.D.
1004-0079
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
5
DEFENDANTS, EUNICE SUHR, M.D., BRYCE BECKER, P.A. AND PAUL MROZ, M.D.’S ANSWER TO COMPLAIN1
Spenci er v. Suhr
Kern County of Superior Court Case No. BCV-24-100724
PROOF OF SERVICE
CCP §§ 1011, 1013, 1013a, 2015.5
FRCP 5(b)
STATE OF CALIFORNIA, COUNTY OF FRESNO
I am employed in the County of Fresno, State of California. Iam over the age of 18 and nota
party to the within action; my business address is 8405 North Fresno Street, Suite 150, Fresno, CA 93720.
On May 14, 2024, I served the document described as DEFENDANTS, EUNICE SUHR, M.D.,
BRYCE BECKER, P.A. AND PAUL MROZ, M.D.’S ANSWER TO COMPLAINT on the interested
parties in this action [1] by placing the true copies thereof enclosed in sealed envelope(s) addressee(s) as
stated on the attached service list: [1] by placing L] the original [1] a true copy thereof enclosed in sealed
envelope(s) addressed as follows:
SEE ATTACHED SERVICE LIST
10
0 BY MAIL: (J I deposited such envelope in the mail at Fresno, California. The envelope was mailed
11
with postage thereon fully prepaid.
12)
OO As follows: I am “readily familiar” with the firm’s practice of collection and
13 processing correspondence for mailing. Under that practice it would be deposited with
U.S. postal service on that same day with postage thereon fully prepaid at Fresno,
14 California in the ordinary course of business. I am aware that on motion of the party
served, service is presumed invalid if postal cancellation date or postage meter date is
15 more than one day after date of deposit for mailing in affidavit.
16
(0 (BY PERSONAL SERVICE) I personally delivered such envelope(s) to the office(s) of the
17 addressee(s) listed on the attached service list.
18 OC (BY FACSIMILE) I faxed the document to the person(s) at the fax number(s) listed in the attached
service list. The telephone number of the sending facsimile machine was (559) 438-2080. No error was
19) reported by the fax machine that I used.
20 Kl (BY ELECTRONIC SERVICE) | transmitted electronically by email(s) of the above-referenced
document to the addressee(s) at the email addresses listed in the attached service list.
21
22
1 (BY OVERNIGHT COURIER) I enclosed said document in an envelope(s) or package(s) addressed
to the person(s) at the addresses listed on the attached service list. I placed the envelope(s) or package(s)
23 for collection and overnight delivery at an office or a regularly utilized drop box of the overnight service
carrier or delivered such document to a courier or driver authorized by the overnight service carrier to
24 receive documents.
25 Executed on May 14, 2024, at Fresno, California.
26 I declare under penalty of perjury under the laws of the State of California that the above
(State)
is true and correct.
27
28
MK Jimenez
Signatyre
1
PROOF OF SERVICE
Spencer v. Suhr
Kern County of Superior Court Case No. BCV-24-100724
SERVICE LIST
Joseph A. Androvich Attorneys for Plaintiffs, LINDA SPENCER
BRELSFORD, ANDROVICH & WHITE and HARVEY SPENCER
2001 I Street,
Sacramento, CA 95811
jandrovich@baw-attorneys.com
mtran@baw-attorneys.com
Dennis R. Thelen an ‘for Defendant, JUSTIN T. LEE,
LeBeau Thelen LLP,
5001 E Commercecenter Dr, Ste 300
Bakersfield, CA 93309-1687
10 dthelen@lebeauthelen.com
gwitthans@lebeauthelen.com
11 tcherry@lebeauthelen.com
12
Deborah S. Tropp Attorneys for Defendants, KEVIN
13 Kevin J. Castellanos McCLENAHAN and HALL AMBULANCE
MeNeéeil Tropp & Braun LLP SERVICES, INC.
14 4695 Macarthur Ct, Ste 800
Newport Beach, CA 92660
15
dtro) tbattorneys.com
16 kcastellanos@mtbattorneys.com
7 Hugh S. Spackman Attorneys for Defendants, DIGNITY
18
Clinkenbeard, Ramsey, Spackman & Clark LLP HEALTH and DIGNITY COMMUNITY
PO Box 21007, CARE
19 Santa Barbara, CA 93121-1007
hspackman@crslawfirm.com
20
21 James C. Schaeffer Attorneys for Defendant, KL FERGUSON,
Laura L. Cota MD.
22 Schaeffer Cota Rosen LLP
500 E Esplanade Dr Ste 950
23
Oxnard, CA 93036-0515
24 jschaeffer@scr-legal.com
Icota@scr-legal.com
25
26 1006-0079
27
28
2
PROOF OF SERVICE
Preview
Richard S. Salinas, #154959 Lindsey R. Fries, PL#554357 SALINAS LAW GROUP 8405 North Fresno Street, Suite 150 Fresno, California 93720 Telephone: (559) 438-2080 Facsimile: (559) 438-8363 rsalinas@salinaslg.com |fries@salinaslg.com Attomeys for Defendants, EUNICE SUHR, M.D., BRYCE BECKER, P.A. and PAUL MROZ, M.D. SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF KERN 10 11 LINDA SPENCER and HARVEY SPENCER, ) Case No. BCV-24-100724 12 Plaintiff, DEFENDANTS, EUNICE SUHR, M.D., BRYCE BECKER, P.A. AND PAUL 13 vs. MROZ, M.D.’S ANSWER TO 14 COMPLAINT DIGNITY HEALTH; ARROYO GRANDE 15 COMMUNITY HOSPITAL; DIGNITY HEALTH WOMEN’S CENTER- 16 SOUTHWEST; HALL AMBULANCE 17 SERVICE, INC.; KEVIN MCCLENAHAN EMT/PARAMEDIC; EUNICE SUHR, M.D.; 18 BRYCE BECKER, P.A.; KL FERGUSON, M.D.; PAUL MROZ, M.D.; BOB FUKANO, 19 RP.H.; JUSTIN T. LEE, M.D.; and DOES 1 20 through 30, inclusive, Action Filed: February 29, 2024 Trial Date: 21 Defendants. 22 23 Defendants, EUNICE SUHR, M.D., BRYCE BECKER, P.A. AND PAUL MROZ, M.D 24 (hereinafter “Defendants”), for Answer to Plaintiffs unverified Complaint, alleges as follows: 25 1 By virtue of the provisions of Section 431.30(d) of the Code of Civil Procedure, 26 Defendants generally deny the unverified Complaint and each and every allegation therein. 27 WW 28 Mt 1 DEFENDANTS, EUNICE SUHR, M.D., BRYCE BECKER, P.A. AND PAUL MROZ, M.D.’S ANSWER TO COMPLAINT FIRST AFFIRMATIVE DEFENSE 2 Defendants allege that the damages, if any, complained of by Plaintiffs were proximately caused by the negligence of firms, persons, corporations and/or entities other than Defendants, and that said negligence comparatively reduces the percentage of any negligence by Defendants, if any be found, which negligence Defendants expressly deny. SECOND AFFIRMATIVE DEFENSE 3 Defendants allege that in the event Defendants are found to be negligent, which is expressly herein denied, Defendants may elect to introduce evidence of any amounts paid or payable, if any, as a benefit to Plaintiffs pursuant to Civil Code section 3333.1. 10 THIRD AFFIRMATIVE DEFENSE 11 4 Defendants allege that in the event Defendants are found to be negligent, which is 12 expressly herein denied, the damages for non-economic losses shall not exceed the amounts 13 specified in Civil Code section 3333.2. 14 FOURTH AFFIRMATIVE DEFENSE is 5 Defendants allege that in the event Defendants are found to be negligent, which is 16 expressly herein denied, Defendants may elect to have future damages, if in excess of the amount 17 specified in Code of Civil Procedure section 667.7, paid in whole or in part as specified in Code 18 of Civil Procedure section 667.7. 19 FIFTH AFFIRMATIVE DEFENSE 20 6 Defendants allege that Plaintiffs did not exercise ordinary care, caution or 21 prudence to avoid the happening of the incident complained of herein, and said incident and the 22 injuries and damages, if any, sustained by Plaintiff were directly and proximately caused and 23 contributed to by the negligence of said Plaintiff. 24 SIXTH AFFIRMATIVE DEFENSE 25 7. Defendants allege that the action is barred by the appropriate statute of limitations 26 as set forth in Code of Civil Procedure sections 335.1 and 340.5, and Defendants request a 27 separate trial in regard to this defense pursuant to Code of Civil Procedure section 597.5. 28 Ml 2 DEFENDANTS, EUNICE SUHR, M.D., BRYCE BECKER, P.A. AND PAUL MROZ, M.D.’S ANSWER TO COMPLAINT SEVENTH AFFIRMATIVE DEFENSE 8 Defendants allege that the Complaint on file herein fails to state facts sufficient to constitute a cause of action against Defendants. EIGHTH AFFIRMATIVE DEFENSE 9 Defendants allege that in the event Defendants are found to be negligent, which is expressly herein denied, the liability of Defendant is limited by reason of California Civil Code section 1431.2. NINTH AFFIRMATIVE DEFENSE 10. Defendants allege that Plaintiffs acted with full knowledge of all the facts and 10 circumstances surrounding Plaintiffs’ injuries, and that said matters of which Plaintiffs assumed 11 the risk proximately contributed to and proximately caused Plaintiff's injuries, if any. 12 TENTH AFFIRMATIVE DEFENSE 13 11. In the event it is found that Defendants failed to disclose all material information 14 to Plaintiffs, a reasonably prudent person would have consented to the medical treatment or 15 operation had there been full disclosure of the risks and benefits. 16 ELEVENTH AFFIRMATIVE DEFENSE 17 12. Defendants allege that he is not liable for any of the alleged damages pursuant to 18 Civil Code section 1714.8 “for any occurrence or result solely on the basis that the occurrence or 19 result was caused by the natural course of a disease or condition, or was the natural or expected 20 result of reasonable treatment rendered for the disease or condition.” 21 TWELFTH AFFIRMATIVE DEFENSE 22 13. Defendants allege that the complaint, and the allegations contained therein, is 23 barred by §1317(c) and (f) of the Health and Safety Code. 24 THIRTEENTH AFFIRMATIVE DEFENSE 25 14. As a separate and distinct affirmative defense, Defendants contend that even if a 26 reasonable person in Plaintiffs’ position might not have consented to the procedure(s) or aa treatment performed on her by Defendants if she had been given enough information about its 28 risks, Plaintiff still would have consented to the procedure or treatment. 3 DEFENDANTS, EUNICE SUHR, M.D., BRYCE BECKER, P.A. AND PAUL MROZ, M.D.’S ANSWER TO COMPLAINT FOURTEENTH AFFIRMATIVE DEFENSE 15. As a separate and distinct affirmative defense, Defendants contend that they had no duty to disclose to Plaintiffs the likelihood of success or risks associated with procedure(s) or treatment they performed on the Plaintiff, because Plaintiff asked not to be informed of the likelihood of success or risks of the procedure or treatment. FIFTEENTH AFFIRMATIVE DEFENSE 16. As a separate and distinct affirmative defense, Defendants contend that they were not required to inform Plaintiffs of the likelihood of success or risks of the procedure(s) or treatment they performed on the Plaintiff as the treatment or procedure is a simple procedure and 10 it is understood that the risks are minor and not likely to occur. il SIXTEENTH AFFIRMATIVE DEFENSE 12 17. As a separate and distinct affirmative defense, Defendants contend that they were 13 not required to inform Plaintiffs of the likelihood of success or risks of the procedure(s) or 14 treatment they performed on the Plaintiff as the information would have so seriously upset 15 Plaintiff that Plaintiff would not have been able to reasonably consider the risks of refusing to 16 have the medical procedure. 17 SEVENTEENTH AFFIRMATIVE DEFENSE 18 18. As a separate and distinct affirmative defense, Defendants contend that they were 19 not required to inform Plaintiff of the likelihood of success or risks of the procedure(s) or 20 treatment they performed on the Plaintiff because an emergency existed. 21 EIGHTEENTH AFFIRMATIVE DEFENSE 22 19. Defendants allege that liability for damages, if any, is further limited by the recent aan decisions of Cabrera v. E. Rojas Properties, Inc. (2011) 192 Cal.App.4th 1319, and Howell v. 24 Hamilton Meats & Provisions (2011) 52 Cal.4th 541, which in conjunction hold that a plaintiff aaa may not recover for “phantom” damages in the form of medical expenses billed yet not actually 26 paid and related principles set forth in each case and their progeny.” 27 M 28 M 4 DEFENDANTS, EUNICE SUHR, M.D., BRYCE BECKER, P.A. AND PAUL MROZ, M.D.’S ANSWER TO COMPLAINT WHEREFORE, Defendants pray that Plaintiffs take nothing by reason of their Complaint and that Defendants have and recover judgment for costs of suit and for such other relief as the Court deems proper. D Dated: May _['f_, 2024 S. LAW GROUP C7 6 B Richard S-Salitas Lindsey R. Fries Attorneys for Defendants, EUNICE SUHR, M.D., BRYCE BECKER, P.A. 10 and PAUL MROZ, M.D. 1004-0079 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 5 DEFENDANTS, EUNICE SUHR, M.D., BRYCE BECKER, P.A. AND PAUL MROZ, M.D.’S ANSWER TO COMPLAIN1 Spenci er v. Suhr Kern County of Superior Court Case No. BCV-24-100724 PROOF OF SERVICE CCP §§ 1011, 1013, 1013a, 2015.5 FRCP 5(b) STATE OF CALIFORNIA, COUNTY OF FRESNO I am employed in the County of Fresno, State of California. Iam over the age of 18 and nota party to the within action; my business address is 8405 North Fresno Street, Suite 150, Fresno, CA 93720. On May 14, 2024, I served the document described as DEFENDANTS, EUNICE SUHR, M.D., BRYCE BECKER, P.A. AND PAUL MROZ, M.D.’S ANSWER TO COMPLAINT on the interested parties in this action [1] by placing the true copies thereof enclosed in sealed envelope(s) addressee(s) as stated on the attached service list: [1] by placing L] the original [1] a true copy thereof enclosed in sealed envelope(s) addressed as follows: SEE ATTACHED SERVICE LIST 10 0 BY MAIL: (J I deposited such envelope in the mail at Fresno, California. The envelope was mailed 11 with postage thereon fully prepaid. 12) OO As follows: I am “readily familiar” with the firm’s practice of collection and 13 processing correspondence for mailing. Under that practice it would be deposited with U.S. postal service on that same day with postage thereon fully prepaid at Fresno, 14 California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is 15 more than one day after date of deposit for mailing in affidavit. 16 (0 (BY PERSONAL SERVICE) I personally delivered such envelope(s) to the office(s) of the 17 addressee(s) listed on the attached service list. 18 OC (BY FACSIMILE) I faxed the document to the person(s) at the fax number(s) listed in the attached service list. The telephone number of the sending facsimile machine was (559) 438-2080. No error was 19) reported by the fax machine that I used. 20 Kl (BY ELECTRONIC SERVICE) | transmitted electronically by email(s) of the above-referenced document to the addressee(s) at the email addresses listed in the attached service list. 21 22 1 (BY OVERNIGHT COURIER) I enclosed said document in an envelope(s) or package(s) addressed to the person(s) at the addresses listed on the attached service list. I placed the envelope(s) or package(s) 23 for collection and overnight delivery at an office or a regularly utilized drop box of the overnight service carrier or delivered such document to a courier or driver authorized by the overnight service carrier to 24 receive documents. 25 Executed on May 14, 2024, at Fresno, California. 26 I declare under penalty of perjury under the laws of the State of California that the above (State) is true and correct. 27 28 MK Jimenez Signatyre 1 PROOF OF SERVICE Spencer v. Suhr Kern County of Superior Court Case No. BCV-24-100724 SERVICE LIST Joseph A. Androvich Attorneys for Plaintiffs, LINDA SPENCER BRELSFORD, ANDROVICH & WHITE and HARVEY SPENCER 2001 I Street, Sacramento, CA 95811 jandrovich@baw-attorneys.com mtran@baw-attorneys.com Dennis R. Thelen an ‘for Defendant, JUSTIN T. LEE, LeBeau Thelen LLP, 5001 E Commercecenter Dr, Ste 300 Bakersfield, CA 93309-1687 10 dthelen@lebeauthelen.com gwitthans@lebeauthelen.com 11 tcherry@lebeauthelen.com 12 Deborah S. Tropp Attorneys for Defendants, KEVIN 13 Kevin J. Castellanos McCLENAHAN and HALL AMBULANCE MeNeéeil Tropp & Braun LLP SERVICES, INC. 14 4695 Macarthur Ct, Ste 800 Newport Beach, CA 92660 15 dtro) tbattorneys.com 16 kcastellanos@mtbattorneys.com 7 Hugh S. Spackman Attorneys for Defendants, DIGNITY 18 Clinkenbeard, Ramsey, Spackman & Clark LLP HEALTH and DIGNITY COMMUNITY PO Box 21007, CARE 19 Santa Barbara, CA 93121-1007 hspackman@crslawfirm.com 20 21 James C. Schaeffer Attorneys for Defendant, KL FERGUSON, Laura L. Cota MD. 22 Schaeffer Cota Rosen LLP 500 E Esplanade Dr Ste 950 23 Oxnard, CA 93036-0515 24 jschaeffer@scr-legal.com Icota@scr-legal.com 25 26 1006-0079 27 28 2 PROOF OF SERVICE