(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) 25. At all times during the employment relationship, PLAINTIFFS performed their duties in a highly satisfactory, competent and diligent manner. 26. PLAINTIFFS have filed Charges of Discrimination with the California Department…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) In fact, both the reasons given for Ms. Smith’s ultimate termination and the underlying reasons for the draft disciplinary letter which she printed from Mr. White’s screen were pretext for retaliatory…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) 1. The depositions of Plaintiffs JAMES PATEL and MARI SINDHURI support their claim for bystander emotional distress under Thing, in this medical malpractice action. Here, the decedent’s husband and sister have…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) LIABILITY: Regional Medical Center: Hospital nursing personnel fell below the standard of care in the following areas: 1) Regardless whether Ms. Cruz or the breech patient arrived at the hospital first,…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) FIRST CAUSE OF ACTION (Sexual Harassment in Violation of Gov’t. Code §12900 et seq., by All PLAINTIFFS and Against All DEFENDANTS) 21. PLAINTIFFS repeat and reallege the allegations contained in paragraphs…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) FACTUAL ALLEGATIONS 10. PLAINTIFF JANE DOE 1 commenced employment with DEFENDANT STARS in or about April 1998 as a waitress. At no time was PLAINTIFF DOE 1 employed as a stripper.…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) Foundation has a very clear national policy regarding Corrective/Disciplinary Action because it is obligated to have one. Foundation Group (FG) must comply with specific legal/regulatory standards that include, but are not…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) Plaintiffs’ Opposition to Motion for Summary Adjudication By David X., M.D. and Valley Physicians MEMORANDUM OF POINTS AND AUTHORITIES INTRODUCTION This is a medical malpractice and wrongful death action. Thirty-two year…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) Nursing notes picked up again in the OR. The first reference after 10:52 am was at 11:05, with Ms. Cruz in the OR. The anesthesia record of Dr. X. referred to…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) Through the present, Diane Cash continues to treat with Dr. S. and Dr. C. and continues to receive counseling from Dr. Y., for her injuries sustained in the bus accident of…