(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) SECOND CAUSE OF ACTION BY ALL PLAINTIFFS AGAINST ALL DEFENDANTS BASED UPON HOSTILE WORK ENVIRONMENT HARASSMENT 93. Plaintiffs incorporate herein by reference each and every allegation contained in paragraphs1 through 87…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) PLAINTIFFS’ EXPERTS ARE REQUIRED TO TESTIFY ONLY AS TO WHETHER THE CAUSATION WAS A SUBSTANTIAL FACTOR – AND THEY ARE NOT REQUIRED TO QUANTIFY THE PERCENTAGE OF INJURY Plaintiffs’ experts are…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) FIRST CAUSE OF ACTION BY ALL PLAINTIFFS AGAINST DEFENDANT UCC BASED UPON EMPLOYMENT DISCRIMINATION 88. Plaintiffs incorporate herein by reference each and every allegation contained in paragraphs1 through 87 with full…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) At 10:20 am, Dr. U. was informed by L&D personnel (while operating on the breech patient) that the FHR on Ms. Cruz had fallen further. As a result, Dr. U. called…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) MEMORANDUM OF POINTS AND AUTHORITIES I INTRODUCTION This is a wrongful death action involving the death of Trevor Smith, who was a forty-one-year-old father and husband from Sacramento. He died of…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) IV THE MOTHER DOES NOT HAVE TO SHOW CONTEMPORANEOUS OBSERVATION OF HER CHILD’S BIRTH INJURY TO CLAIM EMOTIONAL DISTRESS AS A DIRECT VICTIM The plaintiff mother does not have to show…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) DAMAGES A. Physical Injuries. The bus struck Diane Cash from the left, as she walked eastbound on Campus Commons Road across University Avenue. Ms. Cash fell and hit her head and…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) The Espinosa court also held that having demonstrated the substantial factors in causing plaintiff’s brain damage, It was not necessary that plaintiff prove any particular apportionment as was required by the…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) Plaintiff’s Settlement Conference Brief BRIEF SUMMARY OF THE CASE: This action for malpractice involves severe birth-related brain injuries to Martha Cruz, born XX/XX/2002, at Regional Medical Center in West Sacramento. Briefly,…
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the proceedings.) According to the police report concerning the bus-pedestrian collision, Diane Cash was approximately two-thirds of the way across the intersection at the time of impact. The impact knocked her to the…