The following blog entry is written from a defendant’s position as trial approaches. Reviewing this kind of briefing should help potential plaintiffs and clients better understand how parties in personal injury cases present such issues to the court.
(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this medical malpractice case and its proceedings.)
It is worth noting that situations similar to those described in this medical negligence case could just as easily occur at any of the healthcare facilities in the area, such as Kaiser Permanente, UCSF Medical Center, San Francisco General, California Pacific Medical Center, or St. Francis Memorial Hospital.
Notice of Motion and Motion for Summary Judgment by Defendant Richard Brown, M.D. (C.C.P. §437c); Memorandum of Points and Authorities in Support Thereof.
This Motion will be made upon the grounds that there are no triable issues of material fact in this action in that the care and treatment rendered by defendant Richard Brown, M.D., to plaintiff Travis Lee, complied, at all times, with the applicable standard of care. Moreover, the care and treatment of defendant in no way caused, or contributed to, plaintiff’s alleged injuries and damages. Defendant Richard Brown, M.D., is, therefore, entitled to judgment as a matter of law. For more information you are welcome to contact San Francisco personal injury lawyer, Moseley Collins.
This Motion will be based upon this Notice, the Memorandum of Points and Authorities, all pleadings, records, and papers on file in this action, and upon such other oral and documentary evidence as may be presented at the hearing of this Motion. (See Part 2 of 8.)
For more information you are welcome to contact San Francisco personal injury lawyer, Moseley Collins.