LIABILITY
The care and treatment rendered to Ms. White by Cindy Brown, M.D., and SAC Medical Group, Inc., fell below the standard of care in many respects, and it was that failure that caused the premature birth of Tomas and Owen and their ultimate demise.

Ms. White was at risk for pre-term labor and premature lengthening and dilatation of her cervix for the following reasons:

1. She was pregnant with twins;
2. She recently had undergone a LEEP procedure, i.e., a removal of a portion of her cervix due to abnormal Pap smear/biopsy;
3. She had delivered a child vaginally within the last year prior to this pregnancy.

The standard of care required Dr. Brown to refer Ms.. White to a perinatologist/high risk pregnancy specialist or comply with the standard of care of a perinatologist by assessing Ms.. White's cervix every two weeks throughout her pregnancy by way of transvaginal ultrasounds.

Secondly, the standard of care required, upon plaintiff's complaint on March 3rd of cervical pinching or vaginal pain, an immediate vaginal examination to determine whether or not the cervix had dilated and evaluation of the cervix by ultrasound.

Had Dr. Brown complied with the standard of care, early intervention would have occurred. Ms.. White would have been put on bed rest, been advised to stop working and more likely than not would have been able to prolong the pregnancy to 32 plus weeks. The twin baby boys died from the effects of premature labor and would have survived had Dr. Brown complied with the standard of care.

Dr. Brown failed to comply with the standard of care to render simply normal obstetrical care. She also failed to comply with ACOG guidelines relating to pre-term labor.

All the plaintiffs are really asking is that Dr. Brown be held to the same standards that she held her own self during her recent twin pregnancy, where she was put to bed rest and remained unable to cooperate with written discovery or the deposition process until after delivery. Copies of letters from her attorneys and her OB/GYN are attached as Exhibits A and B respectively.

DAMAGES

Plaintiffs, Sean and Joan White, seek damages for the wrongful death of their twin boys, and they are certainly entitled to the maximum amount of $250,000.00 for each child, as permitted by MICRA.

Plaintiffs have also sustained economic damages in the amount of $1,988.35 for funeral and burial expenses.
Plaintiff, William White, previously served a C.C.P. §998 Offer to Compromise on Dr. Brown the amount of $239,999.99. This §998 offer expired on October 20, 2006, by operation of law.

Plaintiff, Joan White, previously served a C.C.P. §998 Offer to Compromise on Dr. Brown in the amount of $239,999.99. This §998 offer expired on October 20, 2006, by operation of law.

Plaintiffs now demand $501,988.35 in full and final settlement of this action.

For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.

During the prenatal visit on March 3, 2004, Ms. White complained to Dr. Brown about pinching she was feeling at the cervix, to which Dr. Brown replied that it was caused by the way the babies were sitting in the uterus, that the head may be touching the cervix.

Dr. Brown did not do a vaginal exam to evaluate her cervix, or to see if it had lengthened or dilated. Furthermore, she failed to perform a transvaginal ultrasound which is commonly used to evaluate the cervix. It is doubtful that Dr. Brown had the competence to perform such an ultrasound.

The following day, on March 4, 2004, Ms. White experienced a little bit of pinkish discharge, and through the night started feeling cramping. The next morning, concerned that something was wrong, Ms. White called Universal Memorial Hospital, and they recommended that she come in to the Labor and Delivery Department, and be hooked up to a monitor to see what was going on. Dr. Gonzalez was the OB/GYN covering for Dr. Brown on that day. Upon examination, he performed a vaginal examination and determined that she was dilated 3 cm. He started her on medication in an attempt to stop the pre-term labor and further dilation of her cervix. At that time, Ms. White was in her 23rd week of the pregnancy.

For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.

PLAINTIFFS’ TRAIL BRIEF
Plaintiffs William White and Joan White submit the following trial brief in the above entitled matter.

PARTIES
Plaintiffs: William White and Joan White
Defendants: Cindy Brown, M.D., and SAC Medical Group

STATEMENT OF FACTS
Plaintiff, Joan White, began seeing Dr. Brown prior to or at the beginning of her pregnancy with her son, Ethan, who was born XX/XX/2003. During the pregnancy, Ms. White had an abnormal PAP smear. As a result of that abnormal PAP smear, on May 27, 2003, she underwent a colposcopy and a LEEP procedure, during which a portion of the cervix where the abnormal tissue is present is removed. This process can lead to an incompetent cervix and put Ms. White at high risk for pre-term labor.

In November of 2003, Ms. White discovered she was pregnant again, and started her prenatal care with Dr. Brown. In December of 2003, an ultrasound was performed and it was determined that Ms.. White was pregnant with twins. The ultrasound was performed in December by a radiologist at SanSkid Imaging Center. In February and March of 2004, Dr. Brown performed ultrasounds in her office; however, they were grossly inadequate and did not come close to complying with the guidelines set forth by the American College of Obstetrics and Gynecology. Ms. White began experiencing dizziness and lack of energy for which Dr. Brown recommended increasing her iron intake. Ms. White asked Dr. Brown if she could go on disability, and Dr. Brown advised her that it was too early in the pregnancy. (See Part 2 of 3.)

Request For Sanctions

California Code of Civil procedure Section 2023 provides for monetary sanctions where there is a failure to respond to interrogatories, evasive responses and objections lacking substantial justification are misuses of the discovery process. It further specifies that misuses of the discovery process include, but are not limited to, the following: .... (2) Using a discovery method in a manner that does not comply with its specified procedures; ....(4) Failing to respond or to submit to an authorized method of discovery; (5) Making, without substantial justification, an non-meritorious objection to discovery; (6) Making an evasive response to discovery; ....(8) Making or opposing, unsuccessfully and without substantial justification, a motion to compel or to limit discovery; and (9) Failing to confer in person, by telephone, or by letter with an opposing party or attorney in a reasonable and good faith attempt to resolve informally any dispute concerning discovery...... C.C.P. Section 2023.

Plaintiffs propounded special interrogatories to obtain information from defendant regarding the relevant facts and witnesses in the present action. The discovery was not propounded to harass the defendant and was propounded in good faith in order to obtain relevant information in this tragic birth injury matter.

CONCLUSION

For the foregoing reasons, plaintiffs respectfully request the court grant this motion and compel further responses to special interrogatories by defendant University to be received within ten days of the Court's order; and issue an order imposing sanctions against defendant and its attorneys of record in the sum of $2,100.00.

For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.

University's Assertion Of Boilerplate Objections Is Without Basis

In Greg Mannino v. Superior Court (1983) 142 Cal.App.3d 776, petitioner filed a personal injury action against real party in interest and propounded a six sets of special interrogatories. Real party filed a verified response after the date an answer was required and included numerous objections. Petitioner's subsequent motion to compel further answers was denied.

On appeal, the Court vacated the order denying motion to compel, holding that real party did not file on time and provided no reasonable excuse for the delay. Id. at 778-779. The court reasoned that the objections contained in the responses were based on relevancy, remoteness, vagueness, ambiguity and the claim that the interrogatories are too burdensome, stating that it does not require more than 60 days to raise these familiar complaints. Although the delay was short in this case, and it was the sixth set of interrogatories propounded to real party in interest, the court emphasized that the discovery process is subject to frequent abuse and, like a cancerous growth, can destroy a meritorious cause or defense when the party with the greater resources chooses to employ it in an unethical manner. Id.

In the instant birth injury matter, the objections made by University to the first seven special interrogatories propounded by plaintiff are without merit.

The medical records only identify Dr. Green and Dr. Brown as involved in the neonatal resuscitation and one labor/delivery nurse attending the birth. However, it has come out during depositions and through the course of discovery, through testimony of family and friends, that there was a resuscitation team as well as a great number of people in the room during the birth and the immediate post-birth period. Thus, the identification of those witnesses known to University was requested through special interrogatories.

More importantly, defendant University already agreed that they should and will provide further answers to plaintiffs special interrogatories. After counsel for plaintiffs initial meet and confer attempt, defense counsel agreed that further answers to plaintiffs special interrogatories would be provided no later than July 13, 2002. After receiving no additional responses by that date, counsel for plaintiffs made several additional meet and confer attempts. To date, however, no further responses have been provided by University. (See Part 6 of 6.)

For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.

In the instant matter, plaintiffs are entitled to an order compelling University to further respond to plaintiffs' Special Interrogatories, Numbers One through Seven.

First, repeated attempts to meet and confer and to obtain the information from defendants have been unsuccessful. Plaintiffs received University's written responses to their first set of special interrogatories on May 16, 2002, after granting four extensions. Thereafter, in an attempt to meet and confer over the inadequacy of the responses, plaintiffs sent a letter to University outlining the alleged deficiencies in responses to Special Interrogatories, One through Seven.

Thereafter, although defendant agreed to provide further responses to the specified interrogatories, no response has been received as of the date of this motion. Moreover, most recent additional meet and confer attempts by counsel for plaintiffs have been met with silence. Because, as discussed in detail below, University has not provided further responses to plaintiffs' interrogatories after agreeing to do so, plaintiffs are entitled to an order compelling defendant University to provide further responses.

More importantly, the information being requested from University is directly relevant to the issue of negligence in this birth injury case.

For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.

LEGAL ARGUMENT

Plaintiffs Are Entitled to an Order Compelling Responses To Special Interrogatories

Code of Civil Procedure section 2030(f) requires that a party to whom interrogatories have been propounded shall respond in writing under oath separately to each interrogatory by (1) an answer containing the information sought to be discovered, (2) an exercise of the parties option to produce writings, or (3) an objection to the particular interrogatory. Further, section 2030(f)(l) specifies that each answer in the response shall be as complete and straightforward as the information reasonably available to the responding party permits. If an interrogatory cannot be answered completely, it shall be answered to the extent possible.

Lastly, section 2030(1) provides that if the propounding party, on receipt of a response to interrogatories, deems that (1) an answer to a particular interrogatory is incomplete or evasive, (2) an exercise of the option to produce documents under paragraph (2) of subdivision (f) is unwarranted of the required specification of those documents is inadequate, or (3) an objection to an interrogatory is without merit or is too general, that party may move for an order compelling a further response.

In the instant birth injury matter, plaintiffs are entitled to an order compelling University to further respond to plaintiffs' Special Interrogatories, Numbers One through Seven. (See Part 4 of 6.)

Contrary to defendant's objection as stated in their Special Interrogatory Responses, these individuals were not identified in the medical records in the possession of plaintiffs and/or their counsel. The medical records only identify Dr. Green and Dr. Brown as involved in the neonatal resuscitation and one labor/delivery nurse attending the birth. However, it has come out during depositions and through the course of discovery, through testimony of family and friends, that there was a resuscitation team as well as a great number of people in the room during the birth and the immediate post-birth period.

Also uncovered during the course of discovery is the fact that, according to University's own pediatric department rules and regulations, a neonatal team "would include a neonatal transport nurse and a NICU nurse, as well as the neonatologist or his/her designee." Further, University's women and infants services procedure manual specifies that an Advance Practice Nurse, Transitional RN or NICU Charge RN shall be present at every delivery. Thus, it is clear that there are individuals known to University who were present who are not identified or reflected in the McCoy records.

By letter dated June 16, 2002, defendant University indicated that it would provide further Responses to Plaintiffs' Special Interrogatories, Set One. Defendant agreed to provide supplemental responses on or before July 13, 2002. In addition, defendant agreed to extend plaintiffs time for filing a motion to compel further responses, up to and including July 27, 2002.

On or about July 16, 2002, after not having received any further responses to Plaintiffs' Special Interrogatories Set One, counsel for plaintiffs telephoned defense counsel Andy Stone in order to obtain a status of the responses. Mr. Stone informed plaintiffs' counsel that defense counsel Barbara Stein would be handling the responses and would give a status update by the end of business that day.

At the end of the day, having not received a call from Ms. Stein, plaintiffs counsel called her to again inquire as to the status of the responses. Plaintiffs' counsel left a message for Ms. Stein and her assistant that an update on the responses was necessary or plaintiffs would be forced to file a motion to compel further responses. Defense counsel did not respond.

On or about July 17, 2002, counsel for plaintiffs left Ms. Stein another message inquiring as to the status of the responses. Again, the message went unanswered. On July 25, 2002, counsel for plaintiff informed defense counsel by letter that further responses to plaintiffs' Special Interrogatories were still outstanding and overdue. The attempts to telephone and meet and confer by plaintiffs' counsel have been met with silence and letters have gone unanswered..

To date, plaintiffs have not received further responses to special interrogatories. Accordingly, plaintiffs respectfully request this Court to issue an order compelling defendant to further respond to Plaintiffs' Special Interrogatories, Set One, Numbers One through Seven. Additionally, plaintiffs request sanctions be imposed for having to bring this Motion to Compel in the amount of $2275.00. (See Part 3 of 6.)

For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.

Memorandum of Points and Authorities in Support of Plaintiffs' Motion to Compel Answers to Special Interrogatories, and for Monetary Sanctions

INTRODUCTION

This is an action for medical negligence arising out of the birth of the minor plaintiff, John Smith, at University Hospital in Sacramento in April 2000 which resulted in severe neurologic injury to the minor. Plaintiffs allege that defendant University Medical Center ("University") and others carelessly and negligently managed the medical care of plaintiffs including but not limited to delivery and post-delivery care of minor plaintiff John Smith. As a result of defendant's negligence John Smith suffered severe brain injury, paresis and other neurological damage, resulting in impairment of mental and bodily function.

STATEMENT OF FACTS

Plaintiffs served their first set of Special Interrogatories on defendant University on February 28, 2002. University requested four extensions of time to respond to the interrogatories, all of which were granted by plaintiffs. After having an extended six weeks to answer, University served written responses on May 16, 2002. Defendant responded to Special Interrogatory, Numbers One through Seven, with an inadequate boiler plate objection, stating that defendant did not have to produce the information because it was equally available to plaintiffs.
Plaintiffs' counsel attempted to meet and confer with University with regard to their deficient responses to the special interrogatories by letter dated May 31, 2002. In their meet and confer correspondence, plaintiffs' counsel outlined each alleged insufficient interrogatory response, the answer given by University as well as the reason the answer was inadequate, and an explanation as to why the information requested in the interrogatories was relevant.

For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.

To meet this burden of proof, the defendant must show that either one or more elements of the cause of action cannot be established or there is a complete defense to that cause of action (Code Civ. Proc., § 437c(o)(2).) This means that where plaintiff has the burden of proof at trial by a preponderance of evidence, the defendant must present evidence that would require a reasonable trier of fact not to find the underlying material fact more likely than not. Otherwise, he [defendant] would not be entitled to judgment as a matter of law. But would have to present his evidence to a trier of fact [the jury]. (Brackets added.) (Aguilar, supra, 25 Cal.4th at p.851.)

The import of the more likely than not in the foregoing quote is that a moving defendant must generally present evidence that, if uncontradicted, would constitute a preponderance of evidence that an essential element of the plaintiff's case cannot be established.... The same is true when a moving defendant seeks to secure dismissal of the complaint based on an affirmative defense. (Emphasis added.) (Kids' Universe v. In2labs (2002) 95 Cal.App.870, 879.) Consequently, if the Defendants' expert declaration is disputed by a declaration by plaintiff's expert, then the matter is contradicted and the summary judgment must be denied.

Consequently, if the defendants fail to meet the above burden or persuasion, their motion must be denied:

Therefore, at the summary judgment stage, the defendants in the present case had an initial burden of production to make a prima facie showing that their conduct came within the exposure exemption. [Citations omitted.] If they failed to meet that burden, the plaintiff need not make any showing at all. (Pepperell v. Scottsdale Ins. Co. (1998) 62 Cal.App.4th 1045, 1054...].) Defendants contend that Dr. Amendola's declaration, together with Consumer Cause's discovery responses, shifted the burden of production to Consumer Cause. We disagree. (Consumer Cause, Inc. v. SmileCare (2001) 91 Cal.App.4th 454, 469 - 470.

Plaintiffs now respectfully request this court deny defendants’ motion for summary judgment.

For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.

THE MOVING PARTY HAS THE BURDEN OF PERSUASION

A party who seeks an court's action in his or her favor bears the burden of persuasion thereon:

Evidence Code, § 500 states as follows: Except as otherwise provided by law, a party has the burden of proof as to each fact the existence or nonexistence of which is essential to the claim for relief or defense that he or she is asserting.

As our Supreme Court recently explained:
[
F]rom commencement to conclusion, the party moving for summary judgment bears the burden of persuasion that there is no triable issue of material fact and that he is entitled to judgment as a matter of law. That is because of the general principle that a party who seeks a court's action in his favor bears the burden of persuasion thereon. "There is a triable issue of material fact if, and only if, the evidence would allow a reasonable trier of fact to find the underlying fact in favor of the party opposing the motion in accordance with the applicable standard of proof...." (Aguilar v. Atlantic Richfield Co. (2001) 25 Cal.4th 826, 850.)

In effect, the defendants in this medical malpractice action as the moving parties for summary judgment bear the burden of persuasion that one or more elements of the cause of action in question "cannot be established," or that "there is a complete defense" thereto. (Aguilar, supra, 25 Cal.4th at p.850.) Consequently, the burden of persuasion does not shift. Rather, when the court rules, one party has met its burden of persuasion and the other has not.

Regarding the burden of proof, the Supreme Court addressed that issue as follows:

[T]he party moving for summary judgment bears an initial burden of production to make a prima facie showing of the nonexistence of any triable issue of material fact; if he carries his burden of production, he causes a shift, and the opposing party is then subjected to a burden of production of his own to make a prima facie showing of the existence of a triable issue of material fact. A prima facie showing is one that is sufficient to support the position of the party in question.

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PLAINTIFF HAS PRESENTED HIS EXPERT DECLARATION WHICH DISPUTES THE DEFENDANT'S EXPERT'S CONCLUSIONS - AND THIS DISPUTE REQUIRES DENIAL OF THE SUMMARY JUDGMENT

Plaintiff's obstetric and gynecology, John Zee, M.D. has properly presented his opinion in his declaration testimony. Plaintiff's expert declaration, which disputes the declaration of the Defendant's expert declaration, requires denial of this motion for summary judgement. Dr. Zee meets all the requirements of expert testimony - including the standard of care as it relates to nurses and physicians:

To qualify a witness as a medical expert, it must be shown that the witness (1) has the required professional knowledge, learning and skill of the subject under inquiry sufficient to qualify him to speak with authority on the subject; and (2) is familiar with the standard required of a physician under similar circumstances; where a witness has disclosed sufficient knowledge of the subject to entitle his opinion to go to the jury, the question of the degree of his knowledge goes more to the weight of the evidence than to its admissibility. (Emphasis added.) (Evans v. Ohanesian (1974) 39 Cal.App.3d 121, 128.)

Consequently, Defendant is not in a position to argue the "weight" of Dr. Zee's testimony; that is the domain of the trier of fact, in this case, the jury. The Plaintiffs have properly presented their expert testimony on standard of care and causation. Defendants' experts' declarations are now controverted by the Plaintiffs' expert who concludes the Defendants’ actions were below the standard of care and also significant contributing factors in the cause of the child's condition:

And counter affidavits disclosing evidence or inferences reasonably deducible from such evidence of a triable issue of fact require denial of the motion.
(Emphasis added.) (Sesma v. Cueto, supra, 129 Cal.App.3d at p. 113.)

As the Supreme Court explained in D'Amico v. Board of Medical Examiners (1974) 11 Cal.3d 1, 20, the purpose of the summary judgment procedure is to see "whether the parties possessed the evidence requiring the weighing procedure of a trial." This Court now has two qualified expert declarations - both in dispute - and the jury should weigh the opinions at trial.

Similarly, Defendants' expert declaration has now been controverted; a triable issue exists - and not just on the standard of care and causation. (See Part 4 of 5.)

For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.

BRIEF STATEMENT OF FACTS
This medical malpractice action arises out of the prenatal, perinatal and postnatal care and treatment provided to Molly Brown and her minor son Mark Brown by defendants Tom White, M.D., Richard Hill, M.D., and Memorial Hospital (hereinafter "Memorial"). On June 20, 2000, Mrs. Brown delivered her son, Mark at Memorial. Plaintiffs contend that as a result of defendants' alleged negligence in caring for Mrs. Brown and her son Mark Brown while at the hospital, Mark Brown suffered permanent neurological damages, including cerebral palsy.

As to defendant Memorial, plaintiffs contend its nurses negligently delayed in attaching Mrs. Brown to a fetal heart monitor upon her presentation to the hospital, that defendant failed to implement intrauterine resuscitation maneuvers, and that defendant's nurses failed to timely contact Dr. White. (See, Molly Brown's responses to special interrogatory no. 23). Plaintiffs further contend that, as a result of this alleged negligence, plaintiff Mark Brown suffered physical, emotional and other damages. Plaintiffs allege defendants' negligence caused Molly Brown to suffer physical, emotional and loss of earnings damage. Mrs. Brown brings her claim for emotional distress as a direct victim, under Burgess v. Superior Court (1992) 2 Cal.4th 1064. Plaintiff Stan Brown contends he suffered emotional distress as a bystander, pursuant to Thing v. LaChusa (1989) 48 Cal.3d 644 and loss of consortium damages as a result of his wife's alleged injuries. (See Part 3 of 5.)

PLAINTIFFS' MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO DEFENDANT MEMORIAL HOSPITAL'S MOTION FOR SUMMARY JUDGMENT

INTRODUCTION

This is a medical malpractice action arising out of a birth injury suffered by the minor, Mark Brown. The minor suffered birth injuries resulting in cerebral palsy, and cognitive and developmental delay.

Memorial Hospital, where the minor was born, now moves for summary judgment claiming that the nurses acted within the medical standard of care and did not cause injury to the minor.

There is a triable issue of fact; Plaintiff has submitted evidence contradicting the Defendants' expert declaration. Plaintiff presents the expert declaration of John Zee, M.D., board certified in obstetrics and gynecology, contradicting the moving party's expert declaration. This counter declaration requires the denial of summary judgment (Sesma v. Cueto (1982) 129 Cal.App.3d 108, superceded on other grounds).

The moving party bears the burden of persuasion and the initial burden of proof: [F]rom commencement to conclusion, the party moving for summary judgment bears the burden of persuasion that there is no triable issue of material fact and that he is entitled to judgment as a matter of law. (Emphasis added.) (Aguilar v. Atlantic Richfield Co. (2001) 25 Cal.4th 826, 850.) Here the Plaintiff has now contradicted the Defendants' expert declaration; the Defendant has failed to carry its burden of persuasion. (See Part 2 of 5.)

(Please note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this birth injury/personal injury case and its proceedings.)

It was exactly this type of NIED claim that led to the Supreme Court's unanimous opinion in Bird v. Saenz (2000) 28 Cal.4th 910, and bears repeating. There, the Supreme Court acknowledged the crucial point the Court of Appeal had overlooked - lay people, as a general rule, necessarily lack the ability to meaningfully comprehend medical errors when they occur. Being distressed by watching medical care rendered to a loved one is not enough to state a claim:
The Court of Appeal did not explain how a bystander without medical acumen, except in the most extreme case...could meaningfully be aware that a course of treatment is causing injury. In any event, a rule permitting bystanders to sue for NIED on account of unperceived medical errors hidden in a course of treatment cannot be reconciled with Thing's requirement that the plaintiff be aware of the connection between the injury-producing event and the injury. The Court of Appeal's rule would, moreover, impose nearly strict liability on health care providers for NIED to bystanders who observe emotionally stressful procedures that turn out in retrospect to have involved negligence. We may reject such a rule as inconsistent with Thing.

Thus, allowing the father to amend is futile, because he could not possibly have witnessed or meaningfully comprehended the transmission of a latent bacterial infection from mother to child during birth. The only way he could have known about the infection is to be told about it after the fact. The demurrer to his NIED claim should be sustained without leave to amend.

CONCLUSION
The court should sustain the demurrer to the father's NIED claim without leave to amend, because the nature of the injury to the child makes it impossible for him to truthfully plead he knew a bacterial infection was passed at the time it occurred during birth. The demurrer to the mother's claim should be sustained. She should be required to clarify what causes of action she asserts, and to plead the elements entitling her to recovery under Burgess, as cannot qualify as a bystander which is what she has attempted to plead.

For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.