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01/20/2023
Open
Malpractice - Medical Malpractice
1. Decedent Luis Marquez was a resident of Los Angeles County, California.
2. Luis Marquez suffered a wrongful death on November 14, 2021 . He brings his surviving claims by and through his successor in interest, Margarita De La Rocha.
3. Plaintiff Margarita De La Rocha is Luis's mother. She is acting both individually and as the successor in interest to Luis Marquez under Code of Civil Procedure section 377.32. An affidavit, as required by that section, will be filed with the Court. Margarita De La Rocha is a resident of Los Angeles County, California.
4. At all times mentioned herein, Defendant Prime Healthcare Services - St. Francis, LLC, (also referred to as "St. Francis") and Does 2-15 are believed to be the owner, licensee, manager of St. Francis Medical Center and in the business of providing healthcare services subject to the requirements of State and Federal Law. At all times mentioned, Defendant Prime Healthcare Services - St. Francis, LLC's principal operating location is at 3630 E Imperial Hwy, Lynwood, Ca. , and is qualified to do business in California, and subject to the jurisdiction of the Superior Court of California. At all times relevant to this action Prime Healthcare was doing business as St. Francis Medical Center in Los Angeles County, California.
5. At all times mentioned herein, Defendant AME Medical Group, Inc. and Does 16- 30 are believed to be the owner, licensee, manager of Urgent Care - AME Medical Group in the business of providing healthcare services subject to the requirements of State and Federal Law. At all times mentioned, Defendant Prime Healthcare's principal operating location is at Paramount Blvd., Downey, Ca. , and is qualified to do business in California, and subject to the jurisdiction of the Superior Court of California. At all times relevant to this action Prime Healthcare was doing business as Urgent Care - AME Medical Group in Los Angeles County, California.
6. At all times mentioned herein, Defendant Doe 1 is a security company, entity unknown, responsible for hiring, employing, training, supervising security guards. Defendant Doe
Page 21 entered into a contract or other arrangement with Defendant Prime Healthcare Services - St. Francis, LLC, and/or its designee, to provide security services and security guards at St. Francis Medical Center.
7. The true names and capacities of the defendants named herein as DOES 1 through 100, inclusive, whether individual, corporate, associate, or otherwise, are unknown to plaintiffs, who therefore sues such defendants by fictitious names pursuant to Code of Civil Procedure section 474. Plaintiffs are informed and believe that said DOE defendants are California residents, and Plaintiffs will amend this Complaint to show such true names and capacities when they have been determined.
8. Each of the Defendants designated herein as a DOE is responsible, in some manner, for the events and happenings herein referred to, thereby legally causing the injuries and damages to Plaintiff as hereinafter alleged.
9. In this complaint, plaintiffs refer to AME Medical Group and Prime Healthcare Services - St. Francis, LLC, and DOES 1 through 100, inclusive, as "Defendants." Whenever plaintiffs refer to the "Defendants," they are referring AME Medical Group, Prime Healthcare Services - St. Francis, LLC, and DOES 1 through 100, inclusive, as if they had identified each of them individually.
VENUE
10. These events took place Urgent Care - AME Medical Group and St. Francis Medical Center located in Los Angeles County at Paramount Blvd., Downey, CA. . . Venue is therefore proper in Los Angeles County.
Plaintiffs are informed and believe and thereon alleges the following:
11. On November 13, 2021 , Luis Marquez, 37 years old, presented to Urgent Care AME Medical Group. He complained of anxiety and depression that had been getting
Page 3FUMIKO WASSERMAN
WENDY L. WILCOX
DE LA ROCHA MARGARITA
MARQUEZ LUIS
AME MEDICAL GROUP INC. DBA URGENT CARE AME MEDICAL GROUP
PRIME HEALTHCARE SERVICES ST. FRANCIS LLC DBA ST. FRANCIS MEDICAL CENTER
O'NEILL SEAN
TROTTER MICHAEL JOHN
O'MEARA JOHN V.
1/20/2023: Complaint
9/5/2024: Request for Dismissal: Request for Dismissal
7/16/2024: Order to Show Cause re: Dismissal (Settlement): Order to Show Cause re: Dismissal (Settlement)
7/16/2024: Order to Show Cause re: Dismissal (Settlement): Order to Show Cause re: Dismissal (Settlement)
7/11/2024: Notice : Notice AME MEDICAL GROUP, INC.S NOTICE OF TAKING MOTION FOR SUMMARY JUDGMENT OFF CALENDAR
7/10/2024: Notice of Settlement: Notice of Settlement
7/3/2024: Notice : Notice OF NONOPPOSITION TO DEFENDANT AME MEDICAL GROUPS MOTION FOR SUMMARY JUDGMENT
6/17/2024: Notice : Notice Of Taking Defendant Prime Healthcare Service -St. Francis, LLC DBA St. Francis Medical Center's Motion For Summary Judgment Off Calendar
5/21/2024: Notice : Notice Ntc of MSJ Hearings
5/14/2024: Certificate of Mailing for: Certificate of Mailing for (Court Order Re: Scheduling) of 05/14/2024
5/14/2024: Minute Order: Minute Order (Court Order Re: Scheduling)
5/9/2024: Certificate of Mailing for: (Court Order Re: Recusal) of 05/09/2024
5/9/2024: Minute Order: (Court Order Re: Recusal)
5/9/2024: Notice of Case Reassignment/Vacate Hearings
Minute Order: (Court Order Re: Recusal)
Certificate of Mailing for: Minute Order (Court Order Re: Recusal)
3/21/2024: Separate Statement: of undisputed material facts in support of Motion for Summary Judgment by Prime Healthcare Services St. Francis, LLC
3/21/2024: Notice of Lodging : Exhibits H, N, R, and S from evidence in support fo defendant Prime Healthcare Services St Francis LLC DBA St. Francis Mecidal Center's MSJ
DocketOrder to Show Cause re: Payment of Waived Fees; by:
[-] Read LessDocketOrder to Show Cause Re: Dismissal (Settlement) scheduled for 09/09/2024 at 08:30 AM in Compton Courthouse at Department B Not Held - Vacated by Court on 09/06/2024
[-] Read LessDocketOn the Complaint filed by LUIS MARQUEZ, et al. on 01/20/2023, entered Request for Dismissal with prejudice filed by LUIS MARQUEZ as to the entire action
[-] Read LessDocketRequest for Dismissal; Filed by: LUIS MARQUEZ (Plaintiff); MARGARITA DE LA ROCHA (Plaintiff)
[-] Read LessDocketOrder to Show Cause Re: Dismissal (Settlement) scheduled for 09/09/2024 at 08:30 AM in Compton Courthouse at Department B
[-] Read LessDocketOrder to Show Cause re: Dismissal (Settlement); Filed by: Clerk
[-] Read LessDocketOrder to Show Cause re: Dismissal (Settlement); Filed by: Clerk
[-] Read LessDocketTrial Setting Conference scheduled for 07/18/2024 at 08:30 AM in Compton Courthouse at Department B Not Held - Vacated by Court on 07/16/2024
[-] Read LessDocketHearing on Motion for Summary Judgment Re: AME Medical Group scheduled for 07/18/2024 at 08:30 AM in Compton Courthouse at Department B Not Held - Vacated by Court on 07/16/2024
[-] Read LessDocketNotice AME MEDICAL GROUP, INC.S NOTICE OF TAKING MOTION FOR SUMMARY JUDGMENT OFF CALENDAR; Filed by: AME MEDICAL GROUP, INC. (Defendant); As to: LUIS MARQUEZ (Plaintiff); MARGARITA DE LA ROCHA (Plaintiff)
[-] Read LessDocketProof of Personal Service; Filed by: LUIS MARQUEZ (Plaintiff); MARGARITA DE LA ROCHA (Plaintiff); As to: PRIME HEALTHCARE SERVICES ST. FRANCIS, LLC (Defendant); Service Date: 02/01/2023; Service Cost Waived: No
[-] Read LessDocketProof of Personal Service; Filed by: LUIS MARQUEZ (Plaintiff); MARGARITA DE LA ROCHA (Plaintiff); As to: AME MEDICAL GROUP, INC. (Defendant); Service Date: 01/27/2023; Service Cost: 98.00; Service Cost Waived: No
[-] Read LessDocketCase Management Conference scheduled for 08/30/2023 at 08:30 AM in Compton Courthouse at Department B
[-] Read LessDocketNotice of Case Management Conference; Filed by: Clerk
[-] Read LessDocketNotice of Posting of Jury Fees; Filed by: LUIS MARQUEZ (Plaintiff); MARGARITA DE LA ROCHA (Plaintiff)
[-] Read LessDocketCase assigned to Hon. George F. Bird in Department B Compton Courthouse
[-] Read LessDocketComplaint; Filed by: LUIS MARQUEZ (Plaintiff); MARGARITA DE LA ROCHA (Plaintiff); As to: AME MEDICAL GROUP, INC. (Defendant); PRIME HEALTHCARE SERVICES ST. FRANCIS, LLC (Defendant)
[-] Read LessDocketCivil Case Cover Sheet; Filed by: LUIS MARQUEZ (Plaintiff); MARGARITA DE LA ROCHA (Plaintiff); As to: AME MEDICAL GROUP, INC. (Defendant); PRIME HEALTHCARE SERVICES ST. FRANCIS, LLC (Defendant)
[-] Read LessDocketSummons on Complaint; Issued and Filed by: LUIS MARQUEZ (Plaintiff); MARGARITA DE LA ROCHA (Plaintiff); As to: AME MEDICAL GROUP, INC. (Defendant); PRIME HEALTHCARE SERVICES ST. FRANCIS, LLC (Defendant)
[-] Read LessDocketNotice of Case Assignment - Unlimited Civil Case; Filed by: Clerk
[-] Read Less