(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this wrongful death/personal injury case and its proceedings.) DEFENDANTS OWED DECEDENT THE HIGHEST STANDARD OF CARE UNDER COMMON CARRIER LIABILITY BECAUSE DECEDENT LOST HER FREEDOM OF MOVEMENT AND ACTION ONCE…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this wrongful death/personal injury case and its proceedings.) Thus, it is not unusual or atypical that the extent and nature of these emotional conditions was not discerned as part of…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this wrongful death/personal injury case and its proceedings.) SUMMARY OF FACTS This is an action for damages for wrongful death brought by the personal representative of the Estate of Claudia…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this wrongful death/personal injury case and its proceedings.) Plaintiff’s Opposition to Defendants’ Demurrer to Plaintiff’s Second Amended Complaint MEMORANDUM OF POINTS AND AUTHORITIES SUMMARY OF ARGUMENT This is an action…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this wrongful death/personal injury case and its proceedings.) Dr. Everstine has diagnosed the following emotional and psychological injuries secondary to the subject incident: 1) Paul Smith: PTSD; anxiety; major depression;…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this wrongful death/personal injury case and its proceedings.) Dr. Everstine has opined that this treatment is reasonable, necessary and causally related to the subject incident. Dr. Everstine opines that, “each…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this wrongful death/personal injury case and its proceedings.) DISCUSSION Because Defendants Offer Insufficient Undisputed Material Facts to Shift the Burden to Plaintiff, the Motion Must Fail The party moving for…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this wrongful death/personal injury case and its proceedings.) Plaintiffs’ Memorandum of Points and Authorities in Opposition to Defendant Radio Roseville’s Motion for Summary Adjudication INTRODUCTION In their latest attempt to…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of this wrongful death case and its proceedings.) PLAINTIFFS AGREE TO DISMISS THEIR FOURTH CAUSE OF ACTION AS TO DR. XY Plaintiffs agree to dismiss their Fourth Cause of Action for Fraud-Concealment as to…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of this wrongful death case and its proceedings.) Plaintiffs’ Opposition to Dr. David XY’s Demurrer to Fourth Amended Complaint; Memorandum of Points and Authorities. MEMORANDUM OF POINTS AND AUTHORITIES THIS COURT LACKS JURISDICTION TO…