On March 28, 2018 a
Notice Filed - of Motion for Judgment notwithstanding the Verdict
was filed
involving a dispute between
Norwoods, Natalie,
and
Dpm,
Fanous, Michael M,
for Complaint for Medical Malpractice
in the District Court of San Bernardino County.
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(". Keith Esq. (State Bar N0. 135537)
Kc i
('ireer.
1h .(Q x gjfl g _-.__‘__gg_Ll__;~1;L_lg_i_1_.
GREER & ASSOCIATES, A.P.C.
Wm athsPCALIFORNM
cwmcfififvgfiwm°
16855 w. Bernardo Dr. STE 255
San Diego, California 92127 OCT £7 2023
Telephone: (858) 613-6677
Facsimile: (858) 613-6680 W ophanie Reed. Deputy
Attorneys for Dc fendanl
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO
NATALIE NORWOODS, Case Nu; CIVDs 806935
1
plaintiff, NOTICE 0F MOTION FOR JNov
PURSUANT To CCP §629
VS.
DATEIBD
MICHAEL M. FANOUS, DPM TIMETBD
DEPARTMENT 327
Defendant
T0: ALL PARTIES AND THEIR COUNSEL OF RECORD
PLEASE TAKE NOTICE THAT, pursuant to Code of Civil Procedure §629,
Defendant Michael Fanous, D.P.M.. hereby Moves for a Judgment non obstinule
verec/ic/o (.INOV) at a time to be set by the Court 0n the grounds that a motion for
directed verdict should have been granted in favor ofDefendanl ¥an0us had such a
motion been brought on the grounds that the evidence cannot support a finding ofliabilil)
for past damages while simultaneously not supporting a finding ofno liability for future
damages under {he evidence adduced in this matter. Such inconsistent verdicts as to past
and future damages on the facts ot‘this case arc clearly unsupportable and are evidence FAX
NOTlCE O!" MO HON FOR JNOV PURSUANT T0 CCP §629DATE:TBDTIME:TBDDEPAR‘I‘MENT 527 -
l
RY
that motion for directed verdict. iI‘it had been brought, should have been granted. (CCP
629(a). Notice of Entry of Judgment was served on Defendant by electronic mail on
October l3, 2023.
The Motion for JNOV will be based on this Notiocc ofMotion and upon the
supporting affidavits/declarations and memoranda to be filed within ten (10) days
pursuant t0 CCP 659a. I
f
Dated this 27th day of October, 2023, GREER & SLSOCIATEWS, APC
(Wit
C. Keith Grey
12
Attorney for Defendant
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NOTICE OF MOTION FOR JNOV PURSUANT TO CCP §629DATEzTBDTlMEzTBDDEPARTMENT $27 - 2
Document Filed Date
October 27, 2023
Case Filing Date
March 28, 2018
Category
Complaint for Medical Malpractice
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(". Keith Esq. (State Bar N0. 135537) Kc i ('ireer. 1h .(Q x gjfl g _-.__‘__gg_Ll__;~1;L_lg_i_1_. GREER & ASSOCIATES, A.P.C. Wm athsPCALIFORNM cwmcfififvgfiwm° 16855 w. Bernardo Dr. STE 255 San Diego, California 92127 OCT £7 2023 Telephone: (858) 613-6677 Facsimile: (858) 613-6680 W ophanie Reed. Deputy Attorneys for Dc fendanl SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO NATALIE NORWOODS, Case Nu; CIVDs 806935 1 plaintiff, NOTICE 0F MOTION FOR JNov PURSUANT To CCP §629 VS. DATEIBD MICHAEL M. FANOUS, DPM TIMETBD DEPARTMENT 327 Defendant T0: ALL PARTIES AND THEIR COUNSEL OF RECORD PLEASE TAKE NOTICE THAT, pursuant to Code of Civil Procedure §629, Defendant Michael Fanous, D.P.M.. hereby Moves for a Judgment non obstinule verec/ic/o (.INOV) at a time to be set by the Court 0n the grounds that a motion for directed verdict should have been granted in favor ofDefendanl ¥an0us had such a motion been brought on the grounds that the evidence cannot support a finding ofliabilil) for past damages while simultaneously not supporting a finding ofno liability for future damages under {he evidence adduced in this matter. Such inconsistent verdicts as to past and future damages on the facts ot‘this case arc clearly unsupportable and are evidence FAX NOTlCE O!" MO HON FOR JNOV PURSUANT T0 CCP §629DATE:TBDTIME:TBDDEPAR‘I‘MENT 527 - l RY that motion for directed verdict. iI‘it had been brought, should have been granted. (CCP 629(a). Notice of Entry of Judgment was served on Defendant by electronic mail on October l3, 2023. The Motion for JNOV will be based on this Notiocc ofMotion and upon the supporting affidavits/declarations and memoranda to be filed within ten (10) days pursuant t0 CCP 659a. I f Dated this 27th day of October, 2023, GREER & SLSOCIATEWS, APC (Wit C. Keith Grey 12 Attorney for Defendant 13 l4 16 l7 19 20 2} 22 23 24 2S 26 27 28 NOTICE OF MOTION FOR JNOV PURSUANT TO CCP §629DATEzTBDTlMEzTBDDEPARTMENT $27 - 2