It is worth noting that situations similar to those described in this medical malpractice case could just as easily occur at any of the healthcare facilities in the area, such as Kaiser Permanente, UC Davis Medical Center, Mercy, Methodist, or Sutter.
(Please also note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this personal injury lawsuit and its proceedings.)
Defendant Jonathan Black, M.D.’s Notice of Motion and Motion for Summary Judgment; Memorandum of Points and Authorities
Defendant, Jonathan Black, M.D., will move this Court for an Order granting Summary Judgment in his favor and against Plaintiff, Susan Dean.
This Motion is made pursuant to Code of Civil Procedure § 437c on the grounds that the care and treatment provided by defendant, Jonathan Black, M.D., at all times complied with the applicable standard of care in the community and that the care and treatment was not causally related to the damages claimed by plaintiff. As such, there are no triable issues of material fact and defendant, Jonathan Black, M.D., is entitled to summary judgment as a matter of law.
This Motion is based on this Notice; the following Memorandum of Points and Authorities; the Separate Statement of Undisputed Material Facts and Supporting Evidence; and on such oral and documentary evidence as may be presented at the hearing on this Motion.
WHEREFORE, defendant, Jonathan Black, M.D., prays this Motion be granted and that judgment be entered in his favor against plaintiff plus costs, as taxed. (See Part 2 of 4.)
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.