AI Analysis:
The message explicitly names 'Judge Allan Goodman' in the subject line and contains a direct attorney opinion from Robert Sheinbein characterizing him as 'terrible.' This is a clear, substantive negative evaluation of the judge from a practicing attorney, which is highly relevant for assessing Judge Goodman's reputation and quality as a workers' compensation judge.
Never. He is terrible. Regards, Robert A. Sheinbein Attorney at Law 11777 San Vicente Blvd., Suite 665 Los Angeles, CA 90049 310-274-8200 310-275-0442 Fax THIS MESSAGE IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHOM IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. If the reader of this message is not the intended recipient or the employee or agent responsible for delivering the message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify my offices by telephone to 310-274-8200.
AI Analysis:
The message explicitly names 'Judge Goodman' and provides substantive information about the judge's courtroom behavior and decision-making. It describes a specific incident where Judge Goodman warned a vocational rehabilitation expert against a particular testimony, and when the expert ignored the warning, the judge awarded 100% disability to the applicant. This reveals the judge's demeanor (firm, follows through on warnings), fairness (willing to rule in applicant's favor when warranted), and courtroom conduct. This is highly useful for evaluating Judge Goodman from a California workers' compensation attorney's perspective.
Tony, He usually finds that the injured employee can return to work as a parking lot attendant. Years ago Judge Goodman warned him, "Don't tell me that the Applicant can work as a parking lot attendant." Nevertheless that is exactly what his testimony was. The Judge was flabbergasted and awarded my client 100% . Jeff Linnetz Los Angeles
AI Analysis:
The message explicitly mentions 'Judge Goodman' in a substantive context, describing a specific courtroom interaction where the judge warned VR expert Rob Liebman not to testify that an applicant can work as a parking lot attendant. The message further implies the judge was 'flabbergasted' (truncated) when Liebman gave that exact testimony anyway. This provides meaningful information about Judge Goodman's courtroom demeanor, expectations of expert witnesses, and apparent sympathy or attentiveness to applicant limitations — all useful for evaluating the judge from a workers' compensation attorney's perspective.
Anthony Polakov Date: December 14, 2021 3:19:00 PM Subject: RE: SCIF VR Expert-Rob Liebman Reply to list Reply to sender Print List: lawnet Sent By: Anthony S. Polakov Reply To Sender Reply To List Search Settings Ok, well my guy cannot be a parking attendant. THE AME Hasday found him 100% not capable of working in the open labor market. Anthony S. Polakov, Esq. Stoll, Nussbaum & Polakov, APC 11620 Wilshire Blvd. Suite 500 Los Angeles, CA 90025 (310)996-7500 (310)575-4353 Fax apolakov@stolllaw.com Please take notice that Stoll, Nussbaum & Polakov is under a mandatory work from home order due to the Covid-19 pandemic. As a result, our physical office is closed and all employees are working remotely in hopes of doing our part to slow the spread of COVID-19. We ask that all correspondence, pleadings, discovery and/or other communications be electronically sent via email, dropbox, or other electronic means to mail@stolllaw.com until further notice. Any communications sent via U.S. Mail, and/or personal or overnight delivery will encounter significant delays in receipt because all mail will be forwarded and remotely processed . These delays can be avoided by sending all communications by email, dropbox and/or other electronic means to the following address: mail@stolllaw.com . PLEASE NOTE OUR NEW ADDRESS : 11620 Wilshire Blvd., Suite 500 Los Angeles, CA 90025 310.996.7500 office 310.575.4353 fax From: Jeffrey Linnetz (lawnet listserver) [mailto:listsender@lawnet.caaa.org] Sent: Tuesday, December 14, 2021 1:17 PM To: Statewide List Service <lawnet@lawnet.caaa.org> Subject: Re: [lawnet] SCIF VR Expert-Rob Liebman List: lawnet Sent By: Jeffrey Linnetz Reply To Sender Reply To List Search Settings Tony, He usually finds that the injured employee can return to work as a parking lot attendant. Years ago Judge Goodman warned him, "Don't tell me that the Applicant can work as a parking lot attendant." Nevertheless that is exactly what his testimony was. The Judge was flabbergasted and awarded my client 100% . Jeff Linnetz Los Angeles On Tue, Dec 14, 2021 at 12:34 PM Anthony S. Polakov (lawnet listserver) < listsender@lawnet.caaa.org > wrote: List: lawnet Sent By: Anthony S. Polakov Reply To Sender Reply To List Search Settings He is SCIF’s expert. Not mine. Anthony S. Polakov, Esq. Stoll, Nussbaum & Polakov, APC 11620 Wilshire Blvd. Suite 500 Los Angeles, CA 90025 (310)996-7500 (310)575-4353 Fax apolakov@stolllaw.com Please take notice that Stoll, Nussbaum & Polakov is under a mandatory work from home order due to the Covid-19 pandemic. As a result, our physical office is closed and all employees are working remotely in hopes of doing our part to slow the spread of COVID-19. We ask that all correspondence, pleadings, discovery and/or other communications be electronically sent via email, dropbox, or other electronic means to mail@stolllaw.com until further notice. Any communications sent via U.S. Mail, and/or personal or overnight delivery will encounter significant delays in receipt because all mail will be forwarded and remotely processed . These delays can be avoided by sending all communications by email, dropbox and/or other electronic means to the following address: mail@stolllaw.com . PLEASE NOTE OUR NEW ADDRESS : 11620 Wilshire Blvd., Suite 500 Los Angeles, CA 90025 310.996.7500 office 310.575.4353 fax From: Jeffrey Linnetz (lawnet listserver) [mailto: listsender@lawnet.caaa.org ] Sent: Tuesday, December 14, 2021 12:30 PM To: Statewide List Service < lawnet@lawnet.caaa.org > Subject: Re: [lawnet] SCIF VR Expert-Rob Liebman List: lawnet Sent By: Jeffrey Linnetz Reply To Sender Reply To List Search Settings Tony, I would not use him. He was appointed by Judge Spoeri on a case. He issued a report which concluded my client could return to work. His opinions were not well supported on cross examination. Jeff Linnetz Los Angeles On Tue, Dec 14, 2021 at 11:52 AM Anthony S. Polakov (lawnet listserver) < listsender@lawnet.caaa.org > wrote: List: lawnet Sent By: Anthony S. Polakov Reply To Sender Reply To List Search Settings Netsters: Anyone familiar with this VR expert. I have a 100% case that we have used a VR expert to confirm the 100%. SCIF has advised that they are using Rob Liebman as their expert. Is he fair, or very defense oriented? Credibility? thank you, Anthony S. Polakov Los Angeles, CA
AI Analysis:
The message explicitly mentions retired judge Allan Goodman by name and provides substantive characterizations of him as 'cerebral and detail oriented.' An attorney (David Aiso) is recommending him as an arbitrator for a complex UIM case involving Ehlers Danlos syndrome, suggesting he would be a strong candidate when presented with strong expert testimony and medical evidence. However, this message is about UIM arbitration (civil/personal injury context), not California workers' compensation, which slightly reduces its relevance for evaluating Goodman specifically as a workers' comp judge. The information is still useful for assessing his general judicial temperament and reputation among attorneys.
"David Aiso" Date: October 24, 2025 1:16:00 PM Subject: Re: Suggestions for UIM arbitrators for USAA Reply to list Reply to sender Print Abe, Interesting fact pattern and medical condition with a lot at stake. I think if I were presented with your situation, I would seriously consider retired judge Allan Goodman. Cerebral and detail oriented. If you have a strong, capable expert on Ehlers Danlos syndrome, and sufficient medically based evidence, retired judge Allan Goodman, should be a serious candidate to serve as your arbitrator. David Aiso. From: Abram Zukor (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Friday, October 24, 2025 9:51 AM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: [caala-workproduct] Suggestions for UIM arbitrators for USAA List: caala-workproduct Sent by: Abram Zukor (Reply Privately) Search Client involved in 3 separate MVAs each one year apart - complicated medical history (Ehlers Danlos syndrome) - 3 underlying consolidated cases resolved - now proceeding against USAA for UIM Arbitration. Policy has $300k limits - we’re arguing each accident insured up to $300k for a total of $900k. Looking for suggestions for arbitrator - binding UIM TIA Abe Cell:(310)710-2239 Sent from my iPhone
AI Analysis:
The message explicitly names 'Allan Goodman, Judge, Retired' and provides a direct attorney opinion about him. John Rosenberg states he 'always liked him when he was on the bench' and that he 'has been good to work with' as an arbitrator in a pending Kaiser med mal case. This contains substantive attorney experience and a positive assessment of the judge's demeanor and workability. However, confidence is slightly reduced because the context is a med mal arbitration rather than California workers' compensation, which may limit direct applicability to a WC attorney's evaluation. The judge is also retired and acting as an arbitrator rather than a sitting WCJ.
I have Allan Goodman, Judge, Retired, as the arbitrator in a pending Kaiser med mal case. While we are far from an arbitration hearing, I always liked him when he was on the bench and so far he has been good to work with. John Rosenberg
AI Analysis:
The message explicitly mentions 'Judge Allan Goodman' by name and identifies him as a proposed arbitrator for a Lyft UM (uninsured motorist) case. An attorney is soliciting opinions and experiences about him from colleagues, indicating he is being evaluated in a professional legal capacity. However, the message itself contains no substantive information about Goodman's rulings, demeanor, fairness, or case management style — it is purely a query seeking that information. It is relevant because it confirms the judge's identity and context (ADR arbitrator), but the confidence is moderate since no actual evaluative information about the judge is provided within this message itself.
"Alexander Larian" Date: March 27, 2025 3:41:00 PM Subject: Judge Allan Goodman from ADR Reply to list Reply to sender Print List: caala-workproduct Sent by: Alexander Larian (Reply Privately) Search Mates, Defense is proposing Goodman as arbitrator for a Lyft UM case. Thoughts on him?
AI Analysis:
Paul Goodman is mentioned by name in the context of a panel selection discussion for a Southern California workers' compensation case. The message indicates Goodman was 'struck by da' (struck by the defense attorney), which provides limited but meaningful information — it suggests the defense found Goodman unfavorable, potentially implying he may be perceived as more applicant/claimant-friendly. However, the message contains no direct discussion of his rulings, demeanor, or case management style, making the information limited in scope for a full evaluation.
Danny Keiller Alexander Sparkuhl Jason Phillips (struck by da) Strike Keiller or Sparkuhl? both setting timely. Geoffrey Smith Robert Ruder Paul Goodman(struck by da). Strike Smith or Ruder? both setting timely I appreciate your assistance. Ibrahim Ellahib Anaheim
AI Analysis:
The message explicitly mentions 'Paul Goodman' by name in the context of a workers' compensation case (denied hearing loss). The attorney is asking for a comparative evaluation of Goodman versus a medical evaluator (Steven Burres ENT), indicating they are considering striking one of them. This implies Goodman is a judge or QME being evaluated for a specific case type. However, the message contains no substantive information *about* Goodman's rulings, demeanor, or tendencies — it is soliciting that information rather than providing it. The value for judge evaluation is limited but the name is clearly referenced in a relevant legal context, making it marginally useful as a signal that attorneys are uncertain about Goodman's favorability in hearing loss cases.
I see little and somewhat conflicting info on the above. Who is better for a denied hearing loss case? Client worked for same employer for at least a decade.
AI Analysis:
The message is completely empty — no sender, no subject, and no body content. There is no information about Judge Goodman or any other judge, making it entirely irrelevant for evaluation purposes.
Goodman is odd but applicant oriented
AI Analysis:
The message is completely empty — no sender, no subject, and no body content. There is no information about Judge Goodman or any other judge, making it entirely irrelevant for evaluation purposes.
AI Analysis:
The message is completely empty — no sender, no subject, and no body content. There is no information whatsoever about Judge Goodman or any other judge, making it entirely irrelevant for evaluation purposes.
AI Analysis:
The message is completely empty — no sender, no subject, and no body content. There is no information whatsoever about Judge Goodman or any other judge, making it entirely irrelevant for evaluation purposes.
AI Analysis:
This message does not mention Judge Goodman at all. It is a discussion among civil attorneys (CAALA listserv) about a probate/personal injury matter involving a deceased defendant with an open insurance policy. The message references a probate attorney named Karen Krause, attorney Ben Siminou, and a Court of Appeal opinion, but contains no reference to Judge Goodman or any workers' compensation proceedings. The content is entirely unrelated to evaluating Judge Goodman.
"Greg Jackson" Date: July 15, 2026 9:28:00 AM Subject: Re: Deceased Defendant (driver) with Open Policy Reply to list Reply to sender Print Attachments: 2024.12.30 b319906 opinion.pdf (268 K) List: caala-workproduct Sent by: Gregory Jackson (Reply Privately) Search Karen Krause was our probate attorney on a matter like this. Defendant died just before trial on an open policy. It went up to the Court of Appeal but we won (shout out to Ben Siminou) on the issue of ‘does a 998 that expired prior to the defendant’s death also apply to the administrator of the estate’. If she wasn’t familiar before, she certainly became familiar. She was very professional and easy to work with, did not overbill/create busy work on her end, knew what we needed her to do was get the probate court to appoint an administrator (no family members of decedent in our case), and then just keep that probate case open while we worked through trial and then appeals. So it does not kill your open policy argument. You DO need to Doe in the personal representative/administrator of the estate of decedent. I’ve attached the opinion from the Court of Appeal for reference. Greg Jackson Partner and Managing Attorney The Simon Law Group p : (855) 855-8910 f : (310) 914-5401 m : (714) 617-2180 a : 2916 W 164th Street Torrance CA 90504 w : www.JusticeTeam.com e : greg@justiceteam.com Orange County | Los Angeles | Arizona | Texas This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of the company. Finally, the recipient should check this email and any attachments for the presence of viruses. The company accepts no liability for any damage caused by any virus transmitted by this email. From: Marilyn Smith (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Tuesday, July 14, 2026 4:59 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re: [caala-workproduct] Deceased Defendant (driver) with Open Policy List: caala-workproduct Sent by: Marilyn Smith (Reply Privately) Search There’s a way to clawback property transferred with the fraudulent intent to thwart creditors. Tougher to do before judgment, but could be possible if can show aware of potential judgment amount (or even just the seriousness of damages). Marilyn M. Smith Marilyn Smith Law APC 301 E. Colorado Blvd., Suite 620 Pasadena, CA 91101 V: 626-683-8102 www.marilynsmithlaw.com This email does not constitute particularlized legal advice and is intended for informational or work product discussion purposes within a closed listserve. It is not to be distributed outside of the CAALA Listserve. This email address is used only for Listserve purposes. To contact me directly, please send an email to Marilyn@Loomms.com . From: Isaac Toveg (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Tuesday, July 14, 2026 4:25 PM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: Re: [caala-workproduct] Deceased Defendant (driver) with Open Policy List: caala-workproduct Sent by: Isaac Toveg (Reply Privately) Search If there is no probate as decedent quitclaim all of his real property just a few days prior to his death and his attorney claims that there is no property so no probate. Further, this decedent may have faked his own death! His attorney claims no carriers are involved and suddenly now has alzheimers. Isaac Toveg On Tuesday, July 14, 2026 at 04:17:45 PM PDT, Marilyn Smith (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: Marilyn Smith (Reply Privately) Search You don’t “open a probate”, you file a creditor’s claim IN probate. Must do it within one year of death or you are barred. It’s all judicial council forms, but of course you file (and pay filing fees) because it’s a new matter. By the filing the claim, you set your PI client up to be the administrator of the estate. That usually gets the real heirs to show up and take over the case. Whether they do or not, you’ve still preserved your right to go after estate assets to satisfy any judgment or settlement that is in excess of the policy. You’re right, most probate attorneys have not had to deal with this. But they should know about presenting a creditor’s claim within a limited time period. This is just another form of that. Marilyn M. Smith Marilyn Smith Law APC 301 E. Colorado Blvd., Suite 620 Pasadena, CA 91101 V: 626-683-8102 www.marilynsmithlaw.com This email does not constitute particularlized legal advice and is intended for informational or work product discussion purposes within a closed listserve. It is not to be distributed outside of the CAALA Listserve. This email address is used only for Listserve purposes. To contact me directly, please send an email to Marilyn@Loomms.com . From: Jack Timourian (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Tuesday, July 14, 2026 3:54 PM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: [caala-workproduct] Deceased Defendant (driver) with Open Policy List: caala-workproduct Sent by: Jack Timourian (Reply Privately) Search Does anyone have insight they would be willing to share on this issue? Deceased Defendant with an open policy. I know if I go the "estate of XX, deceased" route, I would be able to serve the insurance carrier, but this would cap recovery to the policy limits. Does anyone know of an attorney who can point me the right direction or a probate attorney who can assist with opening an estate? I have contacted a few probate attorneys, but none of them really understand the intricacy between personal injury and the need to open an estate (most think I represent the decedent, even after telling them I represent a plaintiff in a personal injury action against the decedent). Thanks in advance. CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
AI Analysis:
This message does not mention Judge Goodman at all. It is entirely about a letter with 264 signatories related to neuropsychological DME raw data and recusal issues, and contains a list of neuropsychologists with their contact information. There is no reference to Judge Goodman, their rulings, courtroom behavior, or any cases before them.
"Jennifer Bagosy" Date: February 28, 2026 12:08:00 PM Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal Reply to list Reply to sender Print Attachments: exhibit a. collective statement regarding with signers as of 2025.06.23 (002).pdf (6535 K) List: caala-workproduct Sent by: Jennifer Bagosy (Reply Privately) Search I was just sent a version of the letter from June 2025. They are up to 264 signatories (!!) Letter attached. I asked my assistant to make a list without realizing how many there were now: 1. Catherine Marreiro, PhD - 533 Airport Boulevard, Suite 400, Burlingame, CA 94010, 650-770-2224 2. Kyle Boone, Ph D, ABPP-ABCN 24564 Hawthorne Blvd., Suite 208 Hillside Village, Building B Torrance, California 90505 Email: kylebboone@gmail.com 3. William McMullen, Ph.D., ABPP-CN Van Ness Campus Medical Office Building 1100 Van Ness Avenue Floor 6 San Francisco, CA 94109 Get Directions 415-600-7886 4. Delia Silva, Psy.D., ABPP-CN Main Office Location (By appointment only) 3990 Old Town Avenue, Suite C-303 San Diego, CA 92110 Contact Information Phone (858) 964-0722 Fax (866) 437-0375 Email Address Office@neuropacific.com 5. Dr. Lauren Drag, PhD, ABPP-CN, Silicon Valley Assessment, 15100 Los Gatos Boulevard, Ste 3, Los Gatos, CA, 95032, United StatesPh (408) 827-5699 Fax (855) 557-8583info@svassessment.com 6. Dr. Maya Yutsis, PhD, ABPP-CN, Silicon Valley Assessment, 15100 Los Gatos Boulevard, Ste 3, Los Gatos, CA, 95032, United StatesPh (408) 827-5699 Fax (855) 557-8583info@svassessment.com 7. Katherine Kruser, PsyD, QME Kruser@SacNeuropsychology.com 10419 Old Placerville Road, Suite 252 Sacramento, CA 95827 8. Jeffrey C. Wertheimer, PhD, ABPP-CN, Cedars-Sinai Neuropsychology - Outpatient Adults 8700 Beverly Blvd, North Tower, Suite 7215, Los Angeles, CA 90048 9. Jay Rosen, PhD - (424) 391-3670 10. Michelle Zeller, Psy.D., ABPP-CN, Our Locations • Los Angeles: 5805 Sepulveda Blvd ste 850, Los Angeles, CA 91411 • Century City: 2080 Century Park East, Suite 1409 Los Angeles, CA 90067 • Torrance: 22330 Hawthorne Blvd, Ste 213, Torrance, CA 90505 11. Deborah Cahn-Weiner, Ph.D., ABPP-CN - No info 12. Mi-Yeoung Jo, PsyD, ABPP-CN, (866) 518-3940 13. Talin Babikian, PhD, ABPP-CN, 2403 Perkins Ln, Redondo Beach, CA 90278 18161 Patronella Ave, Torrance, CA 90504 14. Molly Memel, PhD, ABPP-CN, - no info 15. Rebecca Goodman, PhD, ABPP-CN 5266 Hollister Avenue Building A Suite 104 (ground floor) Goleta CA 93111 Phone: (805) 699-5810 Fax: (805) 824-0733 16. Haygoush Kalinian, PhD Coastal Neuropsychology & Concussion Specialists 30320 Rancho Viejo Rd #102, San Juan Capistrano, CA 92675 (949) 481-8414 17. Robert M. Bilder, PhD, ABPP-CN - (949)-461-2620 18. Robert Gray, PhD, ABPP-CN - (424) 391-3670 19. Amir Ramezani, PhD - 24/7 Support: 1-877-509-1138 20. Leah Ellenberg, Ph. D., ABPP-CN - 9401 Wilshire Blvd, #730 Beverly Hills, CA 90212, leahellenberg@gmail.com 21. Charles Filanosky, PhD, ABPP-RP - 3452 E Foothill Blvd, Ste 518 Pasadena, CA 91107, (626) 988-6442, office@huntingtonpsych.com 22. Po-Haong Lu, PsyD - 626-298-7159; 595 E Colorado Blvd Ste 205 Pasadena, CA 91101, USA 23. Angela Eastvold, PhD, ABPP-CN - 120 Birmingham Drive Suite 110-A San Diego, CA 92007 United States - angela@angelaeastvoldphd.com 760-420-2640 24. Maura Mitrushina, Ph.D., ABPP-CN - 855-398-1007 25. Ann Gottuso, PhD, ABPP-CN - 2001 S Barrington Ave, Suite 2;15, West Los Angeles, CA 90025; care@lifethreadstherapy.com ; (310) 873-3319 26. Gayle Deutsch, PhD, ABPP-CN - roger@partnersforlifetherapy.com roger@partnersforlifetherapy.com 27. Simon Tan PsyD, ABPP-CN - (650) 723-7181 28. Ernest T. Bryant, Ph D, ABPP-CN - (424) 391-3670 29. Andrew Levine, PhD, ABPP-CN - 592 14th Street, Arcata, CA 95521; 707-595-7997; ajlevine@north-coast-neuropsych.com 30. John Wager, PhD, ABPP-CN - (650) 687-7322; drjohnwager@gmail.com 31. Dominique Kinney, PhD, ABPP-CN - experts@arrowheadeval.com; 888-888-5902 32. Brandon Kopald, Psy.D., ABPP-CN - 400 Parnassus Avenue, #001, San Francisco CA 94117; profiles@ucsf.edu 33. Frederick Hives II, PhD, ABPP-CN - (323) 813-6218 34. Lars Hungerford, PhD, ABPP-CN - 18553981007 35. Karen L. Schiltz, PhD Neuropsychologist - Golden State Neuropsychology 4764 Park Granada, Suite 101 Calabasas, CA 91302 Phone: (805) 379-4939 36. Tara L. Victor, PhD, ABPP-CN - 760 Westwood Plaza, Los Angeles, CA 90095 37. Shelley Peery, PhD - 833 Market Street, Suite 809 San Francisco, CA 94103 38. Karen Lau, PhD, ABPP-CN - 2211 Post Street, Suite 300 ' San Francisco, CA 94115 ' karen@drkarenlauphd.com ' (650) 503-4773 39. Robert Tomaszewski, PhD, ABPP-CN - Neuropsychological Rehabilitation Center 21053 Devonshire Street, Suite 101 Chatsworth, California 91311 ; Tel: (818) 886-7222 40. David M. Lechuga, PhD, ABPP, ABN - 13 Orchard Road, Suite 103, Lake Forest, California, 92630 USA 41. Dana Chidekel, PhD, ABN, ABPdN - drdanac@drdanac.com ' (818) 705-4305 42. William D. Hooker, Ph.D., ABN - Northern California Neuropsychology Forum, 3145 Geary Blvd., #451, San Francisco, CA 94118 43. Dale Sherman, PhD, QME - 323.839.7231 44. June Paltzer, PhD, ABPP-CN - (916) 801-7372; 3511 Del Paso Rd., Ste. 160-344, Sacramento, CA 95835. Offices in San Francisco and Sacramento. 45. Karen Earnest, PhD, ABPP-CN - 122 A E. Foothill Blvd., # 415, Arcadia, CA 91006; ke@karenearnestphd.com ; (626) 975-7635 46. John Bellone, PhD, ABPP-CN - 1440 North Harbor Boulevard, Suite 255, Fullerton, CA 92835, (657) 221-1088 47. Erin Green-Krogmann, PhD, ABPP-CN - erin.r.green@gmail.com; 925.938.5252 48. Virginia Zuverza-Chavarria, PhD, ABPP-CN - 700 Mount Vernon Avenu, Bakersfield, CA 93306, 661.326.2000 49. Kimberly Lanni, PhD, ABPP - info@refine-psychiatry.com 50. Mark Alfano, PhDABPP CN, RP - 855-398-1007 51. Steve Nitch, Ph. D., ABPP-CN - admissions@barnlifellc.com; (714) 597-6931 52. Kristina Agbayani, PhD, ABPP-CN - (949)-461-2620 53. Andrew L. Wong, PhD, ABPP-CN - 8700 Beverly Blvd., Los Angeles, CA 90048, 1-800-CEDARS-1 54. Jessica Foley, PhD, ABPP-CN - (415) 353-2057 55. Andrew Dean, Ph. D., ABPP-CN - (866) 518-3940 56. Allison R. Kaup, PhD, ABPP-CN - 655 Redwood Hwy, Suite 240, Mill Valley, CA; (866) 247-4292; info@segaltelenet.com 57. Mark W. Bondi, PhD, ABPP-CN - 3350 La Jolla Village Drive, San Diego, CA 92161-0002, 858-552-8585 58. Jose M. Lafosse, Ph.D., ABPP-CN - (866) 757-6975 59. Hayley Kristinsson, PhD, ABPP-CN - 714-456-7720 60. Philip Sayegh, PhD, MPH - 1150 South Robertson Blvd, Los Angeles, CA 90035, 424.333.4551 61. Sara Mason, PsyD - 2001 S Barrington Ave, Suite 215, West Los Angeles, CA 90025; care@lifethreadstherapy.com; (310) 873-3319 62. Kimberly Miller, PhD, ABPP-CN - brainpower@bpwimh.com 63. Michael H. Kabat, Ph.D., ABPP-CN - 949.891.2468; jessica@oc-traumatherapy.com 64. Brigid Rose, PhD, ABPP-CN - support@mentalhealthpractitioners.com; 4159686515 65. Roger Light, PhD, ABPP-CN - 21515 Hawthorne Blvd., Suite 1083, Torrance, CA 90503; drrogerlight@thelightcentersouthbay.com 66. Jeremy Jinkerson, PhD - 3465 Camino del Rio South, Suite 320, San Diego, CA 92108-3909; allen@malesurvivortherapy.com 67. David D. O'Grady, Ph.D., ABPP-CN - 1150 South Robertson Blvd., Los Angeles, CA 90035; 424.333.4551 68. Anneliese Radke, Psy.D., ABPP-CN - info@lifeadjustmentteam.com 69. Joanne M. Hamilton, ABPP-CN - 9968 Hibert Street Suite 105 San Diego CA 92131; frontdesk@adultanhsocal.com 70. Travis G. Fogel, PhD., ABPP-CN - (909) 558-6488 71. Sarah Tomaszewski Farias, PhD, ABPP-CN - No info available. 72. Allyson C. Rosen, PhD, ABPP-CN - (650) 723-2300 73. Sabine Gysens, PhD - (415) 613-9290 74. George Kahle Henry, PhD, ABPP-CN - (949) 461-2620 75. Kirsty Bortnik, PhD, ABPP-CN - (310) 582-7640 76. Joelle Broffman, PsyD, ABPP-CN - admissions@barnlifellc.com 77. Kristin K. Jacobson, PsyD, ABPP-CN - (323) 813-6218 78. Alice Ruzicka, PhD, ABN - office@huntingtonpsych.com 79. Renee Low, Ph D, ABN - (855) 769-2898 80. Stacy S. Wilkins, PhD, ABPP/CN - UCLAProfiles@mednet.ucla.edu UCLAProfiles@mednet.ucla.edu 81. Christine M. Naber, PhD - Connect@HeimbergNP.com 82. Aura Barragan, Psy.D - info@amfmhealthcare.com 83. Richard L. Delmonico, PhD - (707) 651-1044 84. Lauren Bennett, PhD, ABPP-CN - care@ketamineuplift.com 85. William J. Lynch, PhD, ABPP/CN - (424) 835-99610 86. Rujvi Kamat, PhD, ABPP-CN - 1 (800) 526-7736 87. Carrie R. McDonald, PhD, ABPP-CN - (855) 769-2898 88. Nancy A. Blum, PhD. - (818) 996-7579 89. Krista Freece, PhD, ABN - (949) 461-2620 90. Howard Glidden, PhD, ABN - (866) 707-5893 91. Travis Shivley-Scott, PhD - (424) 835-9960 92. Karen Mikolic, PhD, ABN - hello@mychildassessment.com; (310) 622-4453 93. Talia Seider, PhD, ABPP-CN - support@empowertherapyandcoaching.com 94. Heather Pedersen, PhD, ABPP-CN - info@refine-psychiatry.com 95. Michael DeBellis, PsyD, ABN - mikedebellis@mac.com 96. Nicholas Thaler, PhD, ABPP-CN - 2403 Perkins Ln, Redondo Beach, CA 90278 ; 18161 Patronella Ave, Torrance, CA 90504;424) 433-2424 97. Caroline J. Grantz, PhD - care@personalpractitioners.com 98. Michael DeBillis, PsyD, ABN - 520 S. Sepulveda Blvd. Suite 306, Los Angeles, CA 90049; admin@alignonlinetherapy.com admin@alignonlinetherapy.com 99. Nicholas Thaler, PhD, ABPP-CN - (855) 769-2898 100. Caroline J. Grantz, PHD - (866) 707-5893 101. Phillip K. Stenquist, PhD, ABPP-CN - info@segaltelenet.com 102. Brian Yochim, PhD, ABPP-CN - Brian.Yochim@va.gov 103. Olivia Harner, PhD, ABPP - (949) 461-2620 104. David Anderson, PhD, ABPP-CN/CI - (323) 813-6218 105. Alexis D. Kulick, PhD, ABPP - Bodyandsoulhealthcenter@gmail.com 106. Lori Holt, PHD, ABPP-CN - info@neuroscience.la; 13108551265 107. Joel S. Eppig, Ph.D. - ctri-support@ucsd.edu ctri-support@ucsd.edu 108. Delany Thrasher, PhD, ABPP-CN - info@sawtellepsych.com; (323) 886-5426 109. Anne Reader Murray, PhD, ABPP-CN - (866) 707-5893 110. Jeffrey M. Lulow, PhD - (818) 789-6689 111. Kaitlen B. Casaletto, PhD, ABPP-CN - kaitlin.casaletto@ucsf.edu 112. Alexandra Apple, PhD - (415) 476-7000 113. Hope Goldberg, PhD, ABPP-CN - info@mfcmedical.com; (310) 935-0170 114. William C. Hochberger, PhD, ABPP-CN - frontdesk@adultanhsocal.com; 9968 Hibert Street Suite 105 San Diego CA 92131 115. Paul Mangal, PhD - office@huntingtonpsych.com;16265346523 116. Virdette L. Brumm, Ph.D - Montage Health, 23625 Holman Highway, Monterey, CA 93940 (831) 624-5311 117. Christy Hom, PhD, ABPdN - (714) 456-7890 118. Eric J. Freitag, PsyD, FACPN - info@amfmhealthcare.com; 949-421-6977 119. Howard J. Friedman, ABPP (CN), ABN - californiapsychological@gmail.com 120. Jonathan E. Romain, PhD, MS, ABPP-CN - admissions@barnlifellc.com 121. Patricia Gross, PhD, ABPP-CN - care@personalpractitioners.com; 4159686515 122. Katie Denny PhD, ABPP-CN - (855) 618-0425 123. Katherine Bangen, PhD, ABPP-CN - (888) 447-2996 124. Lisa Graves, PhD - no info 125. John Knippa, PhD, ABN - (877) 686-3622 126. Ashley K. Miller, PhD, ABPP-CN - info@aspireneuropsych.com; 2815 Mitchell Drive, Suite 119 (we are located in Building 2), Walnut Creek, CA 94598, 925.885.6070 127. Karen Hanson Bondi, PhD - 3452 E Foothill Blvd, Ste 518, Pasadena, CA 91107; office@huntingtonpsych.com; (626) 534-6449 128. Lori Alasantro, PhD, ABPP-CN - drchester@chesterneuropsych.com; (310) 218-5001 129. Amanda Gooding, PhD, ABPP-CN - (866) 707-5893 130. Anita Herrera-Hamilton, Ph.D ABPP - admissions@barnlifellc.com; 7145976931 131. Caitlin Moore, PhD, ABPP - 100 Shoreline Highway, Building B, #100; help@californiabrainhealth.com ; 415-877-4408 132. William Britt, PhD, ABN - (877) 558-6248 133. Janet K. Brewer, JD, PsyD - (310) 553-6704 134. Mimi Wong, PhD, ABPP-CN - (805) 719-7896 135. Charles Furst, PhD, ABPP-CN - drfurst@gmail.com 136. Dawn A. Osterweil, PhD, ABPP - LAneuropsychgrp@gmail.com 137. Robert W. Elliott, PhD, ABCN, ABN - drbobusc@gmail.com 138. Amy M. Schonfeld, PhD, Clinical Neuropsychologist - 32420 Pacific Coast Highway, Malibu, CA 90265 139. Duke Han, PhD, ABPP-CN - dukehan@usc.edu 140. Lisa Delano-Wood, PhD - ctri-support@ucsd.edu ctri-support@ucsd.edu 141. Kimberly Alfano, PhD, ABPP (CN, RP) - dralfanoabpp@yahoo.com 142. Alena Stasenko, PhD - ctri-support@ucsd.edu ctri-support@ucsd.edu 143. Inna Fishman, PhD - ifishman@sdsu.edu 144. Annette Swain, PhD, ABPP-CN - (818) 385-0913 145. Monica Smith, PhD, ABN - (209) 208-8024 146. Mili Parikh, PhD, ABPP - (858) 946-5059 147. Margaret A. Donohue, PhD. - (619) 213-300 148. Charles H. Hinkin, Ph.D., ABPP-CN - drchester@chesterneuropsych.com 149. R. Dempsey, PsyD, ABPP, QME - admin@soundmedeval.com 150. Samantha O'Bannon, PsyD - marissa@mhonjiyotherapy.com 151. Robert A. Beatty, JD, PhD, ABPP - ask@beattey.org 152. William T. J. Johnson, PhD, ABPP-CN - (866) 707-5893 153. Tony L. Strickland, MS, PhD, ABN, FNAN - (310) 642-9595 154. Emmanuel A. Zamora, PsyD - (800) 282-3284 155. Joshua McKeever, PhD - 415-877-4408; help@californiabrainhealth.com 156. Carmen C. Velazquez, Ph.D. - no info 157. Anne Nolty, PhD, ABPP-CN - admissions@fuller.edu 158. Grace Mucci, PhD, ABPdN - (323) 813-6218 159. Tom Kiely, PhD - tomkielyphd@gmail.com 160. Joel Kramer, PsyD, ABPP-CN - (323) 813-6218 161. Andrea Alioto, PhD, ABPP-CN - (408) 530-6900 162. Johanna Rengifo, PhD - (415) 600-5555 163. Ruth Serepca, PhD - info@php.com 164. Abigail Kramer, PhD - (323) 813-6218 165. Sarah Banks, PhD, ABPP-CN - 858-657-8540 166. Arnold D. Purisch, PhD, ABPP-CN, ABN - apurisch@gmail.com; (949)829-8141 167. Yuri Rassovsky, PhD, ABPP-CN - admissions@barnlifellc.com 168. Lauren Keats, PsyD - relatetherapycenter@gmail.com 169. Saskia DeVaughn, PhD, ABPP-CN - (833) 277-0071 170. Katie Beckwith, PhD, ABPP-CN - admissions@casapacifica.org 171. Christian Carter, PhD, ABPP-CN - (619) 532-6400 172. Ashley Whitaker, PhD, ABPP-CN - (602) 933-5437 173. Melissa Balderrama, PsyD, ABPP - (424) 433-2424 174. Garima Lupas, PhD, ABPP - info@refine-psychiatry.com 175. James A. Moses, PhD, ABPP-CN - 445 Burgess Dr, Menlo Park, CA, 94025 176. Bianca Georgecu, PsyD, ABPP - (888) 313-2244 177. Brandon Gavett, Ph.D. ABPP-CN - Connect@HeimbergNP.com 178. April Thames, PhD - drchester@chesterneuropsych.com 179. Michelle Conover, Ph.D., QME - mailto:admin@soundmedeval.com 180. Daniel Jacobson, PhD, ABPP-CN - 865.576.7658 181. Carlos Saucedo, PhD, ABPP-CN - info@aspireneuropsych.com 182. Sharon H. O'Neil, PhD, ABPP-CN - 4650 Sunset Blvd., Los Angeles, CA 90027, 323-660-2450 183. Audrey Khatchikia, PhD - 100 N. Brand Blvd., Suite 606, Glendale, CA 91203 (818) 476-0066 184. Natalie C. Kelly, PhD, ABPP-CN - info@stepwiseneuro.com; 909-258-4943 185. Shital Pavawalla, Ph.D., ABPP-CN - mary@marybtherapy.com; (310) 946-0600 186. Alexander Tan, PhD, ABPP-CN - 1120 W. La Veta Ave., Suite 470; Orange, CA 92868; 714-650-8383 187. Phuong M. Chau, PhD, ABPP-CN - 8700 Beverly Blvd. Los Angeles, CA 90048; 1-800-CEDARS-1 188. Deborah Budding, Ph.D., ABN - 2309 Pacific Coast Hwy, Suite 208, Hermosa Beach, California 90254 ph - 310-792-8146 189. J. Brandon Birath, PhD, ABPP-CN - no info 190. Robert A. Leark, PhD. - 866-492-5336 191. Edgar Angelone, PhD, ABPN, ABAP, IQEEGB - info@marinneuropsychology.com; (415) 457-3451 192. Robert Geffner, PhD, ABPP, ABN - bgeffner@alliant.edu bgeffner@alliant.edu 183. Tatyana Jones, Ph.D. - 7601 Imperial Hwy, Downey, CA 90242; (562) 401-8192 184. Stephen E. Francis, Ph.D. ABN FACPN - (323) 813-6218 185. David Franklin, PsyD., MHA. ABN - (562) 784-0487 186. Natalie Wager, PsyD, ABPdN - info@refine-psychiatry.com info@refine-psychiatry.com 187. Jayme Neiman-Kimel, Ph.D., ABPdN - (310) 209-4994 188. Sharon Perlman Berry, PsyD, ABN - drperlmanberry@gmail.com 189. Sarah Borish, Ph.D., Ed.M. - info@bayareacognitivehealth.com 190. Michelle McDonnell, Ph.D. - 909-558-1900' 191. Ann Simun, PsyD - (310) 478-8888 192. Vanesa Zizak, PhD ABPP-CN - (949) 743-1457 193. Alexis Smith, Psy.D., CA 28050 - (925) 324-159 194. KATRINA KEIL, PHD - (909) 621-8617 195. JENNIFER SUMNER, PHD - jsumner@psych.ucla.edu 196. Shannon J. Curry, PsyD, MSCP - info@aspireneuropsych.com 197. Sean Brannon, PhD, ABN - 909-425-7679 198. Ni Sun-Suslow, PhD - admin@neuropsychinstitute.org 199. Dean Delis, PhD, ABPP-CN - (323) 813-6218 200. Susan Woolley Katz, PhD, ABPP-CN - No info 201. Michelle Madore, PhD - mmadore@stanford.edu 202. Ellen Woo, PhD, ABPP-CN - ewoo@csufresno.edu 203. Loren Carillo King, PhD, ABPP-CN - allen@malesurvivortherapy.com 204. Bal S. Grewal, PhD, QME - info@sawtellepsych.com 205. Jeremy Blank, PsyD - (562) 784-0487 206. Shaul M. Saddick, PhD - 858 455-6587 207. Julien Guillaumot, PhD - (760) 444-4755 208. Linda Nelson, PhD, ABN - (310) 458-4581 209. Tammy Grabeck, PhD - (323) 813-6218 210. Ariati S. Rakic, Ph.D. - (925) 389-6723 211. Larry Wornian, PhD - LWornian@aol.com; 925-833-3603 212. Carla Back-Madruga, PhD - (323) 813-6218 213. Erika Mozer, PsyD - (650) 704-5376 214. Joy G. Nichols, PhD - 9096511899 215. Vindia G. Fernandez, PhD - (424) 255-6388 216. Anh Phuong Ha, PhD - 4158774408 217. Dov Gold, Psy.D. - info@refine-psychiatry.com 218. Jeffrey Kline, PhD, ABPP - (650) 329-8904 219. Rayna Hirst, PhD - rhirst@paloaltou.edu 220. J. Vincent Filotco, PhD - (858) 534-1213 221. Roxanna Farinpour, PhD - (760) 200-0688 222. Richard J. Perrillo, Ph.D - (310) 858-0379 223. Margaret Ellenora Wiggins, Ph.D. - info@refine-psychiatry.com 224. Lynn Warner Ph.D. - (518) 442-3300 225. Nina Rudnick, PsyD - 4243334551 226. Paola Suarez, PhD - support@empowertherapyandcoaching.com 227. Fernando Gonzalez, PHD, ABpp (RP) - nfo@phwcare.com 228. Arpi Minassian, PhD. - 8888977509 229. Grahamm Wiest, Psy.D - care@ketamineuplift.com 230. Natalie Kurniadi, PhD - admissions@fielding.edu 231. Rinku Lalchandani, PhD, ABPP - (831) 264-8081 232. Miriam Krumholz, PsyD - (888)6629378 233. Nora Elizabeth Jimenez, PhD - (866) 393-6491 234. Einat Brenner, PhD, - (858) 657-8540 235. Mark Mapstone, PhD - mark.mapstone@uci.edu; (949) 824-7184 236. Leslie Hall, PhD - (510) 282-8735 237. Elizabeth Choi, PhD - support@empowertherapyandcoaching.com 238. Randall C. Epperson, PhD, ABPP/CN, ABN - 3236967962; californiapsychological@gmail.com 239. Carrie Thaler, PhD - carriethaler@earthlink.net 240. Julia Nunan-Saah, PhD - drchester@chesterneuropsych.com 241. Aida Saldivar, Ph.D., ABPP, QME - 805-719-7896 242. Nancy Elisabeth Sullivan, PhD, PSY15181 - 310-800-7112 243. Zahra Sattaur, Psy.D - 8772794461 244. Tania Abouezzeddine PSY25118 - No info 245. Elizabeth W Twamley, PhD - (619) 543-6684 246. Jillian Tessier, PhD - 8189459970 247. Ari Kalechstein, PhD - (310) 273-4843 248. Jill Razani, PhD - (562) 951-4000 249. Kimberley Rose, PhD - (916) 454-6847 250. Katherine Sellwood, ABPP - (818) 907-5491 251. Enrique Lopez, PsyD - .3(310) 423-2600 252. Lauren G. Mai, PsyD - 415-668-5998 253. Marc Norman, PhD, ABPP-CN - (619) 543-2827 254. Peter Van Oot, PhD - pvanoot@nu.edu 255. Deborah Anderson, PhD - 8182352158 256. Stephanie Chin Mammen, PsyD - 818-741-1119 257. Paul C. Lebby - (559) 353-3000 258. Kendall Maxwell, PhD - (310) 423-3933 259. K Wortman, PhD - (510) 485-0008 260. Jenna Axelrod, PhD, ABPP - (562) 999-4707 261. Jerry Chen, PhD, ABPP - 800-679-1730; admin@momentous-health.com 262. Khushnoo K. Indorewalla, PsyD, ABPP-CN - info@sawtellepsych.com 263. Kaitlyn Young Sciortino, PhD, ABPP-CN - (323)813-6218 264. Meena Saleh, PhD - (510) 255-3552 -----Original Message----- From: greg@justiceteam.com Sent: February 26, 2026 9:33:00 AM To: caala-workproduct@lists.trialsmith.com Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal Here's a Burbank order granting the raw data/audio subject to PO, but not Judge Arian [cid:slg_oca_emailsignature_4s_1x1_v1_fc31d3c0-b93d-4153-a0d5-cad733aff375.gif] Greg Jackson Partner and Managing Attorney The Simon Law Group p: (855) 855-8910 f: (310) 914-5401 m: (714) 617-2180 a: 2916 W 164th Street Torrance CA 90504 w: www.JusticeTeam.com e: greg@justiceteam.com<mailto:%7BE-mail%7D> Orange County ' Los Angeles ' Arizona ' Texas <https://www.facebook.com/TheSimonLawGroup> [cid:instagram_32x32_3473fb9a-cef8-4bd0-89b9-ebad3ae209f4.png]<https://www.instagram.com/thesimonlawgroup> [cid:facebook_32x32_22f3b732-9ee9-4be2-89af-5f59b15a773c.png] <https://www.facebook.com/TheSimonLawGroup> [cid:linkedin_32x32_2f01fc51-e68d-4f7e-a219-1ce2be0d0f5e.png] <https://www.linkedin.com/company/the-simon-law-group> [cid:podcast-7858222_640_3b7e9899-d89c-4e5d-92d6-940be75f7bd5.png] <https://justiceteampodcast.com/> [cid:linktree_21c8e52f-1f37-476a-bbec-61b73bbfeb66.jpg] <https://linktr.ee/JusticeTeam> This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of the company. Finally, the recipient should check this email and any attachments for the presence of viruses. The company accepts no liability for any damage caused by any virus transmitted by this email. From: Karen Jacobs (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Wednesday, February 25, 2026 5:48 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re:[caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Karen Jacobs (Reply Privately)<mailto:kjacobs@jacobslawfirm.net?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> Search<http://www.caala.org/index.cfm?pg=search> Has anyone attempted to compel production of raw data in Burbank, Dept B, Judge Lee Arian? Any indication on how he's likely to rule? -----Original Message----- From: ssh@habbaspilaw.com<mailto:ssh@habbaspilaw.com> Sent: February 20, 2026 4:23:00 PM To: caala-workproduct@lists.trialsmith.com<mailto:caala-workproduct@lists.trialsmith.com> Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal We just had Boone compelled to produce raw data based on Randy's Trucking. Immediately after she withdrew and the defense has yet to request a new one. Keep filing on this issue. Samer Habbas LAW OFFICES OF SAMER HABBAS 200 Spectrum Center Drive Suite 1230 Irvine, CA 92618 Tel: (949) 727-9300 Fax: (949) 727-9308 ssh@habbaspilaw.com<mailto:ssh@habbaspilaw.com> www.habbaspilaw.com<http://www.habbaspilaw.com> This communication, including attachments, is confidential, may be subject to legal privileges, and is intended for the sole use of the addressee. Any use, duplication, disclosure or dissemination of this communication, other than by the addressee, is prohibited. If you have received this communication in error, please notify the sender immediately and delete or destroy this communication and all copies. On Fri, Feb 20, 2026 at 3:00 PM Jennifer Bagosy (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com<mailto:listsender-caala-workproduct@lists.trialsmith.com>> wrote: > *List:* caala-workproduct * Sent by:* Jennifer Bagosy (Reply Privately) > <jby@bhattorneys.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal<mailto:jby@bhattorneys.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal>> > Search <http://www.caala.org/index.cfm?pg=search> > Has anyone seen whether Dr. Christine Naber has ever produced raw data or > been ordered to? > > -----Original Message----- > > From: greg@justiceteam.com<mailto:greg@justiceteam.com> > Sent: February 09, 2026 3:33:00 PM > To: caala-workproduct@lists.trialsmith.com<mailto:caala-workproduct@lists.trialsmith.com> > Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal > > NICE, thank you Nareg!! I'll get this added to the Dropbox, I appreciate > the update and good luck with getting sanctions! > > > > > [cid:slg_oca_emailsignature_4s_1x1_v1_fc31d3c0-b93d-4153-a0d5-cad733aff375.gif] > Greg Jackson > Partner and Managing Attorney The Simon Law Group > > p: (855) 855-8910 f: (310) 914-5401 m: (714) 617-2180 > a: 2916 W 164th Street Torrance CA 90504 > <https://www.google.com/maps/search/2916+W+164th+Street+Torrance+CA+90504?entry=gmail&source=g> > w: www.JusticeTeam.com<http://www.JusticeTeam.com> e: greg@justiceteam.com<mailto:%7BE-mail%7D<mailto:greg@justiceteam.com%3cmailto:%7BE-mail%7D>> > Orange County ' Los Angeles ' Arizona ' Texas > > <https://www.facebook.com/TheSimonLawGroup> > [cid:instagram_32x32_3473fb9a-cef8-4bd0-89b9-ebad3ae209f4.png]< > https://www.instagram.com/thesimonlawgroup> > [cid:facebook_32x32_22f3b732-9ee9-4be2-89af-5f59b15a773c.png] < > https://www.facebook.com/TheSimonLawGroup> > [cid:linkedin_32x32_2f01fc51-e68d-4f7e-a219-1ce2be0d0f5e.png] < > https://www.linkedin.com/company/the-simon-law-group> > [cid:podcast-7858222_640_3b7e9899-d89c-4e5d-92d6-940be75f7bd5.png] < > https://justiceteampodcast.com/> > [cid:linktree_21c8e52f-1f37-476a-bbec-61b73bbfeb66.jpg] < > https://linktr.ee/JusticeTeam> > > > > This email and any files transmitted with it are confidential and intended > solely for the use of the individual or entity to whom they are addressed. > If you have received this email in error please notify the system manager. > Please note that any views or opinions presented in this email are solely > those of the author and do not necessarily represent those of the company. > Finally, the recipient should check this email and any attachments for the > presence of viruses. The company accepts no liability for any damage caused > by any virus transmitted by this email. > > > From: Nareg Kitsinian <nareg@kitsinianlaw.com<mailto:nareg@kitsinianlaw.com>> > Sent: Wednesday, February 4, 2026 2:29 PM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com<mailto:caala-workproduct@lists.trialsmith.com>> > Cc: Greg Jackson <greg@justiceteam.com<mailto:greg@justiceteam.com>> > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data > and Recusal > > Greg, > See attached, signed order, ordering Dr. Hungerford to produce raw data > etc. > Hungerford, did not recuse himself as he promised to do so in that > ridiculous declaration signed by other doctors. > > He did go through with the DME and interviewed my client after all, but > opted not to conduct his own testing and obtained the treating providers > raw data instead. I have asked that the raw data be turned over and OC > seems to think he is clever and is making the argument that the courts > order only applies if Hungerford did the testing. An ex parte to enforce > with sanctions is on its way. > > Please add the attached to your drop box. I'll let you know if Hungerford > sends us the raw data. > > > > > > > -- > > > [cid:image001.png@01DC99C8.7EA9ABF0][cid:image002.jpg@01DC99C8.7EA9ABF0] > > LATLC > > 2025 Secretary - 2029 President > > > Nareg S. Kitsinian, Esq. > Attorney at Law > > > nareg@kitsinianlaw.com<mailto:nareg@kitsinianlaw.com<mailto:nareg@kitsinianlaw.com%3cmailto:nareg@kitsinianlaw.com>> > > www.kitsinianlaw.com<https://www.kitsinianlaw.com/> > > > Tel: (818)786-5777 ' Fax: (818)786-5778 > > > 16501 Ventura Blvd., Ste. 506, Encino, CA 91436 > <https://www.google.com/maps/search/16501+Ventura+Blvd.,+Ste.+506,+Encino,+CA+91436?entry=gmail&source=g> > <https://maps.app.goo.gl/tGQhp8PaYVZQ2VQaA> > > > > [cid:image003.png@01DC99C8.7EA9ABF0] < > https://www.facebook.com/kitsinianlaw> [cid:image004.png@01DC99C8.7EA9ABF0] > <https://www.linkedin.com/company/kitsinian-law-firm> > [cid:image005.png@01DC99C8.7EA9ABF0] < > https://www.instagram.com/kitsinianlawfirm/> > > > > > > > > ________________________________ > From: Gregory Jackson (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com<mailto<mailto:listsender-caala-workproduct@lists.trialsmith.com%3cmailto>: > listsender-caala-workproduct@lists.trialsmith.com<mailto:listsender-caala-workproduct@lists.trialsmith.com>>> > Sent: Thursday, November 20, 2025 3:27 PM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com<mailto<mailto:caala-workproduct@lists.trialsmith.com%3cmailto>: > caala-workproduct@lists.trialsmith.com<mailto:caala-workproduct@lists.trialsmith.com>>> > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data > and Recusal > > List: caala-workproduct Sent by: Gregory Jackson (Reply Privately)<mailto: <mailto:%0b>> greg@justiceteam.com<mailto:greg@justiceteam.com> > ?subject=Re%3A%20%5Bcaala-workproduct%5D%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > > Search<http://www.caala.org/index.cfm?pg=search> > > > > > Added! > > > > > [cid:image006.gif@01DC99C8.7EA9ABF0] > > Greg Jackson > Partner and Managing Attorney The Simon Law Group > > p: (855) 855-8910 f: (310) 914-5401 m: (714) 617-2180 > a: 2916 W 164th Street Torrance CA 90504 > <https://www.google.com/maps/search/2916+W+164th+Street+Torrance+CA+90504?entry=gmail&source=g> > w: www.JusticeTeam.com<http://www.JusticeTeam.com> e: greg@justiceteam.com<mailto:greg@justiceteam.com> > <mailto:%7BE-mail%7D> > Orange County ' Los Angeles ' Arizona ' Texas > > > [cid:image007.png@01DC99C8.7EA9ABF0]< > https://www.instagram.com/thesimonlawgroup> > > [cid:image008.png@01DC99C8.7EA9ABF0]< > https://www.facebook.com/TheSimonLawGroup> > > [cid:image009.png@01DC99C8.7EA9ABF0]< > https://www.linkedin.com/company/the-simon-law-group> > > [cid:image010.png@01DC99C8.7EA9ABF0]<https://justiceteampodcast.com/> > > [cid:image011.jpg@01DC99C8.7EA9ABF0]<https://linktr.ee/JusticeTeam> > > > > > This email and any files transmitted with it are confidential and intended > solely for the use of the individual or entity to whom they are addressed. > If you have received this email in error please notify the system manager. > Please note that any views or opinions presented in this email are solely > those of the author and do not necessarily represent those of the company. > Finally, the recipient should check this email and any attachments for the > presence of viruses. The company accepts no liability for any damage caused > by any virus transmitted by this email. > > > > > From: Nareg Kitsinian (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com<mailto<mailto:listsender-caala-workproduct@lists.trialsmith.com%3cmailto>: > listsender-caala-workproduct@lists.trialsmith.com<mailto:listsender-caala-workproduct@lists.trialsmith.com>>> > Sent: Thursday, November 20, 2025 3:21 PM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com<mailto<mailto:caala-workproduct@lists.trialsmith.com%3cmailto>: > caala-workproduct@lists.trialsmith.com<mailto:caala-workproduct@lists.trialsmith.com>>> > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data > and Recusal > > > > List: caala-workproduct Sent by: Nareg Kitsinian (Reply Privately)<mailto: <mailto:%0b>> nareg@kitsinianlaw.com<mailto:nareg@kitsinianlaw.com> > ?subject=Re%3A%20%5Bcaala-workproduct%5D%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > > > Search<http://www.caala.org/index.cfm?pg=search> > > > > > > Greg, attached is our LASC minute order from 3/25 compelling Filoteo who > did produce. Please add to your folder. > > > > > > > > -- > > > [cid:image001.png@01DC99C8.7EA9ABF0][cid:image002.jpg@01DC99C8.7EA9ABF0] > > LATLC > > 2025 Secretary - 2029 President > > > Nareg S. Kitsinian, Esq. > Attorney at Law > > > nareg@kitsinianlaw.com<mailto:nareg@kitsinianlaw.com<mailto:nareg@kitsinianlaw.com%3cmailto:nareg@kitsinianlaw.com>> > > www.kitsinianlaw.com<https://www.kitsinianlaw.com/> > > > Tel: (818)786-5777 ' Fax: (818)786-5778 > > > 16501 Ventura Blvd., Ste. 506, Encino, CA 91436 > <https://www.google.com/maps/search/16501+Ventura+Blvd.,+Ste.+506,+Encino,+CA+91436?entry=gmail&source=g> > <https://maps.app.goo.gl/tGQhp8PaYVZQ2VQaA> > > > > [cid:image003.png@01DC99C8.7EA9ABF0] < > https://www.facebook.com/kitsinianlaw> [cid:image004.png@01DC99C8.7EA9ABF0] > <https://www.linkedin.com/company/kitsinian-law-firm> > [cid:image005.png@01DC99C8.7EA9ABF0] < > https://www.instagram.com/kitsinianlawfirm/> > > > > > > > > ________________________________ > > From: Gregory Jackson (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com<mailto<mailto:listsender-caala-workproduct@lists.trialsmith.com%3cmailto>: > listsender-caala-workproduct@lists.trialsmith.com<mailto:listsender-caala-workproduct@lists.trialsmith.com>>> > Sent: Thursday, November 20, 2025 3:01 PM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com<mailto<mailto:caala-workproduct@lists.trialsmith.com%3cmailto>: > caala-workproduct@lists.trialsmith.com<mailto:caala-workproduct@lists.trialsmith.com>>> > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data > and Recusal > > > > List: caala-workproduct Sent by: Gregory Jackson (Reply Privately)<mailto: <mailto:%0b>> greg@justiceteam.com<mailto:greg@justiceteam.com> > ?subject=Re%3A%20%5Bcaala-workproduct%5D%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > > > Search<http://www.caala.org/index.cfm?pg=search> > > > > > > No problem! You'll see specific subfolders for a number of experts, some > oppositions, lot of stuff in there to use. For that huge declaration > defense is listing now, a number of those experts who signed off on it have > actually produced raw data anyway - so you can use these minute orders and > stipulations in the Dropbox to impeach it. > > > > > > > [cid:image006.gif@01DC99C8.7EA9ABF0] > > > Greg Jackson > Partner and Managing Attorney The Simon Law Group > > > p: (855) 855-8910 f: (310) 914-5401 m: (714) 617-2180 > a: 2916 W 164th Street Torrance CA 90504 > <https://www.google.com/maps/search/2916+W+164th+Street+Torrance+CA+90504?entry=gmail&source=g> > w: www.JusticeTeam.com<http://www.JusticeTeam.com> e: greg@justiceteam.com<mailto:greg@justiceteam.com> > <mailto:%7BE-mail%7D> > Orange County ' Los Angeles ' Arizona ' Texas > > > > > [cid:image007.png@01DC99C8.7EA9ABF0]< > https://www.instagram.com/thesimonlawgroup> > > > [cid:image008.png@01DC99C8.7EA9ABF0]< > https://www.facebook.com/TheSimonLawGroup> > > > [cid:image009.png@01DC99C8.7EA9ABF0]< > https://www.linkedin.com/company/the-simon-law-group> > > > [cid:image010.png@01DC99C8.7EA9ABF0]<https://justiceteampodcast.com/> > > > [cid:image011.jpg@01DC99C8.7EA9ABF0]<https://linktr.ee/JusticeTeam> > > > > > > This email and any files transmitted with it are confidential and intended > solely for the use of the individual or entity to whom they are addressed. > If you have received this email in error please notify the system manager. > Please note that any views or opinions presented in this email are solely > those of the author and do not necessarily represent those of the company. > Finally, the recipient should check this email and any attachments for the > presence of viruses. The company accepts no liability for any damage caused > by any virus transmitted by this email. > > > > > From: Nareg Kitsinian (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com<mailto<mailto:listsender-caala-workproduct@lists.trialsmith.com%3cmailto>: > listsender-caala-workproduct@lists.trialsmith.com<mailto:listsender-caala-workproduct@lists.trialsmith.com>>> > Sent: Thursday, November 20, 2025 2:45 PM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com<mailto<mailto:caala-workproduct@lists.trialsmith.com%3cmailto>: > caala-workproduct@lists.trialsmith.com<mailto:caala-workproduct@lists.trialsmith.com>>> > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data > and Recusal > > > > List:caala-workproduct Sent by: Nareg Kitsinian (Reply Privately)<mailto: <mailto:%0b>> nareg@kitsinianlaw.com<mailto:nareg@kitsinianlaw.com> > ?subject=Re%3A%20%5Bcaala-workproduct%5D%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > > > Search<http://www.caala.org/index.cfm?pg=search> > > > > > > Greg, > > This - is awesome! I will send you the minute order when I have it. This > dropbox folder you have compiled is a treasure - really the nail in the > coffin. Everyone should be sharing their minute orders on this issue moving > forward. > > Thank you! > > -- > > > [cid:image001.png@01DC99C8.7EA9ABF0][cid:image002.jpg@01DC99C8.7EA9ABF0] > > LATLC > > 2025 Secretary - 2029 President > > > Nareg S. Kitsinian, Esq. > Attorney at Law > > > nareg@kitsinianlaw.com<mailto:nareg@kitsinianlaw.com<mailto:nareg@kitsinianlaw.com%3cmailto:nareg@kitsinianlaw.com>> > > www.kitsinianlaw.com<https://www.kitsinianlaw.com/> > > > Tel: (818)786-5777 ' Fax: (818)786-5778 > > > 16501 Ventura Blvd., Ste. 506, Encino, CA 91436 > <https://www.google.com/maps/search/16501+Ventura+Blvd.,+Ste.+506,+Encino,+CA+91436?entry=gmail&source=g> > <https://maps.app.goo.gl/tGQhp8PaYVZQ2VQaA> > > > > [cid:image003.png@01DC99C8.7EA9ABF0] < > https://www.facebook.com/kitsinianlaw> [cid:image004.png@01DC99C8.7EA9ABF0] > <https://www.linkedin.com/company/kitsinian-law-firm> > [cid:image005.png@01DC99C8.7EA9ABF0] < > https://www.instagram.com/kitsinianlawfirm/> > > > > > > > > ________________________________ > > From: Gregory Jackson (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com<mailto<mailto:listsender-caala-workproduct@lists.trialsmith.com%3cmailto>: > listsender-caala-workproduct@lists.trialsmith.com<mailto:listsender-caala-workproduct@lists.trialsmith.com>>> > Sent: Thursday, November 20, 2025 2:10 PM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com<mailto<mailto:caala-workproduct@lists.trialsmith.com%3cmailto>: > caala-workproduct@lists.trialsmith.com<mailto:caala-workproduct@lists.trialsmith.com>>> > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data > and Recusal > > > > List:caala-workproduct Sent by: Gregory Jackson (Reply Privately)<mailto: <mailto:%0b>> greg@justiceteam.com<mailto:greg@justiceteam.com> > ?subject=Re%3A%20%5Bcaala-workproduct%5D%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > > > Search<http://www.caala.org/index.cfm?pg=search> > > > > > > Nareg, > > > > Thank you for sharing this! Please keep us posted if Dr. Hungerford > proceeds with the exam and complies/produces the raw data so we can add him > to the list, and once you get the final minute order please circulate that > as well. > > > > Here is the Dropbox of neuropsych dirt I've compiled, check out the > 'Minute Orders' subfolder and there are at least a dozen in there including > 8 from this year. If you send me your final minute order once the court > posts it I'll add it to the Dropbox! > > > > > https://www.dropbox.com/scl/fo/c0pued3e3ftj4j0x88qji/ALFU7MTTieoSk3Dud4IyfHc?rlkey=67d52jz1uxzspr3mol96dfbkr&st=2kghiflq&dl=0 > > > > > > > > > [cid:image006.gif@01DC99C8.7EA9ABF0] > > > Greg Jackson > Partner and Managing Attorney The Simon Law Group > > > p: (855) 855-8910 f: (310) 914-5401 m: (714) 617-2180 > a: 2916 W 164th Street Torrance CA 90504 > <https://www.google.com/maps/search/2916+W+164th+Street+Torrance+CA+90504?entry=gmail&source=g> > w: www.JusticeTeam.com<http://www.JusticeTeam.com> e: greg@justiceteam.com<mailto:greg@justiceteam.com> > <mailto:%7BE-mail%7D> > Orange County ' Los Angeles ' Arizona ' Texas > > > > > [cid:image007.png@01DC99C8.7EA9ABF0]< > https://www.instagram.com/thesimonlawgroup> > > > [cid:image008.png@01DC99C8.7EA9ABF0]< > https://www.facebook.com/TheSimonLawGroup> > > > [cid:image009.png@01DC99C8.7EA9ABF0]< > https://www.linkedin.com/company/the-simon-law-group> > > > [cid:image010.png@01DC99C8.7EA9ABF0]<https://justiceteampodcast.com/> > > > [cid:image011.jpg@01DC99C8.7EA9ABF0]<https://linktr.ee/JusticeTeam> > > > > > > This email and any files transmitted with it are confidential and intended > solely for the use of the individual or entity to whom they are addressed. > If you have received this email in error please notify the system manager. > Please note that any views or opinions presented in this email are solely > those of the author and do not necessarily represent those of the company. > Finally, the recipient should check this email and any attachments for the > presence of viruses. The company accepts no liability for any damage caused > by any virus transmitted by this email. > > > > > From: Nareg Kitsinian (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com<mailto<mailto:listsender-caala-workproduct@lists.trialsmith.com%3cmailto>: > listsender-caala-workproduct@lists.trialsmith.com<mailto:listsender-caala-workproduct@lists.trialsmith.com>>> > Sent: Thursday, November 20, 2025 11:25 AM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com<mailto<mailto:caala-workproduct@lists.trialsmith.com%3cmailto>: > caala-workproduct@lists.trialsmith.com<mailto:caala-workproduct@lists.trialsmith.com>>> > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data > and Recusal > > > > List:caala-workproduct Sent by: Nareg Kitsinian (Reply Privately)<mailto: <mailto:%0b>> nareg@kitsinianlaw.com<mailto:nareg@kitsinianlaw.com> > ?subject=Re%3A%20%5Bcaala-workproduct%5D%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > > > Search<http://www.caala.org/index.cfm?pg=search> > > > > > > We successfully opposed a motion to compel a mental exam with Dr. Lars > Hungerford today in San Bernardino Superior Court with Judge Joseph Widman. > He made all the right calls in line with Randys Trucking and compelled that > the raw data be turned over and plaintiff can record the examination. > > > > This hearing was different then past hearings. The defense play now is to > use this declaration that they say 94% of neuropsychs have signed attesting > they would recuse themselves if compelled to turn over data. It's > persuasive, but not enough to circumvent the law. > > > > In my motion I attached two minute orders/tentative rulings where LASC > courts also ruled in line with Randy Trucking. > > Concerningly, this prompted the defense to argue at the hearing that he > would like to lodge 10 other recent orders throughout CA that he has > collected that went in the opposite direction and did not compel > disclosure. Judge Widman did not buy the argument. But I raise this because > if 10 other courtrooms are still ruling against disclosure, it can be > problematic given the judge and we should begin collecting orders in all > superior courts where a judge rules with Randy Trucking so that they can be > Judicially Noticed in these motions. This is the second motion I have won > in the last 5 months on a TBI case. The law is with us, but it is striking > to me that 10 other courts recently ruled in another direction. > > > > Attached is our tentative ruling from this morning. I hope others will > share over time so we can use them as time passes. > > > > > > > > > > > > -- > > > [cid:image001.png@01DC99C8.7EA9ABF0][cid:image002.jpg@01DC99C8.7EA9ABF0] > > LATLC > > 2025 Secretary - 2029 President > > > Nareg S. Kitsinian, Esq. > Attorney at Law > > > nareg@kitsinianlaw.com<mailto:nareg@kitsinianlaw.com<mailto:nareg@kitsinianlaw.com%3cmailto:nareg@kitsinianlaw.com>> > > www.kitsinianlaw.com<https://www.kitsinianlaw.com/> > > > Tel: (818)786-5777 ' Fax: (818)786-5778 > > > 16501 Ventura Blvd., Ste. 506, Encino, CA 91436 > <https://www.google.com/maps/search/16501+Ventura+Blvd.,+Ste.+506,+Encino,+CA+91436?entry=gmail&source=g> > <https://maps.app.goo.gl/tGQhp8PaYVZQ2VQaA> > > > > [cid:image003.png@01DC99C8.7EA9ABF0] < > https://www.facebook.com/kitsinianlaw> [cid:image004.png@01DC99C8.7EA9ABF0] > <https://www.linkedin.com/company/kitsinian-law-firm> > [cid:image005.png@01DC99C8.7EA9ABF0] < > https://www.instagram.com/kitsinianlawfirm/> > > > > > > > > ________________________________ > > From: Kane Handel (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com<mailto<mailto:listsender-caala-workproduct@lists.trialsmith.com%3cmailto>: > listsender-caala-workproduct@lists.trialsmith.com<mailto:listsender-caala-workproduct@lists.trialsmith.com>>> > Sent: Tuesday, November 4, 2025 11:05 AM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com<mailto<mailto:caala-workproduct@lists.trialsmith.com%3cmailto>: > caala-workproduct@lists.trialsmith.com<mailto:caala-workproduct@lists.trialsmith.com>>> > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data > and Recusal > > > > List:caala-workproduct Sent by: Kane Handel (Reply Privately)<mailto: <mailto:%0b>> kanehandel33@gmail.com<mailto:kanehandel33@gmail.com> > ?subject=Re%3A%20%5Bcaala-workproduct%5D%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > > > Search<http://www.caala.org/index.cfm?pg=search> > > > > > > file a motion!!! > > On 11/4/25 9:44 AM, Nareg Kitsinian (caala-workproduct listserver) wrote: > > List:caala-workproduct Sent by: Nareg Kitsinian (Reply Privately)<mailto: <mailto:%0b>> nareg@kitsinianlaw.com<mailto:nareg@kitsinianlaw.com> > ?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > > > Search<http://www.caala.org/index.cfm?pg=search> > > > > I have a TBI case where Dr. Hungerford has refused to provide the raw data > to me and is claiming in his declaration to withdraw if the court orders > him to turn over the data, citing this same declaration signed by 180 other > NeuroPsychs. Does anyone have any prior experience with Dr. Lars > Hungerford, perhaps agreeing to turn over raw data in the past that I can > use in our opposition? > Nareg > > -----Original Message----- > > From: antonio@ac3law.com<mailto:antonio@ac3law.com<mailto:antonio@ac3law.com%3cmailto:antonio@ac3law.com>> > Sent: September 29, 2025 3:43:00 PM > To: caala-workproduct@lists.trialsmith.com<mailto<mailto:caala-workproduct@lists.trialsmith.com%3cmailto>: > caala-workproduct@lists.trialsmith.com<mailto:caala-workproduct@lists.trialsmith.com>> > Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal > > Interestingly, Delis isn't a signatory. > > On Fri, Sep 19, 2025 at 3:57 PM Delavar Omidfar (caala-workproduct > listserver) <listsender-caala-workproduct@lists.trialsmith.com<mailto:listsender-caala-workproduct@lists.trialsmith.com>><mailto: <mailto:%0b>> listsender-caala-workproduct@lists.trialsmith.com<mailto:listsender-caala-workproduct@lists.trialsmith.com>> wrote: > > > *List:* caala-workproduct * Sent by:* Delavar Omidfar (Reply Privately) > > < > domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal<mailto:domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > ><mailto:domidfar@makkabilaw.com <mailto:domidfar@makkabilaw.com%0b>> ?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > > Search <http://www.caala.org/index.cfm?pg=search>< > http://www.caala.org/index.cfm?pg=search> > > Andrew - Do you have the case information or copies of the App Case? > > > > > > -----Original Message----- > > > > From: andrew@a2zlegal.com<mailto:andrew@a2zlegal.com<mailto:andrew@a2zlegal.com%3cmailto:andrew@a2zlegal.com>> > > Sent: September 17, 2025 6:35:00 PM > > To: caala-workproduct@lists.trialsmith.com<mailto<mailto:caala-workproduct@lists.trialsmith.com%3cmailto>: > caala-workproduct@lists.trialsmith.com<mailto:caala-workproduct@lists.trialsmith.com>> > > Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal > > > > This is nonsense. I had to take up a writ where the judge would not allow > > them to turn over the data to us and my writ was granted, court order > > reversed. If I remember correctly they included this garbage in their > > opposition as well but the Appellate Court did not buy it. > > > > <https://www.google.com/maps/search/1306+W.+Magnolia+Blvd.+%0D%0A+%0D%0A+Burbank,+CA+91506?entry=gmail&source=g> > > > > <https://www.google.com/maps/search/1306+W.+Magnolia+Blvd.+%0D%0A+%0D%0A+Burbank,+CA+91506?entry=gmail&source=g>> > Andrew Zeytuntsyan > > > > Founder / Trial Attorney > > > > [ > > > https://storage-use.letsignit.com/62705ddc173a9394d8bcc888/logo_62705ddc173a9394d8bcc888_e895719889494628d401a7b8776c8039.png > > ] > > > > 1306 W. Magnolia Blvd. > <https://www.google.com/maps/search/1306+W.+Magnolia+Blvd.+%0D%0A+%0D%0A+Burbank,+CA+91506?entry=gmail&source=g> > > > > Burbank, CA 91506 > <https://www.google.com/maps/search/1306+W.+Magnolia+Blvd.+%0D%0A+%0D%0A+Burbank,+CA+91506?entry=gmail&source=g> > > > > T. (323) 882-6500 > > > > F. (800) 506-7176 > > > > a2zlegal.com< > > > https://cloud.letsignit.com/collect/bc/627076c3c8565ddc6ca471ae?p=L3lrFhURv2eXFz8AUdcQMg7oZ5M7umbVf2WSzpdzFq7D1iSXrK3ZaujaqDpZOQqyzyjZl0xri-GrOODYWlP3QLZm0iplL-zlOXM4lSHQ28oSIcbvk9_JHfvcYEayMxKfUiuqgPOYkIcclIOWPouVUq8U-TmlvnN27_c7uQRHayw= > > > > > > > [ > > > https://storage-use.letsignit.com/62705ddc173a9394d8bcc888/253796901116998898398879131612511431317.png > > ] > > > > The information in this electronic mail message is confidential and for > > use of only the named recipient. The information may be protected by > > privilege, work product immunity or other applicable law. If you are not > > the intended recipient the retention, dissemination, distribution or > > copying of this e-mail message is strictly prohibited. If you receive > this > > message in error please notify us immediately. > > > > ________________________________ > > From: Delavar Omidfar (caala-workproduct listserver) < > > listsender-caala-workproduct@lists.trialsmith.com<mailto<mailto:listsender-caala-workproduct@lists.trialsmith.com%3cmailto>: > listsender-caala-workproduct@lists.trialsmith.com<mailto:listsender-caala-workproduct@lists.trialsmith.com>>> > > Sent: Friday, September 12, 2025 3:15 PM > > To: CAALA Work Product Discussion List < > > caala-workproduct@lists.trialsmith.com<mailto<mailto:caala-workproduct@lists.trialsmith.com%3cmailto>: > caala-workproduct@lists.trialsmith.com<mailto:caala-workproduct@lists.trialsmith.com>>> > > Subject: [caala-workproduct] Neuropsych Declaration re DME Raw Data and > > Recusal > > > > List: caala-workproduct Sent by: Delavar Omidfar (Reply > Privately)<mailto: <mailto:%0b>> <mailto:%0b>> > domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal<mailto:domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > <mailto:domidfar@makkabilaw.com <mailto:domidfar@makkabilaw.com%0b>> ?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal>> > > Search<http://www.caala.org/index.cfm?pg=search>< > http://www.caala.org/index.cfm?pg=search> > > > > > Mates, > > I was recently provided with the attached declaration signed by over 180 > > neuropsychologists and psychologists regarding the protection of > > psychological testing materials. Most importantly, all signatories have > > declared: > > > > "I would not agree to releasing protected test information that would > > jeopardize future use of tests to a non-psychologist, including > attorneys, > > even under a protective order. If this stipulation cannot be met, I would > > recuse myself from a case." > > > > My suspicion is that some of these same psychologists have previously > > agreed to perform mental examinations and released raw data under > > protective orders. If true, this creates a significant inconsistency that > > could be used to challenge their credibility and position. > > > > I'm reaching out to see if any of you have: > > > > 1. Documentation of any of these 185 signatories previously agreeing to > > release raw test data under protective order > > 2. Thoughts on strategies for overcoming this collective stance in future > > cases > > 3. Legal precedents, other than Randy's Trucking, that could compel > > production despite this declaration > > 4. Counter Declaration by psychs who can counter their arguments about > > test security > > > > The complete list of 185 signatories is below. Notable names include many > > prominent California neuropsychologists who regularly serve as defense > > experts, i.e. Hinkin, Boone, Kopald, Lechuga, Hooker, Bondi, Elliot, > Zamora. > > > > List of Signatories > > Catherine Marreiro, PhD, ABPP-CN > > Kyle Boone, PhD, ABPP-CN > > William McMullen Jr., PhD, ABPP-CN > > Delia M. Silva, Psy.D., ABPP-CN, Neuropsychologist > > Lauren Drag, PhD, ABPP-CN > > Maya Yutsis, PhD, ABPP-CN > > Katherine Kruser, Psy.D., Neuropsychologist > > Jeffrey Wertheimer, PhD, ABPP-CN > > Jay Rosen, PhD > > Michelle Zeller, Psy.D., ABPP-CN > > Deborah Cahn-Weiner, Ph.D., ABPP-CN > > Mi-Yeoung Jo, PsyD, ABPP-CN > > Talin Babikian, PhD, ABPP-CN > > Molly Memel, PhD, ABPP-CN > > Rebecca Goodman, PhD, ABPP-CN > > Haygoush Kalinian, PhD, Clinical Neuropsychologist > > Robert M. Bilder, PhD, ABPP-CN > > Robert Gray, PhD, ABPP-CN > > Amir Ramezani, PhD > > Leah Ellenberg, Ph. D., ABPP-CN > > Charles Filanosky, PhD, ABPP-RP > > Po-Haong Lu, PsyD > > Angela Eastvold, PhD, ABPP-CN > > Maura Mitrushina, Ph.D., ABPP-CN > > Ann Gottuso, PhD, ABPP-CN > > Gayle Deutsch, PhD, ABPP-CN > > Simon Tan PsyD, ABPP-CN > > Andrew Levine, PhD, ABPP-CN > > Ernest T. Bryant, PhD, ABPP-CN > > John Wager, PhD, ABPP-CN > > Dominique Kinney, PhD, ABPP-CN > > Brandon Kopald, Psy.D., ABPP-CN > > Frederick Hives II, PhD, ABPP-CN > > Lars Hungerford, PhD, ABPP-CN > > Karen L. Schiltz, PhD, Neuropsychologist > > Tara L. Victor, PhD, ABPP-CN > > Shelley Peery, PhD > > Karen Lau, PhD, ABPP-CN > > Robert Tomaszewski, PhD, ABPP-CN > > David M. Lechuga, PhD, ABPP, ABN > > Elma Chidekel, PhD, ABN, ABPdN > > William D. Hooker, Ph.D., ABN > > Dale Sherman, PhD, QME > > June Paltzer, PhD, ABPP-CN > > Karen Earnest, PhD, ABPP-CN > > John Bellone, PhD, ABPP-CN > > Erin Green-Krogmann, PhD, ABPP-CN > > Virginia Zuverza-Chavarria, PhD, ABPP-CN > > Kimberly Lanni, PhD, ABPP, Board Certified in Clinical Neuropsychology > > Mark Alfano, Ph.D., ABPP CN, RP > > Steve Nitch, Ph. D., ABPP-CN > > Kristina Agbayani, PhD, ABPP-CN > > Andrew L. Wong, PhD, ABPP-CN > > Jessica Foley, PhD, ABPP-CN > > Andrew Dean, Ph. D., ABPP-CN > > Allison R. Kaup, PhD > > Mark W. Bondi, PhD, ABPP-CN > > Jose M. Lafosse, Ph.D., ABPP-CN > > Philip Sayegh, PhD, MPH > > Sara Mason, PsyD > > Kimberly Miller, PhD, ABPP-CN > > Hayley Kristinsson, PsyD, ABPP-CN > > Michael H. Kabat, Ph.D., ABPP-CN > > Brigid Rose, PhD, ABPP-CN > > Roger Light, PhD, ABPP-CN > > Jeremy Jinkerson, PhD > > David D. O'Grady, Ph.D., ABPP-CN > > Anneliese Radke, Psy.D. > > Joanne M. Hamilton, ABPP-CN > > Travis G. Fogel, Ph.D., ABPP-CN > > Sarah Tomaszewski Farias, Ph.D. ABPP-CN > > Allyson C. Rosen, PhD, ABPP-CN > > Sabine Gysens, PhD > > George Kahle Henry, PhD. ABPP-CN > > Kirsty Bortnik, PhD, ABPP-CN > > Joelle Broffman, PsyD, ABPP-CN > > Kristin K. Jacobson, PsyD, ABPP-CN > > Alice Ruzicka, Ph.D., ABN > > Renee Low, Ph.D., ABN > > Stacy S Wilkins, PhD, ABPP/CN > > Christine M. Naber, PhD > > Aura Barragan, Psy.D. > > Richard L. Delmonico, PhD, Licensed Psychologist CA PSY12604, Clinical > > Neuropsychologist > > Lauren Bennett, PhD, ABPP-CN > > William J. Lynch, Ph.D., ABPP/CN, Licensed Psychologist [PSY 5151] > > Rujvi Kamat, PhD, ABPP-CN > > Krista Freeze, PhD, ABN > > Carrie R. McDonald, Ph.D., ABPP-CN > > Nancy A. Blum, Ph.D. > > Travis Shivley-Scott, PhD > > Karen Mikolic, PhD, ABN > > Talia Seider, PhD, ABPP-CN > > Heather Pedersen, PhD, ABPP-CN > > Michael DeBellis Psy.D., ABN > > Nicholas Thaler, PhD, ABPP-CN > > Caroline J. Grantz, PhD > > Philip K. Stenquist, Ph.D., ABPP-CN > > Brian Yochim, PhD, ABPP-CN > > Olivia Harner, PhD, ABPP > > David Anderson, PhD, ABPP-CN/CI > > Alexis D. Kulick, Ph.D., ABPP > > Lori Holt, PhD, ABPP-CN > > Joel S. Eppig, Ph.D. > > Delany Thrasher, Ph.D., ABPP-CN > > Annie Reader Murray, Ph.D., ABPP-CN > > Jeffrey M. Zulow, Ph.D. > > Kaitlin B. Casaletto, PhD, ABPP-CN > > Alexandra Apple, PhD > > Hope Goldberg, PhD, ABPP-CN > > William C. Hochberger, PhD > > Paul Mangal, PhD > > Virdette L. Brumm, Ph.D. > > Christy Hom, PhD, ABPdN > > Eric J. Freitag, PsyD, FACPN > > Howard J. Friedman, ABPP (CN), ABN > > Jonathan E. Romain, PhD, MS, ABPP-CN > > Patricia Gross, PhD, ABPP-CN > > Katie Denny PhD, ABPP-CN > > Katherine Bangen, PhD, ABPP-CN > > Lisa Graves, PhD > > John Knippa, PhD, ABN > > Ashley K. Miller, PhD, ABPP-CN > > Karen Hanson Bondi, Ph.D. > > Lori Alasantro, PhD, ABPP-CN > > Amanda Gooding, PhD, ABPP-CN > > Anita Herrera-Hamilton, Ph.D ABPP > > Caitlin Moore, PHD, ABPP > > William Britt, PhD, ABN > > Janet K. Brewer, JD, PsyD > > Mimi Wong, PhD, ABPP-CN > > Charles Furst, PhD, ABPP-CN > > Robert W. Elliott, PhD, ABCN, ABN > > Amy M. Schonfeld, PhD, Clinical Neuropsychologist > > Brian A. Osterweil, Ph.D., ABPP > > Duke Han, PhD, ABPP-CN > > Lisa Delano-Wood, PhD > > Kimberly Alfano, PhD, ABPP (CN, RP) > > Alena Stasenko, PhD > > Inna Fishman, PhD > > Annette Swain PhD ABPP-CN > > Monica Smith, PhD, ABN > > Mili Parikh, PhD, ABPP > > Charles H. Hinkin, Ph.D., ABPP-CN > > R. Dempsey, PsyD, ABPP, QME > > Margaret A. Donohue, PhD > > Samantha O'Bannon, Psy.D., Clinical Neuropsychologist PSY 32564 > > William T.J. Johnson, Ph.D., ABPP-CN > > Tony L. Strickland, MS, PhD, ABN, FNAN > > Emmanuel A. Zamora, Psy.D., Neuropsychologist > > Joshua McKeever, PhD, Clinical Neuropsychologist > > Carmen C. Velazquez, Ph.D. > > Anne Nolty, PhD, ABPP-CN > > Grace Mucci, PhD, ABPdN > > Tom Kiely, PhD > > Joel Kramer, PsyD, ABPP-CN > > Andrea Alioto, PhD, ABPP-CN > > Johanna Rengifo, PhD > > Ruth Serepca, PhD > > Abigail Kramer, PhD > > Sarah Banks, PhD, ABPP-CN > > Arnold D. Purisch, Ph.D., ABPP-CN, ABN > > Yuri Rassovsky, PhD, ABPP-CN > > Lauren Keats, PsyD > > Saskia DeVaughn, PhD, ABPP-CN > > Katie Beckwith, PhD, ABPP-CN > > Ashley Whitaker, PhD, ABPP-CN > > Christian Carter, Ph.D., ABPP-CN > > Melissa Balderrama, PsyD, ABPP > > Hannah Brunet, PhD, ABPP-CN > > Garima Lupas, PhD, ABPP, Board Certified in Clinical Neuropsychology > > James A. Moses, Ph.D., ABPP-CN/CL > > Bianca Georgescu, Psy.D., ABPP > > Brandon Gavett, Ph.D. ABPP-CN > > April Thames, PhD > > Michelle Conover, Ph.D., QME > > Daniel Jacobson, PhD, ABPP-CN > > Carlos Saucedo, PhD, ABPP-CN > > Sharon H. O'Neil, PhD, ABPP-CN > > Audrey Khatchikia, PhD > > Natalie C. Kelly, PhD, ABPP-CN > > Shital Pavawalla, Ph.D., ABPP-CN > > Alexander Tan, Ph.D., ABPP-CN > > Phuong M. Chau, PhD ABPP-CN > > Deborah Budding, Ph.D., ABN > > > > > > > > > > > > > > > > > > CAUTION:This email originated from outside of the organization. Do not > click links or open attachments unless you recognize the sender and know > the content is safe. > > > > > > > > CAUTION:This email originated from outside of the organization. Do not > click links or open attachments unless you recognize the sender and know > the content is safe. > > > > > > > > CAUTION: This email originated from outside of the organization. Do not > click links or open attachments unless you recognize the sender and know > the content is safe. > > > > > CAUTION: This email originated from outside of the organization. Do not > click links or open attachments unless you recognize the sender and know > the content is safe. > > > > CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
AI Analysis:
This message does not mention Judge Goodman at all. It discusses Judge Lee Arian in Burbank Dept B and references a minute order related to raw data/audio production in neuropsych DME cases. The judge being evaluated (Goodman) is not referenced anywhere in the message thread.
"Greg Jackson" Date: February 26, 2026 9:33:00 AM Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal Reply to list Reply to sender Print Attachments: 2022.11.04 minute order - dr. mi yeoung jo.pdf (60 K) List: caala-workproduct Sent by: Gregory Jackson (Reply Privately) Search Here’s a Burbank order granting the raw data/audio subject to PO, but not Judge Arian Greg Jackson Partner and Managing Attorney The Simon Law Group p : (855) 855-8910 f : (310) 914-5401 m : (714) 617-2180 a : 2916 W 164th Street Torrance CA 90504 w : www.JusticeTeam.com e : greg@justiceteam.com Orange County | Los Angeles | Arizona | Texas This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of the company. Finally, the recipient should check this email and any attachments for the presence of viruses. The company accepts no liability for any damage caused by any virus transmitted by this email. From: Karen Jacobs (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Wednesday, February 25, 2026 5:48 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re:[caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Karen Jacobs (Reply Privately) Search Has anyone attempted to compel production of raw data in Burbank, Dept B, Judge Lee Arian? Any indication on how he's likely to rule? -----Original Message----- From: ssh@habbaspilaw.com Sent: February 20, 2026 4:23:00 PM To: caala-workproduct@lists.trialsmith.com Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal We just had Boone compelled to produce raw data based on Randy's Trucking. Immediately after she withdrew and the defense has yet to request a new one. Keep filing on this issue. Samer Habbas LAW OFFICES OF SAMER HABBAS 200 Spectrum Center Drive Suite 1230 Irvine, CA 92618 Tel: (949) 727-9300 Fax: (949) 727-9308 ssh@habbaspilaw.com www.habbaspilaw.com This communication, including attachments, is confidential, may be subject to legal privileges, and is intended for the sole use of the addressee. Any use, duplication, disclosure or dissemination of this communication, other than by the addressee, is prohibited. If you have received this communication in error, please notify the sender immediately and delete or destroy this communication and all copies. On Fri, Feb 20, 2026 at 3:00 PM Jennifer Bagosy (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: > *List:* caala-workproduct * Sent by:* Jennifer Bagosy (Reply Privately) > < jby@bhattorneys.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal > > Search < http://www.caala.org/index.cfm?pg=search > > Has anyone seen whether Dr. Christine Naber has ever produced raw data or > been ordered to? > > -----Original Message----- > > From: greg@justiceteam.com > Sent: February 09, 2026 3:33:00 PM > To: caala-workproduct@lists.trialsmith.com > Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal > > NICE, thank you Nareg!! I'll get this added to the Dropbox, I appreciate > the update and good luck with getting sanctions! > > > > > [cid:slg_oca_emailsignature_4s_1x1_v1_fc31d3c0-b93d-4153-a0d5-cad733aff375.gif] > Greg Jackson > Partner and Managing Attorney The Simon Law Group > > p: (855) 855-8910 f: (310) 914-5401 m: (714) 617-2180 > a: 2916 W 164th Street Torrance CA 90504 > < https://www.google.com/maps/search/2916+W+164th+Street+Torrance+CA+90504?entry=gmail&source=g > > w: www.JusticeTeam.com e: greg@justiceteam.com<mailto:%7BE-mail%7D > > Orange County ' Los Angeles ' Arizona ' Texas > > < https://www.facebook.com/TheSimonLawGroup > > [cid:instagram_32x32_3473fb9a-cef8-4bd0-89b9-ebad3ae209f4.png]< > https://www.instagram.com/thesimonlawgroup > > [cid:facebook_32x32_22f3b732-9ee9-4be2-89af-5f59b15a773c.png] < > https://www.facebook.com/TheSimonLawGroup > > [cid:linkedin_32x32_2f01fc51-e68d-4f7e-a219-1ce2be0d0f5e.png] < > https://www.linkedin.com/company/the-simon-law-group > > [cid:podcast-7858222_640_3b7e9899-d89c-4e5d-92d6-940be75f7bd5.png] < > https://justiceteampodcast.com/ > > [cid:linktree_21c8e52f-1f37-476a-bbec-61b73bbfeb66.jpg] < > https://linktr.ee/JusticeTeam > > > > > This email and any files transmitted with it are confidential and intended > solely for the use of the individual or entity to whom they are addressed. > If you have received this email in error please notify the system manager. > Please note that any views or opinions presented in this email are solely > those of the author and do not necessarily represent those of the company. > Finally, the recipient should check this email and any attachments for the > presence of viruses. The company accepts no liability for any damage caused > by any virus transmitted by this email. > > > From: Nareg Kitsinian < nareg@kitsinianlaw.com > > Sent: Wednesday, February 4, 2026 2:29 PM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com > > Cc: Greg Jackson < greg@justiceteam.com > > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data > and Recusal > > Greg, > See attached, signed order, ordering Dr. Hungerford to produce raw data > etc. > Hungerford, did not recuse himself as he promised to do so in that > ridiculous declaration signed by other doctors. > > He did go through with the DME and interviewed my client after all, but > opted not to conduct his own testing and obtained the treating providers > raw data instead. I have asked that the raw data be turned over and OC > seems to think he is clever and is making the argument that the courts > order only applies if Hungerford did the testing. An ex parte to enforce > with sanctions is on its way. > > Please add the attached to your drop box. I'll let you know if Hungerford > sends us the raw data. > > > > > > > -- > > > [ cid:image001.png@01DC99C8.7EA9ABF0 ][ cid:image002.jpg@01DC99C8.7EA9ABF0 ] > > LATLC > > 2025 Secretary - 2029 President > > > Nareg S. Kitsinian, Esq. > Attorney at Law > > > nareg@kitsinianlaw.com<mailto:nareg@kitsinianlaw.com > > > www.kitsinianlaw.com<https://www.kitsinianlaw.com/> > > > Tel: (818)786-5777 ' Fax: (818)786-5778 > > > 16501 Ventura Blvd., Ste. 506, Encino, CA 91436 > < https://www.google.com/maps/search/16501+Ventura+Blvd.,+Ste.+506,+Encino,+CA+91436?entry=gmail&source=g > > < https://maps.app.goo.gl/tGQhp8PaYVZQ2VQaA > > > > > [ cid:image003.png@01DC99C8.7EA9ABF0 ] < > https://www.facebook.com/kitsinianlaw > [ cid:image004.png@01DC99C8.7EA9ABF0 ] > < https://www.linkedin.com/company/kitsinian-law-firm > > [ cid:image005.png@01DC99C8.7EA9ABF0 ] < > https://www.instagram.com/kitsinianlawfirm/ > > > > > > > > > ________________________________ > From: Gregory Jackson (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com<mailto : > listsender-caala-workproduct@lists.trialsmith.com >> > Sent: Thursday, November 20, 2025 3:27 PM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com<mailto : > caala-workproduct@lists.trialsmith.com >> > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data > and Recusal > > List: caala-workproduct Sent by: Gregory Jackson (Reply Privately)< mailto: > greg@justiceteam.com > ?subject=Re%3A%20%5Bcaala-workproduct%5D%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > > Search< http://www.caala.org/index.cfm?pg=search > > > > > > Added! > > > > > [ cid:image006.gif@01DC99C8.7EA9ABF0 ] > > Greg Jackson > Partner and Managing Attorney The Simon Law Group > > p: (855) 855-8910 f: (310) 914-5401 m: (714) 617-2180 > a: 2916 W 164th Street Torrance CA 90504 > < https://www.google.com/maps/search/2916+W+164th+Street+Torrance+CA+90504?entry=gmail&source=g > > w: www.JusticeTeam.com<http://www.JusticeTeam.com> e: greg@justiceteam.com > < mailto:%7BE-mail%7D > > Orange County ' Los Angeles ' Arizona ' Texas > > > [ cid:image007.png@01DC99C8.7EA9ABF0 ]< > https://www.instagram.com/thesimonlawgroup > > > [ cid:image008.png@01DC99C8.7EA9ABF0 ]< > https://www.facebook.com/TheSimonLawGroup > > > [ cid:image009.png@01DC99C8.7EA9ABF0 ]< > https://www.linkedin.com/company/the-simon-law-group > > > [ cid:image010.png@01DC99C8.7EA9ABF0 ]< https://justiceteampodcast.com/ > > > [ cid:image011.jpg@01DC99C8.7EA9ABF0 ]< https://linktr.ee/JusticeTeam > > > > > > This email and any files transmitted with it are confidential and intended > solely for the use of the individual or entity to whom they are addressed. > If you have received this email in error please notify the system manager. > Please note that any views or opinions presented in this email are solely > those of the author and do not necessarily represent those of the company. > Finally, the recipient should check this email and any attachments for the > presence of viruses. The company accepts no liability for any damage caused > by any virus transmitted by this email. > > > > > From: Nareg Kitsinian (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com<mailto : > listsender-caala-workproduct@lists.trialsmith.com >> > Sent: Thursday, November 20, 2025 3:21 PM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com<mailto : > caala-workproduct@lists.trialsmith.com >> > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data > and Recusal > > > > List: caala-workproduct Sent by: Nareg Kitsinian (Reply Privately)< mailto: > nareg@kitsinianlaw.com > ?subject=Re%3A%20%5Bcaala-workproduct%5D%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > > > Search< http://www.caala.org/index.cfm?pg=search > > > > > > > Greg, attached is our LASC minute order from 3/25 compelling Filoteo who > did produce. Please add to your folder. > > > > > > > > -- > > > [ cid:image001.png@01DC99C8.7EA9ABF0 ][ cid:image002.jpg@01DC99C8.7EA9ABF0 ] > > LATLC > > 2025 Secretary - 2029 President > > > Nareg S. Kitsinian, Esq. > Attorney at Law > > > nareg@kitsinianlaw.com<mailto:nareg@kitsinianlaw.com > > > www.kitsinianlaw.com<https://www.kitsinianlaw.com/> > > > Tel: (818)786-5777 ' Fax: (818)786-5778 > > > 16501 Ventura Blvd., Ste. 506, Encino, CA 91436 > < https://www.google.com/maps/search/16501+Ventura+Blvd.,+Ste.+506,+Encino,+CA+91436?entry=gmail&source=g > > < https://maps.app.goo.gl/tGQhp8PaYVZQ2VQaA > > > > > [ cid:image003.png@01DC99C8.7EA9ABF0 ] < > https://www.facebook.com/kitsinianlaw > [ cid:image004.png@01DC99C8.7EA9ABF0 ] > < https://www.linkedin.com/company/kitsinian-law-firm > > [ cid:image005.png@01DC99C8.7EA9ABF0 ] < > https://www.instagram.com/kitsinianlawfirm/ > > > > > > > > > ________________________________ > > From: Gregory Jackson (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com<mailto : > listsender-caala-workproduct@lists.trialsmith.com >> > Sent: Thursday, November 20, 2025 3:01 PM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com<mailto : > caala-workproduct@lists.trialsmith.com >> > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data > and Recusal > > > > List: caala-workproduct Sent by: Gregory Jackson (Reply Privately)< mailto: > greg@justiceteam.com > ?subject=Re%3A%20%5Bcaala-workproduct%5D%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > > > Search< http://www.caala.org/index.cfm?pg=search > > > > > > > No problem! You'll see specific subfolders for a number of experts, some > oppositions, lot of stuff in there to use. For that huge declaration > defense is listing now, a number of those experts who signed off on it have > actually produced raw data anyway - so you can use these minute orders and > stipulations in the Dropbox to impeach it. > > > > > > > [ cid:image006.gif@01DC99C8.7EA9ABF0 ] > > > Greg Jackson > Partner and Managing Attorney The Simon Law Group > > > p: (855) 855-8910 f: (310) 914-5401 m: (714) 617-2180 > a: 2916 W 164th Street Torrance CA 90504 > < https://www.google.com/maps/search/2916+W+164th+Street+Torrance+CA+90504?entry=gmail&source=g > > w: www.JusticeTeam.com<http://www.JusticeTeam.com> e: greg@justiceteam.com > < mailto:%7BE-mail%7D > > Orange County ' Los Angeles ' Arizona ' Texas > > > > > [ cid:image007.png@01DC99C8.7EA9ABF0 ]< > https://www.instagram.com/thesimonlawgroup > > > > [ cid:image008.png@01DC99C8.7EA9ABF0 ]< > https://www.facebook.com/TheSimonLawGroup > > > > [ cid:image009.png@01DC99C8.7EA9ABF0 ]< > https://www.linkedin.com/company/the-simon-law-group > > > > [ cid:image010.png@01DC99C8.7EA9ABF0 ]< https://justiceteampodcast.com/ > > > > [ cid:image011.jpg@01DC99C8.7EA9ABF0 ]< https://linktr.ee/JusticeTeam > > > > > > > This email and any files transmitted with it are confidential and intended > solely for the use of the individual or entity to whom they are addressed. > If you have received this email in error please notify the system manager. > Please note that any views or opinions presented in this email are solely > those of the author and do not necessarily represent those of the company. > Finally, the recipient should check this email and any attachments for the > presence of viruses. The company accepts no liability for any damage caused > by any virus transmitted by this email. > > > > > From: Nareg Kitsinian (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com<mailto : > listsender-caala-workproduct@lists.trialsmith.com >> > Sent: Thursday, November 20, 2025 2:45 PM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com<mailto : > caala-workproduct@lists.trialsmith.com >> > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data > and Recusal > > > > List:caala-workproduct Sent by: Nareg Kitsinian (Reply Privately)< mailto: > nareg@kitsinianlaw.com > ?subject=Re%3A%20%5Bcaala-workproduct%5D%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > > > Search< http://www.caala.org/index.cfm?pg=search > > > > > > > Greg, > > This - is awesome! I will send you the minute order when I have it. This > dropbox folder you have compiled is a treasure - really the nail in the > coffin. Everyone should be sharing their minute orders on this issue moving > forward. > > Thank you! > > -- > > > [ cid:image001.png@01DC99C8.7EA9ABF0 ][ cid:image002.jpg@01DC99C8.7EA9ABF0 ] > > LATLC > > 2025 Secretary - 2029 President > > > Nareg S. Kitsinian, Esq. > Attorney at Law > > > nareg@kitsinianlaw.com<mailto:nareg@kitsinianlaw.com > > > www.kitsinianlaw.com<https://www.kitsinianlaw.com/> > > > Tel: (818)786-5777 ' Fax: (818)786-5778 > > > 16501 Ventura Blvd., Ste. 506, Encino, CA 91436 > < https://www.google.com/maps/search/16501+Ventura+Blvd.,+Ste.+506,+Encino,+CA+91436?entry=gmail&source=g > > < https://maps.app.goo.gl/tGQhp8PaYVZQ2VQaA > > > > > [ cid:image003.png@01DC99C8.7EA9ABF0 ] < > https://www.facebook.com/kitsinianlaw > [ cid:image004.png@01DC99C8.7EA9ABF0 ] > < https://www.linkedin.com/company/kitsinian-law-firm > > [ cid:image005.png@01DC99C8.7EA9ABF0 ] < > https://www.instagram.com/kitsinianlawfirm/ > > > > > > > > > ________________________________ > > From: Gregory Jackson (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com<mailto : > listsender-caala-workproduct@lists.trialsmith.com >> > Sent: Thursday, November 20, 2025 2:10 PM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com<mailto : > caala-workproduct@lists.trialsmith.com >> > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data > and Recusal > > > > List:caala-workproduct Sent by: Gregory Jackson (Reply Privately)< mailto: > greg@justiceteam.com > ?subject=Re%3A%20%5Bcaala-workproduct%5D%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > > > Search< http://www.caala.org/index.cfm?pg=search > > > > > > > Nareg, > > > > Thank you for sharing this! Please keep us posted if Dr. Hungerford > proceeds with the exam and complies/produces the raw data so we can add him > to the list, and once you get the final minute order please circulate that > as well. > > > > Here is the Dropbox of neuropsych dirt I've compiled, check out the > 'Minute Orders' subfolder and there are at least a dozen in there including > 8 from this year. If you send me your final minute order once the court > posts it I'll add it to the Dropbox! > > > > > https://www.dropbox.com/scl/fo/c0pued3e3ftj4j0x88qji/ALFU7MTTieoSk3Dud4IyfHc?rlkey=67d52jz1uxzspr3mol96dfbkr&st=2kghiflq&dl=0 > > > > > > > > > [ cid:image006.gif@01DC99C8.7EA9ABF0 ] > > > Greg Jackson > Partner and Managing Attorney The Simon Law Group > > > p: (855) 855-8910 f: (310) 914-5401 m: (714) 617-2180 > a: 2916 W 164th Street Torrance CA 90504 > < https://www.google.com/maps/search/2916+W+164th+Street+Torrance+CA+90504?entry=gmail&source=g > > w: www.JusticeTeam.com<http://www.JusticeTeam.com> e: greg@justiceteam.com > < mailto:%7BE-mail%7D > > Orange County ' Los Angeles ' Arizona ' Texas > > > > > [ cid:image007.png@01DC99C8.7EA9ABF0 ]< > https://www.instagram.com/thesimonlawgroup > > > > [ cid:image008.png@01DC99C8.7EA9ABF0 ]< > https://www.facebook.com/TheSimonLawGroup > > > > [ cid:image009.png@01DC99C8.7EA9ABF0 ]< > https://www.linkedin.com/company/the-simon-law-group > > > > [ cid:image010.png@01DC99C8.7EA9ABF0 ]< https://justiceteampodcast.com/ > > > > [ cid:image011.jpg@01DC99C8.7EA9ABF0 ]< https://linktr.ee/JusticeTeam > > > > > > > This email and any files transmitted with it are confidential and intended > solely for the use of the individual or entity to whom they are addressed. > If you have received this email in error please notify the system manager. > Please note that any views or opinions presented in this email are solely > those of the author and do not necessarily represent those of the company. > Finally, the recipient should check this email and any attachments for the > presence of viruses. The company accepts no liability for any damage caused > by any virus transmitted by this email. > > > > > From: Nareg Kitsinian (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com<mailto : > listsender-caala-workproduct@lists.trialsmith.com >> > Sent: Thursday, November 20, 2025 11:25 AM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com<mailto : > caala-workproduct@lists.trialsmith.com >> > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data > and Recusal > > > > List:caala-workproduct Sent by: Nareg Kitsinian (Reply Privately)< mailto: > nareg@kitsinianlaw.com > ?subject=Re%3A%20%5Bcaala-workproduct%5D%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > > > Search< http://www.caala.org/index.cfm?pg=search > > > > > > > We successfully opposed a motion to compel a mental exam with Dr. Lars > Hungerford today in San Bernardino Superior Court with Judge Joseph Widman. > He made all the right calls in line with Randys Trucking and compelled that > the raw data be turned over and plaintiff can record the examination. > > > > This hearing was different then past hearings. The defense play now is to > use this declaration that they say 94% of neuropsychs have signed attesting > they would recuse themselves if compelled to turn over data. It's > persuasive, but not enough to circumvent the law. > > > > In my motion I attached two minute orders/tentative rulings where LASC > courts also ruled in line with Randy Trucking. > > Concerningly, this prompted the defense to argue at the hearing that he > would like to lodge 10 other recent orders throughout CA that he has > collected that went in the opposite direction and did not compel > disclosure. Judge Widman did not buy the argument. But I raise this because > if 10 other courtrooms are still ruling against disclosure, it can be > problematic given the judge and we should begin collecting orders in all > superior courts where a judge rules with Randy Trucking so that they can be > Judicially Noticed in these motions. This is the second motion I have won > in the last 5 months on a TBI case. The law is with us, but it is striking > to me that 10 other courts recently ruled in another direction. > > > > Attached is our tentative ruling from this morning. I hope others will > share over time so we can use them as time passes. > > > > > > > > > > > > -- > > > [ cid:image001.png@01DC99C8.7EA9ABF0 ][ cid:image002.jpg@01DC99C8.7EA9ABF0 ] > > LATLC > > 2025 Secretary - 2029 President > > > Nareg S. Kitsinian, Esq. > Attorney at Law > > > nareg@kitsinianlaw.com<mailto:nareg@kitsinianlaw.com > > > www.kitsinianlaw.com<https://www.kitsinianlaw.com/> > > > Tel: (818)786-5777 ' Fax: (818)786-5778 > > > 16501 Ventura Blvd., Ste. 506, Encino, CA 91436 > < https://www.google.com/maps/search/16501+Ventura+Blvd.,+Ste.+506,+Encino,+CA+91436?entry=gmail&source=g > > < https://maps.app.goo.gl/tGQhp8PaYVZQ2VQaA > > > > > [ cid:image003.png@01DC99C8.7EA9ABF0 ] < > https://www.facebook.com/kitsinianlaw > [ cid:image004.png@01DC99C8.7EA9ABF0 ] > < https://www.linkedin.com/company/kitsinian-law-firm > > [ cid:image005.png@01DC99C8.7EA9ABF0 ] < > https://www.instagram.com/kitsinianlawfirm/ > > > > > > > > > ________________________________ > > From: Kane Handel (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com<mailto : > listsender-caala-workproduct@lists.trialsmith.com >> > Sent: Tuesday, November 4, 2025 11:05 AM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com<mailto : > caala-workproduct@lists.trialsmith.com >> > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data > and Recusal > > > > List:caala-workproduct Sent by: Kane Handel (Reply Privately)< mailto: > kanehandel33@gmail.com > ?subject=Re%3A%20%5Bcaala-workproduct%5D%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > > > Search< http://www.caala.org/index.cfm?pg=search > > > > > > > file a motion!!! > > On 11/4/25 9:44 AM, Nareg Kitsinian (caala-workproduct listserver) wrote: > > List:caala-workproduct Sent by: Nareg Kitsinian (Reply Privately)< mailto: > nareg@kitsinianlaw.com > ?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > > > Search< http://www.caala.org/index.cfm?pg=search > > > > > I have a TBI case where Dr. Hungerford has refused to provide the raw data > to me and is claiming in his declaration to withdraw if the court orders > him to turn over the data, citing this same declaration signed by 180 other > NeuroPsychs. Does anyone have any prior experience with Dr. Lars > Hungerford, perhaps agreeing to turn over raw data in the past that I can > use in our opposition? > Nareg > > -----Original Message----- > > From: antonio@ac3law.com<mailto:antonio@ac3law.com > > Sent: September 29, 2025 3:43:00 PM > To: caala-workproduct@lists.trialsmith.com<mailto : > caala-workproduct@lists.trialsmith.com > > Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal > > Interestingly, Delis isn't a signatory. > > On Fri, Sep 19, 2025 at 3:57 PM Delavar Omidfar (caala-workproduct > listserver) < listsender-caala-workproduct@lists.trialsmith.com >< mailto: > listsender-caala-workproduct@lists.trialsmith.com > wrote: > > > *List:* caala-workproduct * Sent by:* Delavar Omidfar (Reply Privately) > > < > domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal > >< mailto:domidfar@makkabilaw.com > ?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > > Search < http://www.caala.org/index.cfm?pg=search >< > http://www.caala.org/index.cfm?pg=search > > > Andrew - Do you have the case information or copies of the App Case? > > > > > > -----Original Message----- > > > > From: andrew@a2zlegal.com<mailto:andrew@a2zlegal.com > > > Sent: September 17, 2025 6:35:00 PM > > To: caala-workproduct@lists.trialsmith.com<mailto : > caala-workproduct@lists.trialsmith.com > > > Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal > > > > This is nonsense. I had to take up a writ where the judge would not allow > > them to turn over the data to us and my writ was granted, court order > > reversed. If I remember correctly they included this garbage in their > > opposition as well but the Appellate Court did not buy it. > > > > < https://www.google.com/maps/search/1306+W.+Magnolia+Blvd.+%0D%0A+%0D%0A+Burbank,+CA+91506?entry=gmail&source=g > > > > > < https://www.google.com/maps/search/1306+W.+Magnolia+Blvd.+%0D%0A+%0D%0A+Burbank,+CA+91506?entry=gmail&source=g >> > Andrew Zeytuntsyan > > > > Founder / Trial Attorney > > > > [ > > > https://storage-use.letsignit.com/62705ddc173a9394d8bcc888/logo_62705ddc173a9394d8bcc888_e895719889494628d401a7b8776c8039.png > > ] > > > > 1306 W. Magnolia Blvd. > < https://www.google.com/maps/search/1306+W.+Magnolia+Blvd.+%0D%0A+%0D%0A+Burbank,+CA+91506?entry=gmail&source=g > > > > > Burbank, CA 91506 > < https://www.google.com/maps/search/1306+W.+Magnolia+Blvd.+%0D%0A+%0D%0A+Burbank,+CA+91506?entry=gmail&source=g > > > > > T. (323) 882-6500 > > > > F. (800) 506-7176 > > > > a2zlegal.com< > > > https://cloud.letsignit.com/collect/bc/627076c3c8565ddc6ca471ae?p=L3lrFhURv2eXFz8AUdcQMg7oZ5M7umbVf2WSzpdzFq7D1iSXrK3ZaujaqDpZOQqyzyjZl0xri-GrOODYWlP3QLZm0iplL-zlOXM4lSHQ28oSIcbvk9_JHfvcYEayMxKfUiuqgPOYkIcclIOWPouVUq8U-TmlvnN27_c7uQRHayw= > > > > > > > [ > > > https://storage-use.letsignit.com/62705ddc173a9394d8bcc888/253796901116998898398879131612511431317.png > > ] > > > > The information in this electronic mail message is confidential and for > > use of only the named recipient. The information may be protected by > > privilege, work product immunity or other applicable law. If you are not > > the intended recipient the retention, dissemination, distribution or > > copying of this e-mail message is strictly prohibited. If you receive > this > > message in error please notify us immediately. > > > > ________________________________ > > From: Delavar Omidfar (caala-workproduct listserver) < > > listsender-caala-workproduct@lists.trialsmith.com<mailto : > listsender-caala-workproduct@lists.trialsmith.com >> > > Sent: Friday, September 12, 2025 3:15 PM > > To: CAALA Work Product Discussion List < > > caala-workproduct@lists.trialsmith.com<mailto : > caala-workproduct@lists.trialsmith.com >> > > Subject: [caala-workproduct] Neuropsych Declaration re DME Raw Data and > > Recusal > > > > List: caala-workproduct Sent by: Delavar Omidfar (Reply > Privately)< mailto: > < mailto:%0b >> > domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal > < mailto:domidfar@makkabilaw.com > ?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal>> > > Search< http://www.caala.org/index.cfm?pg=search >< > http://www.caala.org/index.cfm?pg=search > > > > > > Mates, > > I was recently provided with the attached declaration signed by over 180 > > neuropsychologists and psychologists regarding the protection of > > psychological testing materials. Most importantly, all signatories have > > declared: > > > > "I would not agree to releasing protected test information that would > > jeopardize future use of tests to a non-psychologist, including > attorneys, > > even under a protective order. If this stipulation cannot be met, I would > > recuse myself from a case." > > > > My suspicion is that some of these same psychologists have previously > > agreed to perform mental examinations and released raw data under > > protective orders. If true, this creates a significant inconsistency that > > could be used to challenge their credibility and position. > > > > I'm reaching out to see if any of you have: > > > > 1. Documentation of any of these 185 signatories previously agreeing to > > release raw test data under protective order > > 2. Thoughts on strategies for overcoming this collective stance in future > > cases > > 3. Legal precedents, other than Randy's Trucking, that could compel > > production despite this declaration > > 4. Counter Declaration by psychs who can counter their arguments about > > test security > > > > The complete list of 185 signatories is below. Notable names include many > > prominent California neuropsychologists who regularly serve as defense > > experts, i.e. Hinkin, Boone, Kopald, Lechuga, Hooker, Bondi, Elliot, > Zamora. > > > > List of Signatories > > Catherine Marreiro, PhD, ABPP-CN > > Kyle Boone, PhD, ABPP-CN > > William McMullen Jr., PhD, ABPP-CN > > Delia M. Silva, Psy.D., ABPP-CN, Neuropsychologist > > Lauren Drag, PhD, ABPP-CN > > Maya Yutsis, PhD, ABPP-CN > > Katherine Kruser, Psy.D., Neuropsychologist > > Jeffrey Wertheimer, PhD, ABPP-CN > > Jay Rosen, PhD > > Michelle Zeller, Psy.D., ABPP-CN > > Deborah Cahn-Weiner, Ph.D., ABPP-CN > > Mi-Yeoung Jo, PsyD, ABPP-CN > > Talin Babikian, PhD, ABPP-CN > > Molly Memel, PhD, ABPP-CN > > Rebecca Goodman, PhD, ABPP-CN > > Haygoush Kalinian, PhD, Clinical Neuropsychologist > > Robert M. Bilder, PhD, ABPP-CN > > Robert Gray, PhD, ABPP-CN > > Amir Ramezani, PhD > > Leah Ellenberg, Ph. D., ABPP-CN > > Charles Filanosky, PhD, ABPP-RP > > Po-Haong Lu, PsyD > > Angela Eastvold, PhD, ABPP-CN > > Maura Mitrushina, Ph.D., ABPP-CN > > Ann Gottuso, PhD, ABPP-CN > > Gayle Deutsch, PhD, ABPP-CN > > Simon Tan PsyD, ABPP-CN > > Andrew Levine, PhD, ABPP-CN > > Ernest T. Bryant, PhD, ABPP-CN > > John Wager, PhD, ABPP-CN > > Dominique Kinney, PhD, ABPP-CN > > Brandon Kopald, Psy.D., ABPP-CN > > Frederick Hives II, PhD, ABPP-CN > > Lars Hungerford, PhD, ABPP-CN > > Karen L. Schiltz, PhD, Neuropsychologist > > Tara L. Victor, PhD, ABPP-CN > > Shelley Peery, PhD > > Karen Lau, PhD, ABPP-CN > > Robert Tomaszewski, PhD, ABPP-CN > > David M. Lechuga, PhD, ABPP, ABN > > Elma Chidekel, PhD, ABN, ABPdN > > William D. Hooker, Ph.D., ABN > > Dale Sherman, PhD, QME > > June Paltzer, PhD, ABPP-CN > > Karen Earnest, PhD, ABPP-CN > > John Bellone, PhD, ABPP-CN > > Erin Green-Krogmann, PhD, ABPP-CN > > Virginia Zuverza-Chavarria, PhD, ABPP-CN > > Kimberly Lanni, PhD, ABPP, Board Certified in Clinical Neuropsychology > > Mark Alfano, Ph.D., ABPP CN, RP > > Steve Nitch, Ph. D., ABPP-CN > > Kristina Agbayani, PhD, ABPP-CN > > Andrew L. Wong, PhD, ABPP-CN > > Jessica Foley, PhD, ABPP-CN > > Andrew Dean, Ph. D., ABPP-CN > > Allison R. Kaup, PhD > > Mark W. Bondi, PhD, ABPP-CN > > Jose M. Lafosse, Ph.D., ABPP-CN > > Philip Sayegh, PhD, MPH > > Sara Mason, PsyD > > Kimberly Miller, PhD, ABPP-CN > > Hayley Kristinsson, PsyD, ABPP-CN > > Michael H. Kabat, Ph.D., ABPP-CN > > Brigid Rose, PhD, ABPP-CN > > Roger Light, PhD, ABPP-CN > > Jeremy Jinkerson, PhD > > David D. O'Grady, Ph.D., ABPP-CN > > Anneliese Radke, Psy.D. > > Joanne M. Hamilton, ABPP-CN > > Travis G. Fogel, Ph.D., ABPP-CN > > Sarah Tomaszewski Farias, Ph.D. ABPP-CN > > Allyson C. Rosen, PhD, ABPP-CN > > Sabine Gysens, PhD > > George Kahle Henry, PhD. ABPP-CN > > Kirsty Bortnik, PhD, ABPP-CN > > Joelle Broffman, PsyD, ABPP-CN > > Kristin K. Jacobson, PsyD, ABPP-CN > > Alice Ruzicka, Ph.D., ABN > > Renee Low, Ph.D., ABN > > Stacy S Wilkins, PhD, ABPP/CN > > Christine M. Naber, PhD > > Aura Barragan, Psy.D. > > Richard L. Delmonico, PhD, Licensed Psychologist CA PSY12604, Clinical > > Neuropsychologist > > Lauren Bennett, PhD, ABPP-CN > > William J. Lynch, Ph.D., ABPP/CN, Licensed Psychologist [PSY 5151] > > Rujvi Kamat, PhD, ABPP-CN > > Krista Freeze, PhD, ABN > > Carrie R. McDonald, Ph.D., ABPP-CN > > Nancy A. Blum, Ph.D. > > Travis Shivley-Scott, PhD > > Karen Mikolic, PhD, ABN > > Talia Seider, PhD, ABPP-CN > > Heather Pedersen, PhD, ABPP-CN > > Michael DeBellis Psy.D., ABN > > Nicholas Thaler, PhD, ABPP-CN > > Caroline J. Grantz, PhD > > Philip K. Stenquist, Ph.D., ABPP-CN > > Brian Yochim, PhD, ABPP-CN > > Olivia Harner, PhD, ABPP > > David Anderson, PhD, ABPP-CN/CI > > Alexis D. Kulick, Ph.D., ABPP > > Lori Holt, PhD, ABPP-CN > > Joel S. Eppig, Ph.D. > > Delany Thrasher, Ph.D., ABPP-CN > > Annie Reader Murray, Ph.D., ABPP-CN > > Jeffrey M. Zulow, Ph.D. > > Kaitlin B. Casaletto, PhD, ABPP-CN > > Alexandra Apple, PhD > > Hope Goldberg, PhD, ABPP-CN > > William C. Hochberger, PhD > > Paul Mangal, PhD > > Virdette L. Brumm, Ph.D. > > Christy Hom, PhD, ABPdN > > Eric J. Freitag, PsyD, FACPN > > Howard J. Friedman, ABPP (CN), ABN > > Jonathan E. Romain, PhD, MS, ABPP-CN > > Patricia Gross, PhD, ABPP-CN > > Katie Denny PhD, ABPP-CN > > Katherine Bangen, PhD, ABPP-CN > > Lisa Graves, PhD > > John Knippa, PhD, ABN > > Ashley K. Miller, PhD, ABPP-CN > > Karen Hanson Bondi, Ph.D. > > Lori Alasantro, PhD, ABPP-CN > > Amanda Gooding, PhD, ABPP-CN > > Anita Herrera-Hamilton, Ph.D ABPP > > Caitlin Moore, PHD, ABPP > > William Britt, PhD, ABN > > Janet K. Brewer, JD, PsyD > > Mimi Wong, PhD, ABPP-CN > > Charles Furst, PhD, ABPP-CN > > Robert W. Elliott, PhD, ABCN, ABN > > Amy M. Schonfeld, PhD, Clinical Neuropsychologist > > Brian A. Osterweil, Ph.D., ABPP > > Duke Han, PhD, ABPP-CN > > Lisa Delano-Wood, PhD > > Kimberly Alfano, PhD, ABPP (CN, RP) > > Alena Stasenko, PhD > > Inna Fishman, PhD > > Annette Swain PhD ABPP-CN > > Monica Smith, PhD, ABN > > Mili Parikh, PhD, ABPP > > Charles H. Hinkin, Ph.D., ABPP-CN > > R. Dempsey, PsyD, ABPP, QME > > Margaret A. Donohue, PhD > > Samantha O'Bannon, Psy.D., Clinical Neuropsychologist PSY 32564 > > William T.J. Johnson, Ph.D., ABPP-CN > > Tony L. Strickland, MS, PhD, ABN, FNAN > > Emmanuel A. Zamora, Psy.D., Neuropsychologist > > Joshua McKeever, PhD, Clinical Neuropsychologist > > Carmen C. Velazquez, Ph.D. > > Anne Nolty, PhD, ABPP-CN > > Grace Mucci, PhD, ABPdN > > Tom Kiely, PhD > > Joel Kramer, PsyD, ABPP-CN > > Andrea Alioto, PhD, ABPP-CN > > Johanna Rengifo, PhD > > Ruth Serepca, PhD > > Abigail Kramer, PhD > > Sarah Banks, PhD, ABPP-CN > > Arnold D. Purisch, Ph.D., ABPP-CN, ABN > > Yuri Rassovsky, PhD, ABPP-CN > > Lauren Keats, PsyD > > Saskia DeVaughn, PhD, ABPP-CN > > Katie Beckwith, PhD, ABPP-CN > > Ashley Whitaker, PhD, ABPP-CN > > Christian Carter, Ph.D., ABPP-CN > > Melissa Balderrama, PsyD, ABPP > > Hannah Brunet, PhD, ABPP-CN > > Garima Lupas, PhD, ABPP, Board Certified in Clinical Neuropsychology > > James A. Moses, Ph.D., ABPP-CN/CL > > Bianca Georgescu, Psy.D., ABPP > > Brandon Gavett, Ph.D. ABPP-CN > > April Thames, PhD > > Michelle Conover, Ph.D., QME > > Daniel Jacobson, PhD, ABPP-CN > > Carlos Saucedo, PhD, ABPP-CN > > Sharon H. O'Neil, PhD, ABPP-CN > > Audrey Khatchikia, PhD > > Natalie C. Kelly, PhD, ABPP-CN > > Shital Pavawalla, Ph.D., ABPP-CN > > Alexander Tan, Ph.D., ABPP-CN > > Phuong M. Chau, PhD ABPP-CN > > Deborah Budding, Ph.D., ABN > > > > > > > > > > > > > > > > > > CAUTION:This email originated from outside of the organization. Do not > click links or open attachments unless you recognize the sender and know > the content is safe. > > > > > > > > CAUTION:This email originated from outside of the organization. Do not > click links or open attachments unless you recognize the sender and know > the content is safe. > > > > > > > > CAUTION: This email originated from outside of the organization. Do not > click links or open attachments unless you recognize the sender and know > the content is safe. > > > > > CAUTION: This email originated from outside of the organization. Do not > click links or open attachments unless you recognize the sender and know > the content is safe. > > > > CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
AI Analysis:
This message thread discusses Judge Lee Arian (Burbank, Dept B), Dr. Christine Naber, Dr. Boone, and the topic of compelling production of neuropsych DME raw data. There is no mention of Judge Goodman anywhere in the message or its quoted replies. The message contains no information useful for evaluating Goodman as a judge.
"Karen Jacobs" Date: February 25, 2026 7:48:00 PM Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal Reply to list Reply to sender Print List: caala-workproduct Sent by: Karen Jacobs (Reply Privately) Search Has anyone attempted to compel production of raw data in Burbank, Dept B, Judge Lee Arian? Any indication on how he's likely to rule? -----Original Message----- From: ssh@habbaspilaw.com Sent: February 20, 2026 4:23:00 PM To: caala-workproduct@lists.trialsmith.com Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal We just had Boone compelled to produce raw data based on Randy's Trucking. Immediately after she withdrew and the defense has yet to request a new one. Keep filing on this issue. Samer Habbas LAW OFFICES OF SAMER HABBAS 200 Spectrum Center Drive Suite 1230 Irvine, CA 92618 Tel: (949) 727-9300 Fax: (949) 727-9308 ssh@habbaspilaw.com www.habbaspilaw.com This communication, including attachments, is confidential, may be subject to legal privileges, and is intended for the sole use of the addressee. Any use, duplication, disclosure or dissemination of this communication, other than by the addressee, is prohibited. If you have received this communication in error, please notify the sender immediately and delete or destroy this communication and all copies. On Fri, Feb 20, 2026 at 3:00 PM Jennifer Bagosy (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> wrote: > *List:* caala-workproduct * Sent by:* Jennifer Bagosy (Reply Privately) > <jby@bhattorneys.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > Search <http://www.caala.org/index.cfm?pg=search> > Has anyone seen whether Dr. Christine Naber has ever produced raw data or > been ordered to? > > -----Original Message----- > > From: greg@justiceteam.com > Sent: February 09, 2026 3:33:00 PM > To: caala-workproduct@lists.trialsmith.com > Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal > > NICE, thank you Nareg!! I'll get this added to the Dropbox, I appreciate > the update and good luck with getting sanctions! > > > > > [cid:slg_oca_emailsignature_4s_1x1_v1_fc31d3c0-b93d-4153-a0d5-cad733aff375.gif] > Greg Jackson > Partner and Managing Attorney The Simon Law Group > > p: (855) 855-8910 f: (310) 914-5401 m: (714) 617-2180 > a: 2916 W 164th Street Torrance CA 90504 > <https://www.google.com/maps/search/2916+W+164th+Street+Torrance+CA+90504?entry=gmail&source=g> > w: www.JusticeTeam.com e: greg@justiceteam.com<mailto:%7BE-mail%7D> > Orange County ' Los Angeles ' Arizona ' Texas > > <https://www.facebook.com/TheSimonLawGroup> > [cid:instagram_32x32_3473fb9a-cef8-4bd0-89b9-ebad3ae209f4.png]< > https://www.instagram.com/thesimonlawgroup> > [cid:facebook_32x32_22f3b732-9ee9-4be2-89af-5f59b15a773c.png] < > https://www.facebook.com/TheSimonLawGroup> > [cid:linkedin_32x32_2f01fc51-e68d-4f7e-a219-1ce2be0d0f5e.png] < > https://www.linkedin.com/company/the-simon-law-group> > [cid:podcast-7858222_640_3b7e9899-d89c-4e5d-92d6-940be75f7bd5.png] < > https://justiceteampodcast.com/> > [cid:linktree_21c8e52f-1f37-476a-bbec-61b73bbfeb66.jpg] < > https://linktr.ee/JusticeTeam> > > > > This email and any files transmitted with it are confidential and intended > solely for the use of the individual or entity to whom they are addressed. > If you have received this email in error please notify the system manager. > Please note that any views or opinions presented in this email are solely > those of the author and do not necessarily represent those of the company. > Finally, the recipient should check this email and any attachments for the > presence of viruses. The company accepts no liability for any damage caused > by any virus transmitted by this email. > > > From: Nareg Kitsinian <nareg@kitsinianlaw.com> > Sent: Wednesday, February 4, 2026 2:29 PM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com> > Cc: Greg Jackson <greg@justiceteam.com> > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data > and Recusal > > Greg, > See attached, signed order, ordering Dr. Hungerford to produce raw data > etc. > Hungerford, did not recuse himself as he promised to do so in that > ridiculous declaration signed by other doctors. > > He did go through with the DME and interviewed my client after all, but > opted not to conduct his own testing and obtained the treating providers > raw data instead. I have asked that the raw data be turned over and OC > seems to think he is clever and is making the argument that the courts > order only applies if Hungerford did the testing. An ex parte to enforce > with sanctions is on its way. > > Please add the attached to your drop box. I'll let you know if Hungerford > sends us the raw data. > > > > > > > -- > > > [cid:image001.png@01DC99C8.7EA9ABF0][cid:image002.jpg@01DC99C8.7EA9ABF0] > > LATLC > > 2025 Secretary - 2029 President > > > Nareg S. Kitsinian, Esq. > Attorney at Law > > > nareg@kitsinianlaw.com<mailto:nareg@kitsinianlaw.com> > > www.kitsinianlaw.com<https://www.kitsinianlaw.com/> > > > Tel: (818)786-5777 ' Fax: (818)786-5778 > > > 16501 Ventura Blvd., Ste. 506, Encino, CA 91436 > <https://www.google.com/maps/search/16501+Ventura+Blvd.,+Ste.+506,+Encino,+CA+91436?entry=gmail&source=g> > <https://maps.app.goo.gl/tGQhp8PaYVZQ2VQaA> > > > > [cid:image003.png@01DC99C8.7EA9ABF0] < > https://www.facebook.com/kitsinianlaw> [cid:image004.png@01DC99C8.7EA9ABF0] > <https://www.linkedin.com/company/kitsinian-law-firm> > [cid:image005.png@01DC99C8.7EA9ABF0] < > https://www.instagram.com/kitsinianlawfirm/> > > > > > > > > ________________________________ > From: Gregory Jackson (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com<mailto: > listsender-caala-workproduct@lists.trialsmith.com>> > Sent: Thursday, November 20, 2025 3:27 PM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com<mailto: > caala-workproduct@lists.trialsmith.com>> > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data > and Recusal > > List: caala-workproduct Sent by: Gregory Jackson (Reply Privately)<mailto: > greg@justiceteam.com > ?subject=Re%3A%20%5Bcaala-workproduct%5D%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > > Search<http://www.caala.org/index.cfm?pg=search> > > > > > Added! > > > > > [cid:image006.gif@01DC99C8.7EA9ABF0] > > Greg Jackson > Partner and Managing Attorney The Simon Law Group > > p: (855) 855-8910 f: (310) 914-5401 m: (714) 617-2180 > a: 2916 W 164th Street Torrance CA 90504 > <https://www.google.com/maps/search/2916+W+164th+Street+Torrance+CA+90504?entry=gmail&source=g> > w: www.JusticeTeam.com<http://www.JusticeTeam.com> e: greg@justiceteam.com > <mailto:%7BE-mail%7D> > Orange County ' Los Angeles ' Arizona ' Texas > > > [cid:image007.png@01DC99C8.7EA9ABF0]< > https://www.instagram.com/thesimonlawgroup> > > [cid:image008.png@01DC99C8.7EA9ABF0]< > https://www.facebook.com/TheSimonLawGroup> > > [cid:image009.png@01DC99C8.7EA9ABF0]< > https://www.linkedin.com/company/the-simon-law-group> > > [cid:image010.png@01DC99C8.7EA9ABF0]<https://justiceteampodcast.com/> > > [cid:image011.jpg@01DC99C8.7EA9ABF0]<https://linktr.ee/JusticeTeam> > > > > > This email and any files transmitted with it are confidential and intended > solely for the use of the individual or entity to whom they are addressed. > If you have received this email in error please notify the system manager. > Please note that any views or opinions presented in this email are solely > those of the author and do not necessarily represent those of the company. > Finally, the recipient should check this email and any attachments for the > presence of viruses. The company accepts no liability for any damage caused > by any virus transmitted by this email. > > > > > From: Nareg Kitsinian (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com<mailto: > listsender-caala-workproduct@lists.trialsmith.com>> > Sent: Thursday, November 20, 2025 3:21 PM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com<mailto: > caala-workproduct@lists.trialsmith.com>> > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data > and Recusal > > > > List: caala-workproduct Sent by: Nareg Kitsinian (Reply Privately)<mailto: > nareg@kitsinianlaw.com > ?subject=Re%3A%20%5Bcaala-workproduct%5D%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > > > Search<http://www.caala.org/index.cfm?pg=search> > > > > > > Greg, attached is our LASC minute order from 3/25 compelling Filoteo who > did produce. Please add to your folder. > > > > > > > > -- > > > [cid:image001.png@01DC99C8.7EA9ABF0][cid:image002.jpg@01DC99C8.7EA9ABF0] > > LATLC > > 2025 Secretary - 2029 President > > > Nareg S. Kitsinian, Esq. > Attorney at Law > > > nareg@kitsinianlaw.com<mailto:nareg@kitsinianlaw.com> > > www.kitsinianlaw.com<https://www.kitsinianlaw.com/> > > > Tel: (818)786-5777 ' Fax: (818)786-5778 > > > 16501 Ventura Blvd., Ste. 506, Encino, CA 91436 > <https://www.google.com/maps/search/16501+Ventura+Blvd.,+Ste.+506,+Encino,+CA+91436?entry=gmail&source=g> > <https://maps.app.goo.gl/tGQhp8PaYVZQ2VQaA> > > > > [cid:image003.png@01DC99C8.7EA9ABF0] < > https://www.facebook.com/kitsinianlaw> [cid:image004.png@01DC99C8.7EA9ABF0] > <https://www.linkedin.com/company/kitsinian-law-firm> > [cid:image005.png@01DC99C8.7EA9ABF0] < > https://www.instagram.com/kitsinianlawfirm/> > > > > > > > > ________________________________ > > From: Gregory Jackson (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com<mailto: > listsender-caala-workproduct@lists.trialsmith.com>> > Sent: Thursday, November 20, 2025 3:01 PM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com<mailto: > caala-workproduct@lists.trialsmith.com>> > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data > and Recusal > > > > List: caala-workproduct Sent by: Gregory Jackson (Reply Privately)<mailto: > greg@justiceteam.com > ?subject=Re%3A%20%5Bcaala-workproduct%5D%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > > > Search<http://www.caala.org/index.cfm?pg=search> > > > > > > No problem! You'll see specific subfolders for a number of experts, some > oppositions, lot of stuff in there to use. For that huge declaration > defense is listing now, a number of those experts who signed off on it have > actually produced raw data anyway - so you can use these minute orders and > stipulations in the Dropbox to impeach it. > > > > > > > [cid:image006.gif@01DC99C8.7EA9ABF0] > > > Greg Jackson > Partner and Managing Attorney The Simon Law Group > > > p: (855) 855-8910 f: (310) 914-5401 m: (714) 617-2180 > a: 2916 W 164th Street Torrance CA 90504 > <https://www.google.com/maps/search/2916+W+164th+Street+Torrance+CA+90504?entry=gmail&source=g> > w: www.JusticeTeam.com<http://www.JusticeTeam.com> e: greg@justiceteam.com > <mailto:%7BE-mail%7D> > Orange County ' Los Angeles ' Arizona ' Texas > > > > > [cid:image007.png@01DC99C8.7EA9ABF0]< > https://www.instagram.com/thesimonlawgroup> > > > [cid:image008.png@01DC99C8.7EA9ABF0]< > https://www.facebook.com/TheSimonLawGroup> > > > [cid:image009.png@01DC99C8.7EA9ABF0]< > https://www.linkedin.com/company/the-simon-law-group> > > > [cid:image010.png@01DC99C8.7EA9ABF0]<https://justiceteampodcast.com/> > > > [cid:image011.jpg@01DC99C8.7EA9ABF0]<https://linktr.ee/JusticeTeam> > > > > > > This email and any files transmitted with it are confidential and intended > solely for the use of the individual or entity to whom they are addressed. > If you have received this email in error please notify the system manager. > Please note that any views or opinions presented in this email are solely > those of the author and do not necessarily represent those of the company. > Finally, the recipient should check this email and any attachments for the > presence of viruses. The company accepts no liability for any damage caused > by any virus transmitted by this email. > > > > > From: Nareg Kitsinian (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com<mailto: > listsender-caala-workproduct@lists.trialsmith.com>> > Sent: Thursday, November 20, 2025 2:45 PM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com<mailto: > caala-workproduct@lists.trialsmith.com>> > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data > and Recusal > > > > List:caala-workproduct Sent by: Nareg Kitsinian (Reply Privately)<mailto: > nareg@kitsinianlaw.com > ?subject=Re%3A%20%5Bcaala-workproduct%5D%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > > > Search<http://www.caala.org/index.cfm?pg=search> > > > > > > Greg, > > This - is awesome! I will send you the minute order when I have it. This > dropbox folder you have compiled is a treasure - really the nail in the > coffin. Everyone should be sharing their minute orders on this issue moving > forward. > > Thank you! > > -- > > > [cid:image001.png@01DC99C8.7EA9ABF0][cid:image002.jpg@01DC99C8.7EA9ABF0] > > LATLC > > 2025 Secretary - 2029 President > > > Nareg S. Kitsinian, Esq. > Attorney at Law > > > nareg@kitsinianlaw.com<mailto:nareg@kitsinianlaw.com> > > www.kitsinianlaw.com<https://www.kitsinianlaw.com/> > > > Tel: (818)786-5777 ' Fax: (818)786-5778 > > > 16501 Ventura Blvd., Ste. 506, Encino, CA 91436 > <https://www.google.com/maps/search/16501+Ventura+Blvd.,+Ste.+506,+Encino,+CA+91436?entry=gmail&source=g> > <https://maps.app.goo.gl/tGQhp8PaYVZQ2VQaA> > > > > [cid:image003.png@01DC99C8.7EA9ABF0] < > https://www.facebook.com/kitsinianlaw> [cid:image004.png@01DC99C8.7EA9ABF0] > <https://www.linkedin.com/company/kitsinian-law-firm> > [cid:image005.png@01DC99C8.7EA9ABF0] < > https://www.instagram.com/kitsinianlawfirm/> > > > > > > > > ________________________________ > > From: Gregory Jackson (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com<mailto: > listsender-caala-workproduct@lists.trialsmith.com>> > Sent: Thursday, November 20, 2025 2:10 PM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com<mailto: > caala-workproduct@lists.trialsmith.com>> > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data > and Recusal > > > > List:caala-workproduct Sent by: Gregory Jackson (Reply Privately)<mailto: > greg@justiceteam.com > ?subject=Re%3A%20%5Bcaala-workproduct%5D%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > > > Search<http://www.caala.org/index.cfm?pg=search> > > > > > > Nareg, > > > > Thank you for sharing this! Please keep us posted if Dr. Hungerford > proceeds with the exam and complies/produces the raw data so we can add him > to the list, and once you get the final minute order please circulate that > as well. > > > > Here is the Dropbox of neuropsych dirt I've compiled, check out the > 'Minute Orders' subfolder and there are at least a dozen in there including > 8 from this year. If you send me your final minute order once the court > posts it I'll add it to the Dropbox! > > > > > https://www.dropbox.com/scl/fo/c0pued3e3ftj4j0x88qji/ALFU7MTTieoSk3Dud4IyfHc?rlkey=67d52jz1uxzspr3mol96dfbkr&st=2kghiflq&dl=0 > > > > > > > > > [cid:image006.gif@01DC99C8.7EA9ABF0] > > > Greg Jackson > Partner and Managing Attorney The Simon Law Group > > > p: (855) 855-8910 f: (310) 914-5401 m: (714) 617-2180 > a: 2916 W 164th Street Torrance CA 90504 > <https://www.google.com/maps/search/2916+W+164th+Street+Torrance+CA+90504?entry=gmail&source=g> > w: www.JusticeTeam.com<http://www.JusticeTeam.com> e: greg@justiceteam.com > <mailto:%7BE-mail%7D> > Orange County ' Los Angeles ' Arizona ' Texas > > > > > [cid:image007.png@01DC99C8.7EA9ABF0]< > https://www.instagram.com/thesimonlawgroup> > > > [cid:image008.png@01DC99C8.7EA9ABF0]< > https://www.facebook.com/TheSimonLawGroup> > > > [cid:image009.png@01DC99C8.7EA9ABF0]< > https://www.linkedin.com/company/the-simon-law-group> > > > [cid:image010.png@01DC99C8.7EA9ABF0]<https://justiceteampodcast.com/> > > > [cid:image011.jpg@01DC99C8.7EA9ABF0]<https://linktr.ee/JusticeTeam> > > > > > > This email and any files transmitted with it are confidential and intended > solely for the use of the individual or entity to whom they are addressed. > If you have received this email in error please notify the system manager. > Please note that any views or opinions presented in this email are solely > those of the author and do not necessarily represent those of the company. > Finally, the recipient should check this email and any attachments for the > presence of viruses. The company accepts no liability for any damage caused > by any virus transmitted by this email. > > > > > From: Nareg Kitsinian (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com<mailto: > listsender-caala-workproduct@lists.trialsmith.com>> > Sent: Thursday, November 20, 2025 11:25 AM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com<mailto: > caala-workproduct@lists.trialsmith.com>> > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data > and Recusal > > > > List:caala-workproduct Sent by: Nareg Kitsinian (Reply Privately)<mailto: > nareg@kitsinianlaw.com > ?subject=Re%3A%20%5Bcaala-workproduct%5D%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > > > Search<http://www.caala.org/index.cfm?pg=search> > > > > > > We successfully opposed a motion to compel a mental exam with Dr. Lars > Hungerford today in San Bernardino Superior Court with Judge Joseph Widman. > He made all the right calls in line with Randys Trucking and compelled that > the raw data be turned over and plaintiff can record the examination. > > > > This hearing was different then past hearings. The defense play now is to > use this declaration that they say 94% of neuropsychs have signed attesting > they would recuse themselves if compelled to turn over data. It's > persuasive, but not enough to circumvent the law. > > > > In my motion I attached two minute orders/tentative rulings where LASC > courts also ruled in line with Randy Trucking. > > Concerningly, this prompted the defense to argue at the hearing that he > would like to lodge 10 other recent orders throughout CA that he has > collected that went in the opposite direction and did not compel > disclosure. Judge Widman did not buy the argument. But I raise this because > if 10 other courtrooms are still ruling against disclosure, it can be > problematic given the judge and we should begin collecting orders in all > superior courts where a judge rules with Randy Trucking so that they can be > Judicially Noticed in these motions. This is the second motion I have won > in the last 5 months on a TBI case. The law is with us, but it is striking > to me that 10 other courts recently ruled in another direction. > > > > Attached is our tentative ruling from this morning. I hope others will > share over time so we can use them as time passes. > > > > > > > > > > > > -- > > > [cid:image001.png@01DC99C8.7EA9ABF0][cid:image002.jpg@01DC99C8.7EA9ABF0] > > LATLC > > 2025 Secretary - 2029 President > > > Nareg S. Kitsinian, Esq. > Attorney at Law > > > nareg@kitsinianlaw.com<mailto:nareg@kitsinianlaw.com> > > www.kitsinianlaw.com<https://www.kitsinianlaw.com/> > > > Tel: (818)786-5777 ' Fax: (818)786-5778 > > > 16501 Ventura Blvd., Ste. 506, Encino, CA 91436 > <https://www.google.com/maps/search/16501+Ventura+Blvd.,+Ste.+506,+Encino,+CA+91436?entry=gmail&source=g> > <https://maps.app.goo.gl/tGQhp8PaYVZQ2VQaA> > > > > [cid:image003.png@01DC99C8.7EA9ABF0] < > https://www.facebook.com/kitsinianlaw> [cid:image004.png@01DC99C8.7EA9ABF0] > <https://www.linkedin.com/company/kitsinian-law-firm> > [cid:image005.png@01DC99C8.7EA9ABF0] < > https://www.instagram.com/kitsinianlawfirm/> > > > > > > > > ________________________________ > > From: Kane Handel (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com<mailto: > listsender-caala-workproduct@lists.trialsmith.com>> > Sent: Tuesday, November 4, 2025 11:05 AM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com<mailto: > caala-workproduct@lists.trialsmith.com>> > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data > and Recusal > > > > List:caala-workproduct Sent by: Kane Handel (Reply Privately)<mailto: > kanehandel33@gmail.com > ?subject=Re%3A%20%5Bcaala-workproduct%5D%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > > > Search<http://www.caala.org/index.cfm?pg=search> > > > > > > file a motion!!! > > On 11/4/25 9:44 AM, Nareg Kitsinian (caala-workproduct listserver) wrote: > > List:caala-workproduct Sent by: Nareg Kitsinian (Reply Privately)<mailto: > nareg@kitsinianlaw.com > ?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > > > Search<http://www.caala.org/index.cfm?pg=search> > > > > I have a TBI case where Dr. Hungerford has refused to provide the raw data > to me and is claiming in his declaration to withdraw if the court orders > him to turn over the data, citing this same declaration signed by 180 other > NeuroPsychs. Does anyone have any prior experience with Dr. Lars > Hungerford, perhaps agreeing to turn over raw data in the past that I can > use in our opposition? > Nareg > > -----Original Message----- > > From: antonio@ac3law.com<mailto:antonio@ac3law.com> > Sent: September 29, 2025 3:43:00 PM > To: caala-workproduct@lists.trialsmith.com<mailto: > caala-workproduct@lists.trialsmith.com> > Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal > > Interestingly, Delis isn't a signatory. > > On Fri, Sep 19, 2025 at 3:57 PM Delavar Omidfar (caala-workproduct > listserver) <listsender-caala-workproduct@lists.trialsmith.com><mailto: > listsender-caala-workproduct@lists.trialsmith.com> wrote: > > > *List:* caala-workproduct * Sent by:* Delavar Omidfar (Reply Privately) > > < > domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal > ><mailto:domidfar@makkabilaw.com > ?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > > Search <http://www.caala.org/index.cfm?pg=search>< > http://www.caala.org/index.cfm?pg=search> > > Andrew - Do you have the case information or copies of the App Case? > > > > > > -----Original Message----- > > > > From: andrew@a2zlegal.com<mailto:andrew@a2zlegal.com> > > Sent: September 17, 2025 6:35:00 PM > > To: caala-workproduct@lists.trialsmith.com<mailto: > caala-workproduct@lists.trialsmith.com> > > Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal > > > > This is nonsense. I had to take up a writ where the judge would not allow > > them to turn over the data to us and my writ was granted, court order > > reversed. If I remember correctly they included this garbage in their > > opposition as well but the Appellate Court did not buy it. > > > > <https://www.google.com/maps/search/1306+W.+Magnolia+Blvd.+%0D%0A+%0D%0A+Burbank,+CA+91506?entry=gmail&source=g> > > > > <https://www.google.com/maps/search/1306+W.+Magnolia+Blvd.+%0D%0A+%0D%0A+Burbank,+CA+91506?entry=gmail&source=g>> > Andrew Zeytuntsyan > > > > Founder / Trial Attorney > > > > [ > > > https://storage-use.letsignit.com/62705ddc173a9394d8bcc888/logo_62705ddc173a9394d8bcc888_e895719889494628d401a7b8776c8039.png > > ] > > > > 1306 W. Magnolia Blvd. > <https://www.google.com/maps/search/1306+W.+Magnolia+Blvd.+%0D%0A+%0D%0A+Burbank,+CA+91506?entry=gmail&source=g> > > > > Burbank, CA 91506 > <https://www.google.com/maps/search/1306+W.+Magnolia+Blvd.+%0D%0A+%0D%0A+Burbank,+CA+91506?entry=gmail&source=g> > > > > T. (323) 882-6500 > > > > F. (800) 506-7176 > > > > a2zlegal.com< > > > https://cloud.letsignit.com/collect/bc/627076c3c8565ddc6ca471ae?p=L3lrFhURv2eXFz8AUdcQMg7oZ5M7umbVf2WSzpdzFq7D1iSXrK3ZaujaqDpZOQqyzyjZl0xri-GrOODYWlP3QLZm0iplL-zlOXM4lSHQ28oSIcbvk9_JHfvcYEayMxKfUiuqgPOYkIcclIOWPouVUq8U-TmlvnN27_c7uQRHayw= > > > > > > > [ > > > https://storage-use.letsignit.com/62705ddc173a9394d8bcc888/253796901116998898398879131612511431317.png > > ] > > > > The information in this electronic mail message is confidential and for > > use of only the named recipient. The information may be protected by > > privilege, work product immunity or other applicable law. If you are not > > the intended recipient the retention, dissemination, distribution or > > copying of this e-mail message is strictly prohibited. If you receive > this > > message in error please notify us immediately. > > > > ________________________________ > > From: Delavar Omidfar (caala-workproduct listserver) < > > listsender-caala-workproduct@lists.trialsmith.com<mailto: > listsender-caala-workproduct@lists.trialsmith.com>> > > Sent: Friday, September 12, 2025 3:15 PM > > To: CAALA Work Product Discussion List < > > caala-workproduct@lists.trialsmith.com<mailto: > caala-workproduct@lists.trialsmith.com>> > > Subject: [caala-workproduct] Neuropsych Declaration re DME Raw Data and > > Recusal > > > > List: caala-workproduct Sent by: Delavar Omidfar (Reply > Privately)<mailto: > <mailto:%0b>> > domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal > <mailto:domidfar@makkabilaw.com > ?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal>> > > Search<http://www.caala.org/index.cfm?pg=search>< > http://www.caala.org/index.cfm?pg=search> > > > > > Mates, > > I was recently provided with the attached declaration signed by over 180 > > neuropsychologists and psychologists regarding the protection of > > psychological testing materials. Most importantly, all signatories have > > declared: > > > > "I would not agree to releasing protected test information that would > > jeopardize future use of tests to a non-psychologist, including > attorneys, > > even under a protective order. If this stipulation cannot be met, I would > > recuse myself from a case." > > > > My suspicion is that some of these same psychologists have previously > > agreed to perform mental examinations and released raw data under > > protective orders. If true, this creates a significant inconsistency that > > could be used to challenge their credibility and position. > > > > I'm reaching out to see if any of you have: > > > > 1. Documentation of any of these 185 signatories previously agreeing to > > release raw test data under protective order > > 2. Thoughts on strategies for overcoming this collective stance in future > > cases > > 3. Legal precedents, other than Randy's Trucking, that could compel > > production despite this declaration > > 4. Counter Declaration by psychs who can counter their arguments about > > test security > > > > The complete list of 185 signatories is below. Notable names include many > > prominent California neuropsychologists who regularly serve as defense > > experts, i.e. Hinkin, Boone, Kopald, Lechuga, Hooker, Bondi, Elliot, > Zamora. > > > > List of Signatories > > Catherine Marreiro, PhD, ABPP-CN > > Kyle Boone, PhD, ABPP-CN > > William McMullen Jr., PhD, ABPP-CN > > Delia M. Silva, Psy.D., ABPP-CN, Neuropsychologist > > Lauren Drag, PhD, ABPP-CN > > Maya Yutsis, PhD, ABPP-CN > > Katherine Kruser, Psy.D., Neuropsychologist > > Jeffrey Wertheimer, PhD, ABPP-CN > > Jay Rosen, PhD > > Michelle Zeller, Psy.D., ABPP-CN > > Deborah Cahn-Weiner, Ph.D., ABPP-CN > > Mi-Yeoung Jo, PsyD, ABPP-CN > > Talin Babikian, PhD, ABPP-CN > > Molly Memel, PhD, ABPP-CN > > Rebecca Goodman, PhD, ABPP-CN > > Haygoush Kalinian, PhD, Clinical Neuropsychologist > > Robert M. Bilder, PhD, ABPP-CN > > Robert Gray, PhD, ABPP-CN > > Amir Ramezani, PhD > > Leah Ellenberg, Ph. D., ABPP-CN > > Charles Filanosky, PhD, ABPP-RP > > Po-Haong Lu, PsyD > > Angela Eastvold, PhD, ABPP-CN > > Maura Mitrushina, Ph.D., ABPP-CN > > Ann Gottuso, PhD, ABPP-CN > > Gayle Deutsch, PhD, ABPP-CN > > Simon Tan PsyD, ABPP-CN > > Andrew Levine, PhD, ABPP-CN > > Ernest T. Bryant, PhD, ABPP-CN > > John Wager, PhD, ABPP-CN > > Dominique Kinney, PhD, ABPP-CN > > Brandon Kopald, Psy.D., ABPP-CN > > Frederick Hives II, PhD, ABPP-CN > > Lars Hungerford, PhD, ABPP-CN > > Karen L. Schiltz, PhD, Neuropsychologist > > Tara L. Victor, PhD, ABPP-CN > > Shelley Peery, PhD > > Karen Lau, PhD, ABPP-CN > > Robert Tomaszewski, PhD, ABPP-CN > > David M. Lechuga, PhD, ABPP, ABN > > Elma Chidekel, PhD, ABN, ABPdN > > William D. Hooker, Ph.D., ABN > > Dale Sherman, PhD, QME > > June Paltzer, PhD, ABPP-CN > > Karen Earnest, PhD, ABPP-CN > > John Bellone, PhD, ABPP-CN > > Erin Green-Krogmann, PhD, ABPP-CN > > Virginia Zuverza-Chavarria, PhD, ABPP-CN > > Kimberly Lanni, PhD, ABPP, Board Certified in Clinical Neuropsychology > > Mark Alfano, Ph.D., ABPP CN, RP > > Steve Nitch, Ph. D., ABPP-CN > > Kristina Agbayani, PhD, ABPP-CN > > Andrew L. Wong, PhD, ABPP-CN > > Jessica Foley, PhD, ABPP-CN > > Andrew Dean, Ph. D., ABPP-CN > > Allison R. Kaup, PhD > > Mark W. Bondi, PhD, ABPP-CN > > Jose M. Lafosse, Ph.D., ABPP-CN > > Philip Sayegh, PhD, MPH > > Sara Mason, PsyD > > Kimberly Miller, PhD, ABPP-CN > > Hayley Kristinsson, PsyD, ABPP-CN > > Michael H. Kabat, Ph.D., ABPP-CN > > Brigid Rose, PhD, ABPP-CN > > Roger Light, PhD, ABPP-CN > > Jeremy Jinkerson, PhD > > David D. O'Grady, Ph.D., ABPP-CN > > Anneliese Radke, Psy.D. > > Joanne M. Hamilton, ABPP-CN > > Travis G. Fogel, Ph.D., ABPP-CN > > Sarah Tomaszewski Farias, Ph.D. ABPP-CN > > Allyson C. Rosen, PhD, ABPP-CN > > Sabine Gysens, PhD > > George Kahle Henry, PhD. ABPP-CN > > Kirsty Bortnik, PhD, ABPP-CN > > Joelle Broffman, PsyD, ABPP-CN > > Kristin K. Jacobson, PsyD, ABPP-CN > > Alice Ruzicka, Ph.D., ABN > > Renee Low, Ph.D., ABN > > Stacy S Wilkins, PhD, ABPP/CN > > Christine M. Naber, PhD > > Aura Barragan, Psy.D. > > Richard L. Delmonico, PhD, Licensed Psychologist CA PSY12604, Clinical > > Neuropsychologist > > Lauren Bennett, PhD, ABPP-CN > > William J. Lynch, Ph.D., ABPP/CN, Licensed Psychologist [PSY 5151] > > Rujvi Kamat, PhD, ABPP-CN > > Krista Freeze, PhD, ABN > > Carrie R. McDonald, Ph.D., ABPP-CN > > Nancy A. Blum, Ph.D. > > Travis Shivley-Scott, PhD > > Karen Mikolic, PhD, ABN > > Talia Seider, PhD, ABPP-CN > > Heather Pedersen, PhD, ABPP-CN > > Michael DeBellis Psy.D., ABN > > Nicholas Thaler, PhD, ABPP-CN > > Caroline J. Grantz, PhD > > Philip K. Stenquist, Ph.D., ABPP-CN > > Brian Yochim, PhD, ABPP-CN > > Olivia Harner, PhD, ABPP > > David Anderson, PhD, ABPP-CN/CI > > Alexis D. Kulick, Ph.D., ABPP > > Lori Holt, PhD, ABPP-CN > > Joel S. Eppig, Ph.D. > > Delany Thrasher, Ph.D., ABPP-CN > > Annie Reader Murray, Ph.D., ABPP-CN > > Jeffrey M. Zulow, Ph.D. > > Kaitlin B. Casaletto, PhD, ABPP-CN > > Alexandra Apple, PhD > > Hope Goldberg, PhD, ABPP-CN > > William C. Hochberger, PhD > > Paul Mangal, PhD > > Virdette L. Brumm, Ph.D. > > Christy Hom, PhD, ABPdN > > Eric J. Freitag, PsyD, FACPN > > Howard J. Friedman, ABPP (CN), ABN > > Jonathan E. Romain, PhD, MS, ABPP-CN > > Patricia Gross, PhD, ABPP-CN > > Katie Denny PhD, ABPP-CN > > Katherine Bangen, PhD, ABPP-CN > > Lisa Graves, PhD > > John Knippa, PhD, ABN > > Ashley K. Miller, PhD, ABPP-CN > > Karen Hanson Bondi, Ph.D. > > Lori Alasantro, PhD, ABPP-CN > > Amanda Gooding, PhD, ABPP-CN > > Anita Herrera-Hamilton, Ph.D ABPP > > Caitlin Moore, PHD, ABPP > > William Britt, PhD, ABN > > Janet K. Brewer, JD, PsyD > > Mimi Wong, PhD, ABPP-CN > > Charles Furst, PhD, ABPP-CN > > Robert W. Elliott, PhD, ABCN, ABN > > Amy M. Schonfeld, PhD, Clinical Neuropsychologist > > Brian A. Osterweil, Ph.D., ABPP > > Duke Han, PhD, ABPP-CN > > Lisa Delano-Wood, PhD > > Kimberly Alfano, PhD, ABPP (CN, RP) > > Alena Stasenko, PhD > > Inna Fishman, PhD > > Annette Swain PhD ABPP-CN > > Monica Smith, PhD, ABN > > Mili Parikh, PhD, ABPP > > Charles H. Hinkin, Ph.D., ABPP-CN > > R. Dempsey, PsyD, ABPP, QME > > Margaret A. Donohue, PhD > > Samantha O'Bannon, Psy.D., Clinical Neuropsychologist PSY 32564 > > William T.J. Johnson, Ph.D., ABPP-CN > > Tony L. Strickland, MS, PhD, ABN, FNAN > > Emmanuel A. Zamora, Psy.D., Neuropsychologist > > Joshua McKeever, PhD, Clinical Neuropsychologist > > Carmen C. Velazquez, Ph.D. > > Anne Nolty, PhD, ABPP-CN > > Grace Mucci, PhD, ABPdN > > Tom Kiely, PhD > > Joel Kramer, PsyD, ABPP-CN > > Andrea Alioto, PhD, ABPP-CN > > Johanna Rengifo, PhD > > Ruth Serepca, PhD > > Abigail Kramer, PhD > > Sarah Banks, PhD, ABPP-CN > > Arnold D. Purisch, Ph.D., ABPP-CN, ABN > > Yuri Rassovsky, PhD, ABPP-CN > > Lauren Keats, PsyD > > Saskia DeVaughn, PhD, ABPP-CN > > Katie Beckwith, PhD, ABPP-CN > > Ashley Whitaker, PhD, ABPP-CN > > Christian Carter, Ph.D., ABPP-CN > > Melissa Balderrama, PsyD, ABPP > > Hannah Brunet, PhD, ABPP-CN > > Garima Lupas, PhD, ABPP, Board Certified in Clinical Neuropsychology > > James A. Moses, Ph.D., ABPP-CN/CL > > Bianca Georgescu, Psy.D., ABPP > > Brandon Gavett, Ph.D. ABPP-CN > > April Thames, PhD > > Michelle Conover, Ph.D., QME > > Daniel Jacobson, PhD, ABPP-CN > > Carlos Saucedo, PhD, ABPP-CN > > Sharon H. O'Neil, PhD, ABPP-CN > > Audrey Khatchikia, PhD > > Natalie C. Kelly, PhD, ABPP-CN > > Shital Pavawalla, Ph.D., ABPP-CN > > Alexander Tan, Ph.D., ABPP-CN > > Phuong M. Chau, PhD ABPP-CN > > Deborah Budding, Ph.D., ABN > > > > > > > > > > > > > > > > > > CAUTION:This email originated from outside of the organization. Do not > click links or open attachments unless you recognize the sender and know > the content is safe. > > > > > > > > CAUTION:This email originated from outside of the organization. Do not > click links or open attachments unless you recognize the sender and know > the content is safe. > > > > > > > > CAUTION: This email originated from outside of the organization. Do not > click links or open attachments unless you recognize the sender and know > the content is safe. > > > > > CAUTION: This email originated from outside of the organization. Do not > click links or open attachments unless you recognize the sender and know > the content is safe. > > > >
AI Analysis:
This message does not mention Judge Goodman at all. It is a discussion among attorneys about Dr. Christine Naber producing raw neuropsychological data, DME raw data, sanctions, and a Dropbox file share. The thread involves Jennifer Bagosy and Greg Jackson discussing a neuropsych declaration matter. There is no reference to Judge Goodman, their rulings, courtroom behavior, or any cases before them.
"Jennifer Bagosy" Date: February 20, 2026 4:00:00 PM Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal Reply to list Reply to sender Print List: caala-workproduct Sent by: Jennifer Bagosy (Reply Privately) Search Has anyone seen whether Dr. Christine Naber has ever produced raw data or been ordered to? -----Original Message----- From: greg@justiceteam.com Sent: February 09, 2026 3:33:00 PM To: caala-workproduct@lists.trialsmith.com Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal NICE, thank you Nareg!! I'll get this added to the Dropbox, I appreciate the update and good luck with getting sanctions! [cid:slg_oca_emailsignature_4s_1x1_v1_fc31d3c0-b93d-4153-a0d5-cad733aff375.gif] Greg Jackson Partner and Managing Attorney The Simon Law Group p: (855) 855-8910 f: (310) 914-5401 m: (714) 617-2180 a: 2916 W 164th Street Torrance CA 90504 w: www.JusticeTeam.com e: greg@justiceteam.com<mailto:%7BE-mail%7D> Orange County ' Los Angeles ' Arizona ' Texas <https://www.facebook.com/TheSimonLawGroup> [cid:instagram_32x32_3473fb9a-cef8-4bd0-89b9-ebad3ae209f4.png]<https://www.instagram.com/thesimonlawgroup> [cid:facebook_32x32_22f3b732-9ee9-4be2-89af-5f59b15a773c.png] <https://www.facebook.com/TheSimonLawGroup> [cid:linkedin_32x32_2f01fc51-e68d-4f7e-a219-1ce2be0d0f5e.png] <https://www.linkedin.com/company/the-simon-law-group> [cid:podcast-7858222_640_3b7e9899-d89c-4e5d-92d6-940be75f7bd5.png] <https://justiceteampodcast.com/> [cid:linktree_21c8e52f-1f37-476a-bbec-61b73bbfeb66.jpg] <https://linktr.ee/JusticeTeam> This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of the company. Finally, the recipient should check this email and any attachments for the presence of viruses. The company accepts no liability for any damage caused by any virus transmitted by this email. From: Nareg Kitsinian <nareg@kitsinianlaw.com> Sent: Wednesday, February 4, 2026 2:29 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Cc: Greg Jackson <greg@justiceteam.com> Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal Greg, See attached, signed order, ordering Dr. Hungerford to produce raw data etc. Hungerford, did not recuse himself as he promised to do so in that ridiculous declaration signed by other doctors. He did go through with the DME and interviewed my client after all, but opted not to conduct his own testing and obtained the treating providers raw data instead. I have asked that the raw data be turned over and OC seems to think he is clever and is making the argument that the courts order only applies if Hungerford did the testing. An ex parte to enforce with sanctions is on its way. Please add the attached to your drop box. I'll let you know if Hungerford sends us the raw data. -- [cid:image001.png@01DC99C8.7EA9ABF0][cid:image002.jpg@01DC99C8.7EA9ABF0] LATLC 2025 Secretary - 2029 President Nareg S. Kitsinian, Esq. Attorney at Law nareg@kitsinianlaw.com<mailto:nareg@kitsinianlaw.com> www.kitsinianlaw.com<https://www.kitsinianlaw.com/> Tel: (818)786-5777 ' Fax: (818)786-5778 16501 Ventura Blvd., Ste. 506, Encino, CA 91436<https://maps.app.goo.gl/tGQhp8PaYVZQ2VQaA> [cid:image003.png@01DC99C8.7EA9ABF0] <https://www.facebook.com/kitsinianlaw> [cid:image004.png@01DC99C8.7EA9ABF0] <https://www.linkedin.com/company/kitsinian-law-firm> [cid:image005.png@01DC99C8.7EA9ABF0] <https://www.instagram.com/kitsinianlawfirm/> ________________________________ From: Gregory Jackson (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com<mailto:listsender-caala-workproduct@lists.trialsmith.com>> Sent: Thursday, November 20, 2025 3:27 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com<mailto:caala-workproduct@lists.trialsmith.com>> Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Gregory Jackson (Reply Privately)<mailto:greg@justiceteam.com?subject=Re%3A%20%5Bcaala-workproduct%5D%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> Search<http://www.caala.org/index.cfm?pg=search> Added! [cid:image006.gif@01DC99C8.7EA9ABF0] Greg Jackson Partner and Managing Attorney The Simon Law Group p: (855) 855-8910 f: (310) 914-5401 m: (714) 617-2180 a: 2916 W 164th Street Torrance CA 90504 w: www.JusticeTeam.com<http://www.JusticeTeam.com> e: greg@justiceteam.com<mailto:%7BE-mail%7D> Orange County ' Los Angeles ' Arizona ' Texas [cid:image007.png@01DC99C8.7EA9ABF0]<https://www.instagram.com/thesimonlawgroup> [cid:image008.png@01DC99C8.7EA9ABF0]<https://www.facebook.com/TheSimonLawGroup> [cid:image009.png@01DC99C8.7EA9ABF0]<https://www.linkedin.com/company/the-simon-law-group> [cid:image010.png@01DC99C8.7EA9ABF0]<https://justiceteampodcast.com/> [cid:image011.jpg@01DC99C8.7EA9ABF0]<https://linktr.ee/JusticeTeam> This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of the company. Finally, the recipient should check this email and any attachments for the presence of viruses. The company accepts no liability for any damage caused by any virus transmitted by this email. From: Nareg Kitsinian (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com<mailto:listsender-caala-workproduct@lists.trialsmith.com>> Sent: Thursday, November 20, 2025 3:21 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com<mailto:caala-workproduct@lists.trialsmith.com>> Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Nareg Kitsinian (Reply Privately)<mailto:nareg@kitsinianlaw.com?subject=Re%3A%20%5Bcaala-workproduct%5D%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> Search<http://www.caala.org/index.cfm?pg=search> Greg, attached is our LASC minute order from 3/25 compelling Filoteo who did produce. Please add to your folder. -- [cid:image001.png@01DC99C8.7EA9ABF0][cid:image002.jpg@01DC99C8.7EA9ABF0] LATLC 2025 Secretary - 2029 President Nareg S. Kitsinian, Esq. Attorney at Law nareg@kitsinianlaw.com<mailto:nareg@kitsinianlaw.com> www.kitsinianlaw.com<https://www.kitsinianlaw.com/> Tel: (818)786-5777 ' Fax: (818)786-5778 16501 Ventura Blvd., Ste. 506, Encino, CA 91436<https://maps.app.goo.gl/tGQhp8PaYVZQ2VQaA> [cid:image003.png@01DC99C8.7EA9ABF0] <https://www.facebook.com/kitsinianlaw> [cid:image004.png@01DC99C8.7EA9ABF0] <https://www.linkedin.com/company/kitsinian-law-firm> [cid:image005.png@01DC99C8.7EA9ABF0] <https://www.instagram.com/kitsinianlawfirm/> ________________________________ From: Gregory Jackson (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com<mailto:listsender-caala-workproduct@lists.trialsmith.com>> Sent: Thursday, November 20, 2025 3:01 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com<mailto:caala-workproduct@lists.trialsmith.com>> Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Gregory Jackson (Reply Privately)<mailto:greg@justiceteam.com?subject=Re%3A%20%5Bcaala-workproduct%5D%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> Search<http://www.caala.org/index.cfm?pg=search> No problem! You'll see specific subfolders for a number of experts, some oppositions, lot of stuff in there to use. For that huge declaration defense is listing now, a number of those experts who signed off on it have actually produced raw data anyway - so you can use these minute orders and stipulations in the Dropbox to impeach it. [cid:image006.gif@01DC99C8.7EA9ABF0] Greg Jackson Partner and Managing Attorney The Simon Law Group p: (855) 855-8910 f: (310) 914-5401 m: (714) 617-2180 a: 2916 W 164th Street Torrance CA 90504 w: www.JusticeTeam.com<http://www.JusticeTeam.com> e: greg@justiceteam.com<mailto:%7BE-mail%7D> Orange County ' Los Angeles ' Arizona ' Texas [cid:image007.png@01DC99C8.7EA9ABF0]<https://www.instagram.com/thesimonlawgroup> [cid:image008.png@01DC99C8.7EA9ABF0]<https://www.facebook.com/TheSimonLawGroup> [cid:image009.png@01DC99C8.7EA9ABF0]<https://www.linkedin.com/company/the-simon-law-group> [cid:image010.png@01DC99C8.7EA9ABF0]<https://justiceteampodcast.com/> [cid:image011.jpg@01DC99C8.7EA9ABF0]<https://linktr.ee/JusticeTeam> This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of the company. Finally, the recipient should check this email and any attachments for the presence of viruses. The company accepts no liability for any damage caused by any virus transmitted by this email. From: Nareg Kitsinian (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com<mailto:listsender-caala-workproduct@lists.trialsmith.com>> Sent: Thursday, November 20, 2025 2:45 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com<mailto:caala-workproduct@lists.trialsmith.com>> Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List:caala-workproduct Sent by: Nareg Kitsinian (Reply Privately)<mailto:nareg@kitsinianlaw.com?subject=Re%3A%20%5Bcaala-workproduct%5D%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> Search<http://www.caala.org/index.cfm?pg=search> Greg, This - is awesome! I will send you the minute order when I have it. This dropbox folder you have compiled is a treasure - really the nail in the coffin. Everyone should be sharing their minute orders on this issue moving forward. Thank you! -- [cid:image001.png@01DC99C8.7EA9ABF0][cid:image002.jpg@01DC99C8.7EA9ABF0] LATLC 2025 Secretary - 2029 President Nareg S. Kitsinian, Esq. Attorney at Law nareg@kitsinianlaw.com<mailto:nareg@kitsinianlaw.com> www.kitsinianlaw.com<https://www.kitsinianlaw.com/> Tel: (818)786-5777 ' Fax: (818)786-5778 16501 Ventura Blvd., Ste. 506, Encino, CA 91436<https://maps.app.goo.gl/tGQhp8PaYVZQ2VQaA> [cid:image003.png@01DC99C8.7EA9ABF0] <https://www.facebook.com/kitsinianlaw> [cid:image004.png@01DC99C8.7EA9ABF0] <https://www.linkedin.com/company/kitsinian-law-firm> [cid:image005.png@01DC99C8.7EA9ABF0] <https://www.instagram.com/kitsinianlawfirm/> ________________________________ From: Gregory Jackson (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com<mailto:listsender-caala-workproduct@lists.trialsmith.com>> Sent: Thursday, November 20, 2025 2:10 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com<mailto:caala-workproduct@lists.trialsmith.com>> Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List:caala-workproduct Sent by: Gregory Jackson (Reply Privately)<mailto:greg@justiceteam.com?subject=Re%3A%20%5Bcaala-workproduct%5D%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> Search<http://www.caala.org/index.cfm?pg=search> Nareg, Thank you for sharing this! Please keep us posted if Dr. Hungerford proceeds with the exam and complies/produces the raw data so we can add him to the list, and once you get the final minute order please circulate that as well. Here is the Dropbox of neuropsych dirt I've compiled, check out the 'Minute Orders' subfolder and there are at least a dozen in there including 8 from this year. If you send me your final minute order once the court posts it I'll add it to the Dropbox! https://www.dropbox.com/scl/fo/c0pued3e3ftj4j0x88qji/ALFU7MTTieoSk3Dud4IyfHc?rlkey=67d52jz1uxzspr3mol96dfbkr&st=2kghiflq&dl=0 [cid:image006.gif@01DC99C8.7EA9ABF0] Greg Jackson Partner and Managing Attorney The Simon Law Group p: (855) 855-8910 f: (310) 914-5401 m: (714) 617-2180 a: 2916 W 164th Street Torrance CA 90504 w: www.JusticeTeam.com<http://www.JusticeTeam.com> e: greg@justiceteam.com<mailto:%7BE-mail%7D> Orange County ' Los Angeles ' Arizona ' Texas [cid:image007.png@01DC99C8.7EA9ABF0]<https://www.instagram.com/thesimonlawgroup> [cid:image008.png@01DC99C8.7EA9ABF0]<https://www.facebook.com/TheSimonLawGroup> [cid:image009.png@01DC99C8.7EA9ABF0]<https://www.linkedin.com/company/the-simon-law-group> [cid:image010.png@01DC99C8.7EA9ABF0]<https://justiceteampodcast.com/> [cid:image011.jpg@01DC99C8.7EA9ABF0]<https://linktr.ee/JusticeTeam> This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of the company. Finally, the recipient should check this email and any attachments for the presence of viruses. The company accepts no liability for any damage caused by any virus transmitted by this email. From: Nareg Kitsinian (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com<mailto:listsender-caala-workproduct@lists.trialsmith.com>> Sent: Thursday, November 20, 2025 11:25 AM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com<mailto:caala-workproduct@lists.trialsmith.com>> Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List:caala-workproduct Sent by: Nareg Kitsinian (Reply Privately)<mailto:nareg@kitsinianlaw.com?subject=Re%3A%20%5Bcaala-workproduct%5D%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> Search<http://www.caala.org/index.cfm?pg=search> We successfully opposed a motion to compel a mental exam with Dr. Lars Hungerford today in San Bernardino Superior Court with Judge Joseph Widman. He made all the right calls in line with Randys Trucking and compelled that the raw data be turned over and plaintiff can record the examination. This hearing was different then past hearings. The defense play now is to use this declaration that they say 94% of neuropsychs have signed attesting they would recuse themselves if compelled to turn over data. It's persuasive, but not enough to circumvent the law. In my motion I attached two minute orders/tentative rulings where LASC courts also ruled in line with Randy Trucking. Concerningly, this prompted the defense to argue at the hearing that he would like to lodge 10 other recent orders throughout CA that he has collected that went in the opposite direction and did not compel disclosure. Judge Widman did not buy the argument. But I raise this because if 10 other courtrooms are still ruling against disclosure, it can be problematic given the judge and we should begin collecting orders in all superior courts where a judge rules with Randy Trucking so that they can be Judicially Noticed in these motions. This is the second motion I have won in the last 5 months on a TBI case. The law is with us, but it is striking to me that 10 other courts recently ruled in another direction. Attached is our tentative ruling from this morning. I hope others will share over time so we can use them as time passes. -- [cid:image001.png@01DC99C8.7EA9ABF0][cid:image002.jpg@01DC99C8.7EA9ABF0] LATLC 2025 Secretary - 2029 President Nareg S. Kitsinian, Esq. Attorney at Law nareg@kitsinianlaw.com<mailto:nareg@kitsinianlaw.com> www.kitsinianlaw.com<https://www.kitsinianlaw.com/> Tel: (818)786-5777 ' Fax: (818)786-5778 16501 Ventura Blvd., Ste. 506, Encino, CA 91436<https://maps.app.goo.gl/tGQhp8PaYVZQ2VQaA> [cid:image003.png@01DC99C8.7EA9ABF0] <https://www.facebook.com/kitsinianlaw> [cid:image004.png@01DC99C8.7EA9ABF0] <https://www.linkedin.com/company/kitsinian-law-firm> [cid:image005.png@01DC99C8.7EA9ABF0] <https://www.instagram.com/kitsinianlawfirm/> ________________________________ From: Kane Handel (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com<mailto:listsender-caala-workproduct@lists.trialsmith.com>> Sent: Tuesday, November 4, 2025 11:05 AM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com<mailto:caala-workproduct@lists.trialsmith.com>> Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List:caala-workproduct Sent by: Kane Handel (Reply Privately)<mailto:kanehandel33@gmail.com?subject=Re%3A%20%5Bcaala-workproduct%5D%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> Search<http://www.caala.org/index.cfm?pg=search> file a motion!!! On 11/4/25 9:44 AM, Nareg Kitsinian (caala-workproduct listserver) wrote: List:caala-workproduct Sent by: Nareg Kitsinian (Reply Privately)<mailto:nareg@kitsinianlaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> Search<http://www.caala.org/index.cfm?pg=search> I have a TBI case where Dr. Hungerford has refused to provide the raw data to me and is claiming in his declaration to withdraw if the court orders him to turn over the data, citing this same declaration signed by 180 other NeuroPsychs. Does anyone have any prior experience with Dr. Lars Hungerford, perhaps agreeing to turn over raw data in the past that I can use in our opposition? Nareg -----Original Message----- From: antonio@ac3law.com<mailto:antonio@ac3law.com> Sent: September 29, 2025 3:43:00 PM To: caala-workproduct@lists.trialsmith.com<mailto:caala-workproduct@lists.trialsmith.com> Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal Interestingly, Delis isn't a signatory. On Fri, Sep 19, 2025 at 3:57 PM Delavar Omidfar (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com><mailto:listsender-caala-workproduct@lists.trialsmith.com> wrote: > *List:* caala-workproduct * Sent by:* Delavar Omidfar (Reply Privately) > <domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal><mailto:domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > Search <http://www.caala.org/index.cfm?pg=search><http://www.caala.org/index.cfm?pg=search> > Andrew - Do you have the case information or copies of the App Case? > > > -----Original Message----- > > From: andrew@a2zlegal.com<mailto:andrew@a2zlegal.com> > Sent: September 17, 2025 6:35:00 PM > To: caala-workproduct@lists.trialsmith.com<mailto:caala-workproduct@lists.trialsmith.com> > Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal > > This is nonsense. I had to take up a writ where the judge would not allow > them to turn over the data to us and my writ was granted, court order > reversed. If I remember correctly they included this garbage in their > opposition as well but the Appellate Court did not buy it. > > > Andrew Zeytuntsyan > > Founder / Trial Attorney > > [ > https://storage-use.letsignit.com/62705ddc173a9394d8bcc888/logo_62705ddc173a9394d8bcc888_e895719889494628d401a7b8776c8039.png > ] > > 1306 W. Magnolia Blvd. > > Burbank, CA 91506 > > T. (323) 882-6500 > > F. (800) 506-7176 > > a2zlegal.com< > https://cloud.letsignit.com/collect/bc/627076c3c8565ddc6ca471ae?p=L3lrFhURv2eXFz8AUdcQMg7oZ5M7umbVf2WSzpdzFq7D1iSXrK3ZaujaqDpZOQqyzyjZl0xri-GrOODYWlP3QLZm0iplL-zlOXM4lSHQ28oSIcbvk9_JHfvcYEayMxKfUiuqgPOYkIcclIOWPouVUq8U-TmlvnN27_c7uQRHayw= > > > > [ > https://storage-use.letsignit.com/62705ddc173a9394d8bcc888/253796901116998898398879131612511431317.png > ] > > The information in this electronic mail message is confidential and for > use of only the named recipient. The information may be protected by > privilege, work product immunity or other applicable law. If you are not > the intended recipient the retention, dissemination, distribution or > copying of this e-mail message is strictly prohibited. If you receive this > message in error please notify us immediately. > > ________________________________ > From: Delavar Omidfar (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com<mailto:listsender-caala-workproduct@lists.trialsmith.com>> > Sent: Friday, September 12, 2025 3:15 PM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com<mailto:caala-workproduct@lists.trialsmith.com>> > Subject: [caala-workproduct] Neuropsych Declaration re DME Raw Data and > Recusal > > List: caala-workproduct Sent by: Delavar Omidfar (Reply Privately)<mailto: <mailto:%0b>> domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal<mailto:domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal>> > Search<http://www.caala.org/index.cfm?pg=search><http://www.caala.org/index.cfm?pg=search> > > Mates, > I was recently provided with the attached declaration signed by over 180 > neuropsychologists and psychologists regarding the protection of > psychological testing materials. Most importantly, all signatories have > declared: > > "I would not agree to releasing protected test information that would > jeopardize future use of tests to a non-psychologist, including attorneys, > even under a protective order. If this stipulation cannot be met, I would > recuse myself from a case." > > My suspicion is that some of these same psychologists have previously > agreed to perform mental examinations and released raw data under > protective orders. If true, this creates a significant inconsistency that > could be used to challenge their credibility and position. > > I'm reaching out to see if any of you have: > > 1. Documentation of any of these 185 signatories previously agreeing to > release raw test data under protective order > 2. Thoughts on strategies for overcoming this collective stance in future > cases > 3. Legal precedents, other than Randy's Trucking, that could compel > production despite this declaration > 4. Counter Declaration by psychs who can counter their arguments about > test security > > The complete list of 185 signatories is below. Notable names include many > prominent California neuropsychologists who regularly serve as defense > experts, i.e. Hinkin, Boone, Kopald, Lechuga, Hooker, Bondi, Elliot, Zamora. > > List of Signatories > Catherine Marreiro, PhD, ABPP-CN > Kyle Boone, PhD, ABPP-CN > William McMullen Jr., PhD, ABPP-CN > Delia M. Silva, Psy.D., ABPP-CN, Neuropsychologist > Lauren Drag, PhD, ABPP-CN > Maya Yutsis, PhD, ABPP-CN > Katherine Kruser, Psy.D., Neuropsychologist > Jeffrey Wertheimer, PhD, ABPP-CN > Jay Rosen, PhD > Michelle Zeller, Psy.D., ABPP-CN > Deborah Cahn-Weiner, Ph.D., ABPP-CN > Mi-Yeoung Jo, PsyD, ABPP-CN > Talin Babikian, PhD, ABPP-CN > Molly Memel, PhD, ABPP-CN > Rebecca Goodman, PhD, ABPP-CN > Haygoush Kalinian, PhD, Clinical Neuropsychologist > Robert M. Bilder, PhD, ABPP-CN > Robert Gray, PhD, ABPP-CN > Amir Ramezani, PhD > Leah Ellenberg, Ph. D., ABPP-CN > Charles Filanosky, PhD, ABPP-RP > Po-Haong Lu, PsyD > Angela Eastvold, PhD, ABPP-CN > Maura Mitrushina, Ph.D., ABPP-CN > Ann Gottuso, PhD, ABPP-CN > Gayle Deutsch, PhD, ABPP-CN > Simon Tan PsyD, ABPP-CN > Andrew Levine, PhD, ABPP-CN > Ernest T. Bryant, PhD, ABPP-CN > John Wager, PhD, ABPP-CN > Dominique Kinney, PhD, ABPP-CN > Brandon Kopald, Psy.D., ABPP-CN > Frederick Hives II, PhD, ABPP-CN > Lars Hungerford, PhD, ABPP-CN > Karen L. Schiltz, PhD, Neuropsychologist > Tara L. Victor, PhD, ABPP-CN > Shelley Peery, PhD > Karen Lau, PhD, ABPP-CN > Robert Tomaszewski, PhD, ABPP-CN > David M. Lechuga, PhD, ABPP, ABN > Elma Chidekel, PhD, ABN, ABPdN > William D. Hooker, Ph.D., ABN > Dale Sherman, PhD, QME > June Paltzer, PhD, ABPP-CN > Karen Earnest, PhD, ABPP-CN > John Bellone, PhD, ABPP-CN > Erin Green-Krogmann, PhD, ABPP-CN > Virginia Zuverza-Chavarria, PhD, ABPP-CN > Kimberly Lanni, PhD, ABPP, Board Certified in Clinical Neuropsychology > Mark Alfano, Ph.D., ABPP CN, RP > Steve Nitch, Ph. D., ABPP-CN > Kristina Agbayani, PhD, ABPP-CN > Andrew L. Wong, PhD, ABPP-CN > Jessica Foley, PhD, ABPP-CN > Andrew Dean, Ph. D., ABPP-CN > Allison R. Kaup, PhD > Mark W. Bondi, PhD, ABPP-CN > Jose M. Lafosse, Ph.D., ABPP-CN > Philip Sayegh, PhD, MPH > Sara Mason, PsyD > Kimberly Miller, PhD, ABPP-CN > Hayley Kristinsson, PsyD, ABPP-CN > Michael H. Kabat, Ph.D., ABPP-CN > Brigid Rose, PhD, ABPP-CN > Roger Light, PhD, ABPP-CN > Jeremy Jinkerson, PhD > David D. O'Grady, Ph.D., ABPP-CN > Anneliese Radke, Psy.D. > Joanne M. Hamilton, ABPP-CN > Travis G. Fogel, Ph.D., ABPP-CN > Sarah Tomaszewski Farias, Ph.D. ABPP-CN > Allyson C. Rosen, PhD, ABPP-CN > Sabine Gysens, PhD > George Kahle Henry, PhD. ABPP-CN > Kirsty Bortnik, PhD, ABPP-CN > Joelle Broffman, PsyD, ABPP-CN > Kristin K. Jacobson, PsyD, ABPP-CN > Alice Ruzicka, Ph.D., ABN > Renee Low, Ph.D., ABN > Stacy S Wilkins, PhD, ABPP/CN > Christine M. Naber, PhD > Aura Barragan, Psy.D. > Richard L. Delmonico, PhD, Licensed Psychologist CA PSY12604, Clinical > Neuropsychologist > Lauren Bennett, PhD, ABPP-CN > William J. Lynch, Ph.D., ABPP/CN, Licensed Psychologist [PSY 5151] > Rujvi Kamat, PhD, ABPP-CN > Krista Freeze, PhD, ABN > Carrie R. McDonald, Ph.D., ABPP-CN > Nancy A. Blum, Ph.D. > Travis Shivley-Scott, PhD > Karen Mikolic, PhD, ABN > Talia Seider, PhD, ABPP-CN > Heather Pedersen, PhD, ABPP-CN > Michael DeBellis Psy.D., ABN > Nicholas Thaler, PhD, ABPP-CN > Caroline J. Grantz, PhD > Philip K. Stenquist, Ph.D., ABPP-CN > Brian Yochim, PhD, ABPP-CN > Olivia Harner, PhD, ABPP > David Anderson, PhD, ABPP-CN/CI > Alexis D. Kulick, Ph.D., ABPP > Lori Holt, PhD, ABPP-CN > Joel S. Eppig, Ph.D. > Delany Thrasher, Ph.D., ABPP-CN > Annie Reader Murray, Ph.D., ABPP-CN > Jeffrey M. Zulow, Ph.D. > Kaitlin B. Casaletto, PhD, ABPP-CN > Alexandra Apple, PhD > Hope Goldberg, PhD, ABPP-CN > William C. Hochberger, PhD > Paul Mangal, PhD > Virdette L. Brumm, Ph.D. > Christy Hom, PhD, ABPdN > Eric J. Freitag, PsyD, FACPN > Howard J. Friedman, ABPP (CN), ABN > Jonathan E. Romain, PhD, MS, ABPP-CN > Patricia Gross, PhD, ABPP-CN > Katie Denny PhD, ABPP-CN > Katherine Bangen, PhD, ABPP-CN > Lisa Graves, PhD > John Knippa, PhD, ABN > Ashley K. Miller, PhD, ABPP-CN > Karen Hanson Bondi, Ph.D. > Lori Alasantro, PhD, ABPP-CN > Amanda Gooding, PhD, ABPP-CN > Anita Herrera-Hamilton, Ph.D ABPP > Caitlin Moore, PHD, ABPP > William Britt, PhD, ABN > Janet K. Brewer, JD, PsyD > Mimi Wong, PhD, ABPP-CN > Charles Furst, PhD, ABPP-CN > Robert W. Elliott, PhD, ABCN, ABN > Amy M. Schonfeld, PhD, Clinical Neuropsychologist > Brian A. Osterweil, Ph.D., ABPP > Duke Han, PhD, ABPP-CN > Lisa Delano-Wood, PhD > Kimberly Alfano, PhD, ABPP (CN, RP) > Alena Stasenko, PhD > Inna Fishman, PhD > Annette Swain PhD ABPP-CN > Monica Smith, PhD, ABN > Mili Parikh, PhD, ABPP > Charles H. Hinkin, Ph.D., ABPP-CN > R. Dempsey, PsyD, ABPP, QME > Margaret A. Donohue, PhD > Samantha O'Bannon, Psy.D., Clinical Neuropsychologist PSY 32564 > William T.J. Johnson, Ph.D., ABPP-CN > Tony L. Strickland, MS, PhD, ABN, FNAN > Emmanuel A. Zamora, Psy.D., Neuropsychologist > Joshua McKeever, PhD, Clinical Neuropsychologist > Carmen C. Velazquez, Ph.D. > Anne Nolty, PhD, ABPP-CN > Grace Mucci, PhD, ABPdN > Tom Kiely, PhD > Joel Kramer, PsyD, ABPP-CN > Andrea Alioto, PhD, ABPP-CN > Johanna Rengifo, PhD > Ruth Serepca, PhD > Abigail Kramer, PhD > Sarah Banks, PhD, ABPP-CN > Arnold D. Purisch, Ph.D., ABPP-CN, ABN > Yuri Rassovsky, PhD, ABPP-CN > Lauren Keats, PsyD > Saskia DeVaughn, PhD, ABPP-CN > Katie Beckwith, PhD, ABPP-CN > Ashley Whitaker, PhD, ABPP-CN > Christian Carter, Ph.D., ABPP-CN > Melissa Balderrama, PsyD, ABPP > Hannah Brunet, PhD, ABPP-CN > Garima Lupas, PhD, ABPP, Board Certified in Clinical Neuropsychology > James A. Moses, Ph.D., ABPP-CN/CL > Bianca Georgescu, Psy.D., ABPP > Brandon Gavett, Ph.D. ABPP-CN > April Thames, PhD > Michelle Conover, Ph.D., QME > Daniel Jacobson, PhD, ABPP-CN > Carlos Saucedo, PhD, ABPP-CN > Sharon H. O'Neil, PhD, ABPP-CN > Audrey Khatchikia, PhD > Natalie C. Kelly, PhD, ABPP-CN > Shital Pavawalla, Ph.D., ABPP-CN > Alexander Tan, Ph.D., ABPP-CN > Phuong M. Chau, PhD ABPP-CN > Deborah Budding, Ph.D., ABN > > > > > CAUTION:This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. CAUTION:This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
AI Analysis:
This message does not mention Judge Goodman at all. It is a discussion between attorneys Greg Jackson and Nareg Kitsinian about a neuropsychological DME (Defense Medical Examination) dispute involving Dr. Hungerford, raw data production, and a potential sanctions motion. The conversation is entirely about a court order related to Dr. Hungerford and an opposing counsel's arguments, with no reference to Judge Goodman or any rulings, behavior, or decisions by Judge Goodman.
"Greg Jackson" Date: February 09, 2026 3:33:00 PM Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal Reply to list Reply to sender Print NICE, thank you Nareg!! I’ll get this added to the Dropbox, I appreciate the update and good luck with getting sanctions! Greg Jackson Partner and Managing Attorney The Simon Law Group p : (855) 855-8910 f : (310) 914-5401 m : (714) 617-2180 a : 2916 W 164th Street Torrance CA 90504 w : www.JusticeTeam.com e : greg@justiceteam.com Orange County | Los Angeles | Arizona | Texas This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of the company. Finally, the recipient should check this email and any attachments for the presence of viruses. The company accepts no liability for any damage caused by any virus transmitted by this email. From: Nareg Kitsinian <nareg@kitsinianlaw.com> Sent: Wednesday, February 4, 2026 2:29 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Cc: Greg Jackson <greg@justiceteam.com> Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal Greg, See attached, signed order, ordering Dr. Hungerford to produce raw data etc. Hungerford, did not recuse himself as he promised to do so in that ridiculous declaration signed by other doctors. He did go through with the DME and interviewed my client after all, but opted not to conduct his own testing and obtained the treating providers raw data instead. I have asked that the raw data be turned over and OC seems to think he is clever and is making the argument that the courts order only applies if Hungerford did the testing. An ex parte to enforce with sanctions is on its way. Please add the attached to your drop box. I'll let you know if Hungerford sends us the raw data. -- LATLC 2025 Secretary – 2029 President Nareg S. Kitsinian, Esq. Attorney at Law nareg@kitsinianlaw.com www.kitsinianlaw.com Tel: (818)786-5777 | Fax: (818)786-5778 16501 Ventura Blvd., Ste. 506, Encino, CA 91436 From: Gregory Jackson (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Thursday, November 20, 2025 3:27 PM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Gregory Jackson (Reply Privately) Search Added! Greg Jackson Partner and Managing Attorney The Simon Law Group p : (855) 855-8910 f : (310) 914-5401 m : (714) 617-2180 a : 2916 W 164th Street Torrance CA 90504 w : www.JusticeTeam.com e : greg@justiceteam.com Orange County | Los Angeles | Arizona | Texas This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of the company. Finally, the recipient should check this email and any attachments for the presence of viruses. The company accepts no liability for any damage caused by any virus transmitted by this email. From: Nareg Kitsinian (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Thursday, November 20, 2025 3:21 PM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Nareg Kitsinian (Reply Privately) Search Greg, attached is our LASC minute order from 3/25 compelling Filoteo who did produce. Please add to your folder. -- LATLC 2025 Secretary – 2029 President Nareg S. Kitsinian, Esq. Attorney at Law nareg@kitsinianlaw.com www.kitsinianlaw.com Tel: (818)786-5777 | Fax: (818)786-5778 16501 Ventura Blvd., Ste. 506, Encino, CA 91436 From: Gregory Jackson (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Thursday, November 20, 2025 3:01 PM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Gregory Jackson (Reply Privately) Search No problem! You’ll see specific subfolders for a number of experts, some oppositions, lot of stuff in there to use. For that huge declaration defense is listing now, a number of those experts who signed off on it have actually produced raw data anyway – so you can use these minute orders and stipulations in the Dropbox to impeach it. Greg Jackson Partner and Managing Attorney The Simon Law Group p : (855) 855-8910 f : (310) 914-5401 m : (714) 617-2180 a : 2916 W 164th Street Torrance CA 90504 w : www.JusticeTeam.com e : greg@justiceteam.com Orange County | Los Angeles | Arizona | Texas This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of the company. Finally, the recipient should check this email and any attachments for the presence of viruses. The company accepts no liability for any damage caused by any virus transmitted by this email. From: Nareg Kitsinian (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Thursday, November 20, 2025 2:45 PM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Nareg Kitsinian (Reply Privately) Search Greg, This - is awesome! I will send you the minute order when I have it. This dropbox folder you have compiled is a treasure - really the nail in the coffin. Everyone should be sharing their minute orders on this issue moving forward. Thank you! -- LATLC 2025 Secretary – 2029 President Nareg S. Kitsinian, Esq. Attorney at Law nareg@kitsinianlaw.com www.kitsinianlaw.com Tel: (818)786-5777 | Fax: (818)786-5778 16501 Ventura Blvd., Ste. 506, Encino, CA 91436 From: Gregory Jackson (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Thursday, November 20, 2025 2:10 PM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Gregory Jackson (Reply Privately) Search Nareg, Thank you for sharing this! Please keep us posted if Dr. Hungerford proceeds with the exam and complies/produces the raw data so we can add him to the list, and once you get the final minute order please circulate that as well. Here is the Dropbox of neuropsych dirt I’ve compiled, check out the ‘Minute Orders’ subfolder and there are at least a dozen in there including 8 from this year. If you send me your final minute order once the court posts it I’ll add it to the Dropbox! https://www.dropbox.com/scl/fo/c0pued3e3ftj4j0x88qji/ALFU7MTTieoSk3Dud4IyfHc?rlkey=67d52jz1uxzspr3mol96dfbkr&st=2kghiflq&dl=0 Greg Jackson Partner and Managing Attorney The Simon Law Group p : (855) 855-8910 f : (310) 914-5401 m : (714) 617-2180 a : 2916 W 164th Street Torrance CA 90504 w : www.JusticeTeam.com e : greg@justiceteam.com Orange County | Los Angeles | Arizona | Texas This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of the company. Finally, the recipient should check this email and any attachments for the presence of viruses. The company accepts no liability for any damage caused by any virus transmitted by this email. From: Nareg Kitsinian (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Thursday, November 20, 2025 11:25 AM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Nareg Kitsinian (Reply Privately) Search We successfully opposed a motion to compel a mental exam with Dr. Lars Hungerford today in San Bernardino Superior Court with Judge Joseph Widman. He made all the right calls in line with Randys Trucking and compelled that the raw data be turned over and plaintiff can record the examination. This hearing was different then past hearings. The defense play now is to use this declaration that they say 94% of neuropsychs have signed attesting they would recuse themselves if compelled to turn over data. It's persuasive, but not enough to circumvent the law. In my motion I attached two minute orders/tentative rulings where LASC courts also ruled in line with Randy Trucking. Concerningly, this prompted the defense to argue at the hearing that he would like to lodge 10 other recent orders throughout CA that he has collected that went in the opposite direction and did not compel disclosure. Judge Widman did not buy the argument. But I raise this because if 10 other courtrooms are still ruling against disclosure, it can be problematic given the judge and we should begin collecting orders in all superior courts where a judge rules with Randy Trucking so that they can be Judicially Noticed in these motions. This is the second motion I have won in the last 5 months on a TBI case. The law is with us, but it is striking to me that 10 other courts recently ruled in another direction. Attached is our tentative ruling from this morning. I hope others will share over time so we can use them as time passes. -- LATLC 2025 Secretary – 2029 President Nareg S. Kitsinian, Esq. Attorney at Law nareg@kitsinianlaw.com www.kitsinianlaw.com Tel: (818)786-5777 | Fax: (818)786-5778 16501 Ventura Blvd., Ste. 506, Encino, CA 91436 From: Kane Handel (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Tuesday, November 4, 2025 11:05 AM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Kane Handel (Reply Privately) Search file a motion!!! On 11/4/25 9:44 AM, Nareg Kitsinian (caala-workproduct listserver) wrote: List: caala-workproduct Sent by: Nareg Kitsinian (Reply Privately) Search I have a TBI case where Dr. Hungerford has refused to provide the raw data to me and is claiming in his declaration to withdraw if the court orders him to turn over the data, citing this same declaration signed by 180 other NeuroPsychs. Does anyone have any prior experience with Dr. Lars Hungerford, perhaps agreeing to turn over raw data in the past that I can use in our opposition? Nareg -----Original Message----- From: antonio@ac3law.com Sent: September 29, 2025 3:43:00 PM To: caala-workproduct@lists.trialsmith.com Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal Interestingly, Delis isn't a signatory. On Fri, Sep 19, 2025 at 3:57 PM Delavar Omidfar (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> wrote: > *List:* caala-workproduct * Sent by:* Delavar Omidfar (Reply Privately) > <domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > Search <http://www.caala.org/index.cfm?pg=search> > Andrew - Do you have the case information or copies of the App Case? > > > -----Original Message----- > > From: andrew@a2zlegal.com > Sent: September 17, 2025 6:35:00 PM > To: caala-workproduct@lists.trialsmith.com > Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal > > This is nonsense. I had to take up a writ where the judge would not allow > them to turn over the data to us and my writ was granted, court order > reversed. If I remember correctly they included this garbage in their > opposition as well but the Appellate Court did not buy it. > > > Andrew Zeytuntsyan > > Founder / Trial Attorney > > [ > https://storage-use.letsignit.com/62705ddc173a9394d8bcc888/logo_62705ddc173a9394d8bcc888_e895719889494628d401a7b8776c8039.png > ] > > 1306 W. Magnolia Blvd. > > Burbank, CA 91506 > > T. (323) 882-6500 > > F. (800) 506-7176 > > a2zlegal.com< > https://cloud.letsignit.com/collect/bc/627076c3c8565ddc6ca471ae?p=L3lrFhURv2eXFz8AUdcQMg7oZ5M7umbVf2WSzpdzFq7D1iSXrK3ZaujaqDpZOQqyzyjZl0xri-GrOODYWlP3QLZm0iplL-zlOXM4lSHQ28oSIcbvk9_JHfvcYEayMxKfUiuqgPOYkIcclIOWPouVUq8U-TmlvnN27_c7uQRHayw= > > > > [ > https://storage-use.letsignit.com/62705ddc173a9394d8bcc888/253796901116998898398879131612511431317.png > ] > > The information in this electronic mail message is confidential and for > use of only the named recipient. The information may be protected by > privilege, work product immunity or other applicable law. If you are not > the intended recipient the retention, dissemination, distribution or > copying of this e-mail message is strictly prohibited. If you receive this > message in error please notify us immediately. > > ________________________________ > From: Delavar Omidfar (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com > > Sent: Friday, September 12, 2025 3:15 PM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com > > Subject: [caala-workproduct] Neuropsych Declaration re DME Raw Data and > Recusal > > List: caala-workproduct Sent by: Delavar Omidfar (Reply Privately)< mailto: > domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal > > Search <http://www.caala.org/index.cfm?pg=search> > > Mates, > I was recently provided with the attached declaration signed by over 180 > neuropsychologists and psychologists regarding the protection of > psychological testing materials. Most importantly, all signatories have > declared: > > "I would not agree to releasing protected test information that would > jeopardize future use of tests to a non-psychologist, including attorneys, > even under a protective order. If this stipulation cannot be met, I would > recuse myself from a case." > > My suspicion is that some of these same psychologists have previously > agreed to perform mental examinations and released raw data under > protective orders. If true, this creates a significant inconsistency that > could be used to challenge their credibility and position. > > I'm reaching out to see if any of you have: > > 1. Documentation of any of these 185 signatories previously agreeing to > release raw test data under protective order > 2. Thoughts on strategies for overcoming this collective stance in future > cases > 3. Legal precedents, other than Randy's Trucking, that could compel > production despite this declaration > 4. Counter Declaration by psychs who can counter their arguments about > test security > > The complete list of 185 signatories is below. Notable names include many > prominent California neuropsychologists who regularly serve as defense > experts, i.e. Hinkin, Boone, Kopald, Lechuga, Hooker, Bondi, Elliot, Zamora. > > List of Signatories > Catherine Marreiro, PhD, ABPP-CN > Kyle Boone, PhD, ABPP-CN > William McMullen Jr., PhD, ABPP-CN > Delia M. Silva, Psy.D., ABPP-CN, Neuropsychologist > Lauren Drag, PhD, ABPP-CN > Maya Yutsis, PhD, ABPP-CN > Katherine Kruser, Psy.D., Neuropsychologist > Jeffrey Wertheimer, PhD, ABPP-CN > Jay Rosen, PhD > Michelle Zeller, Psy.D., ABPP-CN > Deborah Cahn-Weiner, Ph.D., ABPP-CN > Mi-Yeoung Jo, PsyD, ABPP-CN > Talin Babikian, PhD, ABPP-CN > Molly Memel, PhD, ABPP-CN > Rebecca Goodman, PhD, ABPP-CN > Haygoush Kalinian, PhD, Clinical Neuropsychologist > Robert M. Bilder, PhD, ABPP-CN > Robert Gray, PhD, ABPP-CN > Amir Ramezani, PhD > Leah Ellenberg, Ph. D., ABPP-CN > Charles Filanosky, PhD, ABPP-RP > Po-Haong Lu, PsyD > Angela Eastvold, PhD, ABPP-CN > Maura Mitrushina, Ph.D., ABPP-CN > Ann Gottuso, PhD, ABPP-CN > Gayle Deutsch, PhD, ABPP-CN > Simon Tan PsyD, ABPP-CN > Andrew Levine, PhD, ABPP-CN > Ernest T. Bryant, PhD, ABPP-CN > John Wager, PhD, ABPP-CN > Dominique Kinney, PhD, ABPP-CN > Brandon Kopald, Psy.D., ABPP-CN > Frederick Hives II, PhD, ABPP-CN > Lars Hungerford, PhD, ABPP-CN > Karen L. Schiltz, PhD, Neuropsychologist > Tara L. Victor, PhD, ABPP-CN > Shelley Peery, PhD > Karen Lau, PhD, ABPP-CN > Robert Tomaszewski, PhD, ABPP-CN > David M. Lechuga, PhD, ABPP, ABN > Elma Chidekel, PhD, ABN, ABPdN > William D. Hooker, Ph.D., ABN > Dale Sherman, PhD, QME > June Paltzer, PhD, ABPP-CN > Karen Earnest, PhD, ABPP-CN > John Bellone, PhD, ABPP-CN > Erin Green-Krogmann, PhD, ABPP-CN > Virginia Zuverza-Chavarria, PhD, ABPP-CN > Kimberly Lanni, PhD, ABPP, Board Certified in Clinical Neuropsychology > Mark Alfano, Ph.D., ABPP CN, RP > Steve Nitch, Ph. D., ABPP-CN > Kristina Agbayani, PhD, ABPP-CN > Andrew L. Wong, PhD, ABPP-CN > Jessica Foley, PhD, ABPP-CN > Andrew Dean, Ph. D., ABPP-CN > Allison R. Kaup, PhD > Mark W. Bondi, PhD, ABPP-CN > Jose M. Lafosse, Ph.D., ABPP-CN > Philip Sayegh, PhD, MPH > Sara Mason, PsyD > Kimberly Miller, PhD, ABPP-CN > Hayley Kristinsson, PsyD, ABPP-CN > Michael H. Kabat, Ph.D., ABPP-CN > Brigid Rose, PhD, ABPP-CN > Roger Light, PhD, ABPP-CN > Jeremy Jinkerson, PhD > David D. O'Grady, Ph.D., ABPP-CN > Anneliese Radke, Psy.D. > Joanne M. Hamilton, ABPP-CN > Travis G. Fogel, Ph.D., ABPP-CN > Sarah Tomaszewski Farias, Ph.D. ABPP-CN > Allyson C. Rosen, PhD, ABPP-CN > Sabine Gysens, PhD > George Kahle Henry, PhD. ABPP-CN > Kirsty Bortnik, PhD, ABPP-CN > Joelle Broffman, PsyD, ABPP-CN > Kristin K. Jacobson, PsyD, ABPP-CN > Alice Ruzicka, Ph.D., ABN > Renee Low, Ph.D., ABN > Stacy S Wilkins, PhD, ABPP/CN > Christine M. Naber, PhD > Aura Barragan, Psy.D. > Richard L. Delmonico, PhD, Licensed Psychologist CA PSY12604, Clinical > Neuropsychologist > Lauren Bennett, PhD, ABPP-CN > William J. Lynch, Ph.D., ABPP/CN, Licensed Psychologist [PSY 5151] > Rujvi Kamat, PhD, ABPP-CN > Krista Freeze, PhD, ABN > Carrie R. McDonald, Ph.D., ABPP-CN > Nancy A. Blum, Ph.D. > Travis Shivley-Scott, PhD > Karen Mikolic, PhD, ABN > Talia Seider, PhD, ABPP-CN > Heather Pedersen, PhD, ABPP-CN > Michael DeBellis Psy.D., ABN > Nicholas Thaler, PhD, ABPP-CN > Caroline J. Grantz, PhD > Philip K. Stenquist, Ph.D., ABPP-CN > Brian Yochim, PhD, ABPP-CN > Olivia Harner, PhD, ABPP > David Anderson, PhD, ABPP-CN/CI > Alexis D. Kulick, Ph.D., ABPP > Lori Holt, PhD, ABPP-CN > Joel S. Eppig, Ph.D. > Delany Thrasher, Ph.D., ABPP-CN > Annie Reader Murray, Ph.D., ABPP-CN > Jeffrey M. Zulow, Ph.D. > Kaitlin B. Casaletto, PhD, ABPP-CN > Alexandra Apple, PhD > Hope Goldberg, PhD, ABPP-CN > William C. Hochberger, PhD > Paul Mangal, PhD > Virdette L. Brumm, Ph.D. > Christy Hom, PhD, ABPdN > Eric J. Freitag, PsyD, FACPN > Howard J. Friedman, ABPP (CN), ABN > Jonathan E. Romain, PhD, MS, ABPP-CN > Patricia Gross, PhD, ABPP-CN > Katie Denny PhD, ABPP-CN > Katherine Bangen, PhD, ABPP-CN > Lisa Graves, PhD > John Knippa, PhD, ABN > Ashley K. Miller, PhD, ABPP-CN > Karen Hanson Bondi, Ph.D. > Lori Alasantro, PhD, ABPP-CN > Amanda Gooding, PhD, ABPP-CN > Anita Herrera-Hamilton, Ph.D ABPP > Caitlin Moore, PHD, ABPP > William Britt, PhD, ABN > Janet K. Brewer, JD, PsyD > Mimi Wong, PhD, ABPP-CN > Charles Furst, PhD, ABPP-CN > Robert W. Elliott, PhD, ABCN, ABN > Amy M. Schonfeld, PhD, Clinical Neuropsychologist > Brian A. Osterweil, Ph.D., ABPP > Duke Han, PhD, ABPP-CN > Lisa Delano-Wood, PhD > Kimberly Alfano, PhD, ABPP (CN, RP) > Alena Stasenko, PhD > Inna Fishman, PhD > Annette Swain PhD ABPP-CN > Monica Smith, PhD, ABN > Mili Parikh, PhD, ABPP > Charles H. Hinkin, Ph.D., ABPP-CN > R. Dempsey, PsyD, ABPP, QME > Margaret A. Donohue, PhD > Samantha O'Bannon, Psy.D., Clinical Neuropsychologist PSY 32564 > William T.J. Johnson, Ph.D., ABPP-CN > Tony L. Strickland, MS, PhD, ABN, FNAN > Emmanuel A. Zamora, Psy.D., Neuropsychologist > Joshua McKeever, PhD, Clinical Neuropsychologist > Carmen C. Velazquez, Ph.D. > Anne Nolty, PhD, ABPP-CN > Grace Mucci, PhD, ABPdN > Tom Kiely, PhD > Joel Kramer, PsyD, ABPP-CN > Andrea Alioto, PhD, ABPP-CN > Johanna Rengifo, PhD > Ruth Serepca, PhD > Abigail Kramer, PhD > Sarah Banks, PhD, ABPP-CN > Arnold D. Purisch, Ph.D., ABPP-CN, ABN > Yuri Rassovsky, PhD, ABPP-CN > Lauren Keats, PsyD > Saskia DeVaughn, PhD, ABPP-CN > Katie Beckwith, PhD, ABPP-CN > Ashley Whitaker, PhD, ABPP-CN > Christian Carter, Ph.D., ABPP-CN > Melissa Balderrama, PsyD, ABPP > Hannah Brunet, PhD, ABPP-CN > Garima Lupas, PhD, ABPP, Board Certified in Clinical Neuropsychology > James A. Moses, Ph.D., ABPP-CN/CL > Bianca Georgescu, Psy.D., ABPP > Brandon Gavett, Ph.D. ABPP-CN > April Thames, PhD > Michelle Conover, Ph.D., QME > Daniel Jacobson, PhD, ABPP-CN > Carlos Saucedo, PhD, ABPP-CN > Sharon H. O'Neil, PhD, ABPP-CN > Audrey Khatchikia, PhD > Natalie C. Kelly, PhD, ABPP-CN > Shital Pavawalla, Ph.D., ABPP-CN > Alexander Tan, Ph.D., ABPP-CN > Phuong M. Chau, PhD ABPP-CN > Deborah Budding, Ph.D., ABN > > > > > CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
AI Analysis:
This message does not mention Judge Goodman at all. It is a discussion between attorneys Greg Jackson and Nareg Kitsinian about neuropsychological expert declarations, DME raw data, a Dropbox folder of resources, and minute orders/stipulations related to expert witnesses. The conversation is entirely about litigation strategy and shared work product resources, with no reference to Judge Goodman or any rulings, decisions, or behavior associated with that judge.
"Greg Jackson" Date: November 20, 2025 5:03:00 PM Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal Reply to list Reply to sender Print No problem! You’ll see specific subfolders for a number of experts, some oppositions, lot of stuff in there to use. For that huge declaration defense is listing now, a number of those experts who signed off on it have actually produced raw data anyway – so you can use these minute orders and stipulations in the Dropbox to impeach it. Greg Jackson Partner and Managing Attorney The Simon Law Group p : (855) 855-8910 f : (310) 914-5401 m : (714) 617-2180 a : 2916 W 164th Street Torrance CA 90504 w : www.JusticeTeam.com e : greg@justiceteam.com Orange County | Los Angeles | Arizona | Texas This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of the company. Finally, the recipient should check this email and any attachments for the presence of viruses. The company accepts no liability for any damage caused by any virus transmitted by this email. From: Nareg Kitsinian (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Thursday, November 20, 2025 2:45 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Nareg Kitsinian (Reply Privately) Search Greg, This - is awesome! I will send you the minute order when I have it. This dropbox folder you have compiled is a treasure - really the nail in the coffin. Everyone should be sharing their minute orders on this issue moving forward. Thank you! -- LATLC 2025 Secretary – 2029 President Nareg S. Kitsinian, Esq. Attorney at Law nareg@kitsinianlaw.com www.kitsinianlaw.com Tel: (818)786-5777 | Fax: (818)786-5778 16501 Ventura Blvd., Ste. 506, Encino, CA 91436 From: Gregory Jackson (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Thursday, November 20, 2025 2:10 PM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Gregory Jackson (Reply Privately) Search Nareg, Thank you for sharing this! Please keep us posted if Dr. Hungerford proceeds with the exam and complies/produces the raw data so we can add him to the list, and once you get the final minute order please circulate that as well. Here is the Dropbox of neuropsych dirt I’ve compiled, check out the ‘Minute Orders’ subfolder and there are at least a dozen in there including 8 from this year. If you send me your final minute order once the court posts it I’ll add it to the Dropbox! https://www.dropbox.com/scl/fo/c0pued3e3ftj4j0x88qji/ALFU7MTTieoSk3Dud4IyfHc?rlkey=67d52jz1uxzspr3mol96dfbkr&st=2kghiflq&dl=0 Greg Jackson Partner and Managing Attorney The Simon Law Group p : (855) 855-8910 f : (310) 914-5401 m : (714) 617-2180 a : 2916 W 164th Street Torrance CA 90504 w : www.JusticeTeam.com e : greg@justiceteam.com Orange County | Los Angeles | Arizona | Texas This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of the company. Finally, the recipient should check this email and any attachments for the presence of viruses. The company accepts no liability for any damage caused by any virus transmitted by this email. From: Nareg Kitsinian (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Thursday, November 20, 2025 11:25 AM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Nareg Kitsinian (Reply Privately) Search We successfully opposed a motion to compel a mental exam with Dr. Lars Hungerford today in San Bernardino Superior Court with Judge Joseph Widman. He made all the right calls in line with Randys Trucking and compelled that the raw data be turned over and plaintiff can record the examination. This hearing was different then past hearings. The defense play now is to use this declaration that they say 94% of neuropsychs have signed attesting they would recuse themselves if compelled to turn over data. It's persuasive, but not enough to circumvent the law. In my motion I attached two minute orders/tentative rulings where LASC courts also ruled in line with Randy Trucking. Concerningly, this prompted the defense to argue at the hearing that he would like to lodge 10 other recent orders throughout CA that he has collected that went in the opposite direction and did not compel disclosure. Judge Widman did not buy the argument. But I raise this because if 10 other courtrooms are still ruling against disclosure, it can be problematic given the judge and we should begin collecting orders in all superior courts where a judge rules with Randy Trucking so that they can be Judicially Noticed in these motions. This is the second motion I have won in the last 5 months on a TBI case. The law is with us, but it is striking to me that 10 other courts recently ruled in another direction. Attached is our tentative ruling from this morning. I hope others will share over time so we can use them as time passes. -- LATLC 2025 Secretary – 2029 President Nareg S. Kitsinian, Esq. Attorney at Law nareg@kitsinianlaw.com www.kitsinianlaw.com Tel: (818)786-5777 | Fax: (818)786-5778 16501 Ventura Blvd., Ste. 506, Encino, CA 91436 From: Kane Handel (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Tuesday, November 4, 2025 11:05 AM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Kane Handel (Reply Privately) Search file a motion!!! On 11/4/25 9:44 AM, Nareg Kitsinian (caala-workproduct listserver) wrote: List: caala-workproduct Sent by: Nareg Kitsinian (Reply Privately) Search I have a TBI case where Dr. Hungerford has refused to provide the raw data to me and is claiming in his declaration to withdraw if the court orders him to turn over the data, citing this same declaration signed by 180 other NeuroPsychs. Does anyone have any prior experience with Dr. Lars Hungerford, perhaps agreeing to turn over raw data in the past that I can use in our opposition? Nareg -----Original Message----- From: antonio@ac3law.com Sent: September 29, 2025 3:43:00 PM To: caala-workproduct@lists.trialsmith.com Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal Interestingly, Delis isn't a signatory. On Fri, Sep 19, 2025 at 3:57 PM Delavar Omidfar (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> wrote: > *List:* caala-workproduct * Sent by:* Delavar Omidfar (Reply Privately) > <domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > Search <http://www.caala.org/index.cfm?pg=search> > Andrew - Do you have the case information or copies of the App Case? > > > -----Original Message----- > > From: andrew@a2zlegal.com > Sent: September 17, 2025 6:35:00 PM > To: caala-workproduct@lists.trialsmith.com > Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal > > This is nonsense. I had to take up a writ where the judge would not allow > them to turn over the data to us and my writ was granted, court order > reversed. If I remember correctly they included this garbage in their > opposition as well but the Appellate Court did not buy it. > > > Andrew Zeytuntsyan > > Founder / Trial Attorney > > [ > https://storage-use.letsignit.com/62705ddc173a9394d8bcc888/logo_62705ddc173a9394d8bcc888_e895719889494628d401a7b8776c8039.png > ] > > 1306 W. Magnolia Blvd. > > Burbank, CA 91506 > > T. (323) 882-6500 > > F. (800) 506-7176 > > a2zlegal.com< > https://cloud.letsignit.com/collect/bc/627076c3c8565ddc6ca471ae?p=L3lrFhURv2eXFz8AUdcQMg7oZ5M7umbVf2WSzpdzFq7D1iSXrK3ZaujaqDpZOQqyzyjZl0xri-GrOODYWlP3QLZm0iplL-zlOXM4lSHQ28oSIcbvk9_JHfvcYEayMxKfUiuqgPOYkIcclIOWPouVUq8U-TmlvnN27_c7uQRHayw= > > > > [ > https://storage-use.letsignit.com/62705ddc173a9394d8bcc888/253796901116998898398879131612511431317.png > ] > > The information in this electronic mail message is confidential and for > use of only the named recipient. The information may be protected by > privilege, work product immunity or other applicable law. If you are not > the intended recipient the retention, dissemination, distribution or > copying of this e-mail message is strictly prohibited. If you receive this > message in error please notify us immediately. > > ________________________________ > From: Delavar Omidfar (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com > > Sent: Friday, September 12, 2025 3:15 PM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com > > Subject: [caala-workproduct] Neuropsych Declaration re DME Raw Data and > Recusal > > List: caala-workproduct Sent by: Delavar Omidfar (Reply Privately)< mailto: > domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal > > Search <http://www.caala.org/index.cfm?pg=search> > > Mates, > I was recently provided with the attached declaration signed by over 180 > neuropsychologists and psychologists regarding the protection of > psychological testing materials. Most importantly, all signatories have > declared: > > "I would not agree to releasing protected test information that would > jeopardize future use of tests to a non-psychologist, including attorneys, > even under a protective order. If this stipulation cannot be met, I would > recuse myself from a case." > > My suspicion is that some of these same psychologists have previously > agreed to perform mental examinations and released raw data under > protective orders. If true, this creates a significant inconsistency that > could be used to challenge their credibility and position. > > I'm reaching out to see if any of you have: > > 1. Documentation of any of these 185 signatories previously agreeing to > release raw test data under protective order > 2. Thoughts on strategies for overcoming this collective stance in future > cases > 3. Legal precedents, other than Randy's Trucking, that could compel > production despite this declaration > 4. Counter Declaration by psychs who can counter their arguments about > test security > > The complete list of 185 signatories is below. Notable names include many > prominent California neuropsychologists who regularly serve as defense > experts, i.e. Hinkin, Boone, Kopald, Lechuga, Hooker, Bondi, Elliot, Zamora. > > List of Signatories > Catherine Marreiro, PhD, ABPP-CN > Kyle Boone, PhD, ABPP-CN > William McMullen Jr., PhD, ABPP-CN > Delia M. Silva, Psy.D., ABPP-CN, Neuropsychologist > Lauren Drag, PhD, ABPP-CN > Maya Yutsis, PhD, ABPP-CN > Katherine Kruser, Psy.D., Neuropsychologist > Jeffrey Wertheimer, PhD, ABPP-CN > Jay Rosen, PhD > Michelle Zeller, Psy.D., ABPP-CN > Deborah Cahn-Weiner, Ph.D., ABPP-CN > Mi-Yeoung Jo, PsyD, ABPP-CN > Talin Babikian, PhD, ABPP-CN > Molly Memel, PhD, ABPP-CN > Rebecca Goodman, PhD, ABPP-CN > Haygoush Kalinian, PhD, Clinical Neuropsychologist > Robert M. Bilder, PhD, ABPP-CN > Robert Gray, PhD, ABPP-CN > Amir Ramezani, PhD > Leah Ellenberg, Ph. D., ABPP-CN > Charles Filanosky, PhD, ABPP-RP > Po-Haong Lu, PsyD > Angela Eastvold, PhD, ABPP-CN > Maura Mitrushina, Ph.D., ABPP-CN > Ann Gottuso, PhD, ABPP-CN > Gayle Deutsch, PhD, ABPP-CN > Simon Tan PsyD, ABPP-CN > Andrew Levine, PhD, ABPP-CN > Ernest T. Bryant, PhD, ABPP-CN > John Wager, PhD, ABPP-CN > Dominique Kinney, PhD, ABPP-CN > Brandon Kopald, Psy.D., ABPP-CN > Frederick Hives II, PhD, ABPP-CN > Lars Hungerford, PhD, ABPP-CN > Karen L. Schiltz, PhD, Neuropsychologist > Tara L. Victor, PhD, ABPP-CN > Shelley Peery, PhD > Karen Lau, PhD, ABPP-CN > Robert Tomaszewski, PhD, ABPP-CN > David M. Lechuga, PhD, ABPP, ABN > Elma Chidekel, PhD, ABN, ABPdN > William D. Hooker, Ph.D., ABN > Dale Sherman, PhD, QME > June Paltzer, PhD, ABPP-CN > Karen Earnest, PhD, ABPP-CN > John Bellone, PhD, ABPP-CN > Erin Green-Krogmann, PhD, ABPP-CN > Virginia Zuverza-Chavarria, PhD, ABPP-CN > Kimberly Lanni, PhD, ABPP, Board Certified in Clinical Neuropsychology > Mark Alfano, Ph.D., ABPP CN, RP > Steve Nitch, Ph. D., ABPP-CN > Kristina Agbayani, PhD, ABPP-CN > Andrew L. Wong, PhD, ABPP-CN > Jessica Foley, PhD, ABPP-CN > Andrew Dean, Ph. D., ABPP-CN > Allison R. Kaup, PhD > Mark W. Bondi, PhD, ABPP-CN > Jose M. Lafosse, Ph.D., ABPP-CN > Philip Sayegh, PhD, MPH > Sara Mason, PsyD > Kimberly Miller, PhD, ABPP-CN > Hayley Kristinsson, PsyD, ABPP-CN > Michael H. Kabat, Ph.D., ABPP-CN > Brigid Rose, PhD, ABPP-CN > Roger Light, PhD, ABPP-CN > Jeremy Jinkerson, PhD > David D. O'Grady, Ph.D., ABPP-CN > Anneliese Radke, Psy.D. > Joanne M. Hamilton, ABPP-CN > Travis G. Fogel, Ph.D., ABPP-CN > Sarah Tomaszewski Farias, Ph.D. ABPP-CN > Allyson C. Rosen, PhD, ABPP-CN > Sabine Gysens, PhD > George Kahle Henry, PhD. ABPP-CN > Kirsty Bortnik, PhD, ABPP-CN > Joelle Broffman, PsyD, ABPP-CN > Kristin K. Jacobson, PsyD, ABPP-CN > Alice Ruzicka, Ph.D., ABN > Renee Low, Ph.D., ABN > Stacy S Wilkins, PhD, ABPP/CN > Christine M. Naber, PhD > Aura Barragan, Psy.D. > Richard L. Delmonico, PhD, Licensed Psychologist CA PSY12604, Clinical > Neuropsychologist > Lauren Bennett, PhD, ABPP-CN > William J. Lynch, Ph.D., ABPP/CN, Licensed Psychologist [PSY 5151] > Rujvi Kamat, PhD, ABPP-CN > Krista Freeze, PhD, ABN > Carrie R. McDonald, Ph.D., ABPP-CN > Nancy A. Blum, Ph.D. > Travis Shivley-Scott, PhD > Karen Mikolic, PhD, ABN > Talia Seider, PhD, ABPP-CN > Heather Pedersen, PhD, ABPP-CN > Michael DeBellis Psy.D., ABN > Nicholas Thaler, PhD, ABPP-CN > Caroline J. Grantz, PhD > Philip K. Stenquist, Ph.D., ABPP-CN > Brian Yochim, PhD, ABPP-CN > Olivia Harner, PhD, ABPP > David Anderson, PhD, ABPP-CN/CI > Alexis D. Kulick, Ph.D., ABPP > Lori Holt, PhD, ABPP-CN > Joel S. Eppig, Ph.D. > Delany Thrasher, Ph.D., ABPP-CN > Annie Reader Murray, Ph.D., ABPP-CN > Jeffrey M. Zulow, Ph.D. > Kaitlin B. Casaletto, PhD, ABPP-CN > Alexandra Apple, PhD > Hope Goldberg, PhD, ABPP-CN > William C. Hochberger, PhD > Paul Mangal, PhD > Virdette L. Brumm, Ph.D. > Christy Hom, PhD, ABPdN > Eric J. Freitag, PsyD, FACPN > Howard J. Friedman, ABPP (CN), ABN > Jonathan E. Romain, PhD, MS, ABPP-CN > Patricia Gross, PhD, ABPP-CN > Katie Denny PhD, ABPP-CN > Katherine Bangen, PhD, ABPP-CN > Lisa Graves, PhD > John Knippa, PhD, ABN > Ashley K. Miller, PhD, ABPP-CN > Karen Hanson Bondi, Ph.D. > Lori Alasantro, PhD, ABPP-CN > Amanda Gooding, PhD, ABPP-CN > Anita Herrera-Hamilton, Ph.D ABPP > Caitlin Moore, PHD, ABPP > William Britt, PhD, ABN > Janet K. Brewer, JD, PsyD > Mimi Wong, PhD, ABPP-CN > Charles Furst, PhD, ABPP-CN > Robert W. Elliott, PhD, ABCN, ABN > Amy M. Schonfeld, PhD, Clinical Neuropsychologist > Brian A. Osterweil, Ph.D., ABPP > Duke Han, PhD, ABPP-CN > Lisa Delano-Wood, PhD > Kimberly Alfano, PhD, ABPP (CN, RP) > Alena Stasenko, PhD > Inna Fishman, PhD > Annette Swain PhD ABPP-CN > Monica Smith, PhD, ABN > Mili Parikh, PhD, ABPP > Charles H. Hinkin, Ph.D., ABPP-CN > R. Dempsey, PsyD, ABPP, QME > Margaret A. Donohue, PhD > Samantha O'Bannon, Psy.D., Clinical Neuropsychologist PSY 32564 > William T.J. Johnson, Ph.D., ABPP-CN > Tony L. Strickland, MS, PhD, ABN, FNAN > Emmanuel A. Zamora, Psy.D., Neuropsychologist > Joshua McKeever, PhD, Clinical Neuropsychologist > Carmen C. Velazquez, Ph.D. > Anne Nolty, PhD, ABPP-CN > Grace Mucci, PhD, ABPdN > Tom Kiely, PhD > Joel Kramer, PsyD, ABPP-CN > Andrea Alioto, PhD, ABPP-CN > Johanna Rengifo, PhD > Ruth Serepca, PhD > Abigail Kramer, PhD > Sarah Banks, PhD, ABPP-CN > Arnold D. Purisch, Ph.D., ABPP-CN, ABN > Yuri Rassovsky, PhD, ABPP-CN > Lauren Keats, PsyD > Saskia DeVaughn, PhD, ABPP-CN > Katie Beckwith, PhD, ABPP-CN > Ashley Whitaker, PhD, ABPP-CN > Christian Carter, Ph.D., ABPP-CN > Melissa Balderrama, PsyD, ABPP > Hannah Brunet, PhD, ABPP-CN > Garima Lupas, PhD, ABPP, Board Certified in Clinical Neuropsychology > James A. Moses, Ph.D., ABPP-CN/CL > Bianca Georgescu, Psy.D., ABPP > Brandon Gavett, Ph.D. ABPP-CN > April Thames, PhD > Michelle Conover, Ph.D., QME > Daniel Jacobson, PhD, ABPP-CN > Carlos Saucedo, PhD, ABPP-CN > Sharon H. O'Neil, PhD, ABPP-CN > Audrey Khatchikia, PhD > Natalie C. Kelly, PhD, ABPP-CN > Shital Pavawalla, Ph.D., ABPP-CN > Alexander Tan, Ph.D., ABPP-CN > Phuong M. Chau, PhD ABPP-CN > Deborah Budding, Ph.D., ABN > > > > > CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
AI Analysis:
This message thread is entirely about finding an appearance attorney for Palm Springs courthouse and a discussion about neuropsychological DME raw data and a recusal list. There is no mention of Judge Goodman anywhere in the message, nor any information about their rulings, demeanor, or courtroom behavior. The message is completely unrelated to evaluating Judge Goodman.
I can. -- Shirin Buckman, Esq. Law Office of Shirin Buckman 42215 Washington St., Ste #A-220 Palm Desert, CA 92211 Phone: (323) 645-7430 Cell: (323) 463-3326 ShirinBuckmanLaw@gmail.com Confidentiality Notice: This email is intended for the sole use of the intended recipient(s) and may contain confidential, proprietary or privileged information. If you are not the intended recipient, you are notified that any use, review, dissemination, copying or action taken based on this message or its attachments, if any, is prohibited. If you are not the intended recipient, please contact the sender by reply email and destroy or delete all copies of the original message and any attachments. On Thu, Nov 20, 2025 at 2:24 PM David Shapiro (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: David Shapiro (Reply Privately) Search Does anyone know of an appearance attorney who will appear Palm springs Courthouse. From: Gregory Jackson (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Thursday, November 20, 2025 2:11 PM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Gregory Jackson (Reply Privately) Search Nareg, Thank you for sharing this! Please keep us posted if Dr. Hungerford proceeds with the exam and complies/produces the raw data so we can add him to the list, and once you get the final minute order please circulate that as well. Here is the Dropbox of neuropsych dirt I’ve compiled, check out the ‘Minute Orders’ subfolder and there are at least a dozen in there including 8 from this year. If you send me your final minute order once the court posts it I’ll add it to the Dropbox! https://www.dropbox.com/scl/fo/c0pued3e3ftj4j0x88qji/ALFU7MTTieoSk3Dud4IyfHc?rlkey=67d52jz1uxzspr3mol96dfbkr&st=2kghiflq&dl=0 Greg Jackson Partner and Managing Attorney The Simon Law Group p : (855) 855-8910 f : (310) 914-5401 m : (714) 617-2180 a : 2916 W 164th Street Torrance CA 90504 w : www.JusticeTeam.com e : greg@justiceteam.com Orange County | Los Angeles | Arizona | Texas This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of the company. Finally, the recipient should check this email and any attachments for the presence of viruses. The company accepts no liability for any damage caused by any virus transmitted by this email. From: Nareg Kitsinian (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Thursday, November 20, 2025 11:25 AM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Nareg Kitsinian (Reply Privately) Search We successfully opposed a motion to compel a mental exam with Dr. Lars Hungerford today in San Bernardino Superior Court with Judge Joseph Widman. He made all the right calls in line with Randys Trucking and compelled that the raw data be turned over and plaintiff can record the examination. This hearing was different then past hearings. The defense play now is to use this declaration that they say 94% of neuropsychs have signed attesting they would recuse themselves if compelled to turn over data. It's persuasive, but not enough to circumvent the law. In my motion I attached two minute orders/tentative rulings where LASC courts also ruled in line with Randy Trucking. Concerningly, this prompted the defense to argue at the hearing that he would like to lodge 10 other recent orders throughout CA that he has collected that went in the opposite direction and did not compel disclosure. Judge Widman did not buy the argument. But I raise this because if 10 other courtrooms are still ruling against disclosure, it can be problematic given the judge and we should begin collecting orders in all superior courts where a judge rules with Randy Trucking so that they can be Judicially Noticed in these motions. This is the second motion I have won in the last 5 months on a TBI case. The law is with us, but it is striking to me that 10 other courts recently ruled in another direction. Attached is our tentative ruling from this morning. I hope others will share over time so we can use them as time passes. -- LATLC 2025 Secretary – 2029 President Nareg S. Kitsinian, Esq. Attorney at Law nareg@kitsinianlaw.com www.kitsinianlaw.com Tel: (818)786-5777 | Fax: (818)786-5778 16501 Ventura Blvd., Ste. 506, Encino, CA 91436 From: Kane Handel (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Tuesday, November 4, 2025 11:05 AM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Kane Handel (Reply Privately) Search file a motion!!! On 11/4/25 9:44 AM, Nareg Kitsinian (caala-workproduct listserver) wrote: List: caala-workproduct Sent by: Nareg Kitsinian (Reply Privately) Search I have a TBI case where Dr. Hungerford has refused to provide the raw data to me and is claiming in his declaration to withdraw if the court orders him to turn over the data, citing this same declaration signed by 180 other NeuroPsychs. Does anyone have any prior experience with Dr. Lars Hungerford, perhaps agreeing to turn over raw data in the past that I can use in our opposition? Nareg -----Original Message----- From: antonio@ac3law.com Sent: September 29, 2025 3:43:00 PM To: caala-workproduct@lists.trialsmith.com Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal Interestingly, Delis isn't a signatory. On Fri, Sep 19, 2025 at 3:57 PM Delavar Omidfar (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> wrote: > *List:* caala-workproduct * Sent by:* Delavar Omidfar (Reply Privately) > <domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > Search <http://www.caala.org/index.cfm?pg=search> > Andrew - Do you have the case information or copies of the App Case? > > > -----Original Message----- > > From: andrew@a2zlegal.com > Sent: September 17, 2025 6:35:00 PM > To: caala-workproduct@lists.trialsmith.com > Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal > > This is nonsense. I had to take up a writ where the judge would not allow > them to turn over the data to us and my writ was granted, court order > reversed. If I remember correctly they included this garbage in their > opposition as well but the Appellate Court did not buy it. > > > Andrew Zeytuntsyan > > Founder / Trial Attorney > > [ > https://storage-use.letsignit.com/62705ddc173a9394d8bcc888/logo_62705ddc173a9394d8bcc888_e895719889494628d401a7b8776c8039.png > ] > > 1306 W. Magnolia Blvd. > > Burbank, CA 91506 > > T. (323) 882-6500 > > F. (800) 506-7176 > > a2zlegal.com < > https://cloud.letsignit.com/collect/bc/627076c3c8565ddc6ca471ae?p=L3lrFhURv2eXFz8AUdcQMg7oZ5M7umbVf2WSzpdzFq7D1iSXrK3ZaujaqDpZOQqyzyjZl0xri-GrOODYWlP3QLZm0iplL-zlOXM4lSHQ28oSIcbvk9_JHfvcYEayMxKfUiuqgPOYkIcclIOWPouVUq8U-TmlvnN27_c7uQRHayw= > > > > [ > https://storage-use.letsignit.com/62705ddc173a9394d8bcc888/253796901116998898398879131612511431317.png > ] > > The information in this electronic mail message is confidential and for > use of only the named recipient. The information may be protected by > privilege, work product immunity or other applicable law. If you are not > the intended recipient the retention, dissemination, distribution or > copying of this e-mail message is strictly prohibited. If you receive this > message in error please notify us immediately. > > ________________________________ > From: Delavar Omidfar (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com > > Sent: Friday, September 12, 2025 3:15 PM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com > > Subject: [caala-workproduct] Neuropsych Declaration re DME Raw Data and > Recusal > > List: caala-workproduct Sent by: Delavar Omidfar (Reply Privately)< mailto: > domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal > > Search <http://www.caala.org/index.cfm?pg=search> > > Mates, > I was recently provided with the attached declaration signed by over 180 > neuropsychologists and psychologists regarding the protection of > psychological testing materials. Most importantly, all signatories have > declared: > > "I would not agree to releasing protected test information that would > jeopardize future use of tests to a non-psychologist, including attorneys, > even under a protective order. If this stipulation cannot be met, I would > recuse myself from a case." > > My suspicion is that some of these same psychologists have previously > agreed to perform mental examinations and released raw data under > protective orders. If true, this creates a significant inconsistency that > could be used to challenge their credibility and position. > > I'm reaching out to see if any of you have: > > 1. Documentation of any of these 185 signatories previously agreeing to > release raw test data under protective order > 2. Thoughts on strategies for overcoming this collective stance in future > cases > 3. Legal precedents, other than Randy's Trucking, that could compel > production despite this declaration > 4. Counter Declaration by psychs who can counter their arguments about > test security > > The complete list of 185 signatories is below. Notable names include many > prominent California neuropsychologists who regularly serve as defense > experts, i.e. Hinkin, Boone, Kopald, Lechuga, Hooker, Bondi, Elliot, Zamora. > > List of Signatories > Catherine Marreiro, PhD, ABPP-CN > Kyle Boone, PhD, ABPP-CN > William McMullen Jr., PhD, ABPP-CN > Delia M. Silva, Psy.D., ABPP-CN, Neuropsychologist > Lauren Drag, PhD, ABPP-CN > Maya Yutsis, PhD, ABPP-CN > Katherine Kruser, Psy.D., Neuropsychologist > Jeffrey Wertheimer, PhD, ABPP-CN > Jay Rosen, PhD > Michelle Zeller, Psy.D., ABPP-CN > Deborah Cahn-Weiner, Ph.D., ABPP-CN > Mi-Yeoung Jo, PsyD, ABPP-CN > Talin Babikian, PhD, ABPP-CN > Molly Memel, PhD, ABPP-CN > Rebecca Goodman, PhD, ABPP-CN > Haygoush Kalinian, PhD, Clinical Neuropsychologist > Robert M. Bilder, PhD, ABPP-CN > Robert Gray, PhD, ABPP-CN > Amir Ramezani, PhD > Leah Ellenberg, Ph. D., ABPP-CN > Charles Filanosky, PhD, ABPP-RP > Po-Haong Lu, PsyD > Angela Eastvold, PhD, ABPP-CN > Maura Mitrushina, Ph.D., ABPP-CN > Ann Gottuso, PhD, ABPP-CN > Gayle Deutsch, PhD, ABPP-CN > Simon Tan PsyD, ABPP-CN > Andrew Levine, PhD, ABPP-CN > Ernest T. Bryant, PhD, ABPP-CN > John Wager, PhD, ABPP-CN > Dominique Kinney, PhD, ABPP-CN > Brandon Kopald, Psy.D., ABPP-CN > Frederick Hives II, PhD, ABPP-CN > Lars Hungerford, PhD, ABPP-CN > Karen L. Schiltz, PhD, Neuropsychologist > Tara L. Victor, PhD, ABPP-CN > Shelley Peery, PhD > Karen Lau, PhD, ABPP-CN > Robert Tomaszewski, PhD, ABPP-CN > David M. Lechuga, PhD, ABPP, ABN > Elma Chidekel, PhD, ABN, ABPdN > William D. Hooker, Ph.D., ABN > Dale Sherman, PhD, QME > June Paltzer, PhD, ABPP-CN > Karen Earnest, PhD, ABPP-CN > John Bellone, PhD, ABPP-CN > Erin Green-Krogmann, PhD, ABPP-CN > Virginia Zuverza-Chavarria, PhD, ABPP-CN > Kimberly Lanni, PhD, ABPP, Board Certified in Clinical Neuropsychology > Mark Alfano, Ph.D., ABPP CN, RP > Steve Nitch, Ph. D., ABPP-CN > Kristina Agbayani, PhD, ABPP-CN > Andrew L. Wong, PhD, ABPP-CN > Jessica Foley, PhD, ABPP-CN > Andrew Dean, Ph. D., ABPP-CN > Allison R. Kaup, PhD > Mark W. Bondi, PhD, ABPP-CN > Jose M. Lafosse, Ph.D., ABPP-CN > Philip Sayegh, PhD, MPH > Sara Mason, PsyD > Kimberly Miller, PhD, ABPP-CN > Hayley Kristinsson, PsyD, ABPP-CN > Michael H. Kabat, Ph.D., ABPP-CN > Brigid Rose, PhD, ABPP-CN > Roger Light, PhD, ABPP-CN > Jeremy Jinkerson, PhD > David D. O'Grady, Ph.D., ABPP-CN > Anneliese Radke, Psy.D. > Joanne M. Hamilton, ABPP-CN > Travis G. Fogel, Ph.D., ABPP-CN > Sarah Tomaszewski Farias, Ph.D. ABPP-CN > Allyson C. Rosen, PhD, ABPP-CN > Sabine Gysens, PhD > George Kahle Henry, PhD. ABPP-CN > Kirsty Bortnik, PhD, ABPP-CN > Joelle Broffman, PsyD, ABPP-CN > Kristin K. Jacobson, PsyD, ABPP-CN > Alice Ruzicka, Ph.D., ABN > Renee Low, Ph.D., ABN > Stacy S Wilkins, PhD, ABPP/CN > Christine M. Naber, PhD > Aura Barragan, Psy.D. > Richard L. Delmonico, PhD, Licensed Psychologist CA PSY12604, Clinical > Neuropsychologist > Lauren Bennett, PhD, ABPP-CN > William J. Lynch, Ph.D., ABPP/CN, Licensed Psychologist [PSY 5151] > Rujvi Kamat, PhD, ABPP-CN > Krista Freeze, PhD, ABN > Carrie R. McDonald, Ph.D., ABPP-CN > Nancy A. Blum, Ph.D. > Travis Shivley-Scott, PhD > Karen Mikolic, PhD, ABN > Talia Seider, PhD, ABPP-CN > Heather Pedersen, PhD, ABPP-CN > Michael DeBellis Psy.D., ABN > Nicholas Thaler, PhD, ABPP-CN > Caroline J. Grantz, PhD > Philip K. Stenquist, Ph.D., ABPP-CN > Brian Yochim, PhD, ABPP-CN > Olivia Harner, PhD, ABPP > David Anderson, PhD, ABPP-CN/CI > Alexis D. Kulick, Ph.D., ABPP > Lori Holt, PhD, ABPP-CN > Joel S. Eppig, Ph.D. > Delany Thrasher, Ph.D., ABPP-CN > Annie Reader Murray, Ph.D., ABPP-CN > Jeffrey M. Zulow, Ph.D. > Kaitlin B. Casaletto, PhD, ABPP-CN > Alexandra Apple, PhD > Hope Goldberg, PhD, ABPP-CN > William C. Hochberger, PhD > Paul Mangal, PhD > Virdette L. Brumm, Ph.D. > Christy Hom, PhD, ABPdN > Eric J. Freitag, PsyD, FACPN > Howard J. Friedman, ABPP (CN), ABN > Jonathan E. Romain, PhD, MS, ABPP-CN > Patricia Gross, PhD, ABPP-CN > Katie Denny PhD, ABPP-CN > Katherine Bangen, PhD, ABPP-CN > Lisa Graves, PhD > John Knippa, PhD, ABN > Ashley K. Miller, PhD, ABPP-CN > Karen Hanson Bondi, Ph.D. > Lori Alasantro, PhD, ABPP-CN > Amanda Gooding, PhD, ABPP-CN > Anita Herrera-Hamilton, Ph.D ABPP > Caitlin Moore, PHD, ABPP > William Britt, PhD, ABN > Janet K. Brewer, JD, PsyD > Mimi Wong, PhD, ABPP-CN > Charles Furst, PhD, ABPP-CN > Robert W. Elliott, PhD, ABCN, ABN > Amy M. Schonfeld, PhD, Clinical Neuropsychologist > Brian A. Osterweil, Ph.D., ABPP > Duke Han, PhD, ABPP-CN > Lisa Delano-Wood, PhD > Kimberly Alfano, PhD, ABPP (CN, RP) > Alena Stasenko, PhD > Inna Fishman, PhD > Annette Swain PhD ABPP-CN > Monica Smith, PhD, ABN > Mili Parikh, PhD, ABPP > Charles H. Hinkin, Ph.D., ABPP-CN > R. Dempsey, PsyD, ABPP, QME > Margaret A. Donohue, PhD > Samantha O'Bannon, Psy.D., Clinical Neuropsychologist PSY 32564 > William T.J. Johnson, Ph.D., ABPP-CN > Tony L. Strickland, MS, PhD, ABN, FNAN > Emmanuel A. Zamora, Psy.D., Neuropsychologist > Joshua McKeever, PhD, Clinical Neuropsychologist > Carmen C. Velazquez, Ph.D. > Anne Nolty, PhD, ABPP-CN > Grace Mucci, PhD, ABPdN > Tom Kiely, PhD > Joel Kramer, PsyD, ABPP-CN > Andrea Alioto, PhD, ABPP-CN > Johanna Rengifo, PhD > Ruth Serepca, PhD > Abigail Kramer, PhD > Sarah Banks, PhD, ABPP-CN > Arnold D. Purisch, Ph.D., ABPP-CN, ABN > Yuri Rassovsky, PhD, ABPP-CN > Lauren Keats, PsyD > Saskia DeVaughn, PhD, ABPP-CN > Katie Beckwith, PhD, ABPP-CN > Ashley Whitaker, PhD, ABPP-CN > Christian Carter, Ph.D., ABPP-CN > Melissa Balderrama, PsyD, ABPP > Hannah Brunet, PhD, ABPP-CN > Garima Lupas, PhD, ABPP, Board Certified in Clinical Neuropsychology > James A. Moses, Ph.D., ABPP-CN/CL > Bianca Georgescu, Psy.D., ABPP > Brandon Gavett, Ph.D. ABPP-CN > April Thames, PhD > Michelle Conover, Ph.D., QME > Daniel Jacobson, PhD, ABPP-CN > Carlos Saucedo, PhD, ABPP-CN > Sharon H. O'Neil, PhD, ABPP-CN > Audrey Khatchikia, PhD > Natalie C. Kelly, PhD, ABPP-CN > Shital Pavawalla, Ph.D., ABPP-CN > Alexander Tan, Ph.D., ABPP-CN > Phuong M. Chau, PhD ABPP-CN > Deborah Budding, Ph.D., ABN > > > > > CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Virus-free. www.avast.com
AI Analysis:
This message does not mention Judge Goodman at all. It is a thread about finding an appearance attorney for Palm Springs courthouse and a discussion about neuropsychological examination raw data and recusal motions. The message contains no references to Judge Goodman by any name variation, no rulings by Goodman, and no information that would help evaluate Goodman as a judge.
"David Shapiro" Date: November 20, 2025 4:25:00 PM Subject: Re: APPEARNCE ATTORNEY FOR PALM SPRINGS Reply to list Reply to sender Print Does anyone know of an appearance attorney who will appear Palm springs Courthouse. From: Gregory Jackson (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Thursday, November 20, 2025 2:11 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Gregory Jackson (Reply Privately) Search Nareg, Thank you for sharing this! Please keep us posted if Dr. Hungerford proceeds with the exam and complies/produces the raw data so we can add him to the list, and once you get the final minute order please circulate that as well. Here is the Dropbox of neuropsych dirt I’ve compiled, check out the ‘Minute Orders’ subfolder and there are at least a dozen in there including 8 from this year. If you send me your final minute order once the court posts it I’ll add it to the Dropbox! https://www.dropbox.com/scl/fo/c0pued3e3ftj4j0x88qji/ALFU7MTTieoSk3Dud4IyfHc?rlkey=67d52jz1uxzspr3mol96dfbkr&st=2kghiflq&dl=0 Greg Jackson Partner and Managing Attorney The Simon Law Group p : (855) 855-8910 f : (310) 914-5401 m : (714) 617-2180 a : 2916 W 164th Street Torrance CA 90504 w : www.JusticeTeam.com e : greg@justiceteam.com Orange County | Los Angeles | Arizona | Texas This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of the company. Finally, the recipient should check this email and any attachments for the presence of viruses. The company accepts no liability for any damage caused by any virus transmitted by this email. From: Nareg Kitsinian (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Thursday, November 20, 2025 11:25 AM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Nareg Kitsinian (Reply Privately) Search We successfully opposed a motion to compel a mental exam with Dr. Lars Hungerford today in San Bernardino Superior Court with Judge Joseph Widman. He made all the right calls in line with Randys Trucking and compelled that the raw data be turned over and plaintiff can record the examination. This hearing was different then past hearings. The defense play now is to use this declaration that they say 94% of neuropsychs have signed attesting they would recuse themselves if compelled to turn over data. It's persuasive, but not enough to circumvent the law. In my motion I attached two minute orders/tentative rulings where LASC courts also ruled in line with Randy Trucking. Concerningly, this prompted the defense to argue at the hearing that he would like to lodge 10 other recent orders throughout CA that he has collected that went in the opposite direction and did not compel disclosure. Judge Widman did not buy the argument. But I raise this because if 10 other courtrooms are still ruling against disclosure, it can be problematic given the judge and we should begin collecting orders in all superior courts where a judge rules with Randy Trucking so that they can be Judicially Noticed in these motions. This is the second motion I have won in the last 5 months on a TBI case. The law is with us, but it is striking to me that 10 other courts recently ruled in another direction. Attached is our tentative ruling from this morning. I hope others will share over time so we can use them as time passes. -- LATLC 2025 Secretary – 2029 President Nareg S. Kitsinian, Esq. Attorney at Law nareg@kitsinianlaw.com www.kitsinianlaw.com Tel: (818)786-5777 | Fax: (818)786-5778 16501 Ventura Blvd., Ste. 506, Encino, CA 91436 From: Kane Handel (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Tuesday, November 4, 2025 11:05 AM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Kane Handel (Reply Privately) Search file a motion!!! On 11/4/25 9:44 AM, Nareg Kitsinian (caala-workproduct listserver) wrote: List: caala-workproduct Sent by: Nareg Kitsinian (Reply Privately) Search I have a TBI case where Dr. Hungerford has refused to provide the raw data to me and is claiming in his declaration to withdraw if the court orders him to turn over the data, citing this same declaration signed by 180 other NeuroPsychs. Does anyone have any prior experience with Dr. Lars Hungerford, perhaps agreeing to turn over raw data in the past that I can use in our opposition? Nareg -----Original Message----- From: antonio@ac3law.com Sent: September 29, 2025 3:43:00 PM To: caala-workproduct@lists.trialsmith.com Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal Interestingly, Delis isn't a signatory. On Fri, Sep 19, 2025 at 3:57 PM Delavar Omidfar (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> wrote: > *List:* caala-workproduct * Sent by:* Delavar Omidfar (Reply Privately) > <domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > Search <http://www.caala.org/index.cfm?pg=search> > Andrew - Do you have the case information or copies of the App Case? > > > -----Original Message----- > > From: andrew@a2zlegal.com > Sent: September 17, 2025 6:35:00 PM > To: caala-workproduct@lists.trialsmith.com > Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal > > This is nonsense. I had to take up a writ where the judge would not allow > them to turn over the data to us and my writ was granted, court order > reversed. If I remember correctly they included this garbage in their > opposition as well but the Appellate Court did not buy it. > > > Andrew Zeytuntsyan > > Founder / Trial Attorney > > [ > https://storage-use.letsignit.com/62705ddc173a9394d8bcc888/logo_62705ddc173a9394d8bcc888_e895719889494628d401a7b8776c8039.png > ] > > 1306 W. Magnolia Blvd. > > Burbank, CA 91506 > > T. (323) 882-6500 > > F. (800) 506-7176 > > a2zlegal.com< > https://cloud.letsignit.com/collect/bc/627076c3c8565ddc6ca471ae?p=L3lrFhURv2eXFz8AUdcQMg7oZ5M7umbVf2WSzpdzFq7D1iSXrK3ZaujaqDpZOQqyzyjZl0xri-GrOODYWlP3QLZm0iplL-zlOXM4lSHQ28oSIcbvk9_JHfvcYEayMxKfUiuqgPOYkIcclIOWPouVUq8U-TmlvnN27_c7uQRHayw= > > > > [ > https://storage-use.letsignit.com/62705ddc173a9394d8bcc888/253796901116998898398879131612511431317.png > ] > > The information in this electronic mail message is confidential and for > use of only the named recipient. The information may be protected by > privilege, work product immunity or other applicable law. If you are not > the intended recipient the retention, dissemination, distribution or > copying of this e-mail message is strictly prohibited. If you receive this > message in error please notify us immediately. > > ________________________________ > From: Delavar Omidfar (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com > > Sent: Friday, September 12, 2025 3:15 PM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com > > Subject: [caala-workproduct] Neuropsych Declaration re DME Raw Data and > Recusal > > List: caala-workproduct Sent by: Delavar Omidfar (Reply Privately)< mailto: > domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal > > Search <http://www.caala.org/index.cfm?pg=search> > > Mates, > I was recently provided with the attached declaration signed by over 180 > neuropsychologists and psychologists regarding the protection of > psychological testing materials. Most importantly, all signatories have > declared: > > "I would not agree to releasing protected test information that would > jeopardize future use of tests to a non-psychologist, including attorneys, > even under a protective order. If this stipulation cannot be met, I would > recuse myself from a case." > > My suspicion is that some of these same psychologists have previously > agreed to perform mental examinations and released raw data under > protective orders. If true, this creates a significant inconsistency that > could be used to challenge their credibility and position. > > I'm reaching out to see if any of you have: > > 1. Documentation of any of these 185 signatories previously agreeing to > release raw test data under protective order > 2. Thoughts on strategies for overcoming this collective stance in future > cases > 3. Legal precedents, other than Randy's Trucking, that could compel > production despite this declaration > 4. Counter Declaration by psychs who can counter their arguments about > test security > > The complete list of 185 signatories is below. Notable names include many > prominent California neuropsychologists who regularly serve as defense > experts, i.e. Hinkin, Boone, Kopald, Lechuga, Hooker, Bondi, Elliot, Zamora. > > List of Signatories > Catherine Marreiro, PhD, ABPP-CN > Kyle Boone, PhD, ABPP-CN > William McMullen Jr., PhD, ABPP-CN > Delia M. Silva, Psy.D., ABPP-CN, Neuropsychologist > Lauren Drag, PhD, ABPP-CN > Maya Yutsis, PhD, ABPP-CN > Katherine Kruser, Psy.D., Neuropsychologist > Jeffrey Wertheimer, PhD, ABPP-CN > Jay Rosen, PhD > Michelle Zeller, Psy.D., ABPP-CN > Deborah Cahn-Weiner, Ph.D., ABPP-CN > Mi-Yeoung Jo, PsyD, ABPP-CN > Talin Babikian, PhD, ABPP-CN > Molly Memel, PhD, ABPP-CN > Rebecca Goodman, PhD, ABPP-CN > Haygoush Kalinian, PhD, Clinical Neuropsychologist > Robert M. Bilder, PhD, ABPP-CN > Robert Gray, PhD, ABPP-CN > Amir Ramezani, PhD > Leah Ellenberg, Ph. D., ABPP-CN > Charles Filanosky, PhD, ABPP-RP > Po-Haong Lu, PsyD > Angela Eastvold, PhD, ABPP-CN > Maura Mitrushina, Ph.D., ABPP-CN > Ann Gottuso, PhD, ABPP-CN > Gayle Deutsch, PhD, ABPP-CN > Simon Tan PsyD, ABPP-CN > Andrew Levine, PhD, ABPP-CN > Ernest T. Bryant, PhD, ABPP-CN > John Wager, PhD, ABPP-CN > Dominique Kinney, PhD, ABPP-CN > Brandon Kopald, Psy.D., ABPP-CN > Frederick Hives II, PhD, ABPP-CN > Lars Hungerford, PhD, ABPP-CN > Karen L. Schiltz, PhD, Neuropsychologist > Tara L. Victor, PhD, ABPP-CN > Shelley Peery, PhD > Karen Lau, PhD, ABPP-CN > Robert Tomaszewski, PhD, ABPP-CN > David M. Lechuga, PhD, ABPP, ABN > Elma Chidekel, PhD, ABN, ABPdN > William D. Hooker, Ph.D., ABN > Dale Sherman, PhD, QME > June Paltzer, PhD, ABPP-CN > Karen Earnest, PhD, ABPP-CN > John Bellone, PhD, ABPP-CN > Erin Green-Krogmann, PhD, ABPP-CN > Virginia Zuverza-Chavarria, PhD, ABPP-CN > Kimberly Lanni, PhD, ABPP, Board Certified in Clinical Neuropsychology > Mark Alfano, Ph.D., ABPP CN, RP > Steve Nitch, Ph. D., ABPP-CN > Kristina Agbayani, PhD, ABPP-CN > Andrew L. Wong, PhD, ABPP-CN > Jessica Foley, PhD, ABPP-CN > Andrew Dean, Ph. D., ABPP-CN > Allison R. Kaup, PhD > Mark W. Bondi, PhD, ABPP-CN > Jose M. Lafosse, Ph.D., ABPP-CN > Philip Sayegh, PhD, MPH > Sara Mason, PsyD > Kimberly Miller, PhD, ABPP-CN > Hayley Kristinsson, PsyD, ABPP-CN > Michael H. Kabat, Ph.D., ABPP-CN > Brigid Rose, PhD, ABPP-CN > Roger Light, PhD, ABPP-CN > Jeremy Jinkerson, PhD > David D. O'Grady, Ph.D., ABPP-CN > Anneliese Radke, Psy.D. > Joanne M. Hamilton, ABPP-CN > Travis G. Fogel, Ph.D., ABPP-CN > Sarah Tomaszewski Farias, Ph.D. ABPP-CN > Allyson C. Rosen, PhD, ABPP-CN > Sabine Gysens, PhD > George Kahle Henry, PhD. ABPP-CN > Kirsty Bortnik, PhD, ABPP-CN > Joelle Broffman, PsyD, ABPP-CN > Kristin K. Jacobson, PsyD, ABPP-CN > Alice Ruzicka, Ph.D., ABN > Renee Low, Ph.D., ABN > Stacy S Wilkins, PhD, ABPP/CN > Christine M. Naber, PhD > Aura Barragan, Psy.D. > Richard L. Delmonico, PhD, Licensed Psychologist CA PSY12604, Clinical > Neuropsychologist > Lauren Bennett, PhD, ABPP-CN > William J. Lynch, Ph.D., ABPP/CN, Licensed Psychologist [PSY 5151] > Rujvi Kamat, PhD, ABPP-CN > Krista Freeze, PhD, ABN > Carrie R. McDonald, Ph.D., ABPP-CN > Nancy A. Blum, Ph.D. > Travis Shivley-Scott, PhD > Karen Mikolic, PhD, ABN > Talia Seider, PhD, ABPP-CN > Heather Pedersen, PhD, ABPP-CN > Michael DeBellis Psy.D., ABN > Nicholas Thaler, PhD, ABPP-CN > Caroline J. Grantz, PhD > Philip K. Stenquist, Ph.D., ABPP-CN > Brian Yochim, PhD, ABPP-CN > Olivia Harner, PhD, ABPP > David Anderson, PhD, ABPP-CN/CI > Alexis D. Kulick, Ph.D., ABPP > Lori Holt, PhD, ABPP-CN > Joel S. Eppig, Ph.D. > Delany Thrasher, Ph.D., ABPP-CN > Annie Reader Murray, Ph.D., ABPP-CN > Jeffrey M. Zulow, Ph.D. > Kaitlin B. Casaletto, PhD, ABPP-CN > Alexandra Apple, PhD > Hope Goldberg, PhD, ABPP-CN > William C. Hochberger, PhD > Paul Mangal, PhD > Virdette L. Brumm, Ph.D. > Christy Hom, PhD, ABPdN > Eric J. Freitag, PsyD, FACPN > Howard J. Friedman, ABPP (CN), ABN > Jonathan E. Romain, PhD, MS, ABPP-CN > Patricia Gross, PhD, ABPP-CN > Katie Denny PhD, ABPP-CN > Katherine Bangen, PhD, ABPP-CN > Lisa Graves, PhD > John Knippa, PhD, ABN > Ashley K. Miller, PhD, ABPP-CN > Karen Hanson Bondi, Ph.D. > Lori Alasantro, PhD, ABPP-CN > Amanda Gooding, PhD, ABPP-CN > Anita Herrera-Hamilton, Ph.D ABPP > Caitlin Moore, PHD, ABPP > William Britt, PhD, ABN > Janet K. Brewer, JD, PsyD > Mimi Wong, PhD, ABPP-CN > Charles Furst, PhD, ABPP-CN > Robert W. Elliott, PhD, ABCN, ABN > Amy M. Schonfeld, PhD, Clinical Neuropsychologist > Brian A. Osterweil, Ph.D., ABPP > Duke Han, PhD, ABPP-CN > Lisa Delano-Wood, PhD > Kimberly Alfano, PhD, ABPP (CN, RP) > Alena Stasenko, PhD > Inna Fishman, PhD > Annette Swain PhD ABPP-CN > Monica Smith, PhD, ABN > Mili Parikh, PhD, ABPP > Charles H. Hinkin, Ph.D., ABPP-CN > R. Dempsey, PsyD, ABPP, QME > Margaret A. Donohue, PhD > Samantha O'Bannon, Psy.D., Clinical Neuropsychologist PSY 32564 > William T.J. Johnson, Ph.D., ABPP-CN > Tony L. Strickland, MS, PhD, ABN, FNAN > Emmanuel A. Zamora, Psy.D., Neuropsychologist > Joshua McKeever, PhD, Clinical Neuropsychologist > Carmen C. Velazquez, Ph.D. > Anne Nolty, PhD, ABPP-CN > Grace Mucci, PhD, ABPdN > Tom Kiely, PhD > Joel Kramer, PsyD, ABPP-CN > Andrea Alioto, PhD, ABPP-CN > Johanna Rengifo, PhD > Ruth Serepca, PhD > Abigail Kramer, PhD > Sarah Banks, PhD, ABPP-CN > Arnold D. Purisch, Ph.D., ABPP-CN, ABN > Yuri Rassovsky, PhD, ABPP-CN > Lauren Keats, PsyD > Saskia DeVaughn, PhD, ABPP-CN > Katie Beckwith, PhD, ABPP-CN > Ashley Whitaker, PhD, ABPP-CN > Christian Carter, Ph.D., ABPP-CN > Melissa Balderrama, PsyD, ABPP > Hannah Brunet, PhD, ABPP-CN > Garima Lupas, PhD, ABPP, Board Certified in Clinical Neuropsychology > James A. Moses, Ph.D., ABPP-CN/CL > Bianca Georgescu, Psy.D., ABPP > Brandon Gavett, Ph.D. ABPP-CN > April Thames, PhD > Michelle Conover, Ph.D., QME > Daniel Jacobson, PhD, ABPP-CN > Carlos Saucedo, PhD, ABPP-CN > Sharon H. O'Neil, PhD, ABPP-CN > Audrey Khatchikia, PhD > Natalie C. Kelly, PhD, ABPP-CN > Shital Pavawalla, Ph.D., ABPP-CN > Alexander Tan, Ph.D., ABPP-CN > Phuong M. Chau, PhD ABPP-CN > Deborah Budding, Ph.D., ABN > > > > > CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Virus-free. www.avast.com
AI Analysis:
This message thread is entirely about neuropsychological DME raw data disclosure, Dr. Lars Hungerford, and a TBI case. The judge 'goodman' is not mentioned anywhere in the message. The discussion involves attorneys sharing experiences with a neuropsych expert witness and appellate writ strategy, with no reference to Judge Goodman's rulings, behavior, or courtroom conduct.
"Kane Handel" Date: November 04, 2025 1:06:00 PM Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal Reply to list Reply to sender Print List: caala-workproduct Sent by: Kane Handel (Reply Privately) Search file a motion!!! On 11/4/25 9:44 AM, Nareg Kitsinian (caala-workproduct listserver) wrote: List: caala-workproduct Sent by: Nareg Kitsinian (Reply Privately) Search I have a TBI case where Dr. Hungerford has refused to provide the raw data to me and is claiming in his declaration to withdraw if the court orders him to turn over the data, citing this same declaration signed by 180 other NeuroPsychs. Does anyone have any prior experience with Dr. Lars Hungerford, perhaps agreeing to turn over raw data in the past that I can use in our opposition? Nareg -----Original Message----- From: antonio@ac3law.com Sent: September 29, 2025 3:43:00 PM To: caala-workproduct@lists.trialsmith.com Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal Interestingly, Delis isn't a signatory. On Fri, Sep 19, 2025 at 3:57 PM Delavar Omidfar (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> wrote: > *List:* caala-workproduct * Sent by:* Delavar Omidfar (Reply Privately) > <domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > Search <http://www.caala.org/index.cfm?pg=search> > Andrew - Do you have the case information or copies of the App Case? > > > -----Original Message----- > > From: andrew@a2zlegal.com > Sent: September 17, 2025 6:35:00 PM > To: caala-workproduct@lists.trialsmith.com > Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal > > This is nonsense. I had to take up a writ where the judge would not allow > them to turn over the data to us and my writ was granted, court order > reversed. If I remember correctly they included this garbage in their > opposition as well but the Appellate Court did not buy it. > > > Andrew Zeytuntsyan > > Founder / Trial Attorney > > [ > https://storage-use.letsignit.com/62705ddc173a9394d8bcc888/logo_62705ddc173a9394d8bcc888_e895719889494628d401a7b8776c8039.png > ] > > 1306 W. Magnolia Blvd. > > Burbank, CA 91506 > > T. (323) 882-6500 > > F. (800) 506-7176 > > a2zlegal.com< > https://cloud.letsignit.com/collect/bc/627076c3c8565ddc6ca471ae?p=L3lrFhURv2eXFz8AUdcQMg7oZ5M7umbVf2WSzpdzFq7D1iSXrK3ZaujaqDpZOQqyzyjZl0xri-GrOODYWlP3QLZm0iplL-zlOXM4lSHQ28oSIcbvk9_JHfvcYEayMxKfUiuqgPOYkIcclIOWPouVUq8U-TmlvnN27_c7uQRHayw= > > > > [ > https://storage-use.letsignit.com/62705ddc173a9394d8bcc888/253796901116998898398879131612511431317.png > ] > > The information in this electronic mail message is confidential and for > use of only the named recipient. The information may be protected by > privilege, work product immunity or other applicable law. If you are not > the intended recipient the retention, dissemination, distribution or > copying of this e-mail message is strictly prohibited. If you receive this > message in error please notify us immediately. > > ________________________________ > From: Delavar Omidfar (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com > > Sent: Friday, September 12, 2025 3:15 PM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com > > Subject: [caala-workproduct] Neuropsych Declaration re DME Raw Data and > Recusal > > List: caala-workproduct Sent by: Delavar Omidfar (Reply Privately)<mailto: > domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal > > Search <http://www.caala.org/index.cfm?pg=search> > > Mates, > I was recently provided with the attached declaration signed by over 180 > neuropsychologists and psychologists regarding the protection of > psychological testing materials. Most importantly, all signatories have > declared: > > "I would not agree to releasing protected test information that would > jeopardize future use of tests to a non-psychologist, including attorneys, > even under a protective order. If this stipulation cannot be met, I would > recuse myself from a case." > > My suspicion is that some of these same psychologists have previously > agreed to perform mental examinations and released raw data under > protective orders. If true, this creates a significant inconsistency that > could be used to challenge their credibility and position. > > I'm reaching out to see if any of you have: > > 1. Documentation of any of these 185 signatories previously agreeing to > release raw test data under protective order > 2. Thoughts on strategies for overcoming this collective stance in future > cases > 3. Legal precedents, other than Randy's Trucking, that could compel > production despite this declaration > 4. Counter Declaration by psychs who can counter their arguments about > test security > > The complete list of 185 signatories is below. Notable names include many > prominent California neuropsychologists who regularly serve as defense > experts, i.e. Hinkin, Boone, Kopald, Lechuga, Hooker, Bondi, Elliot, Zamora. > > List of Signatories > Catherine Marreiro, PhD, ABPP-CN > Kyle Boone, PhD, ABPP-CN > William McMullen Jr., PhD, ABPP-CN > Delia M. Silva, Psy.D., ABPP-CN, Neuropsychologist > Lauren Drag, PhD, ABPP-CN > Maya Yutsis, PhD, ABPP-CN > Katherine Kruser, Psy.D., Neuropsychologist > Jeffrey Wertheimer, PhD, ABPP-CN > Jay Rosen, PhD > Michelle Zeller, Psy.D., ABPP-CN > Deborah Cahn-Weiner, Ph.D., ABPP-CN > Mi-Yeoung Jo, PsyD, ABPP-CN > Talin Babikian, PhD, ABPP-CN > Molly Memel, PhD, ABPP-CN > Rebecca Goodman, PhD, ABPP-CN > Haygoush Kalinian, PhD, Clinical Neuropsychologist > Robert M. Bilder, PhD, ABPP-CN > Robert Gray, PhD, ABPP-CN > Amir Ramezani, PhD > Leah Ellenberg, Ph. D., ABPP-CN > Charles Filanosky, PhD, ABPP-RP > Po-Haong Lu, PsyD > Angela Eastvold, PhD, ABPP-CN > Maura Mitrushina, Ph.D., ABPP-CN > Ann Gottuso, PhD, ABPP-CN > Gayle Deutsch, PhD, ABPP-CN > Simon Tan PsyD, ABPP-CN > Andrew Levine, PhD, ABPP-CN > Ernest T. Bryant, PhD, ABPP-CN > John Wager, PhD, ABPP-CN > Dominique Kinney, PhD, ABPP-CN > Brandon Kopald, Psy.D., ABPP-CN > Frederick Hives II, PhD, ABPP-CN > Lars Hungerford, PhD, ABPP-CN > Karen L. Schiltz, PhD, Neuropsychologist > Tara L. Victor, PhD, ABPP-CN > Shelley Peery, PhD > Karen Lau, PhD, ABPP-CN > Robert Tomaszewski, PhD, ABPP-CN > David M. Lechuga, PhD, ABPP, ABN > Elma Chidekel, PhD, ABN, ABPdN > William D. Hooker, Ph.D., ABN > Dale Sherman, PhD, QME > June Paltzer, PhD, ABPP-CN > Karen Earnest, PhD, ABPP-CN > John Bellone, PhD, ABPP-CN > Erin Green-Krogmann, PhD, ABPP-CN > Virginia Zuverza-Chavarria, PhD, ABPP-CN > Kimberly Lanni, PhD, ABPP, Board Certified in Clinical Neuropsychology > Mark Alfano, Ph.D., ABPP CN, RP > Steve Nitch, Ph. D., ABPP-CN > Kristina Agbayani, PhD, ABPP-CN > Andrew L. Wong, PhD, ABPP-CN > Jessica Foley, PhD, ABPP-CN > Andrew Dean, Ph. D., ABPP-CN > Allison R. Kaup, PhD > Mark W. Bondi, PhD, ABPP-CN > Jose M. Lafosse, Ph.D., ABPP-CN > Philip Sayegh, PhD, MPH > Sara Mason, PsyD > Kimberly Miller, PhD, ABPP-CN > Hayley Kristinsson, PsyD, ABPP-CN > Michael H. Kabat, Ph.D., ABPP-CN > Brigid Rose, PhD, ABPP-CN > Roger Light, PhD, ABPP-CN > Jeremy Jinkerson, PhD > David D. O'Grady, Ph.D., ABPP-CN > Anneliese Radke, Psy.D. > Joanne M. Hamilton, ABPP-CN > Travis G. Fogel, Ph.D., ABPP-CN > Sarah Tomaszewski Farias, Ph.D. ABPP-CN > Allyson C. Rosen, PhD, ABPP-CN > Sabine Gysens, PhD > George Kahle Henry, PhD. ABPP-CN > Kirsty Bortnik, PhD, ABPP-CN > Joelle Broffman, PsyD, ABPP-CN > Kristin K. Jacobson, PsyD, ABPP-CN > Alice Ruzicka, Ph.D., ABN > Renee Low, Ph.D., ABN > Stacy S Wilkins, PhD, ABPP/CN > Christine M. Naber, PhD > Aura Barragan, Psy.D. > Richard L. Delmonico, PhD, Licensed Psychologist CA PSY12604, Clinical > Neuropsychologist > Lauren Bennett, PhD, ABPP-CN > William J. Lynch, Ph.D., ABPP/CN, Licensed Psychologist [PSY 5151] > Rujvi Kamat, PhD, ABPP-CN > Krista Freeze, PhD, ABN > Carrie R. McDonald, Ph.D., ABPP-CN > Nancy A. Blum, Ph.D. > Travis Shivley-Scott, PhD > Karen Mikolic, PhD, ABN > Talia Seider, PhD, ABPP-CN > Heather Pedersen, PhD, ABPP-CN > Michael DeBellis Psy.D., ABN > Nicholas Thaler, PhD, ABPP-CN > Caroline J. Grantz, PhD > Philip K. Stenquist, Ph.D., ABPP-CN > Brian Yochim, PhD, ABPP-CN > Olivia Harner, PhD, ABPP > David Anderson, PhD, ABPP-CN/CI > Alexis D. Kulick, Ph.D., ABPP > Lori Holt, PhD, ABPP-CN > Joel S. Eppig, Ph.D. > Delany Thrasher, Ph.D., ABPP-CN > Annie Reader Murray, Ph.D., ABPP-CN > Jeffrey M. Zulow, Ph.D. > Kaitlin B. Casaletto, PhD, ABPP-CN > Alexandra Apple, PhD > Hope Goldberg, PhD, ABPP-CN > William C. Hochberger, PhD > Paul Mangal, PhD > Virdette L. Brumm, Ph.D. > Christy Hom, PhD, ABPdN > Eric J. Freitag, PsyD, FACPN > Howard J. Friedman, ABPP (CN), ABN > Jonathan E. Romain, PhD, MS, ABPP-CN > Patricia Gross, PhD, ABPP-CN > Katie Denny PhD, ABPP-CN > Katherine Bangen, PhD, ABPP-CN > Lisa Graves, PhD > John Knippa, PhD, ABN > Ashley K. Miller, PhD, ABPP-CN > Karen Hanson Bondi, Ph.D. > Lori Alasantro, PhD, ABPP-CN > Amanda Gooding, PhD, ABPP-CN > Anita Herrera-Hamilton, Ph.D ABPP > Caitlin Moore, PHD, ABPP > William Britt, PhD, ABN > Janet K. Brewer, JD, PsyD > Mimi Wong, PhD, ABPP-CN > Charles Furst, PhD, ABPP-CN > Robert W. Elliott, PhD, ABCN, ABN > Amy M. Schonfeld, PhD, Clinical Neuropsychologist > Brian A. Osterweil, Ph.D., ABPP > Duke Han, PhD, ABPP-CN > Lisa Delano-Wood, PhD > Kimberly Alfano, PhD, ABPP (CN, RP) > Alena Stasenko, PhD > Inna Fishman, PhD > Annette Swain PhD ABPP-CN > Monica Smith, PhD, ABN > Mili Parikh, PhD, ABPP > Charles H. Hinkin, Ph.D., ABPP-CN > R. Dempsey, PsyD, ABPP, QME > Margaret A. Donohue, PhD > Samantha O'Bannon, Psy.D., Clinical Neuropsychologist PSY 32564 > William T.J. Johnson, Ph.D., ABPP-CN > Tony L. Strickland, MS, PhD, ABN, FNAN > Emmanuel A. Zamora, Psy.D., Neuropsychologist > Joshua McKeever, PhD, Clinical Neuropsychologist > Carmen C. Velazquez, Ph.D. > Anne Nolty, PhD, ABPP-CN > Grace Mucci, PhD, ABPdN > Tom Kiely, PhD > Joel Kramer, PsyD, ABPP-CN > Andrea Alioto, PhD, ABPP-CN > Johanna Rengifo, PhD > Ruth Serepca, PhD > Abigail Kramer, PhD > Sarah Banks, PhD, ABPP-CN > Arnold D. Purisch, Ph.D., ABPP-CN, ABN > Yuri Rassovsky, PhD, ABPP-CN > Lauren Keats, PsyD > Saskia DeVaughn, PhD, ABPP-CN > Katie Beckwith, PhD, ABPP-CN > Ashley Whitaker, PhD, ABPP-CN > Christian Carter, Ph.D., ABPP-CN > Melissa Balderrama, PsyD, ABPP > Hannah Brunet, PhD, ABPP-CN > Garima Lupas, PhD, ABPP, Board Certified in Clinical Neuropsychology > James A. Moses, Ph.D., ABPP-CN/CL > Bianca Georgescu, Psy.D., ABPP > Brandon Gavett, Ph.D. ABPP-CN > April Thames, PhD > Michelle Conover, Ph.D., QME > Daniel Jacobson, PhD, ABPP-CN > Carlos Saucedo, PhD, ABPP-CN > Sharon H. O'Neil, PhD, ABPP-CN > Audrey Khatchikia, PhD > Natalie C. Kelly, PhD, ABPP-CN > Shital Pavawalla, Ph.D., ABPP-CN > Alexander Tan, Ph.D., ABPP-CN > Phuong M. Chau, PhD ABPP-CN > Deborah Budding, Ph.D., ABN > > > > >
AI Analysis:
This message thread is entirely about neuropsychological DME raw data disclosure issues, specifically involving Dr. Lars Hungerford and a declaration signed by neuropsychologists. The discussion involves a TBI case, a writ proceeding, and an appellate court ruling. The judge 'goodman' is not mentioned anywhere in this message or the quoted reply chain. This message contains no information relevant to evaluating Judge Goodman.
"Nareg Kitsinian" Date: November 04, 2025 11:45:00 AM Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal Reply to list Reply to sender Print List: caala-workproduct Sent by: Nareg Kitsinian (Reply Privately) Search I have a TBI case where Dr. Hungerford has refused to provide the raw data to me and is claiming in his declaration to withdraw if the court orders him to turn over the data, citing this same declaration signed by 180 other NeuroPsychs. Does anyone have any prior experience with Dr. Lars Hungerford, perhaps agreeing to turn over raw data in the past that I can use in our opposition? Nareg -----Original Message----- From: antonio@ac3law.com Sent: September 29, 2025 3:43:00 PM To: caala-workproduct@lists.trialsmith.com Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal Interestingly, Delis isn't a signatory. On Fri, Sep 19, 2025 at 3:57 PM Delavar Omidfar (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> wrote: > *List:* caala-workproduct * Sent by:* Delavar Omidfar (Reply Privately) > <domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > Search <http://www.caala.org/index.cfm?pg=search> > Andrew - Do you have the case information or copies of the App Case? > > > -----Original Message----- > > From: andrew@a2zlegal.com > Sent: September 17, 2025 6:35:00 PM > To: caala-workproduct@lists.trialsmith.com > Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal > > This is nonsense. I had to take up a writ where the judge would not allow > them to turn over the data to us and my writ was granted, court order > reversed. If I remember correctly they included this garbage in their > opposition as well but the Appellate Court did not buy it. > > > Andrew Zeytuntsyan > > Founder / Trial Attorney > > [ > https://storage-use.letsignit.com/62705ddc173a9394d8bcc888/logo_62705ddc173a9394d8bcc888_e895719889494628d401a7b8776c8039.png > ] > > 1306 W. Magnolia Blvd. > > Burbank, CA 91506 > > T. (323) 882-6500 > > F. (800) 506-7176 > > a2zlegal.com< > https://cloud.letsignit.com/collect/bc/627076c3c8565ddc6ca471ae?p=L3lrFhURv2eXFz8AUdcQMg7oZ5M7umbVf2WSzpdzFq7D1iSXrK3ZaujaqDpZOQqyzyjZl0xri-GrOODYWlP3QLZm0iplL-zlOXM4lSHQ28oSIcbvk9_JHfvcYEayMxKfUiuqgPOYkIcclIOWPouVUq8U-TmlvnN27_c7uQRHayw= > > > > [ > https://storage-use.letsignit.com/62705ddc173a9394d8bcc888/253796901116998898398879131612511431317.png > ] > > The information in this electronic mail message is confidential and for > use of only the named recipient. The information may be protected by > privilege, work product immunity or other applicable law. If you are not > the intended recipient the retention, dissemination, distribution or > copying of this e-mail message is strictly prohibited. If you receive this > message in error please notify us immediately. > > ________________________________ > From: Delavar Omidfar (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com> > Sent: Friday, September 12, 2025 3:15 PM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com> > Subject: [caala-workproduct] Neuropsych Declaration re DME Raw Data and > Recusal > > List: caala-workproduct Sent by: Delavar Omidfar (Reply Privately)<mailto: > domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > Search<http://www.caala.org/index.cfm?pg=search> > > Mates, > I was recently provided with the attached declaration signed by over 180 > neuropsychologists and psychologists regarding the protection of > psychological testing materials. Most importantly, all signatories have > declared: > > "I would not agree to releasing protected test information that would > jeopardize future use of tests to a non-psychologist, including attorneys, > even under a protective order. If this stipulation cannot be met, I would > recuse myself from a case." > > My suspicion is that some of these same psychologists have previously > agreed to perform mental examinations and released raw data under > protective orders. If true, this creates a significant inconsistency that > could be used to challenge their credibility and position. > > I'm reaching out to see if any of you have: > > 1. Documentation of any of these 185 signatories previously agreeing to > release raw test data under protective order > 2. Thoughts on strategies for overcoming this collective stance in future > cases > 3. Legal precedents, other than Randy's Trucking, that could compel > production despite this declaration > 4. Counter Declaration by psychs who can counter their arguments about > test security > > The complete list of 185 signatories is below. Notable names include many > prominent California neuropsychologists who regularly serve as defense > experts, i.e. Hinkin, Boone, Kopald, Lechuga, Hooker, Bondi, Elliot, Zamora. > > List of Signatories > Catherine Marreiro, PhD, ABPP-CN > Kyle Boone, PhD, ABPP-CN > William McMullen Jr., PhD, ABPP-CN > Delia M. Silva, Psy.D., ABPP-CN, Neuropsychologist > Lauren Drag, PhD, ABPP-CN > Maya Yutsis, PhD, ABPP-CN > Katherine Kruser, Psy.D., Neuropsychologist > Jeffrey Wertheimer, PhD, ABPP-CN > Jay Rosen, PhD > Michelle Zeller, Psy.D., ABPP-CN > Deborah Cahn-Weiner, Ph.D., ABPP-CN > Mi-Yeoung Jo, PsyD, ABPP-CN > Talin Babikian, PhD, ABPP-CN > Molly Memel, PhD, ABPP-CN > Rebecca Goodman, PhD, ABPP-CN > Haygoush Kalinian, PhD, Clinical Neuropsychologist > Robert M. Bilder, PhD, ABPP-CN > Robert Gray, PhD, ABPP-CN > Amir Ramezani, PhD > Leah Ellenberg, Ph. D., ABPP-CN > Charles Filanosky, PhD, ABPP-RP > Po-Haong Lu, PsyD > Angela Eastvold, PhD, ABPP-CN > Maura Mitrushina, Ph.D., ABPP-CN > Ann Gottuso, PhD, ABPP-CN > Gayle Deutsch, PhD, ABPP-CN > Simon Tan PsyD, ABPP-CN > Andrew Levine, PhD, ABPP-CN > Ernest T. Bryant, PhD, ABPP-CN > John Wager, PhD, ABPP-CN > Dominique Kinney, PhD, ABPP-CN > Brandon Kopald, Psy.D., ABPP-CN > Frederick Hives II, PhD, ABPP-CN > Lars Hungerford, PhD, ABPP-CN > Karen L. Schiltz, PhD, Neuropsychologist > Tara L. Victor, PhD, ABPP-CN > Shelley Peery, PhD > Karen Lau, PhD, ABPP-CN > Robert Tomaszewski, PhD, ABPP-CN > David M. Lechuga, PhD, ABPP, ABN > Elma Chidekel, PhD, ABN, ABPdN > William D. Hooker, Ph.D., ABN > Dale Sherman, PhD, QME > June Paltzer, PhD, ABPP-CN > Karen Earnest, PhD, ABPP-CN > John Bellone, PhD, ABPP-CN > Erin Green-Krogmann, PhD, ABPP-CN > Virginia Zuverza-Chavarria, PhD, ABPP-CN > Kimberly Lanni, PhD, ABPP, Board Certified in Clinical Neuropsychology > Mark Alfano, Ph.D., ABPP CN, RP > Steve Nitch, Ph. D., ABPP-CN > Kristina Agbayani, PhD, ABPP-CN > Andrew L. Wong, PhD, ABPP-CN > Jessica Foley, PhD, ABPP-CN > Andrew Dean, Ph. D., ABPP-CN > Allison R. Kaup, PhD > Mark W. Bondi, PhD, ABPP-CN > Jose M. Lafosse, Ph.D., ABPP-CN > Philip Sayegh, PhD, MPH > Sara Mason, PsyD > Kimberly Miller, PhD, ABPP-CN > Hayley Kristinsson, PsyD, ABPP-CN > Michael H. Kabat, Ph.D., ABPP-CN > Brigid Rose, PhD, ABPP-CN > Roger Light, PhD, ABPP-CN > Jeremy Jinkerson, PhD > David D. O'Grady, Ph.D., ABPP-CN > Anneliese Radke, Psy.D. > Joanne M. Hamilton, ABPP-CN > Travis G. Fogel, Ph.D., ABPP-CN > Sarah Tomaszewski Farias, Ph.D. ABPP-CN > Allyson C. Rosen, PhD, ABPP-CN > Sabine Gysens, PhD > George Kahle Henry, PhD. ABPP-CN > Kirsty Bortnik, PhD, ABPP-CN > Joelle Broffman, PsyD, ABPP-CN > Kristin K. Jacobson, PsyD, ABPP-CN > Alice Ruzicka, Ph.D., ABN > Renee Low, Ph.D., ABN > Stacy S Wilkins, PhD, ABPP/CN > Christine M. Naber, PhD > Aura Barragan, Psy.D. > Richard L. Delmonico, PhD, Licensed Psychologist CA PSY12604, Clinical > Neuropsychologist > Lauren Bennett, PhD, ABPP-CN > William J. Lynch, Ph.D., ABPP/CN, Licensed Psychologist [PSY 5151] > Rujvi Kamat, PhD, ABPP-CN > Krista Freeze, PhD, ABN > Carrie R. McDonald, Ph.D., ABPP-CN > Nancy A. Blum, Ph.D. > Travis Shivley-Scott, PhD > Karen Mikolic, PhD, ABN > Talia Seider, PhD, ABPP-CN > Heather Pedersen, PhD, ABPP-CN > Michael DeBellis Psy.D., ABN > Nicholas Thaler, PhD, ABPP-CN > Caroline J. Grantz, PhD > Philip K. Stenquist, Ph.D., ABPP-CN > Brian Yochim, PhD, ABPP-CN > Olivia Harner, PhD, ABPP > David Anderson, PhD, ABPP-CN/CI > Alexis D. Kulick, Ph.D., ABPP > Lori Holt, PhD, ABPP-CN > Joel S. Eppig, Ph.D. > Delany Thrasher, Ph.D., ABPP-CN > Annie Reader Murray, Ph.D., ABPP-CN > Jeffrey M. Zulow, Ph.D. > Kaitlin B. Casaletto, PhD, ABPP-CN > Alexandra Apple, PhD > Hope Goldberg, PhD, ABPP-CN > William C. Hochberger, PhD > Paul Mangal, PhD > Virdette L. Brumm, Ph.D. > Christy Hom, PhD, ABPdN > Eric J. Freitag, PsyD, FACPN > Howard J. Friedman, ABPP (CN), ABN > Jonathan E. Romain, PhD, MS, ABPP-CN > Patricia Gross, PhD, ABPP-CN > Katie Denny PhD, ABPP-CN > Katherine Bangen, PhD, ABPP-CN > Lisa Graves, PhD > John Knippa, PhD, ABN > Ashley K. Miller, PhD, ABPP-CN > Karen Hanson Bondi, Ph.D. > Lori Alasantro, PhD, ABPP-CN > Amanda Gooding, PhD, ABPP-CN > Anita Herrera-Hamilton, Ph.D ABPP > Caitlin Moore, PHD, ABPP > William Britt, PhD, ABN > Janet K. Brewer, JD, PsyD > Mimi Wong, PhD, ABPP-CN > Charles Furst, PhD, ABPP-CN > Robert W. Elliott, PhD, ABCN, ABN > Amy M. Schonfeld, PhD, Clinical Neuropsychologist > Brian A. Osterweil, Ph.D., ABPP > Duke Han, PhD, ABPP-CN > Lisa Delano-Wood, PhD > Kimberly Alfano, PhD, ABPP (CN, RP) > Alena Stasenko, PhD > Inna Fishman, PhD > Annette Swain PhD ABPP-CN > Monica Smith, PhD, ABN > Mili Parikh, PhD, ABPP > Charles H. Hinkin, Ph.D., ABPP-CN > R. Dempsey, PsyD, ABPP, QME > Margaret A. Donohue, PhD > Samantha O'Bannon, Psy.D., Clinical Neuropsychologist PSY 32564 > William T.J. Johnson, Ph.D., ABPP-CN > Tony L. Strickland, MS, PhD, ABN, FNAN > Emmanuel A. Zamora, Psy.D., Neuropsychologist > Joshua McKeever, PhD, Clinical Neuropsychologist > Carmen C. Velazquez, Ph.D. > Anne Nolty, PhD, ABPP-CN > Grace Mucci, PhD, ABPdN > Tom Kiely, PhD > Joel Kramer, PsyD, ABPP-CN > Andrea Alioto, PhD, ABPP-CN > Johanna Rengifo, PhD > Ruth Serepca, PhD > Abigail Kramer, PhD > Sarah Banks, PhD, ABPP-CN > Arnold D. Purisch, Ph.D., ABPP-CN, ABN > Yuri Rassovsky, PhD, ABPP-CN > Lauren Keats, PsyD > Saskia DeVaughn, PhD, ABPP-CN > Katie Beckwith, PhD, ABPP-CN > Ashley Whitaker, PhD, ABPP-CN > Christian Carter, Ph.D., ABPP-CN > Melissa Balderrama, PsyD, ABPP > Hannah Brunet, PhD, ABPP-CN > Garima Lupas, PhD, ABPP, Board Certified in Clinical Neuropsychology > James A. Moses, Ph.D., ABPP-CN/CL > Bianca Georgescu, Psy.D., ABPP > Brandon Gavett, Ph.D. ABPP-CN > April Thames, PhD > Michelle Conover, Ph.D., QME > Daniel Jacobson, PhD, ABPP-CN > Carlos Saucedo, PhD, ABPP-CN > Sharon H. O'Neil, PhD, ABPP-CN > Audrey Khatchikia, PhD > Natalie C. Kelly, PhD, ABPP-CN > Shital Pavawalla, Ph.D., ABPP-CN > Alexander Tan, Ph.D., ABPP-CN > Phuong M. Chau, PhD ABPP-CN > Deborah Budding, Ph.D., ABN > > > > >
AI Analysis:
This message does not mention 'goodman' at all. It discusses arbitrators Margaret, Jaqueline, Bacigalupo, and Keosian in the context of a CAALA listserv thread about selecting arbitrators from a strike and rank list. There is no reference to Judge Goodman in any form, and the message contains no information useful for evaluating goodman as a judge.
"Aimee Kirby" Date: March 03, 2025 3:01:00 PM Subject: Re: Need to choose arbitrators from strike and rank list - any good ones here? Reply to list Reply to sender Print List: caala-workproduct Sent by: Aimee Kirby (Reply Privately) Search Margaret and Jaqueline are great. Aimee E. Kirby Dolan Law Firm -----Original Message----- From: ajr@romerolaw.com Sent: March 03, 2025 2:52:00 PM To: caala-workproduct@lists.trialsmith.com Subject: Re: Need to choose arbitrators from strike and rank list - any good ones here? I know Bacigalupo personally (former State Bar judge), and he is a solid person. Litigated plenty in front of Keosian, and he was always fine. Have not ---------------------------------------------- Alan Romero ROMERO LAW, APC 251 S. Lake Avenue, Suite 930 Pasadena, CA 91101-4873 (626) 396-9900 Office (626) 396-9990 Facsimile ajr@romerolaw.com DISCLAIMER AND ADVISORY: The information contained in this electronic communication is legally privileged and confidential information intended only for the use of the individual or entity named to whom it is addressed, and is protected from disclosure. If the reader of this electronic communication is not the intended recipient, the reader is hereby notified that any use, dissemination, disclosure, distribution, or copying of this transmission is strictly prohibited and that there has been and shall be no waiver of any privilege or confidence by the reader's receipt of this electronic communication. If the reader has received this transmission in error, please immediately notify this office by email, telephone, or fax and permanently delete the original transmission and any hard copies that may be in the reader's possession. On Mon, Mar 3, 2025 at 12:50 PM Abraham Niman (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> wrote: > *List:* caala-workproduct * Sent by:* Abraham Niman (Reply Privately) > <avi.caala@gmail.com?subject=Re%3A%20Need%20to%20choose%20arbitrators%20from%20strike%20and%20rank%20list%20-%20any%20good%20ones%20here%3F> > Search <http://www.caala.org/index.cfm?pg=search> > Mates, > > I need to strike 3 names from this ADR list and then order the remaining. > Who would you strike and recommend? > > Thank you > > *NEUTRAL* > > *Hon. Paul Bacigalupo > <https://www.adrservices.com/neutrals/bacigalupo-paul/>* > > > *Hon. Victoria Gerrard Chaney > <https://www.adrservices.com/neutrals/chaney-victoria/>* > > > *Hon. Jacqueline A. Connor* > <http://www.adrservices.com/neutrals/connor-jacqueline/> > > > *Hon. Elizabeth R. Feffer* > <https://www.adrservices.com/neutrals/feffer-elizabeth/> > > > *Hon. Allan J. Goodman* > <https://www.adrservices.com/neutrals/goodman-allan/> > > > *Hon. Gregory Keosian > <https://www.adrservices.com/neutrals/keosian-gregory/>* > > > *Robert S. Mann, Esq.* <http://www.adrservices.com/neutrals/mann-robert/> > > > *Hon. Margaret Oldendorf > <https://www.adrservices.com/neutrals/oldendorf-margaret/>* > > *Hon. Gerald Rosenberg* > <https://www.adrservices.com/neutrals/rosenberg-gerald/> > > > *Hon. Thomas L. Willhite, Jr.* > <https://www.adrservices.com/neutrals/willhite-thomas/> > > >
AI Analysis:
This message makes no mention of 'goodman' in any form. It only discusses judges Bacigalupo and Keosian, with brief opinions about their character and courtroom experience. There is no substantive information about goodman that would help evaluate them as a judge.
I know Bacigalupo personally (former State Bar judge), and he is a solid person. Litigated plenty in front of Keosian, and he was always fine. Have not ---------------------------------------------- Alan Romero ROMERO LAW, APC 251 S. Lake Avenue, Suite 930 Pasadena, CA 91101-4873 (626) 396-9900 Office (626) 396-9990 Facsimile ajr@romerolaw.com DISCLAIMER AND ADVISORY: The information contained in this electronic communication is legally privileged and confidential information intended only for the use of the individual or entity named to whom it is addressed, and is protected from disclosure. If the reader of this electronic communication is not the intended recipient, the reader is hereby notified that any use, dissemination, disclosure, distribution, or copying of this transmission is strictly prohibited and that there has been and shall be no waiver of any privilege or confidence by the reader’s receipt of this electronic communication. If the reader has received this transmission in error, please immediately notify this office by email, telephone, or fax and permanently delete the original transmission and any hard copies that may be in the reader’s possession.
AI Analysis:
This message does not mention Judge Goodman at all. It is a discussion between attorneys on the CAALA listserv about procedural deadlines for filing an opposition to a Motion to Strike/Tax Costs under CCP 1005(b), along with an attached sample opposition. The message is entirely about civil procedure timing rules and has no reference to Judge Goodman or any workers' compensation judge.
"Nina Brahman" Date: October 28, 2024 2:37:00 PM Subject: Re: Opp to Strike/Tax Cost - Sample and Deadline Reply to list Reply to sender Print Attachments: opposition motion to tax costs ware.pdf (4303 K) List: caala-workproduct Sent by: Nina Brahman (Reply Privately) Search Hi Diallah: Motions must be filed at least 16 court days before the hearing. See CCP 1005(b). "b) Unless otherwise ordered or specifically provided by law, all moving and supporting papers shall be served and filed at least 16 court days before the hearing. ....All papers opposing a motion so noticed shall be filed with the court and a copy served on each party at least nine court days, and all reply papers at least five court days before the hearing." Your defendants filed their motion only 9 court days before the hearing. The lack of proper notice is, by itself, ground for a winning opposition. You can either advise them of the deficiency and ask that they move the hearing so you would have the time allowed by the code to file your opposition or oppose it asap. I am attaching one of my oppositions to a Motion to Tax Costs in hopes that it can help you, but these oppositions are very fact oriented so it might take you more than day to gather your evidence. Please let me know if you have any questions. Nina P. Brahman THE BRAHMAN LAW OFFICE, APC 5009 Topanga Canyon Blvd. Woodland Hills, CA 91364 Tel: 310-859-8638 nina@brahmanlaw.com -----Original Message----- From: diallah@justiceforhumans.com Sent: October 28, 2024 1:13:00 PM To: caala-workproduct@lists.trialsmith.com Subject: Re: Opp to Strike/Tax Cost - Sample and Deadline Good morning all Defendants filed a Motion to Strike Costs in the evening on Friday October 25, 2024 to be heard on November 7, 2024. Does anyone have a sample opposition. Also, Defendants timely filed the motion, however, the hearing is set to be heard in 2 weeks. When is my opposition due? If 9 court days prior, that would mean it is due today! TIA Diallah Bhanji RD, Esq. Bhanji Law Firm "Your Gladiator For Justice " Medical Malpractice ' Personal Injury ' Immigration ' Nursing Home Litigation https://JusticeForHumans.com 425-281-6858
AI Analysis:
This message has no mention of Judge Goodman whatsoever. It is a discussion between attorneys (Rod Suarez and Brad) about handling a school complaint case involving physical abuse of a minor, covering topics such as causes of action, jury strategy, deposition protections for minor witnesses, and applicable evidence codes. The message does not reference Judge Goodman by name, discuss any rulings or courtroom behavior, or contain any information that would be useful for evaluating Goodman as a workers' compensation judge.
"Rod Suarez" Date: October 16, 2024 1:28:00 PM Subject: Re: School Complaint Reply to list Reply to sender Print Attachments: california judge bench book - child witness - revised 2016pt.pdf (1910 K) 765 court to control mode of interrogation.doc (22 K) Brad, I know I have an old one from around 2013 or so, but its likely on an old external hard drive in my garage. If I find it, I’ll share. I’ll look for it this weekend. Just remember to also include all intentional torts to the COAs, assault, battery, false imprisonment, and Professional Negligence/negligence per se (CACI No. 600), for violating the applicable teaching standards and CA Education department laws/rules. Physical abuse of a minor by schoolteachers or administrators are very emotionally charged cases to present to a jury. Parents, daily, entrust their children to schoolteachers and administrators when they drop them off at school. A parent trusts that those people will ensure the safety of their sons and daughters. No parent would leave their children with persons who they suspect would hurt them. When those who we rely on to keep our sons and daughters safe breach this trust, its repercussions are life altering. Jurors, parents or not, empathize with that. In case applicable, if the minor is of special abilities (i.e., physical limitations, within autism spectrum, Aspergers, etc.) different rules apply. Finally, if defense counsel requests to depose the minor, different rules for deposition apply (Evid Code 765(b)). Preferably you will reach a stipulation with the agreed protections for the child, otherwise you will need a court order. Remember, DC is entitled to take the deposition, so don’t refuse it, you can just demand protections (ex: age appropriate question language, have mom next to minor, time limitations, multiple breaks or sessions, etc. See attached Judges Bench book with rules and sample limitations. You may also need the child’s doctor or psych to opine whether the minor can be deposed or not, or faces a reasonable risk of injury if he/she is deposed. Cheers! Sincerely, Rodrigo Suarez, Esq. Senior Trial Attorney The Law Offices of Jacob Emrani, APC 714 W. Olympic Blvd., Suite 300 Los Angeles, CA 90015 Phone, Text, and Fax: (858) 345-4311 Email: rod@calljacob.com , janette@calljacob.com and eservice@calljacob.com Reminder of e-service agreement under CCP section 1010.6. Electronic service of communications and/or documents MUST be made to all the identified email addresses to be considered valid e-service: rod@calljacob.com , janette@calljacob.com , and eservice@calljacob.com . Absent modification or subsequent agreement, e-service which does not include all these email addresses breach the agreement, are deficient, invalid, incomplete, and subject to challenge. From: Bradford Treusch (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Wednesday, October 16, 2024 10:05 AM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Cc: Brad@Treusch.net Subject: FW: [caala-workproduct] School Complaint List: caala-workproduct Sent by: Bradford Treusch (Reply Privately) Search From: bradtreusch@gmail.com <bradtreusch@gmail.com> Sent: Wednesday, October 16, 2024 9:19 AM To: 'CAALA Work Product Discussion List' <caala-workproduct@lists.trialsmith.com> Cc: Brad@Treusch.net Subject: RE: [caala-workproduct] School Complaint Does anyone have a Complaint that they can share where they have sued a private preschool or school for physical mistreatment of an enrolled student by a teacher or school employee? BRADFORD L. TREUSCH Law Offices of Bradford L. Treusch 9454 Wilshire Blvd., Suite 600 Beverly Hills, CA 90212-2980 (TEL) 310-557-2599 (CELL) 310-717-9029 (FAX) 310-557-9986 (EMAIL) brad@treusch.net (WEB) treusch.net SUPER LAWYER “AV” RATED FOR OVER 35 YEARS
AI Analysis:
This message does not mention 'goodman' or any judge by that name. It is a thread about California State Bar rules regarding the obligation to report member bad behavior, forwarded within a CAALA listserv. There is no reference to Judge Goodman, their rulings, courtroom behavior, or any workers' compensation proceedings before them.
From: Stephen Mashney (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Monday, April 1, 2024 6:57 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: [caala-workproduct] What is the site for the state bar rule that obligates members to report member bad behavior?
AI Analysis:
This message thread is entirely about a Motion for Expert Witness fees after beating a 998 offer (CCP 998). It involves attorneys Bruce Brusavich, Tom Allen, and Thomas Kielty discussing work product related to motions to tax costs and expert witness fees. There is no mention of Judge Goodman or any judge by that name anywhere in the message. The message contains no information about any judge's rulings, behavior, or courtroom demeanor that would be useful for evaluating Judge Goodman.
"Bruce Brusavich" Date: March 20, 2024 12:54:00 PM Subject: Re: JR4- Motion for Expert Witness fees post 998 Reply to list Reply to sender Print Attachments: cummins - memorandum of ponts authorities filed in support of p's opposition to defendants' motion to tax costs.pdf (5635 K) dec. of bmb opp to tax costs.pdf (6279 K) Here is a successful opposition to a motion to tax my 998 interest and expert fees. Bruce M Brusavich, Partner 371 Van Ness Way, Suite 120 Torrance, CA 90501 310-407-7888 424.288.4368 (Fax) bbrusavich@actslaw.com www.actslaw.com This E-mail is covered by the Electronic Communications Privacy Act, 18 U.S.C. 2510-2521 and is legally privileged. This info is confidential and is intended only for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, Distribution or copying of this communication is strictly prohibited. Please immediately notify Abir Cohen Treyzon Salo, LLP and destroy the message From: Tom Allen (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Wednesday, March 20, 2024 9:27 AM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re: [caala-workproduct] JR4- Motion for Expert Witness fees post 998 List: caala-workproduct Sent by: Tom Allen (Reply Privately) Search I’d like one too, please. From: Thomas Kielty (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Wednesday, March 20, 2024 9:05 AM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: [caala-workproduct] JR4- Motion for Expert Witness fees post 998 List: caala-workproduct Sent by: Thomas Kielty (Reply Privately) Search Does anyone have a Motion for Expert Witness fees after beating a 998? Thanks, Tom -- Very Truly Yours, Thomas W. Kielty Attorney at Law 2447 Pacific Coast Highway, Suite 100 Hermosa Beach, CA 90254-2760 (310) 393-0515 office (310) 626-8521 fax (310) 621-7928 cell tomkielty@twk-law.com This email and any attached files may contain confidential information which is legally privileged. The information is solely for the use of the addressee named above. If you are not the intended recipient, any disclosure, copying, distribution, or other use of the contents of this email is strictly prohibited. If you have received this e-mail in error, please notify us by return email and delete this message. Thank you.
AI Analysis:
This message is entirely about case management software recommendations (PIP, Filevine, CASEpeer) for personal injury law practices. There is no mention of Judge Goodman or any judge by that name, and no discussion of any judge's rulings, courtroom behavior, or demeanor. The message is completely unrelated to evaluating Judge Goodman.
"William Mitchell Margolin Attorney at Law" Date: February 29, 2024 11:32:00 AM Subject: Re: INQUIRY: NON CLOUD BASED EASY PI CASE MANAGEMENT PROGRAM Reply to list Reply to sender Print List: caala-workproduct Sent by: William Margolin (Reply Privately) Search Ty howard From: Howard Blumenthal (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Date: Wednesday, February 28, 2024 at 6:04 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re: [caala-workproduct] INQUIRY: NON CLOUD BASED EASY PI CASE MANAGEMENT PROGRAM List: caala-workproduct Sent by: Howard Blumenthal (Reply Privately) Search But cloud based. Howard S. Blumenthal Blumenthal Law 424-260-1816 On Feb 28, 2024, at 4:46 PM, William Margolin (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> wrote: List: caala-workproduct Sent by: William Margolin (Reply Privately) Search Thank you HO From: Howard Blumenthal (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Date: Wednesday, February 28, 2024 at 12:47 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re: [caala-workproduct] INQUIRY: NON CLOUD BASED EASY PI CASE MANAGEMENT PROGRAM List: caala-workproduct Sent by: Howard Blumenthal (Reply Privately) Search CASEpeer is less than 100 bucks a month Howard S. Blumenthal Blumenthal Law 424-260-1816 On Feb 28, 2024, at 12:10 PM, John Rosenberg (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> wrote: List: caala-workproduct Sent by: John Rosenberg (Reply Privately) Search I used PIP for about twelve years. It was a good program and John Maxwell worked very hard to support it. I switched to Filevine about 5 years ago. I don't know about the changes and improvements that John has made to PIP in the interim, but when I switched to Filevine the increased power and functionality was amazing. One of the things I like about having a cloud based solution is my access to case information from anywhere. This includes while in court, in mediations, in depositions or on vacation. I find that being cloud based is a valuable asset. I have not had any problems with a cloud based solution, although I admit that any cloud solution could be hacked and cause interruptions of service and security breaches or other problems, but so far, this has not happened either with Filevine or other cloud based systems that I use and rely on to run my practice. On Wed, Feb 28, 2024 at 10:35 AM Todd Goodman (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: Todd Goodman (Reply Privately) Search I use for more than 20 years a program called "PIP" PRACTICE INFORMATION POWERTOOL from Hipersoft. It is a non-cloud based PI case management program, based on Filemaker Pro. Runs on a Mac, and also I believe on a PC. Fairly inexpensive, around 390.00 per year, a bit more if you want it to share with other computers in the office. It can also be used via the cloud, but I don't like that kind of information floating out in the cloud, so if I want to have it with me on say my laptop, I scan the file to a thumb drive and take it with me with the needed info. You can contact the owner of Hipersoft, John Maxwell, at 951-840-7624 or go to www.hipersoft.com Call me if you have any further questions Todd Goodman William Margolin (caala-workproduct listserver) wrote on 2/28/24 10:13 AM: List: caala-workproduct Sent by: William Margolin (Reply Privately) Search DEAR CAALA: What Case Management programs are inexpensive for small/or solo practice for PI Primary Practice that works with MAC and PC..that you can recommend? I used to go to “Legaltech” at Bonaventure Hotel and get the rundown on new ones but I don’t think they do that convention anymore since Covid. TY BILL William Mitchell Margolin Attorney at Law- A Professional Law Corporation 23548 Calabasas Road, Suite 202 Calabasas, California 91302 (818) 999-4LAW (4529) Fax: (818) 999-1956 email: legalhelpforyou@msn.com 2010 Candidate for California Superior Court Judge, Los Angeles County SUPER LAWYERS (SOUTHERN CALIFORNIA) 2009, 2010, 2011, 2012, 2015, 2016, 2017, 2018, 2019, 2020, 2021, 2022, 2023, 2024 MARTINDALE HUBBLE - AMERICAN REGISTRY--Congratulations on being in the top 1% of more than 900,000 attorneys in the U.S.! 30 year Member-Consumer Attorney Association of Los Angeles & California. This electronic mail (email) message, including any attachments, is intended for the use of the person or entity to which it is addressed and may contain information that is privileged and confidential, the disclosure of which is governed by applicable law. If the reader of this message is not the intended recipient, or the employee or agent responsible to deliver it to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this information is STRICTLY PROHIBITED. -- Todd W. Goodman, APC P.O. Box 3094 Thousand Oaks, CA 91359 T: 805-494-4615 F: 805-494-4618 law@toddgoodman.com -- John P. Rosenberg, Esq. Law Offices of John P. Rosenberg, PLC 6355 Topanga Canyon Boulevard, Suite 515 Woodland Hills, CA 91367 818 716 6400 jrosenberg@jrosenberg.com This message is a confidential communication from a law firm. Interception of this message is a violation of the Electronic Communications Privacy Act, 18 U.S.C. 2510-2521 and 2707-2709. This message may be protected by the attorney-client privilege and/or the attorney work-product doctrine. If you are not the intended recipient of this message, any disclosure, copying, distribution or use of the information contained in or attached to this message is prohibited. If you have received this message in error, please immediately delete the message and any attachments, and notify me at 818 716-6400. Thank you.
AI Analysis:
This message is entirely unrelated to Judge Goodman. It is a reply from Howard Blumenthal of Blumenthal Law containing only contact information, in response to an inquiry about a non-cloud-based PI case management program. There is no mention of Judge Goodman, no discussion of any judge's rulings, courtroom behavior, or any workers' compensation hearing information.
Howard S. Blumenthal Blumenthal Law 424-260-1816
AI Analysis:
This message is entirely unrelated to Judge Goodman. It is a reply from Howard Blumenthal of Blumenthal Law regarding a non-cloud-based PI case management program inquiry. The message contains no mention of Judge Goodman, no discussion of any judge's rulings, behavior, or courtroom style, and no information that would be useful for evaluating Goodman as a workers' compensation judge.
Howard S. Blumenthal Blumenthal Law 424-260-1816
AI Analysis:
This message is entirely about case management software (PIP vs. Filevine) and cloud-based solutions for law practice management. It makes no mention of Judge Goodman, any judge, or any workers' compensation court proceedings. The message is completely unrelated to evaluating Judge Goodman.
I used PIP for about twelve years. It was a good program and John Maxwell worked very hard to support it. I switched to Filevine about 5 years ago. I don't know about the changes and improvements that John has made to PIP in the interim, but when I switched to Filevine the increased power and functionality was amazing. One of the things I like about having a cloud based solution is my access to case information from anywhere. This includes while in court, in mediations, in depositions or on vacation. I find that being cloud based is a valuable asset. I have not had any problems with a cloud based solution, although I admit that any cloud solution could be hacked and cause interruptions of service and security breaches or other problems, but so far, this has not happened either with Filevine or other cloud based systems that I use and rely on to run my practice.
AI Analysis:
This message does not mention Judge Goodman at all. It is an email from attorney Robert Sheinbein sharing a case (Sapiano Case) related to 'Make Whole' doctrine and property damage reimbursement. The message contains no references to Judge Goodman, any rulings by Goodman, courtroom experiences with Goodman, or any other information that would be useful for evaluating Goodman as a judge.
Here is the Sapiano Case. Regards, Robert A. Sheinbein Attorney at Law 11777 San Vicente Blvd., Suite 665 Los Angeles, CA 90049 310-274-8200 310-275-0442 Fax THIS MESSAGE IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHOM IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. If the reader of this message is not the intended recipient or the employee or agent responsible for delivering the message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify my offices by telephone to 310-274-8200.
AI Analysis:
This message contains no mention of Judge Goodman whatsoever. It is a CAALA listserv discussion about a $17.5 million wrongful death verdict, congratulating attorney Andrew Talebi on his win and commenting negatively on opposing defense attorney Kenton Moore. The message is entirely unrelated to evaluating Judge Goodman.
"David Shapiro" Date: December 15, 2023 7:42:00 PM Subject: Re: $17.5 MILLION WRONGFUL DEATH VERDICT REPORT Reply to list Reply to sender Print List: caala-workproduct Sent by: David Shapiro (Reply Privately) Search An amazing account and excellent work. Congratulations on this win for your firm and the family. As for that shitbird Kenton Moore, well he is the one who has to explain the loss to his principal. Could not happen to a better guy. Hopefully, it will go well from here. David B. Shapiro From: Eric Boim (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Wednesday, December 13, 2023 4:14 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re:[caala-workproduct] $17.5 MILLION WRONGFUL DEATH VERDICT REPORT List: caala-workproduct Sent by: Eric Boim (Reply Privately) Search Congratulations Andrew! Amazing verdict. -----Original Message----- From: andrew@thejtf.com Sent: December 13, 2023 4:46:00 PM To: caala-workproduct@lists.trialsmith.com Subject: Re: $17.5 MILLION WRONGFUL DEATH VERDICT REPORT On cross, they asked our client if he ever facetimed his father while he was at one of the hospitals and our client said he did. They impeached him with his deposition testimony where he gave a different answer. I should have mentioned that this own-goal was brought on by Kenton, which is just further evidence of his tactics backfiring on him at trial. Andrew A. Talebi, Esq. ' Attorney THE JAVID TRIAL FIRM, PC 11740 San Vicente Boulevard, Suite 109, #576 Los Angeles, California 90049 T: 310.929.9132 ' F: 310.929.9133 https://www.thejtf.com This e-mail, and any attachments thereto, is intended only for use by the addressee(s) named herein and may contain legally privileged and or confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this e-mail in error, please immediately notify the sender by telephone at (310) 929-9130 or by return e-mail, and permanently delete the original and any copy of this message, its attachments, and any printout thereof. Unauthorized use, dissemination or reproduction of this message is strictly prohibited and may be unlawful. Thank you. From: Niral Patel (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Date: Wednesday, December 13, 2023 at 12:24 PM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: Re:[caala-workproduct] $17.5 MILLION WRONGFUL DEATH VERDICT REPORT List: caala-workproduct Sent by: Niral Patel (Reply Privately)< mailto:niralpatel@niralpatelinjurylaw.com?subject=Re%3A%20%2417.5%20MILLION%20WRONGFUL%20DEATH%20VERDICT%20REPORT > Search< http://www.caala.org/index.cfm?pg=search > How did the Defense open the door to the facetime video? Niral Patel Niral Patel Injury Law 100 Bayview Circle Suite 100 Newport Beach, CA - 92660 Phone: (805) 748-9317 FAX: (714) 627-4696 Email: NiralPatel@NiralPatelInjuryLaw.com<mailto:NiralPatel@NiralPatelInjuryLaw.com > Web page: NiralPatelInjuryLaw.com CONFIDENTIALITY NOTICE: This email message and any attachments are for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, please contact the sender via reply email and destroy all copies of the original message along with any attachments. [ cid:image001.png@01DA2DBF.3A728C80 ] Friends: We are happy to report that Raphael Javid and myself have, after almost 4 years of an absolute battle, brought home a $17,500,000 verdict in a wrongful death matter in Los Angeles. The case is called Guillermo Aviles, Jr., et al. v. Access Services, et al. and was litigated in Department 15 of Stanley Mosk before Judge Richard Fruin. The trial was bifurcated into liability and damages about a year ago and we obtained a successful liability verdict on May 31, 2023 against Access Services, Global Paratransit, Inc. (a subcontractor of Access) and the driver, Carlos Juarez, Jr. Raphael did a write up after we obtained that verdict but I'll summarize everything. Facts On March 27, 2020, the Decedent, aged 61, was being brought home by Access following dialysis treatment. Upon arriving at his residence, the Decedent was released from the vehicle outside the residence in the street, and not on the curb, and left unattended by the driver. The driver placed the Decedent's bag on the pavement near an enormous pothole. As the Decedent was bending down to pick up his bag, he fell, hit his head in the pothole, fractured his neck at C2, was immediately rendered quadriplegic which threw him into a respiratory arrest followed by a cardiac arrest. Paramedics arrived on scene and were able to resuscitate him. Ultimately, he died on June 26, 2020. Liability Access is supposed to provide curb to curb transportation which basically means that after the rider exits the vehicle, Access is supposed to assist riders to the curb, at a minimum. In our case, they left him in the street. Moreover, the cause of the accident was placing the Decedent's bag on the ground instead of handing it to him or standing next to him when he picked it up. It is well known that dialysis patients suffer from dizziness, fatigue, and weakness following treatment. This is because for some patients, the treatment causes their blood pressure to drop substantially to the point that they become hypotensive. There is express ADA guidance on this topic that instructs paratransit operators like Access to provide Return Trip Assistance and escort the dialysis patient to the door of their location following dialysis treatment. When the Decedent underwent a physical evaluation as part of the eligibility process to become an Access rider, he complained of dizziness and fatigue following dialysis treatment. Moreover, the dialysis records from the date of the incident showed that he had 6 hypotensive episodes during treatment which resulted in treatment having to be stopped. During the liability trial, we argued that when he bent over to pick up his bag, he suffered a hypotensive event which caused him to become dizzy and fall and break his neck. We also put forward evidence that the driver did not follow the ADA guidance or much of the training procedure that was articulated in Access' materials. We also put forward evidence that the Decedent's evaluation indicated that he was designated as being eligible for Beyond the Curb service, which means that the driver should have known that the Decedent required additional assistance after treatment that would require the driver to escort him, as opposed to just letting him out of the vehicle and doing nothing else. Defense Liability Arguments Access argued that their driver did nothing wrong because, from their vantage point, the ride is concluded the moment that the person steps out of the paratransit vehicle and recognizes their surroundings. They also argued that the driver did provide assistance by merely standing by the Decedent as he got out of the vehicle to place his feet on the street. Additionally, the Decedent had a history of cardiac issues, including a prior cardiac arrest. The defense argued that the fall was caused by a cardiac arrest following dialysis treatment and that the Decedent would have fractured his neck regardless of where he fell. They also argued that the cardiac arrest resulted in a substantial amount of brain damaged due to lack of oxygen, which is really what caused him to be paralyzed until his death. Liability Experts Our liability experts were: Dr. Jeffrey Goodman (Cardiologist) - Absolute rockstar. He did an outstanding job testifying and explained complex cardiac information in an accessible and persuasive way for the jury. During the work up, he was an incredible resource for us in evaluating the evidence and having a real mastery of the issues. Dr. Barry Ludwig (Neurologist) - Raphael describes him as regal. I think he did a great job conveying our argument about how severe this neck fracture was and he really helped carry the day for us in Phase 1. Dean McMillan (Paratransit Standard of Care) - It is really hard to find experts in this field and it was her first time being an expert because our prior expert unfortunately passed away. She was not great during deposition or trial and the defense beat her up pretty badly in both. Fortunately, we had so much good evidence without her that we were able to make our case without heavily relying on her. Dr. Mamoo Nakamura (Treating Cardiologist) - He was the last cardiologist that the Decedent saw prior to the incident and he was able to provide us with testimony that he had no concerns about the condition of the Decedent's heart or an elevated risk of a sudden cardiac event leading into the date of the incident. Dr. Hooshang Pak (Post-Incident Treating Neurosurgeon) - Very persuasive witness and conveyed very explicitly the severity of the neck fracture. John Gardiner (Biomech) - He did great getting us over summary judgment but probably a wash during trial. The defense liability experts were: Dr. Michael Chaikin (Cardiologist) - Like many defense experts, he took very extreme positions during his deposition and conveyed them arrogantly. He did the same song and dance during trial. He talks (or rambles) for a long time during his answers and, in my opinion, do not break the information down sufficiently to convey it to someone who has no idea what he is talking about. Dr. Nirav Patel (Neurologist) - Dr. Patel was the treating Neurologist following the incident that the defense morphed into their expert. I thought he delivered the information well and he was a formidable expert for us to go up against. John Brault (Biomech) - He is good but he is very abrasive and I think that backfired on them at trial. Liability Verdict The jury found Access, the subcontractor Global Paratransit, and the driver Carlos Juarez, Jr. each liable for the incident. They also found that Global was an agent of Access. The apportionment was 15% to Juarez, 40% for Global, and 45% for Access. Damages Phase Trial Our damages phase commenced on December 4, 2023. The judge (who I'll do a separate section on) dragged his feet on some MIL rulings and, as a result, some evidence that was ultimately excluded was referenced to the jury. As a result, following his favorable ruling for us and exclusion of evidence, a mistrial was declared on December 5, 2023. We empaneled a new jury on December 6, 2023 and kept trucking through our verdict yesterday. We represented all seven of the Decedent's children (wife pre-deceased). This family is incredible. The Decedent immigrated along with his wife from the Philippines, leaving five of their children behind to start a better life for them here in America. Slowly but surely, they were able to plant roots and bring all of their children here with them in the 1990s. They had two additional children here. For the vast majority of the Decedent's life, he was an MTA bus driver working insane hours to provide for his family. They are a very traditional family with strong family values, constantly focusing on each other and spending as much time together as possible. Each of their birthdays was a massive event that they always spent together, along with holidays and normal family gatherings. That tradition carried throughout their childhood and their adult lives. Our clients are all established and have their own children now but that did not stop them from constantly getting the family together. All but one of our clients lived no more than 15 minutes away from their father. The one child that lived in San Diego came up to Long Beach twice a month with her family to spend time with her father. Two of the children, one of whom is deaf and has some developmental limitations, lived with him in the family home and saw him every single day. The ones that did not live with him either saw their father every day, every other day, or every weekend. They were in constant communications with their father. We also conveyed that in the Filipino culture, reverence for elders is a massive deal. Each of our clients explained that they were looking forward to caring for their father in his elder years and valuing the time that they all had to spend with him. Having that taken from them so abruptly was absolutely devastating for them and we were able to bring that out to the jury. We had no less than 60 family photos and several family videos that we intended to use during our examinations. The judge initially limited us two photos and zero videos because he thought it was cumulative and prejudicial. After getting railroaded, we were able to find an additional handful of individual photos of our clients and their father that the judge ultimately let us use. As a tactical move, we counseled our clients to use the photos as memory triggers to tell stories about the photos without actually showing them to the jury. Our clients hit grand slams during their testimony. It was a very emotional trial but it was an authentic trial. In an unbelievable own-goal, the defense opened the door on the issue of one of the children facetiming the Decedent while he was on his deathbed which that child had recorded and we had marked as an exhibit. As a result, on re-direct, we were able to move that video into evidence which showed the condition of the Decedent a week before his death. It was very powerful evidence which the jury probably would not have seen otherwise. On the issue of life expectancy notwithstanding the incident, our experts were: Dr. Jeffrey Goodman (Cardiologist) - Again, total rockstar. Dr. Mamoo Nakamura (Pre-Incident Cardiologist) - Again, homerun. Dr. George Hon (Treating Nephrologist) - Gave us what we needed that the Decedent's kidney was stable. The defense's only witness was Dr. Michael Chaikin. In a stroke of genius, Raphael obtained a transcript of Dr. Chaikin in another matter that showed that he was an expert in several matters testifying on behalf of the tobacco companies. We were able to get him to admit that during cross and, in our discussions with the jury following the verdict, that was really powerful evidence to get them to disregard his opinions. The Life Expectancy Tables said that a 61 year old man would have lived another 21 years. Obviously, we could not get around the issue that the Decedent had several comorbidities so we did not suggest to the jury that he would have lived that long. Dr. Goodman testified, from a cardiac perspective, the Decedent would have lived another 17 years. In closing, we argued that it would more reasonably have been 10. The defense took the position that he would have lived an additional six months to three years, an opinion that was admittedly rendered by Dr. Chaikin prior to him having the Decedent's complete medical records. Once he had the entire universe, which included records closer in time to the incident which showed that the Decedent's heart condition was improving and healthy, he doubled down and said those records did not change any of his opinions. We believed that opinion was going to be a really tough sell and we hammered him on cross. In the end, the jury awarded us $13,250,000 in past non-economic damages and $4,250,000 in future. Defense Firms The defense was represented by Kenton Moore of McCune & Harber for the overwhelming majority of the case. I really hesitate to cast aspersions towards anyone but I cannot have less respect for him than I do. His tactics are full blown scorched earth and he obstructed us at every moment, in every way, and at all times during the work up for this case. Before joining this office, I cut my teeth as a trial attorney handling complex business litigation so I am used to heavy law and motion but this case generated more law and motion and more MILs than I have ever seen. During trial, he is even worse. He habitually objects to basically everything during testimony, resulting in a lot of breaks in the action to argue with the judge about the evidence. He pretends as though he has never seen any evidence even though we proved, multiple times, that the evidence was exchanged and that he had seen it. He will agree to things in the halls of the court and then come before the judge and pretend like he didn't agree to anything. To put it bluntly: he is a snake, a liar, a cheater, a bully, and an absolute nightmare to work with. Anyone who litigates against him should be prepared to devote countless hours and energy into the case to bodyslam him. Do not give him a single inch. You should also not trust a single thing that comes out of his mouth because it isn't worth the energy that it takes your ears and brain to process the words. The upside is that his hardheadedness backfires spectacularly at trial. He is not impressive and in fact, he is repulsive and the results demonstrate that. Anyone who tries a case against him should be mentally prepared to deal with a lot of frustration but to remain calm, patient, and charming. He does everything he can to get under your skin, which he is very effective at, but you cannot let it get to you and you cannot reward him by reacting to his trash tactics. I could write a dissertation on this jabroni and I am happy to speak with anyone over the phone about how we handled him and how anyone with any active case against him should handle him going forward. For the damages phase, Michael Schonbuch of Daniels Fine associated into the case. Frankly, I wish that the entire case was worked up with him because we had a solid working relationship and I have only positive things to say about working with him for the short period of time that we did. He is a class act, very professional, and a strong advocate who did the best he could trying to get up to speed on a massive file. He also relegated Kenton to backbench because it was obvious that Kenton's general disposition was a huge liability for them. The Judge I don't know how valuable any of this information will be because Judge Fruin is quite old so I would anticipate that his stay on the bench might not be too much longer. In any event, Judge Fruin is tough. We were in his courtroom a lot during the work up and he was absolutely brutal on me as I was the face of the operation for much of the law and motion. He is temperamental as well. Be prepared to take a lot of heat but if you stand your ground and keep pushing and advocating, the ball will bounce your way. Your briefs need to be concise, well researched, and articulated very clearly. During argument, you also need to convey to him how critical certain issues are to the case in order to get the rulings you need. Our estimation is that he may have come to regret bifurcating the trial but he really tied our hands a lot throughout both phases. Anyone in his courtroom needs to be adequately prepared to adjust your gameplan on the fly. All of that being said, during examinations, he let us put on our cases. On balance, he overruled substantially more of the defense objections than he sustained. I think he is really tough on the plaintiffs side of the table and I think that can rub a lot of plaintiffs lawyers the wrong way about him maybe having a bias. I do not think he was biased. If anything, the learning lesson that I took from this experience is that he will force us as plaintiffs lawyers to not be lazy and to make sure that, if we are to be successful, we need to do it right so that the victory is as iron clad as possible. Thoughts and Musings This is obviously a great result for the case and we learned a lot working it up and trying both phases. I think the biggest takeaway for me is how important it is to believe in the strength of your case and the work. No case that is tried is perfect but if you are able to put forward an authentic explanation of your case, I am of the firm belief that the jury will buy it. I know Raphael was in constant communication with many of you during both phases asking for advice. I don't know all of you by name but we want to convey our sincere gratitude for your support and assistance in helping us navigate this case. One more for the good guys. Andrew A. Talebi, Esq. ' Attorney THE JAVID TRIAL FIRM, PC 11740 San Vicente Boulevard, Suite 109, #576 Los Angeles, California 90049 T: 310.929.9132 ' F: 310.929.9133 https://www.thejtf.com<https://www.thejtf.com/ > This e-mail, and any attachments thereto, is intended only for use by the addressee(s) named herein and may contain legally privileged and or confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this e-mail in error, please immediately notify the sender by telephone at (310) 929-9130 or by return e-mail, and permanently delete the original and any copy of this message, its attachments, and any printout thereof. Unauthorized use, dissemination or reproduction of this message is strictly prohibited and may be unlawful. Thank you. Virus-free. www.avast.com
AI Analysis:
This message is entirely about attorney Carmin Shaffer, who is USAA in-house counsel. There is no mention of Judge Goodman anywhere in the message. The message discusses settlement experiences with an opposing attorney, not a judge or workers' compensation judge named Goodman.
I have only had good experiences with the cases I have had with her. She is moving up in USAA house counsel hierarchy. I have settled every case I have had with her, without a lot of useless motions and the like.
AI Analysis:
This message is entirely about a $17.5 million wrongful death verdict and discusses attorney Andrew Talebi's trial experience, including cross-examination tactics by opposing counsel 'Kenton.' There is no mention of Judge Goodman or any judge by that name anywhere in the message. The message contains no information useful for evaluating Judge Goodman as a workers' compensation judge.
"Eric Boim" Date: December 13, 2023 6:14:00 PM Subject: Re: $17.5 MILLION WRONGFUL DEATH VERDICT REPORT Reply to list Reply to sender Print List: caala-workproduct Sent by: Eric Boim (Reply Privately) Search Congratulations Andrew! Amazing verdict. -----Original Message----- From: andrew@thejtf.com Sent: December 13, 2023 4:46:00 PM To: caala-workproduct@lists.trialsmith.com Subject: Re: $17.5 MILLION WRONGFUL DEATH VERDICT REPORT On cross, they asked our client if he ever facetimed his father while he was at one of the hospitals and our client said he did. They impeached him with his deposition testimony where he gave a different answer. I should have mentioned that this own-goal was brought on by Kenton, which is just further evidence of his tactics backfiring on him at trial. Andrew A. Talebi, Esq. ' Attorney THE JAVID TRIAL FIRM, PC 11740 San Vicente Boulevard, Suite 109, #576 Los Angeles, California 90049 T: 310.929.9132 ' F: 310.929.9133 https://www.thejtf.com This e-mail, and any attachments thereto, is intended only for use by the addressee(s) named herein and may contain legally privileged and or confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this e-mail in error, please immediately notify the sender by telephone at (310) 929-9130 or by return e-mail, and permanently delete the original and any copy of this message, its attachments, and any printout thereof. Unauthorized use, dissemination or reproduction of this message is strictly prohibited and may be unlawful. Thank you. From: Niral Patel (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Date: Wednesday, December 13, 2023 at 12:24 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re:[caala-workproduct] $17.5 MILLION WRONGFUL DEATH VERDICT REPORT List: caala-workproduct Sent by: Niral Patel (Reply Privately)<mailto:niralpatel@niralpatelinjurylaw.com?subject=Re%3A%20%2417.5%20MILLION%20WRONGFUL%20DEATH%20VERDICT%20REPORT> Search<http://www.caala.org/index.cfm?pg=search> How did the Defense open the door to the facetime video? Niral Patel Niral Patel Injury Law 100 Bayview Circle Suite 100 Newport Beach, CA - 92660 Phone: (805) 748-9317 FAX: (714) 627-4696 Email: NiralPatel@NiralPatelInjuryLaw.com<mailto:NiralPatel@NiralPatelInjuryLaw.com> Web page: NiralPatelInjuryLaw.com CONFIDENTIALITY NOTICE: This email message and any attachments are for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, please contact the sender via reply email and destroy all copies of the original message along with any attachments. [cid:image001.png@01DA2DBF.3A728C80] Friends: We are happy to report that Raphael Javid and myself have, after almost 4 years of an absolute battle, brought home a $17,500,000 verdict in a wrongful death matter in Los Angeles. The case is called Guillermo Aviles, Jr., et al. v. Access Services, et al. and was litigated in Department 15 of Stanley Mosk before Judge Richard Fruin. The trial was bifurcated into liability and damages about a year ago and we obtained a successful liability verdict on May 31, 2023 against Access Services, Global Paratransit, Inc. (a subcontractor of Access) and the driver, Carlos Juarez, Jr. Raphael did a write up after we obtained that verdict but I'll summarize everything. Facts On March 27, 2020, the Decedent, aged 61, was being brought home by Access following dialysis treatment. Upon arriving at his residence, the Decedent was released from the vehicle outside the residence in the street, and not on the curb, and left unattended by the driver. The driver placed the Decedent's bag on the pavement near an enormous pothole. As the Decedent was bending down to pick up his bag, he fell, hit his head in the pothole, fractured his neck at C2, was immediately rendered quadriplegic which threw him into a respiratory arrest followed by a cardiac arrest. Paramedics arrived on scene and were able to resuscitate him. Ultimately, he died on June 26, 2020. Liability Access is supposed to provide curb to curb transportation which basically means that after the rider exits the vehicle, Access is supposed to assist riders to the curb, at a minimum. In our case, they left him in the street. Moreover, the cause of the accident was placing the Decedent's bag on the ground instead of handing it to him or standing next to him when he picked it up. It is well known that dialysis patients suffer from dizziness, fatigue, and weakness following treatment. This is because for some patients, the treatment causes their blood pressure to drop substantially to the point that they become hypotensive. There is express ADA guidance on this topic that instructs paratransit operators like Access to provide Return Trip Assistance and escort the dialysis patient to the door of their location following dialysis treatment. When the Decedent underwent a physical evaluation as part of the eligibility process to become an Access rider, he complained of dizziness and fatigue following dialysis treatment. Moreover, the dialysis records from the date of the incident showed that he had 6 hypotensive episodes during treatment which resulted in treatment having to be stopped. During the liability trial, we argued that when he bent over to pick up his bag, he suffered a hypotensive event which caused him to become dizzy and fall and break his neck. We also put forward evidence that the driver did not follow the ADA guidance or much of the training procedure that was articulated in Access' materials. We also put forward evidence that the Decedent's evaluation indicated that he was designated as being eligible for Beyond the Curb service, which means that the driver should have known that the Decedent required additional assistance after treatment that would require the driver to escort him, as opposed to just letting him out of the vehicle and doing nothing else. Defense Liability Arguments Access argued that their driver did nothing wrong because, from their vantage point, the ride is concluded the moment that the person steps out of the paratransit vehicle and recognizes their surroundings. They also argued that the driver did provide assistance by merely standing by the Decedent as he got out of the vehicle to place his feet on the street. Additionally, the Decedent had a history of cardiac issues, including a prior cardiac arrest. The defense argued that the fall was caused by a cardiac arrest following dialysis treatment and that the Decedent would have fractured his neck regardless of where he fell. They also argued that the cardiac arrest resulted in a substantial amount of brain damaged due to lack of oxygen, which is really what caused him to be paralyzed until his death. Liability Experts Our liability experts were: Dr. Jeffrey Goodman (Cardiologist) - Absolute rockstar. He did an outstanding job testifying and explained complex cardiac information in an accessible and persuasive way for the jury. During the work up, he was an incredible resource for us in evaluating the evidence and having a real mastery of the issues. Dr. Barry Ludwig (Neurologist) - Raphael describes him as regal. I think he did a great job conveying our argument about how severe this neck fracture was and he really helped carry the day for us in Phase 1. Dean McMillan (Paratransit Standard of Care) - It is really hard to find experts in this field and it was her first time being an expert because our prior expert unfortunately passed away. She was not great during deposition or trial and the defense beat her up pretty badly in both. Fortunately, we had so much good evidence without her that we were able to make our case without heavily relying on her. Dr. Mamoo Nakamura (Treating Cardiologist) - He was the last cardiologist that the Decedent saw prior to the incident and he was able to provide us with testimony that he had no concerns about the condition of the Decedent's heart or an elevated risk of a sudden cardiac event leading into the date of the incident. Dr. Hooshang Pak (Post-Incident Treating Neurosurgeon) - Very persuasive witness and conveyed very explicitly the severity of the neck fracture. John Gardiner (Biomech) - He did great getting us over summary judgment but probably a wash during trial. The defense liability experts were: Dr. Michael Chaikin (Cardiologist) - Like many defense experts, he took very extreme positions during his deposition and conveyed them arrogantly. He did the same song and dance during trial. He talks (or rambles) for a long time during his answers and, in my opinion, do not break the information down sufficiently to convey it to someone who has no idea what he is talking about. Dr. Nirav Patel (Neurologist) - Dr. Patel was the treating Neurologist following the incident that the defense morphed into their expert. I thought he delivered the information well and he was a formidable expert for us to go up against. John Brault (Biomech) - He is good but he is very abrasive and I think that backfired on them at trial. Liability Verdict The jury found Access, the subcontractor Global Paratransit, and the driver Carlos Juarez, Jr. each liable for the incident. They also found that Global was an agent of Access. The apportionment was 15% to Juarez, 40% for Global, and 45% for Access. Damages Phase Trial Our damages phase commenced on December 4, 2023. The judge (who I'll do a separate section on) dragged his feet on some MIL rulings and, as a result, some evidence that was ultimately excluded was referenced to the jury. As a result, following his favorable ruling for us and exclusion of evidence, a mistrial was declared on December 5, 2023. We empaneled a new jury on December 6, 2023 and kept trucking through our verdict yesterday. We represented all seven of the Decedent's children (wife pre-deceased). This family is incredible. The Decedent immigrated along with his wife from the Philippines, leaving five of their children behind to start a better life for them here in America. Slowly but surely, they were able to plant roots and bring all of their children here with them in the 1990s. They had two additional children here. For the vast majority of the Decedent's life, he was an MTA bus driver working insane hours to provide for his family. They are a very traditional family with strong family values, constantly focusing on each other and spending as much time together as possible. Each of their birthdays was a massive event that they always spent together, along with holidays and normal family gatherings. That tradition carried throughout their childhood and their adult lives. Our clients are all established and have their own children now but that did not stop them from constantly getting the family together. All but one of our clients lived no more than 15 minutes away from their father. The one child that lived in San Diego came up to Long Beach twice a month with her family to spend time with her father. Two of the children, one of whom is deaf and has some developmental limitations, lived with him in the family home and saw him every single day. The ones that did not live with him either saw their father every day, every other day, or every weekend. They were in constant communications with their father. We also conveyed that in the Filipino culture, reverence for elders is a massive deal. Each of our clients explained that they were looking forward to caring for their father in his elder years and valuing the time that they all had to spend with him. Having that taken from them so abruptly was absolutely devastating for them and we were able to bring that out to the jury. We had no less than 60 family photos and several family videos that we intended to use during our examinations. The judge initially limited us two photos and zero videos because he thought it was cumulative and prejudicial. After getting railroaded, we were able to find an additional handful of individual photos of our clients and their father that the judge ultimately let us use. As a tactical move, we counseled our clients to use the photos as memory triggers to tell stories about the photos without actually showing them to the jury. Our clients hit grand slams during their testimony. It was a very emotional trial but it was an authentic trial. In an unbelievable own-goal, the defense opened the door on the issue of one of the children facetiming the Decedent while he was on his deathbed which that child had recorded and we had marked as an exhibit. As a result, on re-direct, we were able to move that video into evidence which showed the condition of the Decedent a week before his death. It was very powerful evidence which the jury probably would not have seen otherwise. On the issue of life expectancy notwithstanding the incident, our experts were: Dr. Jeffrey Goodman (Cardiologist) - Again, total rockstar. Dr. Mamoo Nakamura (Pre-Incident Cardiologist) - Again, homerun. Dr. George Hon (Treating Nephrologist) - Gave us what we needed that the Decedent's kidney was stable. The defense's only witness was Dr. Michael Chaikin. In a stroke of genius, Raphael obtained a transcript of Dr. Chaikin in another matter that showed that he was an expert in several matters testifying on behalf of the tobacco companies. We were able to get him to admit that during cross and, in our discussions with the jury following the verdict, that was really powerful evidence to get them to disregard his opinions. The Life Expectancy Tables said that a 61 year old man would have lived another 21 years. Obviously, we could not get around the issue that the Decedent had several comorbidities so we did not suggest to the jury that he would have lived that long. Dr. Goodman testified, from a cardiac perspective, the Decedent would have lived another 17 years. In closing, we argued that it would more reasonably have been 10. The defense took the position that he would have lived an additional six months to three years, an opinion that was admittedly rendered by Dr. Chaikin prior to him having the Decedent's complete medical records. Once he had the entire universe, which included records closer in time to the incident which showed that the Decedent's heart condition was improving and healthy, he doubled down and said those records did not change any of his opinions. We believed that opinion was going to be a really tough sell and we hammered him on cross. In the end, the jury awarded us $13,250,000 in past non-economic damages and $4,250,000 in future. Defense Firms The defense was represented by Kenton Moore of McCune & Harber for the overwhelming majority of the case. I really hesitate to cast aspersions towards anyone but I cannot have less respect for him than I do. His tactics are full blown scorched earth and he obstructed us at every moment, in every way, and at all times during the work up for this case. Before joining this office, I cut my teeth as a trial attorney handling complex business litigation so I am used to heavy law and motion but this case generated more law and motion and more MILs than I have ever seen. During trial, he is even worse. He habitually objects to basically everything during testimony, resulting in a lot of breaks in the action to argue with the judge about the evidence. He pretends as though he has never seen any evidence even though we proved, multiple times, that the evidence was exchanged and that he had seen it. He will agree to things in the halls of the court and then come before the judge and pretend like he didn't agree to anything. To put it bluntly: he is a snake, a liar, a cheater, a bully, and an absolute nightmare to work with. Anyone who litigates against him should be prepared to devote countless hours and energy into the case to bodyslam him. Do not give him a single inch. You should also not trust a single thing that comes out of his mouth because it isn't worth the energy that it takes your ears and brain to process the words. The upside is that his hardheadedness backfires spectacularly at trial. He is not impressive and in fact, he is repulsive and the results demonstrate that. Anyone who tries a case against him should be mentally prepared to deal with a lot of frustration but to remain calm, patient, and charming. He does everything he can to get under your skin, which he is very effective at, but you cannot let it get to you and you cannot reward him by reacting to his trash tactics. I could write a dissertation on this jabroni and I am happy to speak with anyone over the phone about how we handled him and how anyone with any active case against him should handle him going forward. For the damages phase, Michael Schonbuch of Daniels Fine associated into the case. Frankly, I wish that the entire case was worked up with him because we had a solid working relationship and I have only positive things to say about working with him for the short period of time that we did. He is a class act, very professional, and a strong advocate who did the best he could trying to get up to speed on a massive file. He also relegated Kenton to backbench because it was obvious that Kenton's general disposition was a huge liability for them. The Judge I don't know how valuable any of this information will be because Judge Fruin is quite old so I would anticipate that his stay on the bench might not be too much longer. In any event, Judge Fruin is tough. We were in his courtroom a lot during the work up and he was absolutely brutal on me as I was the face of the operation for much of the law and motion. He is temperamental as well. Be prepared to take a lot of heat but if you stand your ground and keep pushing and advocating, the ball will bounce your way. Your briefs need to be concise, well researched, and articulated very clearly. During argument, you also need to convey to him how critical certain issues are to the case in order to get the rulings you need. Our estimation is that he may have come to regret bifurcating the trial but he really tied our hands a lot throughout both phases. Anyone in his courtroom needs to be adequately prepared to adjust your gameplan on the fly. All of that being said, during examinations, he let us put on our cases. On balance, he overruled substantially more of the defense objections than he sustained. I think he is really tough on the plaintiffs side of the table and I think that can rub a lot of plaintiffs lawyers the wrong way about him maybe having a bias. I do not think he was biased. If anything, the learning lesson that I took from this experience is that he will force us as plaintiffs lawyers to not be lazy and to make sure that, if we are to be successful, we need to do it right so that the victory is as iron clad as possible. Thoughts and Musings This is obviously a great result for the case and we learned a lot working it up and trying both phases. I think the biggest takeaway for me is how important it is to believe in the strength of your case and the work. No case that is tried is perfect but if you are able to put forward an authentic explanation of your case, I am of the firm belief that the jury will buy it. I know Raphael was in constant communication with many of you during both phases asking for advice. I don't know all of you by name but we want to convey our sincere gratitude for your support and assistance in helping us navigate this case. One more for the good guys. Andrew A. Talebi, Esq. ' Attorney THE JAVID TRIAL FIRM, PC 11740 San Vicente Boulevard, Suite 109, #576 Los Angeles, California 90049 T: 310.929.9132 ' F: 310.929.9133 https://www.thejtf.com<https://www.thejtf.com/> This e-mail, and any attachments thereto, is intended only for use by the addressee(s) named herein and may contain legally privileged and or confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this e-mail in error, please immediately notify the sender by telephone at (310) 929-9130 or by return e-mail, and permanently delete the original and any copy of this message, its attachments, and any printout thereof. Unauthorized use, dissemination or reproduction of this message is strictly prohibited and may be unlawful. Thank you.
AI Analysis:
This message does not mention Judge Goodman at all. It is a discussion about a $17.5 million wrongful death verdict, focusing on trial tactics, cross-examination of a client about FaceTime testimony, and the behavior of someone named 'Kenton' (apparently opposing counsel). There is no reference to Judge Goodman or any judge by that name in any variation. The message is entirely unrelated to evaluating Judge Goodman.
"Andrew Talebi" Date: December 13, 2023 4:46:00 PM Subject: Re: $17.5 MILLION WRONGFUL DEATH VERDICT REPORT Reply to list Reply to sender Print On cross, they asked our client if he ever facetimed his father while he was at one of the hospitals and our client said he did. They impeached him with his deposition testimony where he gave a different answer. I should have mentioned that this own-goal was brought on by Kenton, which is just further evidence of his tactics backfiring on him at trial. Andrew A. Talebi, Esq. | Attorney THE JAVID TRIAL FIRM, PC 11740 San Vicente Boulevard, Suite 109, #576 Los Angeles, California 90049 T: 310.929.9132 | F: 310.929.9133 https://www.thejtf.com This e-mail, and any attachments thereto, is intended only for use by the addressee(s) named herein and may contain legally privileged and or confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this e-mail in error, please immediately notify the sender by telephone at (310) 929-9130 or by return e-mail, and permanently delete the original and any copy of this message, its attachments, and any printout thereof. Unauthorized use, dissemination or reproduction of this message is strictly prohibited and may be unlawful. Thank you. From: Niral Patel (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Date: Wednesday, December 13, 2023 at 12:24 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re:[caala-workproduct] $17.5 MILLION WRONGFUL DEATH VERDICT REPORT List: caala-workproduct Sent by: Niral Patel (Reply Privately) Search How did the Defense open the door to the facetime video? Niral Patel Niral Patel Injury Law 100 Bayview Circle Suite 100 Newport Beach, CA - 92660 Phone: (805) 748-9317 FAX: (714) 627-4696 Email: NiralPatel@NiralPatelInjuryLaw.com Web page: NiralPatelInjuryLaw.com CONFIDENTIALITY NOTICE: This email message and any attachments are for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, please contact the sender via reply email and destroy all copies of the original message along with any attachments. Friends: We are happy to report that Raphael Javid and myself have, after almost 4 years of an absolute battle, brought home a $17,500,000 verdict in a wrongful death matter in Los Angeles. The case is called Guillermo Aviles, Jr., et al. v. Access Services, et al. and was litigated in Department 15 of Stanley Mosk before Judge Richard Fruin. The trial was bifurcated into liability and damages about a year ago and we obtained a successful liability verdict on May 31, 2023 against Access Services, Global Paratransit, Inc. (a subcontractor of Access) and the driver, Carlos Juarez, Jr. Raphael did a write up after we obtained that verdict but I’ll summarize everything. Facts On March 27, 2020, the Decedent, aged 61, was being brought home by Access following dialysis treatment. Upon arriving at his residence, the Decedent was released from the vehicle outside the residence in the street, and not on the curb, and left unattended by the driver. The driver placed the Decedent’s bag on the pavement near an enormous pothole. As the Decedent was bending down to pick up his bag, he fell, hit his head in the pothole, fractured his neck at C2, was immediately rendered quadriplegic which threw him into a respiratory arrest followed by a cardiac arrest. Paramedics arrived on scene and were able to resuscitate him. Ultimately, he died on June 26, 2020. Liability Access is supposed to provide curb to curb transportation which basically means that after the rider exits the vehicle, Access is supposed to assist riders to the curb, at a minimum. In our case, they left him in the street. Moreover, the cause of the accident was placing the Decedent’s bag on the ground instead of handing it to him or standing next to him when he picked it up. It is well known that dialysis patients suffer from dizziness, fatigue, and weakness following treatment. This is because for some patients, the treatment causes their blood pressure to drop substantially to the point that they become hypotensive. There is express ADA guidance on this topic that instructs paratransit operators like Access to provide Return Trip Assistance and escort the dialysis patient to the door of their location following dialysis treatment. When the Decedent underwent a physical evaluation as part of the eligibility process to become an Access rider, he complained of dizziness and fatigue following dialysis treatment. Moreover, the dialysis records from the date of the incident showed that he had 6 hypotensive episodes during treatment which resulted in treatment having to be stopped. During the liability trial, we argued that when he bent over to pick up his bag, he suffered a hypotensive event which caused him to become dizzy and fall and break his neck. We also put forward evidence that the driver did not follow the ADA guidance or much of the training procedure that was articulated in Access’ materials. We also put forward evidence that the Decedent’s evaluation indicated that he was designated as being eligible for Beyond the Curb service, which means that the driver should have known that the Decedent required additional assistance after treatment that would require the driver to escort him, as opposed to just letting him out of the vehicle and doing nothing else. Defense Liability Arguments Access argued that their driver did nothing wrong because, from their vantage point, the ride is concluded the moment that the person steps out of the paratransit vehicle and recognizes their surroundings. They also argued that the driver did provide assistance by merely standing by the Decedent as he got out of the vehicle to place his feet on the street. Additionally, the Decedent had a history of cardiac issues, including a prior cardiac arrest. The defense argued that the fall was caused by a cardiac arrest following dialysis treatment and that the Decedent would have fractured his neck regardless of where he fell. They also argued that the cardiac arrest resulted in a substantial amount of brain damaged due to lack of oxygen, which is really what caused him to be paralyzed until his death. Liability Experts Our liability experts were: Dr. Jeffrey Goodman (Cardiologist) – Absolute rockstar. He did an outstanding job testifying and explained complex cardiac information in an accessible and persuasive way for the jury. During the work up, he was an incredible resource for us in evaluating the evidence and having a real mastery of the issues. Dr. Barry Ludwig (Neurologist) – Raphael describes him as regal. I think he did a great job conveying our argument about how severe this neck fracture was and he really helped carry the day for us in Phase 1. Dean McMillan (Paratransit Standard of Care) – It is really hard to find experts in this field and it was her first time being an expert because our prior expert unfortunately passed away. She was not great during deposition or trial and the defense beat her up pretty badly in both. Fortunately, we had so much good evidence without her that we were able to make our case without heavily relying on her. Dr. Mamoo Nakamura (Treating Cardiologist) – He was the last cardiologist that the Decedent saw prior to the incident and he was able to provide us with testimony that he had no concerns about the condition of the Decedent’s heart or an elevated risk of a sudden cardiac event leading into the date of the incident. Dr. Hooshang Pak (Post-Incident Treating Neurosurgeon) – Very persuasive witness and conveyed very explicitly the severity of the neck fracture. John Gardiner ( Biomech ) – He did great getting us over summary judgment but probably a wash during trial. The defense liability experts were: Dr. Michael Chaikin (Cardiologist) – Like many defense experts, he took very extreme positions during his deposition and conveyed them arrogantly. He did the same song and dance during trial. He talks (or rambles) for a long time during his answers and, in my opinion, do not break the information down sufficiently to convey it to someone who has no idea what he is talking about. Dr. Nirav Patel (Neurologist) – Dr. Patel was the treating Neurologist following the incident that the defense morphed into their expert. I thought he delivered the information well and he was a formidable expert for us to go up against. John Brault ( Biomech ) – He is good but he is very abrasive and I think that backfired on them at trial. Liability Verdict The jury found Access, the subcontractor Global Paratransit, and the driver Carlos Juarez, Jr. each liable for the incident. They also found that Global was an agent of Access. The apportionment was 15% to Juarez, 40% for Global, and 45% for Access. Damages Phase Trial Our damages phase commenced on December 4, 2023. The judge (who I’ll do a separate section on) dragged his feet on some MIL rulings and, as a result, some evidence that was ultimately excluded was referenced to the jury. As a result, following his favorable ruling for us and exclusion of evidence, a mistrial was declared on December 5, 2023. We empaneled a new jury on December 6, 2023 and kept trucking through our verdict yesterday. We represented all seven of the Decedent’s children (wife pre-deceased). This family is incredible. The Decedent immigrated along with his wife from the Philippines, leaving five of their children behind to start a better life for them here in America. Slowly but surely, they were able to plant roots and bring all of their children here with them in the 1990s. They had two additional children here. For the vast majority of the Decedent’s life, he was an MTA bus driver working insane hours to provide for his family. They are a very traditional family with strong family values, constantly focusing on each other and spending as much time together as possible. Each of their birthdays was a massive event that they always spent together, along with holidays and normal family gatherings. That tradition carried throughout their childhood and their adult lives. Our clients are all established and have their own children now but that did not stop them from constantly getting the family together. All but one of our clients lived no more than 15 minutes away from their father. The one child that lived in San Diego came up to Long Beach twice a month with her family to spend time with her father. Two of the children, one of whom is deaf and has some developmental limitations, lived with him in the family home and saw him every single day. The ones that did not live with him either saw their father every day, every other day, or every weekend. They were in constant communications with their father. We also conveyed that in the Filipino culture, reverence for elders is a massive deal. Each of our clients explained that they were looking forward to caring for their father in his elder years and valuing the time that they all had to spend with him. Having that taken from them so abruptly was absolutely devastating for them and we were able to bring that out to the jury. We had no less than 60 family photos and several family videos that we intended to use during our examinations. The judge initially limited us two photos and zero videos because he thought it was cumulative and prejudicial. After getting railroaded, we were able to find an additional handful of individual photos of our clients and their father that the judge ultimately let us use. As a tactical move, we counseled our clients to use the photos as memory triggers to tell stories about the photos without actually showing them to the jury. Our clients hit grand slams during their testimony. It was a very emotional trial but it was an authentic trial. In an unbelievable own-goal , the defense opened the door on the issue of one of the children facetiming the Decedent while he was on his deathbed which that child had recorded and we had marked as an exhibit. As a result, on re-direct, we were able to move that video into evidence which showed the condition of the Decedent a week before his death. It was very powerful evidence which the jury probably would not have seen otherwise. On the issue of life expectancy notwithstanding the incident, our experts were: Dr. Jeffrey Goodman (Cardiologist) – Again, total rockstar. Dr. Mamoo Nakamura (Pre-Incident Cardiologist) – Again, homerun. Dr. George Hon (Treating Nephrologist) – Gave us what we needed that the Decedent’s kidney was stable. The defense’s only witness was Dr. Michael Chaikin. In a stroke of genius, Raphael obtained a transcript of Dr. Chaikin in another matter that showed that he was an expert in several matters testifying on behalf of the tobacco companies. We were able to get him to admit that during cross and, in our discussions with the jury following the verdict, that was really powerful evidence to get them to disregard his opinions. The Life Expectancy Tables said that a 61 year old man would have lived another 21 years. Obviously, we could not get around the issue that the Decedent had several comorbidities so we did not suggest to the jury that he would have lived that long. Dr. Goodman testified, from a cardiac perspective, the Decedent would have lived another 17 years. In closing, we argued that it would more reasonably have been 10. The defense took the position that he would have lived an additional six months to three years, an opinion that was admittedly rendered by Dr. Chaikin prior to him having the Decedent’s complete medical records. Once he had the entire universe, which included records closer in time to the incident which showed that the Decedent’s heart condition was improving and healthy, he doubled down and said those records did not change any of his opinions. We believed that opinion was going to be a really tough sell and we hammered him on cross. In the end, the jury awarded us $13,250,000 in past non-economic damages and $4,250,000 in future. Defense Firms The defense was represented by Kenton Moore of McCune & Harber for the overwhelming majority of the case. I really hesitate to cast aspersions towards anyone but I cannot have less respect for him than I do. His tactics are full blown scorched earth and he obstructed us at every moment, in every way, and at all times during the work up for this case. Before joining this office, I cut my teeth as a trial attorney handling complex business litigation so I am used to heavy law and motion but this case generated more law and motion and more MILs than I have ever seen. During trial, he is even worse. He habitually objects to basically everything during testimony, resulting in a lot of breaks in the action to argue with the judge about the evidence. He pretends as though he has never seen any evidence even though we proved, multiple times, that the evidence was exchanged and that he had seen it. He will agree to things in the halls of the court and then come before the judge and pretend like he didn’t agree to anything. To put it bluntly: he is a snake, a liar, a cheater, a bully, and an absolute nightmare to work with. Anyone who litigates against him should be prepared to devote countless hours and energy into the case to bodyslam him. Do not give him a single inch. You should also not trust a single thing that comes out of his mouth because it isn’t worth the energy that it takes your ears and brain to process the words. The upside is that his hardheadedness backfires spectacularly at trial. He is not impressive and in fact, he is repulsive and the results demonstrate that. Anyone who tries a case against him should be mentally prepared to deal with a lot of frustration but to remain calm, patient, and charming. He does everything he can to get under your skin, which he is very effective at, but you cannot let it get to you and you cannot reward him by reacting to his trash tactics. I could write a dissertation on this jabroni and I am happy to speak with anyone over the phone about how we handled him and how anyone with any active case against him should handle him going forward. For the damages phase, Michael Schonbuch of Daniels Fine associated into the case. Frankly, I wish that the entire case was worked up with him because we had a solid working relationship and I have only positive things to say about working with him for the short period of time that we did. He is a class act, very professional, and a strong advocate who did the best he could trying to get up to speed on a massive file. He also relegated Kenton to backbench because it was obvious that Kenton’s general disposition was a huge liability for them. The Judge I don’t know how valuable any of this information will be because Judge Fruin is quite old so I would anticipate that his stay on the bench might not be too much longer. In any event, Judge Fruin is tough. We were in his courtroom a lot during the work up and he was absolutely brutal on me as I was the face of the operation for much of the law and motion. He is temperamental as well. Be prepared to take a lot of heat but if you stand your ground and keep pushing and advocating, the ball will bounce your way. Your briefs need to be concise, well researched, and articulated very clearly. During argument, you also need to convey to him how critical certain issues are to the case in order to get the rulings you need. Our estimation is that he may have come to regret bifurcating the trial but he really tied our hands a lot throughout both phases. Anyone in his courtroom needs to be adequately prepared to adjust your gameplan on the fly. All of that being said, during examinations, he let us put on our cases. On balance, he overruled substantially more of the defense objections than he sustained. I think he is really tough on the plaintiffs side of the table and I think that can rub a lot of plaintiffs lawyers the wrong way about him maybe having a bias. I do not think he was biased. If anything, the learning lesson that I took from this experience is that he will force us as plaintiffs lawyers to not be lazy and to make sure that, if we are to be successful, we need to do it right so that the victory is as iron clad as possible. Thoughts and Musings This is obviously a great result for the case and we learned a lot working it up and trying both phases. I think the biggest takeaway for me is how important it is to believe in the strength of your case and the work. No case that is tried is perfect but if you are able to put forward an authentic explanation of your case, I am of the firm belief that the jury will buy it. I know Raphael was in constant communication with many of you during both phases asking for advice. I don’t know all of you by name but we want to convey our sincere gratitude for your support and assistance in helping us navigate this case. One more for the good guys. Andrew A. Talebi, Esq. | Attorney THE JAVID TRIAL FIRM, PC 11740 San Vicente Boulevard, Suite 109, #576 Los Angeles, California 90049 T: 310.929.9132 | F: 310.929.9133 https://www.thejtf.com This e-mail, and any attachments thereto, is intended only for use by the addressee(s) named herein and may contain legally privileged and or confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this e-mail in error, please immediately notify the sender by telephone at (310) 929-9130 or by return e-mail, and permanently delete the original and any copy of this message, its attachments, and any printout thereof. Unauthorized use, dissemination or reproduction of this message is strictly prohibited and may be unlawful. Thank you.
AI Analysis:
This message contains no mention of Judge Goodman whatsoever. It discusses a $17.5 million wrongful death verdict in a civil case before Judge Richard Fruin in Department 15 of Stanley Mosk courthouse. The message is entirely about the Aviles v. Access Services case, trial strategy, and verdict details. It has no relevance to evaluating Judge Goodman in a California workers' compensation context.
"Niral Patel" Date: December 13, 2023 2:24:00 PM Subject: Re: $17.5 MILLION WRONGFUL DEATH VERDICT REPORT Reply to list Reply to sender Print How did the Defense open the door to the facetime video? Niral Patel Niral Patel Injury Law 100 Bayview Circle Suite 100 Newport Beach, CA - 92660 Phone: (805) 748-9317 FAX: (714) 627-4696 Email: NiralPatel@NiralPatelInjuryLaw.com Web page: NiralPatelInjuryLaw.com CONFIDENTIALITY NOTICE: This email message and any attachments are for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, please contact the sender via reply email and destroy all copies of the original message along with any attachments. Friends: We are happy to report that Raphael Javid and myself have, after almost 4 years of an absolute battle, brought home a $17,500,000 verdict in a wrongful death matter in Los Angeles. The case is called Guillermo Aviles, Jr., et al. v. Access Services, et al. and was litigated in Department 15 of Stanley Mosk before Judge Richard Fruin. The trial was bifurcated into liability and damages about a year ago and we obtained a successful liability verdict on May 31, 2023 against Access Services, Global Paratransit, Inc. (a subcontractor of Access) and the driver, Carlos Juarez, Jr. Raphael did a write up after we obtained that verdict but I’ll summarize everything. Facts On March 27, 2020, the Decedent, aged 61, was being brought home by Access following dialysis treatment. Upon arriving at his residence, the Decedent was released from the vehicle outside the residence in the street, and not on the curb, and left unattended by the driver. The driver placed the Decedent’s bag on the pavement near an enormous pothole. As the Decedent was bending down to pick up his bag, he fell, hit his head in the pothole, fractured his neck at C2, was immediately rendered quadriplegic which threw him into a respiratory arrest followed by a cardiac arrest. Paramedics arrived on scene and were able to resuscitate him. Ultimately, he died on June 26, 2020. Liability Access is supposed to provide curb to curb transportation which basically means that after the rider exits the vehicle, Access is supposed to assist riders to the curb, at a minimum. In our case, they left him in the street. Moreover, the cause of the accident was placing the Decedent’s bag on the ground instead of handing it to him or standing next to him when he picked it up. It is well known that dialysis patients suffer from dizziness, fatigue, and weakness following treatment. This is because for some patients, the treatment causes their blood pressure to drop substantially to the point that they become hypotensive. There is express ADA guidance on this topic that instructs paratransit operators like Access to provide Return Trip Assistance and escort the dialysis patient to the door of their location following dialysis treatment. When the Decedent underwent a physical evaluation as part of the eligibility process to become an Access rider, he complained of dizziness and fatigue following dialysis treatment. Moreover, the dialysis records from the date of the incident showed that he had 6 hypotensive episodes during treatment which resulted in treatment having to be stopped. During the liability trial, we argued that when he bent over to pick up his bag, he suffered a hypotensive event which caused him to become dizzy and fall and break his neck. We also put forward evidence that the driver did not follow the ADA guidance or much of the training procedure that was articulated in Access’ materials. We also put forward evidence that the Decedent’s evaluation indicated that he was designated as being eligible for Beyond the Curb service, which means that the driver should have known that the Decedent required additional assistance after treatment that would require the driver to escort him, as opposed to just letting him out of the vehicle and doing nothing else. Defense Liability Arguments Access argued that their driver did nothing wrong because, from their vantage point, the ride is concluded the moment that the person steps out of the paratransit vehicle and recognizes their surroundings. They also argued that the driver did provide assistance by merely standing by the Decedent as he got out of the vehicle to place his feet on the street. Additionally, the Decedent had a history of cardiac issues, including a prior cardiac arrest. The defense argued that the fall was caused by a cardiac arrest following dialysis treatment and that the Decedent would have fractured his neck regardless of where he fell. They also argued that the cardiac arrest resulted in a substantial amount of brain damaged due to lack of oxygen, which is really what caused him to be paralyzed until his death. Liability Experts Our liability experts were: · Dr. Jeffrey Goodman (Cardiologist) – Absolute rockstar. He did an outstanding job testifying and explained complex cardiac information in an accessible and persuasive way for the jury. During the work up, he was an incredible resource for us in evaluating the evidence and having a real mastery of the issues. · Dr. Barry Ludwig (Neurologist) – Raphael describes him as regal. I think he did a great job conveying our argument about how severe this neck fracture was and he really helped carry the day for us in Phase 1. · Dean McMillan (Paratransit Standard of Care) – It is really hard to find experts in this field and it was her first time being an expert because our prior expert unfortunately passed away. She was not great during deposition or trial and the defense beat her up pretty badly in both. Fortunately, we had so much good evidence without her that we were able to make our case without heavily relying on her. · Dr. Mamoo Nakamura (Treating Cardiologist) – He was the last cardiologist that the Decedent saw prior to the incident and he was able to provide us with testimony that he had no concerns about the condition of the Decedent’s heart or an elevated risk of a sudden cardiac event leading into the date of the incident. · Dr. Hooshang Pak (Post-Incident Treating Neurosurgeon) – Very persuasive witness and conveyed very explicitly the severity of the neck fracture. · John Gardiner ( Biomech ) – He did great getting us over summary judgment but probably a wash during trial. The defense liability experts were: · Dr. Michael Chaikin (Cardiologist) – Like many defense experts, he took very extreme positions during his deposition and conveyed them arrogantly. He did the same song and dance during trial. He talks (or rambles) for a long time during his answers and, in my opinion, do not break the information down sufficiently to convey it to someone who has no idea what he is talking about. · Dr. Nirav Patel (Neurologist) – Dr. Patel was the treating Neurologist following the incident that the defense morphed into their expert. I thought he delivered the information well and he was a formidable expert for us to go up against. · John Brault ( Biomech ) – He is good but he is very abrasive and I think that backfired on them at trial. Liability Verdict The jury found Access, the subcontractor Global Paratransit, and the driver Carlos Juarez, Jr. each liable for the incident. They also found that Global was an agent of Access. The apportionment was 15% to Juarez, 40% for Global, and 45% for Access. Damages Phase Trial Our damages phase commenced on December 4, 2023. The judge (who I’ll do a separate section on) dragged his feet on some MIL rulings and, as a result, some evidence that was ultimately excluded was referenced to the jury. As a result, following his favorable ruling for us and exclusion of evidence, a mistrial was declared on December 5, 2023. We empaneled a new jury on December 6, 2023 and kept trucking through our verdict yesterday. We represented all seven of the Decedent’s children (wife pre-deceased). This family is incredible. The Decedent immigrated along with his wife from the Philippines, leaving five of their children behind to start a better life for them here in America. Slowly but surely, they were able to plant roots and bring all of their children here with them in the 1990s. They had two additional children here. For the vast majority of the Decedent’s life, he was an MTA bus driver working insane hours to provide for his family. They are a very traditional family with strong family values, constantly focusing on each other and spending as much time together as possible. Each of their birthdays was a massive event that they always spent together, along with holidays and normal family gatherings. That tradition carried throughout their childhood and their adult lives. Our clients are all established and have their own children now but that did not stop them from constantly getting the family together. All but one of our clients lived no more than 15 minutes away from their father. The one child that lived in San Diego came up to Long Beach twice a month with her family to spend time with her father. Two of the children, one of whom is deaf and has some developmental limitations, lived with him in the family home and saw him every single day. The ones that did not live with him either saw their father every day, every other day, or every weekend. They were in constant communications with their father. We also conveyed that in the Filipino culture, reverence for elders is a massive deal. Each of our clients explained that they were looking forward to caring for their father in his elder years and valuing the time that they all had to spend with him. Having that taken from them so abruptly was absolutely devastating for them and we were able to bring that out to the jury. We had no less than 60 family photos and several family videos that we intended to use during our examinations. The judge initially limited us two photos and zero videos because he thought it was cumulative and prejudicial. After getting railroaded, we were able to find an additional handful of individual photos of our clients and their father that the judge ultimately let us use. As a tactical move, we counseled our clients to use the photos as memory triggers to tell stories about the photos without actually showing them to the jury. Our clients hit grand slams during their testimony. It was a very emotional trial but it was an authentic trial. In an unbelievable own-goal , the defense opened the door on the issue of one of the children facetiming the Decedent while he was on his deathbed which that child had recorded and we had marked as an exhibit. As a result, on re-direct, we were able to move that video into evidence which showed the condition of the Decedent a week before his death. It was very powerful evidence which the jury probably would not have seen otherwise. On the issue of life expectancy notwithstanding the incident, our experts were: · Dr. Jeffrey Goodman (Cardiologist) – Again, total rockstar. · Dr. Mamoo Nakamura (Pre-Incident Cardiologist) – Again, homerun. · Dr. George Hon (Treating Nephrologist) – Gave us what we needed that the Decedent’s kidney was stable. The defense’s only witness was Dr. Michael Chaikin. In a stroke of genius, Raphael obtained a transcript of Dr. Chaikin in another matter that showed that he was an expert in several matters testifying on behalf of the tobacco companies. We were able to get him to admit that during cross and, in our discussions with the jury following the verdict, that was really powerful evidence to get them to disregard his opinions. The Life Expectancy Tables said that a 61 year old man would have lived another 21 years. Obviously, we could not get around the issue that the Decedent had several comorbidities so we did not suggest to the jury that he would have lived that long. Dr. Goodman testified, from a cardiac perspective, the Decedent would have lived another 17 years. In closing, we argued that it would more reasonably have been 10. The defense took the position that he would have lived an additional six months to three years, an opinion that was admittedly rendered by Dr. Chaikin prior to him having the Decedent’s complete medical records. Once he had the entire universe, which included records closer in time to the incident which showed that the Decedent’s heart condition was improving and healthy, he doubled down and said those records did not change any of his opinions. We believed that opinion was going to be a really tough sell and we hammered him on cross. In the end, the jury awarded us $13,250,000 in past non-economic damages and $4,250,000 in future. Defense Firms The defense was represented by Kenton Moore of McCune & Harber for the overwhelming majority of the case. I really hesitate to cast aspersions towards anyone but I cannot have less respect for him than I do. His tactics are full blown scorched earth and he obstructed us at every moment, in every way, and at all times during the work up for this case. Before joining this office, I cut my teeth as a trial attorney handling complex business litigation so I am used to heavy law and motion but this case generated more law and motion and more MILs than I have ever seen. During trial, he is even worse. He habitually objects to basically everything during testimony, resulting in a lot of breaks in the action to argue with the judge about the evidence. He pretends as though he has never seen any evidence even though we proved, multiple times, that the evidence was exchanged and that he had seen it. He will agree to things in the halls of the court and then come before the judge and pretend like he didn’t agree to anything. To put it bluntly: he is a snake, a liar, a cheater, a bully, and an absolute nightmare to work with. Anyone who litigates against him should be prepared to devote countless hours and energy into the case to bodyslam him. Do not give him a single inch. You should also not trust a single thing that comes out of his mouth because it isn’t worth the energy that it takes your ears and brain to process the words. The upside is that his hardheadedness backfires spectacularly at trial. He is not impressive and in fact, he is repulsive and the results demonstrate that. Anyone who tries a case against him should be mentally prepared to deal with a lot of frustration but to remain calm, patient, and charming. He does everything he can to get under your skin, which he is very effective at, but you cannot let it get to you and you cannot reward him by reacting to his trash tactics. I could write a dissertation on this jabroni and I am happy to speak with anyone over the phone about how we handled him and how anyone with any active case against him should handle him going forward. For the damages phase, Michael Schonbuch of Daniels Fine associated into the case. Frankly, I wish that the entire case was worked up with him because we had a solid working relationship and I have only positive things to say about working with him for the short period of time that we did. He is a class act, very professional, and a strong advocate who did the best he could trying to get up to speed on a massive file. He also relegated Kenton to backbench because it was obvious that Kenton’s general disposition was a huge liability for them. The Judge I don’t know how valuable any of this information will be because Judge Fruin is quite old so I would anticipate that his stay on the bench might not be too much longer. In any event, Judge Fruin is tough. We were in his courtroom a lot during the work up and he was absolutely brutal on me as I was the face of the operation for much of the law and motion. He is temperamental as well. Be prepared to take a lot of heat but if you stand your ground and keep pushing and advocating, the ball will bounce your way. Your briefs need to be concise, well researched, and articulated very clearly. During argument, you also need to convey to him how critical certain issues are to the case in order to get the rulings you need. Our estimation is that he may have come to regret bifurcating the trial but he really tied our hands a lot throughout both phases. Anyone in his courtroom needs to be adequately prepared to adjust your gameplan on the fly. All of that being said, during examinations, he let us put on our cases. On balance, he overruled substantially more of the defense objections than he sustained. I think he is really tough on the plaintiffs side of the table and I think that can rub a lot of plaintiffs lawyers the wrong way about him maybe having a bias. I do not think he was biased. If anything, the learning lesson that I took from this experience is that he will force us as plaintiffs lawyers to not be lazy and to make sure that, if we are to be successful, we need to do it right so that the victory is as iron clad as possible. Thoughts and Musings This is obviously a great result for the case and we learned a lot working it up and trying both phases. I think the biggest takeaway for me is how important it is to believe in the strength of your case and the work. No case that is tried is perfect but if you are able to put forward an authentic explanation of your case, I am of the firm belief that the jury will buy it. I know Raphael was in constant communication with many of you during both phases asking for advice. I don’t know all of you by name but we want to convey our sincere gratitude for your support and assistance in helping us navigate this case. One more for the good guys. Andrew A. Talebi, Esq. | Attorney THE JAVID TRIAL FIRM, PC 11740 San Vicente Boulevard, Suite 109, #576 Los Angeles, California 90049 T: 310.929.9132 | F: 310.929.9133 https://www.thejtf.com This e-mail, and any attachments thereto, is intended only for use by the addressee(s) named herein and may contain legally privileged and or confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this e-mail in error, please immediately notify the sender by telephone at (310) 929-9130 or by return e-mail, and permanently delete the original and any copy of this message, its attachments, and any printout thereof. Unauthorized use, dissemination or reproduction of this message is strictly prohibited and may be unlawful. Thank you.
AI Analysis:
This message is entirely about a $17.5 million wrongful death verdict in a civil case before Judge Richard Fruin in Department 15 of Stanley Mosk courthouse. The judge 'goodman' is not mentioned anywhere in this message. The message contains no information about goodman whatsoever, making it completely irrelevant for evaluating goodman as a workers' compensation judge.
"Arya Rhodes" Date: December 13, 2023 1:52:00 PM Subject: Re: $17.5 MILLION WRONGFUL DEATH VERDICT REPORT Reply to list Reply to sender Print List: caala-workproduct Sent by: Arya Rhodes (Reply Privately) Search Raph is a charming beast. Not surprised by this outcome. -- Best regards, Arya Rhodes, Esq. Partner Schimmel & Parks, APLC Comerica Bank Building 15303 Ventura Blvd., Ste. 650 Sherman Oaks, CA 91403 Phone: 818.464.5061 ext 3 Fax: 818.464.5091 www.spattorneys.com CONFIDENTIALITY NOTICE: The information contained in this e-mail message may be privileged, confidential, and/or protected from disclosure. If you are not the intended recipient, any further disclosure or use, dissemination, distribution, or copying of this message or any attachment is strictly prohibited. If you think that you have received this e-mail message in error, please delete it and notify the sender. Thank you. From: Andrew Talebi (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Wednesday, December 13, 2023 11:41 AM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: [caala-workproduct] $17.5 MILLION WRONGFUL DEATH VERDICT REPORT List: caala-workproduct Sent by: Andrew Talebi (Reply Privately) Search Friends: We are happy to report that Raphael Javid and myself have, after almost 4 years of an absolute battle, brought home a $17,500,000 verdict in a wrongful death matter in Los Angeles. The case is called Guillermo Aviles, Jr., et al. v. Access Services, et al. and was litigated in Department 15 of Stanley Mosk before Judge Richard Fruin. The trial was bifurcated into liability and damages about a year ago and we obtained a successful liability verdict on May 31, 2023 against Access Services, Global Paratransit, Inc. (a subcontractor of Access) and the driver, Carlos Juarez, Jr. Raphael did a write up after we obtained that verdict but I’ll summarize everything. Facts On March 27, 2020, the Decedent, aged 61, was being brought home by Access following dialysis treatment. Upon arriving at his residence, the Decedent was released from the vehicle outside the residence in the street, and not on the curb, and left unattended by the driver. The driver placed the Decedent’s bag on the pavement near an enormous pothole. As the Decedent was bending down to pick up his bag, he fell, hit his head in the pothole, fractured his neck at C2, was immediately rendered quadriplegic which threw him into a respiratory arrest followed by a cardiac arrest. Paramedics arrived on scene and were able to resuscitate him. Ultimately, he died on June 26, 2020. Liability Access is supposed to provide curb to curb transportation which basically means that after the rider exits the vehicle, Access is supposed to assist riders to the curb, at a minimum. In our case, they left him in the street. Moreover, the cause of the accident was placing the Decedent’s bag on the ground instead of handing it to him or standing next to him when he picked it up. It is well known that dialysis patients suffer from dizziness, fatigue, and weakness following treatment. This is because for some patients, the treatment causes their blood pressure to drop substantially to the point that they become hypotensive. There is express ADA guidance on this topic that instructs paratransit operators like Access to provide Return Trip Assistance and escort the dialysis patient to the door of their location following dialysis treatment. When the Decedent underwent a physical evaluation as part of the eligibility process to become an Access rider, he complained of dizziness and fatigue following dialysis treatment. Moreover, the dialysis records from the date of the incident showed that he had 6 hypotensive episodes during treatment which resulted in treatment having to be stopped. During the liability trial, we argued that when he bent over to pick up his bag, he suffered a hypotensive event which caused him to become dizzy and fall and break his neck. We also put forward evidence that the driver did not follow the ADA guidance or much of the training procedure that was articulated in Access’ materials. We also put forward evidence that the Decedent’s evaluation indicated that he was designated as being eligible for Beyond the Curb service, which means that the driver should have known that the Decedent required additional assistance after treatment that would require the driver to escort him, as opposed to just letting him out of the vehicle and doing nothing else. Defense Liability Arguments Access argued that their driver did nothing wrong because, from their vantage point, the ride is concluded the moment that the person steps out of the paratransit vehicle and recognizes their surroundings. They also argued that the driver did provide assistance by merely standing by the Decedent as he got out of the vehicle to place his feet on the street. Additionally, the Decedent had a history of cardiac issues, including a prior cardiac arrest. The defense argued that the fall was caused by a cardiac arrest following dialysis treatment and that the Decedent would have fractured his neck regardless of where he fell. They also argued that the cardiac arrest resulted in a substantial amount of brain damaged due to lack of oxygen, which is really what caused him to be paralyzed until his death. Liability Experts Our liability experts were: Dr. Jeffrey Goodman (Cardiologist) – Absolute rockstar. He did an outstanding job testifying and explained complex cardiac information in an accessible and persuasive way for the jury. During the work up, he was an incredible resource for us in evaluating the evidence and having a real mastery of the issues. Dr. Barry Ludwig (Neurologist) – Raphael describes him as regal. I think he did a great job conveying our argument about how severe this neck fracture was and he really helped carry the day for us in Phase 1. Dean McMillan (Paratransit Standard of Care) – It is really hard to find experts in this field and it was her first time being an expert because our prior expert unfortunately passed away. She was not great during deposition or trial and the defense beat her up pretty badly in both. Fortunately, we had so much good evidence without her that we were able to make our case without heavily relying on her. Dr. Mamoo Nakamura (Treating Cardiologist) – He was the last cardiologist that the Decedent saw prior to the incident and he was able to provide us with testimony that he had no concerns about the condition of the Decedent’s heart or an elevated risk of a sudden cardiac event leading into the date of the incident. Dr. Hooshang Pak (Post-Incident Treating Neurosurgeon) – Very persuasive witness and conveyed very explicitly the severity of the neck fracture. John Gardiner (Biomech) – He did great getting us over summary judgment but probably a wash during trial. The defense liability experts were: Dr. Michael Chaikin (Cardiologist) – Like many defense experts, he took very extreme positions during his deposition and conveyed them arrogantly. He did the same song and dance during trial. He talks (or rambles) for a long time during his answers and, in my opinion, do not break the information down sufficiently to convey it to someone who has no idea what he is talking about. Dr. Nirav Patel (Neurologist) – Dr. Patel was the treating Neurologist following the incident that the defense morphed into their expert. I thought he delivered the information well and he was a formidable expert for us to go up against. John Brault (Biomech) – He is good but he is very abrasive and I think that backfired on them at trial. Liability Verdict The jury found Access, the subcontractor Global Paratransit, and the driver Carlos Juarez, Jr. each liable for the incident. They also found that Global was an agent of Access. The apportionment was 15% to Juarez, 40% for Global, and 45% for Access. Damages Phase Trial Our damages phase commenced on December 4, 2023. The judge (who I’ll do a separate section on) dragged his feet on some MIL rulings and, as a result, some evidence that was ultimately excluded was referenced to the jury. As a result, following his favorable ruling for us and exclusion of evidence, a mistrial was declared on December 5, 2023. We empaneled a new jury on December 6, 2023 and kept trucking through our verdict yesterday. We represented all seven of the Decedent’s children (wife pre-deceased). This family is incredible. The Decedent immigrated along with his wife from the Philippines, leaving five of their children behind to start a better life for them here in America. Slowly but surely, they were able to plant roots and bring all of their children here with them in the 1990s. They had two additional children here. For the vast majority of the Decedent’s life, he was an MTA bus driver working insane hours to provide for his family. They are a very traditional family with strong family values, constantly focusing on each other and spending as much time together as possible. Each of their birthdays was a massive event that they always spent together, along with holidays and normal family gatherings. That tradition carried throughout their childhood and their adult lives. Our clients are all established and have their own children now but that did not stop them from constantly getting the family together. All but one of our clients lived no more than 15 minutes away from their father. The one child that lived in San Diego came up to Long Beach twice a month with her family to spend time with her father. Two of the children, one of whom is deaf and has some developmental limitations, lived with him in the family home and saw him every single day. The ones that did not live with him either saw their father every day, every other day, or every weekend. They were in constant communications with their father. We also conveyed that in the Filipino culture, reverence for elders is a massive deal. Each of our clients explained that they were looking forward to caring for their father in his elder years and valuing the time that they all had to spend with him. Having that taken from them so abruptly was absolutely devastating for them and we were able to bring that out to the jury. We had no less than 60 family photos and several family videos that we intended to use during our examinations. The judge initially limited us two photos and zero videos because he thought it was cumulative and prejudicial. After getting railroaded, we were able to find an additional handful of individual photos of our clients and their father that the judge ultimately let us use. As a tactical move, we counseled our clients to use the photos as memory triggers to tell stories about the photos without actually showing them to the jury. Our clients hit grand slams during their testimony. It was a very emotional trial but it was an authentic trial. In an unbelievable own-goal, the defense opened the door on the issue of one of the children facetiming the Decedent while he was on his deathbed which that child had recorded and we had marked as an exhibit. As a result, on re-direct, we were able to move that video into evidence which showed the condition of the Decedent a week before his death. It was very powerful evidence which the jury probably would not have seen otherwise. On the issue of life expectancy notwithstanding the incident, our experts were: Dr. Jeffrey Goodman (Cardiologist) – Again, total rockstar. Dr. Mamoo Nakamura (Pre-Incident Cardiologist) – Again, homerun. Dr. George Hon (Treating Nephrologist) – Gave us what we needed that the Decedent’s kidney was stable. The defense’s only witness was Dr. Michael Chaikin. In a stroke of genius, Raphael obtained a transcript of Dr. Chaikin in another matter that showed that he was an expert in several matters testifying on behalf of the tobacco companies. We were able to get him to admit that during cross and, in our discussions with the jury following the verdict, that was really powerful evidence to get them to disregard his opinions. The Life Expectancy Tables said that a 61 year old man would have lived another 21 years. Obviously, we could not get around the issue that the Decedent had several comorbidities so we did not suggest to the jury that he would have lived that long. Dr. Goodman testified, from a cardiac perspective, the Decedent would have lived another 17 years. In closing, we argued that it would more reasonably have been 10. The defense took the position that he would have lived an additional six months to three years, an opinion that was admittedly rendered by Dr. Chaikin prior to him having the Decedent’s complete medical records. Once he had the entire universe, which included records closer in time to the incident which showed that the Decedent’s heart condition was improving and healthy, he doubled down and said those records did not change any of his opinions. We believed that opinion was going to be a really tough sell and we hammered him on cross. In the end, the jury awarded us $13,250,000 in past non-economic damages and $4,250,000 in future. Defense Firms The defense was represented by Kenton Moore of McCune & Harber for the overwhelming majority of the case. I really hesitate to cast aspersions towards anyone but I cannot have less respect for him than I do. His tactics are full blown scorched earth and he obstructed us at every moment, in every way, and at all times during the work up for this case. Before joining this office, I cut my teeth as a trial attorney handling complex business litigation so I am used to heavy law and motion but this case generated more law and motion and more MILs than I have ever seen. During trial, he is even worse. He habitually objects to basically everything during testimony, resulting in a lot of breaks in the action to argue with the judge about the evidence. He pretends as though he has never seen any evidence even though we proved, multiple times, that the evidence was exchanged and that he had seen it. He will agree to things in the halls of the court and then come before the judge and pretend like he didn’t agree to anything. To put it bluntly: he is a snake, a liar, a cheater, a bully, and an absolute nightmare to work with. Anyone who litigates against him should be prepared to devote countless hours and energy into the case to bodyslam him. Do not give him a single inch. You should also not trust a single thing that comes out of his mouth because it isn’t worth the energy that it takes your ears and brain to process the words. The upside is that his hardheadedness backfires spectacularly at trial. He is not impressive and in fact, he is repulsive and the results demonstrate that. Anyone who tries a case against him should be mentally prepared to deal with a lot of frustration but to remain calm, patient, and charming. He does everything he can to get under your skin, which he is very effective at, but you cannot let it get to you and you cannot reward him by reacting to his trash tactics. I could write a dissertation on this jabroni and I am happy to speak with anyone over the phone about how we handled him and how anyone with any active case against him should handle him going forward. For the damages phase, Michael Schonbuch of Daniels Fine associated into the case. Frankly, I wish that the entire case was worked up with him because we had a solid working relationship and I have only positive things to say about working with him for the short period of time that we did. He is a class act, very professional, and a strong advocate who did the best he could trying to get up to speed on a massive file. He also relegated Kenton to backbench because it was obvious that Kenton’s general disposition was a huge liability for them. The Judge I don’t know how valuable any of this information will be because Judge Fruin is quite old so I would anticipate that his stay on the bench might not be too much longer. In any event, Judge Fruin is tough. We were in his courtroom a lot during the work up and he was absolutely brutal on me as I was the face of the operation for much of the law and motion. He is temperamental as well. Be prepared to take a lot of heat but if you stand your ground and keep pushing and advocating, the ball will bounce your way. Your briefs need to be concise, well researched, and articulated very clearly. During argument, you also need to convey to him how critical certain issues are to the case in order to get the rulings you need. Our estimation is that he may have come to regret bifurcating the trial but he really tied our hands a lot throughout both phases. Anyone in his courtroom needs to be adequately prepared to adjust your gameplan on the fly. All of that being said, during examinations, he let us put on our cases. On balance, he overruled substantially more of the defense objections than he sustained. I think he is really tough on the plaintiffs side of the table and I think that can rub a lot of plaintiffs lawyers the wrong way about him maybe having a bias. I do not think he was biased. If anything, the learning lesson that I took from this experience is that he will force us as plaintiffs lawyers to not be lazy and to make sure that, if we are to be successful, we need to do it right so that the victory is as iron clad as possible. Thoughts and Musings This is obviously a great result for the case and we learned a lot working it up and trying both phases. I think the biggest takeaway for me is how important it is to believe in the strength of your case and the work. No case that is tried is perfect but if you are able to put forward an authentic explanation of your case, I am of the firm belief that the jury will buy it. I know Raphael was in constant communication with many of you during both phases asking for advice. I don’t know all of you by name but we want to convey our sincere gratitude for your support and assistance in helping us navigate this case. One more for the good guys. Andrew A. Talebi, Esq. | Attorney THE JAVID TRIAL FIRM, PC 11740 San Vicente Boulevard, Suite 109, #576 Los Angeles, California 90049 T: 310.929.9132 | F: 310.929.9133 https://link.edgepilot.com/s/955cbb58/ERWqNb4nx0OXEXV0REva6Q?u=https://www.thejtf.com/ This e-mail, and any attachments thereto, is intended only for use by the addressee(s) named herein and may contain legally privileged and or confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this e-mail in error, please immediately notify the sender by telephone at (310) 929-9130 or by return e-mail, and permanently delete the original and any copy of this message, its attachments, and any printout thereof. Unauthorized use, dissemination or reproduction of this message is strictly prohibited and may be unlawful. Thank you.
AI Analysis:
This message does not mention Judge Goodman at all. It discusses a $17.5 million wrongful death verdict in Department 15 of Stanley Mosk before Judge Richard Fruin, and contains a side comment about Kenton Moore. There is no reference to 'goodman' in any form throughout the message.
eric@trautfirm.com Date: December 13, 2023 1:50:00 PM Subject: Re: $17.5 MILLION WRONGFUL DEATH VERDICT REPORT Reply to list Reply to sender Print List: caala-workproduct Sent by: Eric Traut (Reply Privately) Search My wife had an awful experience dealing with Kenton Moore on a case over the last couple years. Not surprising he acted that way, but in the end he probably added value to the case. From: Alex Guerrero (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Wednesday, December 13, 2023 11:46 AM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re:[caala-workproduct] $17.5 MILLION WRONGFUL DEATH VERDICT REPORT List: caala-workproduct Sent by: Alex Guerrero (Reply Privately) Search GREAT FUCKING JOB -----Original Message----- From: andrew@thejtf.com Sent: December 13, 2023 1:41:00 PM To: caala-workproduct@lists.trialsmith.com Subject: $17.5 MILLION WRONGFUL DEATH VERDICT REPORT Friends: We are happy to report that Raphael Javid and myself have, after almost 4 years of an absolute battle, brought home a $17,500,000 verdict in a wrongful death matter in Los Angeles. The case is called Guillermo Aviles, Jr., et al. v. Access Services, et al. and was litigated in Department 15 of Stanley Mosk before Judge Richard Fruin. The trial was bifurcated into liability and damages about a year ago and we obtained a successful liability verdict on May 31, 2023 against Access Services, Global Paratransit, Inc. (a subcontractor of Access) and the driver, Carlos Juarez, Jr. Raphael did a write up after we obtained that verdict but I'll summarize everything. Facts On March 27, 2020, the Decedent, aged 61, was being brought home by Access following dialysis treatment. Upon arriving at his residence, the Decedent was released from the vehicle outside the residence in the street, and not on the curb, and left unattended by the driver. The driver placed the Decedent's bag on the pavement near an enormous pothole. As the Decedent was bending down to pick up his bag, he fell, hit his head in the pothole, fractured his neck at C2, was immediately rendered quadriplegic which threw him into a respiratory arrest followed by a cardiac arrest. Paramedics arrived on scene and were able to resuscitate him. Ultimately, he died on June 26, 2020. Liability Access is supposed to provide curb to curb transportation which basically means that after the rider exits the vehicle, Access is supposed to assist riders to the curb, at a minimum. In our case, they left him in the street. Moreover, the cause of the accident was placing the Decedent's bag on the ground instead of handing it to him or standing next to him when he picked it up. It is well known that dialysis patients suffer from dizziness, fatigue, and weakness following treatment. This is because for some patients, the treatment causes their blood pressure to drop substantially to the point that they become hypotensive. There is express ADA guidance on this topic that instructs paratransit operators like Access to provide Return Trip Assistance and escort the dialysis patient to the door of their location following dialysis treatment. When the Decedent underwent a physical evaluation as part of the eligibility process to become an Access rider, he complained of dizziness and fatigue following dialysis treatment. Moreover, the dialysis records from the date of the incident showed that he had 6 hypotensive episodes during treatment which resulted in treatment having to be stopped. During the liability trial, we argued that when he bent over to pick up his bag, he suffered a hypotensive event which caused him to become dizzy and fall and break his neck. We also put forward evidence that the driver did not follow the ADA guidance or much of the training procedure that was articulated in Access' materials. We also put forward evidence that the Decedent's evaluation indicated that he was designated as being eligible for Beyond the Curb service, which means that the driver should have known that the Decedent required additional assistance after treatment that would require the driver to escort him, as opposed to just letting him out of the vehicle and doing nothing else. Defense Liability Arguments Access argued that their driver did nothing wrong because, from their vantage point, the ride is concluded the moment that the person steps out of the paratransit vehicle and recognizes their surroundings. They also argued that the driver did provide assistance by merely standing by the Decedent as he got out of the vehicle to place his feet on the street. Additionally, the Decedent had a history of cardiac issues, including a prior cardiac arrest. The defense argued that the fall was caused by a cardiac arrest following dialysis treatment and that the Decedent would have fractured his neck regardless of where he fell. They also argued that the cardiac arrest resulted in a substantial amount of brain damaged due to lack of oxygen, which is really what caused him to be paralyzed until his death. Liability Experts Our liability experts were: * Dr. Jeffrey Goodman (Cardiologist) - Absolute rockstar. He did an outstanding job testifying and explained complex cardiac information in an accessible and persuasive way for the jury. During the work up, he was an incredible resource for us in evaluating the evidence and having a real mastery of the issues. * Dr. Barry Ludwig (Neurologist) - Raphael describes him as regal. I think he did a great job conveying our argument about how severe this neck fracture was and he really helped carry the day for us in Phase 1. * Dean McMillan (Paratransit Standard of Care) - It is really hard to find experts in this field and it was her first time being an expert because our prior expert unfortunately passed away. She was not great during deposition or trial and the defense beat her up pretty badly in both. Fortunately, we had so much good evidence without her that we were able to make our case without heavily relying on her. * Dr. Mamoo Nakamura (Treating Cardiologist) - He was the last cardiologist that the Decedent saw prior to the incident and he was able to provide us with testimony that he had no concerns about the condition of the Decedent's heart or an elevated risk of a sudden cardiac event leading into the date of the incident. * Dr. Hooshang Pak (Post-Incident Treating Neurosurgeon) - Very persuasive witness and conveyed very explicitly the severity of the neck fracture. * John Gardiner (Biomech) - He did great getting us over summary judgment but probably a wash during trial. The defense liability experts were: * Dr. Michael Chaikin (Cardiologist) - Like many defense experts, he took very extreme positions during his deposition and conveyed them arrogantly. He did the same song and dance during trial. He talks (or rambles) for a long time during his answers and, in my opinion, do not break the information down sufficiently to convey it to someone who has no idea what he is talking about. * Dr. Nirav Patel (Neurologist) - Dr. Patel was the treating Neurologist following the incident that the defense morphed into their expert. I thought he delivered the information well and he was a formidable expert for us to go up against. * John Brault (Biomech) - He is good but he is very abrasive and I think that backfired on them at trial. Liability Verdict The jury found Access, the subcontractor Global Paratransit, and the driver Carlos Juarez, Jr. each liable for the incident. They also found that Global was an agent of Access. The apportionment was 15% to Juarez, 40% for Global, and 45% for Access. Damages Phase Trial Our damages phase commenced on December 4, 2023. The judge (who I'll do a separate section on) dragged his feet on some MIL rulings and, as a result, some evidence that was ultimately excluded was referenced to the jury. As a result, following his favorable ruling for us and exclusion of evidence, a mistrial was declared on December 5, 2023. We empaneled a new jury on December 6, 2023 and kept trucking through our verdict yesterday. We represented all seven of the Decedent's children (wife pre-deceased). This family is incredible. The Decedent immigrated along with his wife from the Philippines, leaving five of their children behind to start a better life for them here in America. Slowly but surely, they were able to plant roots and bring all of their children here with them in the 1990s. They had two additional children here. For the vast majority of the Decedent's life, he was an MTA bus driver working insane hours to provide for his family. They are a very traditional family with strong family values, constantly focusing on each other and spending as much time together as possible. Each of their birthdays was a massive event that they always spent together, along with holidays and normal family gatherings. That tradition carried throughout their childhood and their adult lives. Our clients are all established and have their own children now but that did not stop them from constantly getting the family together. All but one of our clients lived no more than 15 minutes away from their father. The one child that lived in San Diego came up to Long Beach twice a month with her family to spend time with her father. Two of the children, one of whom is deaf and has some developmental limitations, lived with him in the family home and saw him every single day. The ones that did not live with him either saw their father every day, every other day, or every weekend. They were in constant communications with their father. We also conveyed that in the Filipino culture, reverence for elders is a massive deal. Each of our clients explained that they were looking forward to caring for their father in his elder years and valuing the time that they all had to spend with him. Having that taken from them so abruptly was absolutely devastating for them and we were able to bring that out to the jury. We had no less than 60 family photos and several family videos that we intended to use during our examinations. The judge initially limited us two photos and zero videos because he thought it was cumulative and prejudicial. After getting railroaded, we were able to find an additional handful of individual photos of our clients and their father that the judge ultimately let us use. As a tactical move, we counseled our clients to use the photos as memory triggers to tell stories about the photos without actually showing them to the jury. Our clients hit grand slams during their testimony. It was a very emotional trial but it was an authentic trial. In an unbelievable own-goal, the defense opened the door on the issue of one of the children facetiming the Decedent while he was on his deathbed which that child had recorded and we had marked as an exhibit. As a result, on re-direct, we were able to move that video into evidence which showed the condition of the Decedent a week before his death. It was very powerful evidence which the jury probably would not have seen otherwise. On the issue of life expectancy notwithstanding the incident, our experts were: * Dr. Jeffrey Goodman (Cardiologist) - Again, total rockstar. * Dr. Mamoo Nakamura (Pre-Incident Cardiologist) - Again, homerun. * Dr. George Hon (Treating Nephrologist) - Gave us what we needed that the Decedent's kidney was stable. The defense's only witness was Dr. Michael Chaikin. In a stroke of genius, Raphael obtained a transcript of Dr. Chaikin in another matter that showed that he was an expert in several matters testifying on behalf of the tobacco companies. We were able to get him to admit that during cross and, in our discussions with the jury following the verdict, that was really powerful evidence to get them to disregard his opinions. The Life Expectancy Tables said that a 61 year old man would have lived another 21 years. Obviously, we could not get around the issue that the Decedent had several comorbidities so we did not suggest to the jury that he would have lived that long. Dr. Goodman testified, from a cardiac perspective, the Decedent would have lived another 17 years. In closing, we argued that it would more reasonably have been 10. The defense took the position that he would have lived an additional six months to three years, an opinion that was admittedly rendered by Dr. Chaikin prior to him having the Decedent's complete medical records. Once he had the entire universe, which included records closer in time to the incident which showed that the Decedent's heart condition was improving and healthy, he doubled down and said those records did not change any of his opinions. We believed that opinion was going to be a really tough sell and we hammered him on cross. In the end, the jury awarded us $13,250,000 in past non-economic damages and $4,250,000 in future. Defense Firms The defense was represented by Kenton Moore of McCune & Harber for the overwhelming majority of the case. I really hesitate to cast aspersions towards anyone but I cannot have less respect for him than I do. His tactics are full blown scorched earth and he obstructed us at every moment, in every way, and at all times during the work up for this case. Before joining this office, I cut my teeth as a trial attorney handling complex business litigation so I am used to heavy law and motion but this case generated more law and motion and more MILs than I have ever seen. During trial, he is even worse. He habitually objects to basically everything during testimony, resulting in a lot of breaks in the action to argue with the judge about the evidence. He pretends as though he has never seen any evidence even though we proved, multiple times, that the evidence was exchanged and that he had seen it. He will agree to things in the halls of the court and then come before the judge and pretend like he didn't agree to anything. To put it bluntly: he is a snake, a liar, a cheater, a bully, and an absolute nightmare to work with. Anyone who litigates against him should be prepared to devote countless hours and energy into the case to bodyslam him. Do not give him a single inch. You should also not trust a single thing that comes out of his mouth because it isn't worth the energy that it takes your ears and brain to process the words. The upside is that his hardheadedness backfires spectacularly at trial. He is not impressive and in fact, he is repulsive and the results demonstrate that. Anyone who tries a case against him should be mentally prepared to deal with a lot of frustration but to remain calm, patient, and charming. He does everything he can to get under your skin, which he is very effective at, but you cannot let it get to you and you cannot reward him by reacting to his trash tactics. I could write a dissertation on this jabroni and I am happy to speak with anyone over the phone about how we handled him and how anyone with any active case against him should handle him going forward. For the damages phase, Michael Schonbuch of Daniels Fine associated into the case. Frankly, I wish that the entire case was worked up with him because we had a solid working relationship and I have only positive things to say about working with him for the short period of time that we did. He is a class act, very professional, and a strong advocate who did the best he could trying to get up to speed on a massive file. He also relegated Kenton to backbench because it was obvious that Kenton's general disposition was a huge liability for them. The Judge I don't know how valuable any of this information will be because Judge Fruin is quite old so I would anticipate that his stay on the bench might not be too much longer. In any event, Judge Fruin is tough. We were in his courtroom a lot during the work up and he was absolutely brutal on me as I was the face of the operation for much of the law and motion. He is temperamental as well. Be prepared to take a lot of heat but if you stand your ground and keep pushing and advocating, the ball will bounce your way. Your briefs need to be concise, well researched, and articulated very clearly. During argument, you also need to convey to him how critical certain issues are to the case in order to get the rulings you need. Our estimation is that he may have come to regret bifurcating the trial but he really tied our hands a lot throughout both phases. Anyone in his courtroom needs to be adequately prepared to adjust your gameplan on the fly. All of that being said, during examinations, he let us put on our cases. On balance, he overruled substantially more of the defense objections than he sustained. I think he is really tough on the plaintiffs side of the table and I think that can rub a lot of plaintiffs lawyers the wrong way about him maybe having a bias. I do not think he was biased. If anything, the learning lesson that I took from this experience is that he will force us as plaintiffs lawyers to not be lazy and to make sure that, if we are to be successful, we need to do it right so that the victory is as iron clad as possible. Thoughts and Musings This is obviously a great result for the case and we learned a lot working it up and trying both phases. I think the biggest takeaway for me is how important it is to believe in the strength of your case and the work. No case that is tried is perfect but if you are able to put forward an authentic explanation of your case, I am of the firm belief that the jury will buy it. I know Raphael was in constant communication with many of you during both phases asking for advice. I don't know all of you by name but we want to convey our sincere gratitude for your support and assistance in helping us navigate this case. One more for the good guys. Andrew A. Talebi, Esq. ' Attorney THE JAVID TRIAL FIRM, PC 11740 San Vicente Boulevard, Suite 109, #576 Los Angeles, California 90049 T: 310.929.9132 ' F: 310.929.9133 https://www.thejtf.com This e-mail, and any attachments thereto, is intended only for use by the addressee(s) named herein and may contain legally privileged and or confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this e-mail in error, please immediately notify the sender by telephone at (310) 929-9130 or by return e-mail, and permanently delete the original and any copy of this message, its attachments, and any printout thereof. Unauthorized use, dissemination or reproduction of this message is strictly prohibited and may be unlawful. Thank you.
AI Analysis:
This message is about a $17.5 million wrongful death verdict in a civil case litigated before Judge Richard Fruin in Department 15 of Stanley Mosk courthouse. The judge 'goodman' is not mentioned anywhere in this message. The message contains no information about goodman whatsoever and is entirely unrelated to evaluating goodman as a workers' compensation judge.
"Alex Guerrero" Date: December 13, 2023 1:46:00 PM Subject: Re: $17.5 MILLION WRONGFUL DEATH VERDICT REPORT Reply to list Reply to sender Print List: caala-workproduct Sent by: Alex Guerrero (Reply Privately) Search GREAT FUCKING JOB -----Original Message----- From: andrew@thejtf.com Sent: December 13, 2023 1:41:00 PM To: caala-workproduct@lists.trialsmith.com Subject: $17.5 MILLION WRONGFUL DEATH VERDICT REPORT Friends: We are happy to report that Raphael Javid and myself have, after almost 4 years of an absolute battle, brought home a $17,500,000 verdict in a wrongful death matter in Los Angeles. The case is called Guillermo Aviles, Jr., et al. v. Access Services, et al. and was litigated in Department 15 of Stanley Mosk before Judge Richard Fruin. The trial was bifurcated into liability and damages about a year ago and we obtained a successful liability verdict on May 31, 2023 against Access Services, Global Paratransit, Inc. (a subcontractor of Access) and the driver, Carlos Juarez, Jr. Raphael did a write up after we obtained that verdict but I'll summarize everything. Facts On March 27, 2020, the Decedent, aged 61, was being brought home by Access following dialysis treatment. Upon arriving at his residence, the Decedent was released from the vehicle outside the residence in the street, and not on the curb, and left unattended by the driver. The driver placed the Decedent's bag on the pavement near an enormous pothole. As the Decedent was bending down to pick up his bag, he fell, hit his head in the pothole, fractured his neck at C2, was immediately rendered quadriplegic which threw him into a respiratory arrest followed by a cardiac arrest. Paramedics arrived on scene and were able to resuscitate him. Ultimately, he died on June 26, 2020. Liability Access is supposed to provide curb to curb transportation which basically means that after the rider exits the vehicle, Access is supposed to assist riders to the curb, at a minimum. In our case, they left him in the street. Moreover, the cause of the accident was placing the Decedent's bag on the ground instead of handing it to him or standing next to him when he picked it up. It is well known that dialysis patients suffer from dizziness, fatigue, and weakness following treatment. This is because for some patients, the treatment causes their blood pressure to drop substantially to the point that they become hypotensive. There is express ADA guidance on this topic that instructs paratransit operators like Access to provide Return Trip Assistance and escort the dialysis patient to the door of their location following dialysis treatment. When the Decedent underwent a physical evaluation as part of the eligibility process to become an Access rider, he complained of dizziness and fatigue following dialysis treatment. Moreover, the dialysis records from the date of the incident showed that he had 6 hypotensive episodes during treatment which resulted in treatment having to be stopped. During the liability trial, we argued that when he bent over to pick up his bag, he suffered a hypotensive event which caused him to become dizzy and fall and break his neck. We also put forward evidence that the driver did not follow the ADA guidance or much of the training procedure that was articulated in Access' materials. We also put forward evidence that the Decedent's evaluation indicated that he was designated as being eligible for Beyond the Curb service, which means that the driver should have known that the Decedent required additional assistance after treatment that would require the driver to escort him, as opposed to just letting him out of the vehicle and doing nothing else. Defense Liability Arguments Access argued that their driver did nothing wrong because, from their vantage point, the ride is concluded the moment that the person steps out of the paratransit vehicle and recognizes their surroundings. They also argued that the driver did provide assistance by merely standing by the Decedent as he got out of the vehicle to place his feet on the street. Additionally, the Decedent had a history of cardiac issues, including a prior cardiac arrest. The defense argued that the fall was caused by a cardiac arrest following dialysis treatment and that the Decedent would have fractured his neck regardless of where he fell. They also argued that the cardiac arrest resulted in a substantial amount of brain damaged due to lack of oxygen, which is really what caused him to be paralyzed until his death. Liability Experts Our liability experts were: * Dr. Jeffrey Goodman (Cardiologist) - Absolute rockstar. He did an outstanding job testifying and explained complex cardiac information in an accessible and persuasive way for the jury. During the work up, he was an incredible resource for us in evaluating the evidence and having a real mastery of the issues. * Dr. Barry Ludwig (Neurologist) - Raphael describes him as regal. I think he did a great job conveying our argument about how severe this neck fracture was and he really helped carry the day for us in Phase 1. * Dean McMillan (Paratransit Standard of Care) - It is really hard to find experts in this field and it was her first time being an expert because our prior expert unfortunately passed away. She was not great during deposition or trial and the defense beat her up pretty badly in both. Fortunately, we had so much good evidence without her that we were able to make our case without heavily relying on her. * Dr. Mamoo Nakamura (Treating Cardiologist) - He was the last cardiologist that the Decedent saw prior to the incident and he was able to provide us with testimony that he had no concerns about the condition of the Decedent's heart or an elevated risk of a sudden cardiac event leading into the date of the incident. * Dr. Hooshang Pak (Post-Incident Treating Neurosurgeon) - Very persuasive witness and conveyed very explicitly the severity of the neck fracture. * John Gardiner (Biomech) - He did great getting us over summary judgment but probably a wash during trial. The defense liability experts were: * Dr. Michael Chaikin (Cardiologist) - Like many defense experts, he took very extreme positions during his deposition and conveyed them arrogantly. He did the same song and dance during trial. He talks (or rambles) for a long time during his answers and, in my opinion, do not break the information down sufficiently to convey it to someone who has no idea what he is talking about. * Dr. Nirav Patel (Neurologist) - Dr. Patel was the treating Neurologist following the incident that the defense morphed into their expert. I thought he delivered the information well and he was a formidable expert for us to go up against. * John Brault (Biomech) - He is good but he is very abrasive and I think that backfired on them at trial. Liability Verdict The jury found Access, the subcontractor Global Paratransit, and the driver Carlos Juarez, Jr. each liable for the incident. They also found that Global was an agent of Access. The apportionment was 15% to Juarez, 40% for Global, and 45% for Access. Damages Phase Trial Our damages phase commenced on December 4, 2023. The judge (who I'll do a separate section on) dragged his feet on some MIL rulings and, as a result, some evidence that was ultimately excluded was referenced to the jury. As a result, following his favorable ruling for us and exclusion of evidence, a mistrial was declared on December 5, 2023. We empaneled a new jury on December 6, 2023 and kept trucking through our verdict yesterday. We represented all seven of the Decedent's children (wife pre-deceased). This family is incredible. The Decedent immigrated along with his wife from the Philippines, leaving five of their children behind to start a better life for them here in America. Slowly but surely, they were able to plant roots and bring all of their children here with them in the 1990s. They had two additional children here. For the vast majority of the Decedent's life, he was an MTA bus driver working insane hours to provide for his family. They are a very traditional family with strong family values, constantly focusing on each other and spending as much time together as possible. Each of their birthdays was a massive event that they always spent together, along with holidays and normal family gatherings. That tradition carried throughout their childhood and their adult lives. Our clients are all established and have their own children now but that did not stop them from constantly getting the family together. All but one of our clients lived no more than 15 minutes away from their father. The one child that lived in San Diego came up to Long Beach twice a month with her family to spend time with her father. Two of the children, one of whom is deaf and has some developmental limitations, lived with him in the family home and saw him every single day. The ones that did not live with him either saw their father every day, every other day, or every weekend. They were in constant communications with their father. We also conveyed that in the Filipino culture, reverence for elders is a massive deal. Each of our clients explained that they were looking forward to caring for their father in his elder years and valuing the time that they all had to spend with him. Having that taken from them so abruptly was absolutely devastating for them and we were able to bring that out to the jury. We had no less than 60 family photos and several family videos that we intended to use during our examinations. The judge initially limited us two photos and zero videos because he thought it was cumulative and prejudicial. After getting railroaded, we were able to find an additional handful of individual photos of our clients and their father that the judge ultimately let us use. As a tactical move, we counseled our clients to use the photos as memory triggers to tell stories about the photos without actually showing them to the jury. Our clients hit grand slams during their testimony. It was a very emotional trial but it was an authentic trial. In an unbelievable own-goal, the defense opened the door on the issue of one of the children facetiming the Decedent while he was on his deathbed which that child had recorded and we had marked as an exhibit. As a result, on re-direct, we were able to move that video into evidence which showed the condition of the Decedent a week before his death. It was very powerful evidence which the jury probably would not have seen otherwise. On the issue of life expectancy notwithstanding the incident, our experts were: * Dr. Jeffrey Goodman (Cardiologist) - Again, total rockstar. * Dr. Mamoo Nakamura (Pre-Incident Cardiologist) - Again, homerun. * Dr. George Hon (Treating Nephrologist) - Gave us what we needed that the Decedent's kidney was stable. The defense's only witness was Dr. Michael Chaikin. In a stroke of genius, Raphael obtained a transcript of Dr. Chaikin in another matter that showed that he was an expert in several matters testifying on behalf of the tobacco companies. We were able to get him to admit that during cross and, in our discussions with the jury following the verdict, that was really powerful evidence to get them to disregard his opinions. The Life Expectancy Tables said that a 61 year old man would have lived another 21 years. Obviously, we could not get around the issue that the Decedent had several comorbidities so we did not suggest to the jury that he would have lived that long. Dr. Goodman testified, from a cardiac perspective, the Decedent would have lived another 17 years. In closing, we argued that it would more reasonably have been 10. The defense took the position that he would have lived an additional six months to three years, an opinion that was admittedly rendered by Dr. Chaikin prior to him having the Decedent's complete medical records. Once he had the entire universe, which included records closer in time to the incident which showed that the Decedent's heart condition was improving and healthy, he doubled down and said those records did not change any of his opinions. We believed that opinion was going to be a really tough sell and we hammered him on cross. In the end, the jury awarded us $13,250,000 in past non-economic damages and $4,250,000 in future. Defense Firms The defense was represented by Kenton Moore of McCune & Harber for the overwhelming majority of the case. I really hesitate to cast aspersions towards anyone but I cannot have less respect for him than I do. His tactics are full blown scorched earth and he obstructed us at every moment, in every way, and at all times during the work up for this case. Before joining this office, I cut my teeth as a trial attorney handling complex business litigation so I am used to heavy law and motion but this case generated more law and motion and more MILs than I have ever seen. During trial, he is even worse. He habitually objects to basically everything during testimony, resulting in a lot of breaks in the action to argue with the judge about the evidence. He pretends as though he has never seen any evidence even though we proved, multiple times, that the evidence was exchanged and that he had seen it. He will agree to things in the halls of the court and then come before the judge and pretend like he didn't agree to anything. To put it bluntly: he is a snake, a liar, a cheater, a bully, and an absolute nightmare to work with. Anyone who litigates against him should be prepared to devote countless hours and energy into the case to bodyslam him. Do not give him a single inch. You should also not trust a single thing that comes out of his mouth because it isn't worth the energy that it takes your ears and brain to process the words. The upside is that his hardheadedness backfires spectacularly at trial. He is not impressive and in fact, he is repulsive and the results demonstrate that. Anyone who tries a case against him should be mentally prepared to deal with a lot of frustration but to remain calm, patient, and charming. He does everything he can to get under your skin, which he is very effective at, but you cannot let it get to you and you cannot reward him by reacting to his trash tactics. I could write a dissertation on this jabroni and I am happy to speak with anyone over the phone about how we handled him and how anyone with any active case against him should handle him going forward. For the damages phase, Michael Schonbuch of Daniels Fine associated into the case. Frankly, I wish that the entire case was worked up with him because we had a solid working relationship and I have only positive things to say about working with him for the short period of time that we did. He is a class act, very professional, and a strong advocate who did the best he could trying to get up to speed on a massive file. He also relegated Kenton to backbench because it was obvious that Kenton's general disposition was a huge liability for them. The Judge I don't know how valuable any of this information will be because Judge Fruin is quite old so I would anticipate that his stay on the bench might not be too much longer. In any event, Judge Fruin is tough. We were in his courtroom a lot during the work up and he was absolutely brutal on me as I was the face of the operation for much of the law and motion. He is temperamental as well. Be prepared to take a lot of heat but if you stand your ground and keep pushing and advocating, the ball will bounce your way. Your briefs need to be concise, well researched, and articulated very clearly. During argument, you also need to convey to him how critical certain issues are to the case in order to get the rulings you need. Our estimation is that he may have come to regret bifurcating the trial but he really tied our hands a lot throughout both phases. Anyone in his courtroom needs to be adequately prepared to adjust your gameplan on the fly. All of that being said, during examinations, he let us put on our cases. On balance, he overruled substantially more of the defense objections than he sustained. I think he is really tough on the plaintiffs side of the table and I think that can rub a lot of plaintiffs lawyers the wrong way about him maybe having a bias. I do not think he was biased. If anything, the learning lesson that I took from this experience is that he will force us as plaintiffs lawyers to not be lazy and to make sure that, if we are to be successful, we need to do it right so that the victory is as iron clad as possible. Thoughts and Musings This is obviously a great result for the case and we learned a lot working it up and trying both phases. I think the biggest takeaway for me is how important it is to believe in the strength of your case and the work. No case that is tried is perfect but if you are able to put forward an authentic explanation of your case, I am of the firm belief that the jury will buy it. I know Raphael was in constant communication with many of you during both phases asking for advice. I don't know all of you by name but we want to convey our sincere gratitude for your support and assistance in helping us navigate this case. One more for the good guys. Andrew A. Talebi, Esq. ' Attorney THE JAVID TRIAL FIRM, PC 11740 San Vicente Boulevard, Suite 109, #576 Los Angeles, California 90049 T: 310.929.9132 ' F: 310.929.9133 https://www.thejtf.com This e-mail, and any attachments thereto, is intended only for use by the addressee(s) named herein and may contain legally privileged and or confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this e-mail in error, please immediately notify the sender by telephone at (310) 929-9130 or by return e-mail, and permanently delete the original and any copy of this message, its attachments, and any printout thereof. Unauthorized use, dissemination or reproduction of this message is strictly prohibited and may be unlawful. Thank you.
AI Analysis:
This message is about a $17.5 million wrongful death verdict in a civil case litigated before Judge Richard Fruin in Department 15 of Stanley Mosk courthouse. The judge 'goodman' is not mentioned anywhere in this message. The message contains no information about goodman whatsoever and is entirely unrelated to evaluating goodman as a workers' compensation judge.
"Andrew Talebi" Date: December 13, 2023 1:41:00 PM Subject: $17.5 MILLION WRONGFUL DEATH VERDICT REPORT Reply to list Reply to sender Print List: caala-workproduct Sent by: Andrew Talebi (Reply Privately) Search Friends: We are happy to report that Raphael Javid and myself have, after almost 4 years of an absolute battle, brought home a $17,500,000 verdict in a wrongful death matter in Los Angeles. The case is called Guillermo Aviles, Jr., et al. v. Access Services, et al. and was litigated in Department 15 of Stanley Mosk before Judge Richard Fruin. The trial was bifurcated into liability and damages about a year ago and we obtained a successful liability verdict on May 31, 2023 against Access Services, Global Paratransit, Inc. (a subcontractor of Access) and the driver, Carlos Juarez, Jr. Raphael did a write up after we obtained that verdict but I’ll summarize everything. Facts On March 27, 2020, the Decedent, aged 61, was being brought home by Access following dialysis treatment. Upon arriving at his residence, the Decedent was released from the vehicle outside the residence in the street, and not on the curb, and left unattended by the driver. The driver placed the Decedent’s bag on the pavement near an enormous pothole. As the Decedent was bending down to pick up his bag, he fell, hit his head in the pothole, fractured his neck at C2, was immediately rendered quadriplegic which threw him into a respiratory arrest followed by a cardiac arrest. Paramedics arrived on scene and were able to resuscitate him. Ultimately, he died on June 26, 2020. Liability Access is supposed to provide curb to curb transportation which basically means that after the rider exits the vehicle, Access is supposed to assist riders to the curb, at a minimum. In our case, they left him in the street. Moreover, the cause of the accident was placing the Decedent’s bag on the ground instead of handing it to him or standing next to him when he picked it up. It is well known that dialysis patients suffer from dizziness, fatigue, and weakness following treatment. This is because for some patients, the treatment causes their blood pressure to drop substantially to the point that they become hypotensive. There is express ADA guidance on this topic that instructs paratransit operators like Access to provide Return Trip Assistance and escort the dialysis patient to the door of their location following dialysis treatment. When the Decedent underwent a physical evaluation as part of the eligibility process to become an Access rider, he complained of dizziness and fatigue following dialysis treatment. Moreover, the dialysis records from the date of the incident showed that he had 6 hypotensive episodes during treatment which resulted in treatment having to be stopped. During the liability trial, we argued that when he bent over to pick up his bag, he suffered a hypotensive event which caused him to become dizzy and fall and break his neck. We also put forward evidence that the driver did not follow the ADA guidance or much of the training procedure that was articulated in Access’ materials. We also put forward evidence that the Decedent’s evaluation indicated that he was designated as being eligible for Beyond the Curb service, which means that the driver should have known that the Decedent required additional assistance after treatment that would require the driver to escort him, as opposed to just letting him out of the vehicle and doing nothing else. Defense Liability Arguments Access argued that their driver did nothing wrong because, from their vantage point, the ride is concluded the moment that the person steps out of the paratransit vehicle and recognizes their surroundings. They also argued that the driver did provide assistance by merely standing by the Decedent as he got out of the vehicle to place his feet on the street. Additionally, the Decedent had a history of cardiac issues, including a prior cardiac arrest. The defense argued that the fall was caused by a cardiac arrest following dialysis treatment and that the Decedent would have fractured his neck regardless of where he fell. They also argued that the cardiac arrest resulted in a substantial amount of brain damaged due to lack of oxygen, which is really what caused him to be paralyzed until his death. Liability Experts Our liability experts were: Dr. Jeffrey Goodman (Cardiologist) – Absolute rockstar. He did an outstanding job testifying and explained complex cardiac information in an accessible and persuasive way for the jury. During the work up, he was an incredible resource for us in evaluating the evidence and having a real mastery of the issues. Dr. Barry Ludwig (Neurologist) – Raphael describes him as regal. I think he did a great job conveying our argument about how severe this neck fracture was and he really helped carry the day for us in Phase 1. Dean McMillan (Paratransit Standard of Care) – It is really hard to find experts in this field and it was her first time being an expert because our prior expert unfortunately passed away. She was not great during deposition or trial and the defense beat her up pretty badly in both. Fortunately, we had so much good evidence without her that we were able to make our case without heavily relying on her. Dr. Mamoo Nakamura (Treating Cardiologist) – He was the last cardiologist that the Decedent saw prior to the incident and he was able to provide us with testimony that he had no concerns about the condition of the Decedent’s heart or an elevated risk of a sudden cardiac event leading into the date of the incident. Dr. Hooshang Pak (Post-Incident Treating Neurosurgeon) – Very persuasive witness and conveyed very explicitly the severity of the neck fracture. John Gardiner (Biomech) – He did great getting us over summary judgment but probably a wash during trial. The defense liability experts were: Dr. Michael Chaikin (Cardiologist) – Like many defense experts, he took very extreme positions during his deposition and conveyed them arrogantly. He did the same song and dance during trial. He talks (or rambles) for a long time during his answers and, in my opinion, do not break the information down sufficiently to convey it to someone who has no idea what he is talking about. Dr. Nirav Patel (Neurologist) – Dr. Patel was the treating Neurologist following the incident that the defense morphed into their expert. I thought he delivered the information well and he was a formidable expert for us to go up against. John Brault (Biomech) – He is good but he is very abrasive and I think that backfired on them at trial. Liability Verdict The jury found Access, the subcontractor Global Paratransit, and the driver Carlos Juarez, Jr. each liable for the incident. They also found that Global was an agent of Access. The apportionment was 15% to Juarez, 40% for Global, and 45% for Access. Damages Phase Trial Our damages phase commenced on December 4, 2023. The judge (who I’ll do a separate section on) dragged his feet on some MIL rulings and, as a result, some evidence that was ultimately excluded was referenced to the jury. As a result, following his favorable ruling for us and exclusion of evidence, a mistrial was declared on December 5, 2023. We empaneled a new jury on December 6, 2023 and kept trucking through our verdict yesterday. We represented all seven of the Decedent’s children (wife pre-deceased). This family is incredible. The Decedent immigrated along with his wife from the Philippines, leaving five of their children behind to start a better life for them here in America. Slowly but surely, they were able to plant roots and bring all of their children here with them in the 1990s. They had two additional children here. For the vast majority of the Decedent’s life, he was an MTA bus driver working insane hours to provide for his family. They are a very traditional family with strong family values, constantly focusing on each other and spending as much time together as possible. Each of their birthdays was a massive event that they always spent together, along with holidays and normal family gatherings. That tradition carried throughout their childhood and their adult lives. Our clients are all established and have their own children now but that did not stop them from constantly getting the family together. All but one of our clients lived no more than 15 minutes away from their father. The one child that lived in San Diego came up to Long Beach twice a month with her family to spend time with her father. Two of the children, one of whom is deaf and has some developmental limitations, lived with him in the family home and saw him every single day. The ones that did not live with him either saw their father every day, every other day, or every weekend. They were in constant communications with their father. We also conveyed that in the Filipino culture, reverence for elders is a massive deal. Each of our clients explained that they were looking forward to caring for their father in his elder years and valuing the time that they all had to spend with him. Having that taken from them so abruptly was absolutely devastating for them and we were able to bring that out to the jury. We had no less than 60 family photos and several family videos that we intended to use during our examinations. The judge initially limited us two photos and zero videos because he thought it was cumulative and prejudicial. After getting railroaded, we were able to find an additional handful of individual photos of our clients and their father that the judge ultimately let us use. As a tactical move, we counseled our clients to use the photos as memory triggers to tell stories about the photos without actually showing them to the jury. Our clients hit grand slams during their testimony. It was a very emotional trial but it was an authentic trial. In an unbelievable own-goal, the defense opened the door on the issue of one of the children facetiming the Decedent while he was on his deathbed which that child had recorded and we had marked as an exhibit. As a result, on re-direct, we were able to move that video into evidence which showed the condition of the Decedent a week before his death. It was very powerful evidence which the jury probably would not have seen otherwise. On the issue of life expectancy notwithstanding the incident, our experts were: Dr. Jeffrey Goodman (Cardiologist) – Again, total rockstar. Dr. Mamoo Nakamura (Pre-Incident Cardiologist) – Again, homerun. Dr. George Hon (Treating Nephrologist) – Gave us what we needed that the Decedent’s kidney was stable. The defense’s only witness was Dr. Michael Chaikin. In a stroke of genius, Raphael obtained a transcript of Dr. Chaikin in another matter that showed that he was an expert in several matters testifying on behalf of the tobacco companies. We were able to get him to admit that during cross and, in our discussions with the jury following the verdict, that was really powerful evidence to get them to disregard his opinions. The Life Expectancy Tables said that a 61 year old man would have lived another 21 years. Obviously, we could not get around the issue that the Decedent had several comorbidities so we did not suggest to the jury that he would have lived that long. Dr. Goodman testified, from a cardiac perspective, the Decedent would have lived another 17 years. In closing, we argued that it would more reasonably have been 10. The defense took the position that he would have lived an additional six months to three years, an opinion that was admittedly rendered by Dr. Chaikin prior to him having the Decedent’s complete medical records. Once he had the entire universe, which included records closer in time to the incident which showed that the Decedent’s heart condition was improving and healthy, he doubled down and said those records did not change any of his opinions. We believed that opinion was going to be a really tough sell and we hammered him on cross. In the end, the jury awarded us $13,250,000 in past non-economic damages and $4,250,000 in future. Defense Firms The defense was represented by Kenton Moore of McCune & Harber for the overwhelming majority of the case. I really hesitate to cast aspersions towards anyone but I cannot have less respect for him than I do. His tactics are full blown scorched earth and he obstructed us at every moment, in every way, and at all times during the work up for this case. Before joining this office, I cut my teeth as a trial attorney handling complex business litigation so I am used to heavy law and motion but this case generated more law and motion and more MILs than I have ever seen. During trial, he is even worse. He habitually objects to basically everything during testimony, resulting in a lot of breaks in the action to argue with the judge about the evidence. He pretends as though he has never seen any evidence even though we proved, multiple times, that the evidence was exchanged and that he had seen it. He will agree to things in the halls of the court and then come before the judge and pretend like he didn’t agree to anything. To put it bluntly: he is a snake, a liar, a cheater, a bully, and an absolute nightmare to work with. Anyone who litigates against him should be prepared to devote countless hours and energy into the case to bodyslam him. Do not give him a single inch. You should also not trust a single thing that comes out of his mouth because it isn’t worth the energy that it takes your ears and brain to process the words. The upside is that his hardheadedness backfires spectacularly at trial. He is not impressive and in fact, he is repulsive and the results demonstrate that. Anyone who tries a case against him should be mentally prepared to deal with a lot of frustration but to remain calm, patient, and charming. He does everything he can to get under your skin, which he is very effective at, but you cannot let it get to you and you cannot reward him by reacting to his trash tactics. I could write a dissertation on this jabroni and I am happy to speak with anyone over the phone about how we handled him and how anyone with any active case against him should handle him going forward. For the damages phase, Michael Schonbuch of Daniels Fine associated into the case. Frankly, I wish that the entire case was worked up with him because we had a solid working relationship and I have only positive things to say about working with him for the short period of time that we did. He is a class act, very professional, and a strong advocate who did the best he could trying to get up to speed on a massive file. He also relegated Kenton to backbench because it was obvious that Kenton’s general disposition was a huge liability for them. The Judge I don’t know how valuable any of this information will be because Judge Fruin is quite old so I would anticipate that his stay on the bench might not be too much longer. In any event, Judge Fruin is tough. We were in his courtroom a lot during the work up and he was absolutely brutal on me as I was the face of the operation for much of the law and motion. He is temperamental as well. Be prepared to take a lot of heat but if you stand your ground and keep pushing and advocating, the ball will bounce your way. Your briefs need to be concise, well researched, and articulated very clearly. During argument, you also need to convey to him how critical certain issues are to the case in order to get the rulings you need. Our estimation is that he may have come to regret bifurcating the trial but he really tied our hands a lot throughout both phases. Anyone in his courtroom needs to be adequately prepared to adjust your gameplan on the fly. All of that being said, during examinations, he let us put on our cases. On balance, he overruled substantially more of the defense objections than he sustained. I think he is really tough on the plaintiffs side of the table and I think that can rub a lot of plaintiffs lawyers the wrong way about him maybe having a bias. I do not think he was biased. If anything, the learning lesson that I took from this experience is that he will force us as plaintiffs lawyers to not be lazy and to make sure that, if we are to be successful, we need to do it right so that the victory is as iron clad as possible. Thoughts and Musings This is obviously a great result for the case and we learned a lot working it up and trying both phases. I think the biggest takeaway for me is how important it is to believe in the strength of your case and the work. No case that is tried is perfect but if you are able to put forward an authentic explanation of your case, I am of the firm belief that the jury will buy it. I know Raphael was in constant communication with many of you during both phases asking for advice. I don’t know all of you by name but we want to convey our sincere gratitude for your support and assistance in helping us navigate this case. One more for the good guys. Andrew A. Talebi, Esq. | Attorney THE JAVID TRIAL FIRM, PC 11740 San Vicente Boulevard, Suite 109, #576 Los Angeles, California 90049 T: 310.929.9132 | F: 310.929.9133 https://www.thejtf.com This e-mail, and any attachments thereto, is intended only for use by the addressee(s) named herein and may contain legally privileged and or confidential information. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution or copying of this e-mail, and any attachments thereto, is strictly prohibited. If you have received this e-mail in error, please immediately notify the sender by telephone at (310) 929-9130 or by return e-mail, and permanently delete the original and any copy of this message, its attachments, and any printout thereof. Unauthorized use, dissemination or reproduction of this message is strictly prohibited and may be unlawful. Thank you.
AI Analysis:
This message contains no mention of Judge Goodman whatsoever. It is an email signature block and boilerplate legal disclaimer from attorney Steve Hilst at BestAttorney.com, with no substantive content visible beyond the closing salutation and firm contact information. The subject line references a 'WD Liability Verdict Against Access Services' but contains no discussion of any judge, let alone Goodman. There is no information useful for evaluating this judge.
Sincerely, Steve Hilst Partner www.BestAttorney.com Superior Client Representation Since 1978. 1301 Dove Street, STE 120 | Newport Beach, CA 92660 www.BestAttorney.com 800.956.0123 | 949.752.2999 | 949.752.2777 fax PRIVILEGED/CONFIDENTIAL COMMUNICATION: This email and all attachments are intended SOLELY for the recipients as identified in the "To," "CC" and "BCC" lines of this email. If you are not one of the identified intended recipients, your receipt of this email and its attachments is the result of an inadvertent disclosure or unauthorized transmittal. If you are not the one of the identified intended recipients, any dissemination, distribution, storing, sharing, or copying of this communication is strictly prohibited. If you have received this communication in error, please notify the sender immediately by telephone and destroy all copies of this message. No waiver of any privilege or work product protection is intended by the accidental distribution or disclosure of this message. NOTICE: NO DUTIES ARE ASSUMED, INTENDED, OR CREATED BY THIS COMMUNICATION. If you have not executed a fee contract, this firm does NOT represent you as your attorney. You are encouraged to retain counsel of your choice if you desire to do so.
AI Analysis:
This message is about a liability verdict in Dept 15 before Judge Fruin, not Judge Goodman. The message contains no mention of Judge Goodman whatsoever. It is entirely about a workers' compensation/personal injury case against Access Services tried before Judge Fruin, who is described as 'tough but fair.' There is no information relevant to evaluating Judge Goodman.
Raphael Javid Date: June 01, 2023 5:13:00 PM Subject: WD Liability Verdict Against Access Services Reply to list Reply to sender Print List: caala-workproduct Sent by: Raphael Javid (Reply Privately) Search Hey everyone just wanted to report a unanimous WD liability verdict we got yesterday in Dept 15 Judge Fruin’s courtroom against Access Services after a two week bifurcated trial. Judge Fruin was tough but fair. I tried the case with Andrew Talebi from my office who did great. Here’s some of the relevant details. FACTS: As many of you know Access Services is a public entity managed by the County of Los Angeles that provides ADA paratransit transportation for disabled people. Our client Guillermo Aviles was a 60 year old dialysis patient who used Access to go to and from his dialysis treatments. On March 27, 2020 after being picked up from dialysis the Access driver dropped him in front of his home in Long Beach. Before Mr. Aviles exited the Access van from the passenger side he asked the driver to assist him with his bag which the driver did by taking his bag and placing it on the ground in the street a few feet away from the sidewalk. Thereafter Mr. Aviles exited the van and bent over to pick up his bag for about 8 seconds during which the Access driver closed the door to the Access van and proceeded to walk past him back to the driver door to leave to his next appointment. As the Access driver opened his driver door to leave Mr. Avliles fell forward fracturing his neck rendering him quadriplegic. He died 3 months later in the hospital. LIABILITY: Access is a supposed to provide ‘curb to curb’ transportation which basically means after the rider exits the vehicle they are at a minimum supposed to assist riders to the curb. In this particular case they left him in the street. Moreover the cause of the accident was placing Mr. Aviles bag on the ground instead of handing it to him or at a minimum standing next to him while he picked it up. It is well known that dialysis patients suffer from dizziness, fatigue and weakness after dialysis treatment. This is because for some dialysis patients the treatment causes their blood pressure to drop substantially to the point they become hypotensive meaning their systolic blood pressure drops below 90. There is actually federal ADA guidance on this topic that instructs paratransit operators like Access that they need to give return trip assistance to the door of a dialysis patients home after dialysis appointments. When Mr. Aviles was evaluated by Access to become a rider he complained that he suffered from dizziness and fatigue after dialysis. Moreover the dialysis records from the day of the accident showed that he had 6 hypotensive blood pressure recordings and the treatment had to be stopped due to hypotension. So essentially we argued that when he bent over to pick up his bag on the ground he suffered a hypotensive event which caused him to become dizzy and fall over breaking his neck. DEFENSE ARGUMENTS Access was represented by Kenton Moore of McCune and Harber who took a very aggressive stance on this case. They argued that Mr. Aviles did not have a hypotensive event but rather suffered a sudden cardiac event prior to falling due to the fact that when the paramedics found him in the street he had suffered a cardiac arrest and he had a previous cardiac history. Accordingly they argued that regardless of the neck fracture he would have died from the cardiac event anyways. They also argued that ‘curb to curb’ does not literally mean curb to curb and that they can drop off riders in the street. DEFENSE TACTICS I’ve handled a lot of public entity cases and quite frankly I’ve never encountered the level of obstructionism that Kent Moore did in this case. He coached witnesses in depos, made so many frivolous speaking objections that witnesses would routinely forget the questions, and would instruct his witnesses not to answer every critical question in the case. He was extremely unprofessional throughout the entire case yet tried to put on a different face for the jury which the jury saw right through. Personally my experience with unprofessional defense counsel is that it always backfires and it did in this case. TRIAL In total there were about 20 witnesses. With respect to the standard of care we were able to use their Access’ policies and procedures to establish that they didn’t follow their own protocols. Every Access vehicle has cameras both inside and outside the vehciles so it was clearly apparent what had happened. As for the causation/cardiac arrest issue we were able to establish that the neck fracture that decedent suffered caused a severe spinal cord contusion frorm C1-C4 which cut off the decedent’s ability to breathe and is what caused the cardiac arrest the deceent suffered post accident. We were able to prove that had the fall never happened there would have been no post accident cardiac event. PLAINTIFF’S EXPERTS Dr. Barry Ludwig, Neuro – who was great at trial and has a very regal presence about him. Dr. Jeffrey Goodman, Cardiologist – who was also great behind the scenes evaluating the evidence and figuring out the causation for the cardiac arrest. Dean McMillian, Paratransit expert – this was her first time testifying as an expert and it showed. The defense was able to beat her up pretty bad at deposition however we were able to prove our case without having to rely on her opinions so it didn’t make a diference. Our previous paratransit expert died two months prior to trial so we had to scramble last minute to find an expert and bring them up to speed. Dr. Nakamoora – treating cardiologist at Cedars. Dr. Houshang Pak – treating neursurgeon at Long Beach Memorial Hospital whom was very credible. DEFENSE EXPERTS Dr. Michael Chaikin, Nardiologist – He got a lot of things wrong and seemed like an advocate Dr. Nirav Patel, Neurologist – was a treating physician that the defense elevated to a retained expert. He also got a lot of things wrong and seemed like an advocate. BIFURCATED VERDICT: The Access driver actually works for a company called Global Paratransit that contracts with Access to provide their transportion. The jury found that Global Paratransit was an agent of Access so they are going to be responsible for the entire verdict but the apportionment was as follows: Carlos Juarez (Driver) - 15% Global Paratransit - 40% Access Services - 45% This was a really complicated case and there’s a ton of details that I’m leaving out. Our clients are the 7 adult children of the decedent who now will have an opportunity to show the jury the measure and value of their lost father in the damages trial hopefully in a few months. I hope to report back with good news at that time. Until then keep up the good fight and don’t let anyone or anything stand in your way. RAPHAEL JAVID THE JAVID TRIAL FIRM, PC thejtf.com
AI Analysis:
This message is entirely about David Wright, not about the judge 'goodman'. The message contains no mention of goodman whatsoever. It discusses David Wright's qualifications, personality, and a recommendation from Raffi Ohanian based on their professional history together at Wood Smith Henning & Berman.
I agree with Keith..I too have known David Wright for about 15 years and worked with him at Wood Smith Henning & Berman before I switched over to Thon Beck. He is one of the nicest guys out there, extremely smart and really understands cases objectively. I would recommend him.
AI Analysis:
This message makes no mention of 'goodman' in any form. It is entirely about David Wright, a mediator/arbitrator with a background in defense and plaintiff work. The message contains no information about the judge being evaluated.
Darla, I have known David Wright for over 25 years. When I first met him, he was defense counsel for LaFollette, etc and I tried my first med mal case against him. Years later he started doing Plaintiff work and I would see him at CAALA and we got to know each other better. I would give Steven Heimberg a call because I know he worked in his office for a while. Eventually, David went back to the defense side for reasons that I believe were truly economic. Several years back, he called me to let me know he was going to start doing mediations (initially I think he wanted to be a judge but that did not work out). What I can say for sure is that he will understand the medical issues. He will know bogus defenses if they raise their ugly head in your case. I would like to believe David is fair, but I honestly do not know for sure. There is a Plaintiff's bone in his body for sure. Keith Landrum, D.P.M., J.D. LANDRUM LAW FIRM, LLP 8840 Wilshire Blvd., Suite 321 Beverly Hills, CA 90211 landrumlawllp.com 323-292-4262 323-443-3648 fax Privileged And Confidential Communication. This electronic transmission and any documents attached hereto, (a) are protected by the Electronic Communications Privacy Act (18 USC §§ 2510-2521), (b) may contain confidential and/or legally privileged information, and (c) is for the sole use of the intended recipient named above. If you have received this electronic message in error, please notify the sender and delete the electronic message. Any disclosure, copying, distribution, or use of the contents of the information received in error is strictly prohibited.
AI Analysis:
This message contains no mention of 'goodman' whatsoever. It is entirely about a different judge, David Horowitz, and describes an experience involving a motion to dismiss in a criminal case. There is no connection to the judge being evaluated.
Here is my experience with David Horowitz, once a Deputy Public Defender who became a judge. I represented a fellow, on appeal, who reached an agreement with the prosecutor that if my client passed a polygraph test, the prosecution would drop the case against my client. My client passed the polygraph and the prosecutor moved to dismiss the case, which was in Horowitz' court. Horowitz refused to grant the motion to dismiss. Client was then tried and convictec.
AI Analysis:
This message does not mention 'goodman' at all. It discusses a judge named 'Tarle' in the context of proposed arbitrators, describing the sender's impression of Tarle as a Santa Monica trial judge. There is no reference to goodman by any name variation, and no information that would help evaluate goodman as a judge.
I have arbitrated with none of them. I was impressed with Tarle when he was a Santa Monica trial judge, and had one trial before him. He is fairly recently retired, I believe.
AI Analysis:
This message does not mention Judge Goodman at all. It is an email exchange between attorneys on a CAALA listserver discussing Motions in Limine (MILs) related to a civil trial, including topics like Reptile theory, the Affordable Care Act, and expert witnesses. There is no reference to Judge Goodman, any workers' compensation proceedings, or any judge by that name. The message is entirely unrelated to evaluating Judge Goodman.
Attached are opps to the MIL on Reptile and other documents that can help you on the issue. Good luck MARK IODICE TRIAL LAWYER Licensed in CA, CO, and WA Carpenter & Zuckerman 8827 W. Olympic Boulevard, Beverly Hills, CA 90211 T 310-273-1230 F 310-858-1063 www.cz.law On Fri, Jan 6, 2023 at 12:05 PM Bradley Kramer (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: Bradley Kramer (Reply Privately) Search Hey mates…. Does anyone have an opposition to the following MIL’s filed by Defendants: 1. To permit interaction of reference of the Affordable Care Act 2. To preclude expert witness evidence from non-designated experts 3. To preclude personal medical treatment preferences 4. To preclude reference to Reptile theory 5. To prohibit comments on defendants decision not to call certain witnesses Any help much appreciated. Thanks, BK Best Regards, Bradley I. Kramer, M.D., Esq. biklaw. trial attorneys Medical Malpractice · Personal Injury · Business Litigation 8840 Wilshire Blvd., Suite 350 / Beverly Hills, CA 90211 Tel: (424)-INJURED / (310) 289-2600 / Fax: (866) 289-2771 bkramer@biklaw.com / www.biklaw.com When Having a Great Lawyer Isn't Enough. ®
AI Analysis:
This message thread discusses judges Bruguera, Friedman, and Jill Sperber, with attorney opinions about those judges. There is no mention of 'goodman' anywhere in the message. The content is entirely about other judges and an unrelated UM arbitration case.
Joseph Johnson Date: October 11, 2022 6:13:00 PM Subject: Re: Arbitrator List Reply to list Reply to sender Print List: caala-workproduct Sent by: Joseph Johnson (Reply Privately) Search BIG NO to Friedman. Joseph Johnson, Esq. Law Offices of Joseph Johnson 4929 Wilshire Blvd., Suite 603 Los Angeles, CA 90010 (323) 736-1LAW (1529) ---- On Tue, 11 Oct 2022 16:08:11 -0700 Sherif El Dabe (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> wrote --- List: caala-workproduct Sent by: Sherif El Dabe (Reply Privately) Search No to Jill Sperber. S Edmond El Dabe ELDABE | RITTER TRIAL LAWYERS P 213-985-1120 F 213-985-1125 On Mon, Sep 19, 2022 at 8:57 PM David Shapiro (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: David Shapiro (Reply Privately) Search List mates: Let me add a little more to my post about judge Bruguera. I was before her many years ago and she was first rate. For this reason, I did not hesitate to agree to her for my UM arbitration. So that it does not appear that am guilty of sour grapes let me elaborate on the subject. The case is 5 years old, involves a young Arminian woman, an esthetician who stands 6 to 8 hours a day. Except for her name, if you met my client, you would think she was an attractive woman without a trace of an accent who gives the cultural appearance of a valley girl. The claim involved a minor rear end impact. In the 1990’s and over a period of 10 years, my client was involved in 3 non-fault “soft-tissue” rear end accidents, all of which settled without litigation. We know this because those accidents were identified in a history to a 2003 workers comp claim involving an aggravation of her cervical complaints. Nothing involving her right hip. From 2003 until March 2017, nearly 12 years she had no neck or back complaints. In 2013 her right hip began bothering her after a yoga class. She went to a chiropractor who treated her and gave her exercises. She testified she went to him twice and performed the exercises. Thereafter no hip problems for three years. After her 2017 accident she had minor neck and back complaints which eventually resolved. However, she began to have pain in her right hip. She went to a chiropractor, named Mike Hagopian for 16 weeks. (How State Farm Treats Armenian Claimants with Arminian doctors is a story for another day). She was then referred to Jacob Tauber for her hip problem. This was before Dr. Tauber became known as an admitted felon. This was my last case with Dr. Tauber who us older attorneys considered the darling of both the plaintiff’s and defense bar for over 30 years. Tauber testified at the hearing via zoom. I confess that it did not help to have him testify that he was at home under house arrest. He was embarrassed but testified bravely. However, what ever his misconduct, it had nothing to do with is medical treatment. Tauber diagnosed my client’s hip condition as piriformis syndrome. This is a condition of the piriformis muscle (a swelling or other injury) which causes an impingement of the sciatic nerve and radiculopathy. It often appears as lumbar sciatica caused by a disc disruption. Tauber ordered an MRI to rule out a lumbar pathology. When that proved negative, he ordered an ultrasound which disclosed an edema of the right piriformis muscle and confirmed the radiculopathy via an EMG. Two of the three experts, Lieu (radiology) Rosen (orthopedics) all testified that these tests were necessary. Malar the crackpot chiropractor said no test was necessary because he, with his superior knowledge of chiropractic medicine could analyze and treat my client without necessity of any medical diagnoses or treatment. And even though my client had no accidents, medical treatment for neck and back complaints for over 12 years before the accident, he testified that she was symptomatic with these complaints at the time of the incident. Notwithstanding these objective findings all three defense experts testified that she had low back pathology due to the accidents from 12 years before and that her 2017 accident had nothing to do with her need for medical treatment she underwent due to the rear end accident. My client testified she never had a problem with her hip for 12 years before the accident and no problems for 3 years after her two visits to the chiropractor in 2013. Tauber diagnosed my client’s injury as an aggravation of a pre-existing propensity to the condition due to her visit with the chiropractor 3 years before, and that her condition was chronic. The three experts basically testified she was symptomatic at the time of the incident, that this was a nothing burger injury which would have healed in 3 to 6 weeks with standard PT. Due to the delays caused by her many bathroom breaks, the hearing went from 4 to 6 hours, and because of that, Bruguera forced us to do our closings in writing. During the hearing, defense counsel was all over Tauber about his felony conviction and forced him to admit that he was testifying from his home on house arrest. He virtually ignored all other empirical evidence which supported Tauber’s testimony or contradicted his experts. Defense counsel also extolled Dr. Rosen as a paragon of spine surgery and the founder of some medical ethics society, although I caught him openly lying during the hearing, a matter I brought to the attention of judge Bruguera who ignored this fact and who resolved all objections by repeatedly saying you boys stop fighting “you are arguing before a judge, not a jury.” During his case in chief and in his closing, defense counsel spent most of his argument condemning Tauber as a felon and therefore should not be believed while praising the eminent Dr. Rosen as a god of spine surgery. I should point out the Rosen repeatedly testifies that he is a spine surgeon, and any other medical practitioner is something, well, less. In her written award Bruguera ignored any evidence of objective injury, whether it came from Tauber or the defense experts. The defense experts testified that the tests Tauber ordered to determine my client’s condition were justified. Tauber testified that the therapy she received from her chiropractor as reasonable and necessary. While I thought that there was a possibility that Bruguera would not give away the farm on general damages, I thought she would at least acknowledge the 16 weeks of treatment, pain, and suffering, and the cost my client’s medical specials. Based on my experience with her, I refused to believe that she would paint my client’s case with Tauber’s misconduct. I was dead wrong. I did not anticipate her petty animus towards Tauber. Judge Bruguera justified her minuscule award by spending nearly the entirety of her written award castigating Tauber’s credibility as a physician and bought lock, stock, and barrel everything defense counsel wrote in his closing about Tauber, while extoling the ever-arrogant Dr. Charles Rosen, who is as deep a snake as any you will ever encounter. She virtually ignored any evidence of my client’s injury in favor of her very lucrative benefactor State Farm. Ok, list mates, if you think this is sour grapes so be it. I can handle the disappointment in both Bruguera and her award. I lost plenty on depositions and the hearings but that is the nature of our profession and in the scheme of things have done very well this year, so I’ve moved on. I will certainly take nothing from this case and give my client the entirety of Bruguera’s paltry award. If you want to make an insurance carrier happy, by all means chose Judge Bruguera for your next UM or UIM case. I am certain defense counsel and the carriers they represent will be more than happy to oblige you. David B. Shapiro From: Soheil Bahari (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Friday, September 9, 2022 1:10 PM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: [caala-workproduct] Arbitrator List List: caala-workproduct Sent by: Soheil Bahari (Reply Privately) Search Dear All, Defense is proposing the following arbitrators for a UIM case. Your opinions would be greatly appreciated. Thomas Friedman; Christopher Warner; Mitchell Green; Christopher Conway; Frederick Aguirre; Alan Goodman; Jill Sperber; Darrell Forgey; Martin Handweiler; and Suzanne Bruguera.
AI Analysis:
This message makes no mention of 'goodman' whatsoever. It is solely about an arbitrator named Jill Sperber, with attorney S Edmond El Dabe expressing a negative opinion ('No to Jill Sperber'). There is no information about the judge being evaluated.
No to Jill Sperber. S Edmond El Dabe ELDABE | RITTER TRIAL LAWYERS P 213-985-1120 F 213-985-1125
AI Analysis:
This message does not mention 'goodman' at all. It is entirely about Judge Bruguera, a UM arbitration case involving an Armenian client with hip and neck injuries, Dr. Tauber, and State Farm's handling of Armenian claimants. There is no reference to Judge Goodman in any form.
"David Shapiro" Date: September 19, 2022 10:58:00 PM Subject: RE: Arbitrator List Reply to list Reply to sender Print List: caala-workproduct Sent by: David Shapiro (Reply Privately) Search List mates: Let me add a little more to my post about judge Bruguera. I was before her many years ago and she was first rate. For this reason, I did not hesitate to agree to her for my UM arbitration. So that it does not appear that am guilty of sour grapes let me elaborate on the subject. The case is 5 years old, involves a young Arminian woman, an esthetician who stands 6 to 8 hours a day. Except for her name, if you met my client, you would think she was an attractive woman without a trace of an accent who gives the cultural appearance of a valley girl. The claim involved a minor rear end impact. In the 1990’s and over a period of 10 years, my client was involved in 3 non-fault “soft-tissue” rear end accidents, all of which settled without litigation. We know this because those accidents were identified in a history to a 2003 workers comp claim involving an aggravation of her cervical complaints. Nothing involving her right hip. From 2003 until March 2017, nearly 12 years she had no neck or back complaints. In 2013 her right hip began bothering her after a yoga class. She went to a chiropractor who treated her and gave her exercises. She testified she went to him twice and performed the exercises. Thereafter no hip problems for three years. After her 2017 accident she had minor neck and back complaints which eventually resolved. However, she began to have pain in her right hip. She went to a chiropractor, named Mike Hagopian for 16 weeks. (How State Farm Treats Armenian Claimants with Arminian doctors is a story for another day). She was then referred to Jacob Tauber for her hip problem. This was before Dr. Tauber became known as an admitted felon. This was my last case with Dr. Tauber who us older attorneys considered the darling of both the plaintiff’s and defense bar for over 30 years. Tauber testified at the hearing via zoom. I confess that it did not help to have him testify that he was at home under house arrest. He was embarrassed but testified bravely. However, what ever his misconduct, it had nothing to do with is medical treatment. Tauber diagnosed my client’s hip condition as piriformis syndrome. This is a condition of the piriformis muscle (a swelling or other injury) which causes an impingement of the sciatic nerve and radiculopathy. It often appears as lumbar sciatica caused by a disc disruption. Tauber ordered an MRI to rule out a lumbar pathology. When that proved negative, he ordered an ultrasound which disclosed an edema of the right piriformis muscle and confirmed the radiculopathy via an EMG. Two of the three experts, Lieu (radiology) Rosen (orthopedics) all testified that these tests were necessary. Malar the crackpot chiropractor said no test was necessary because he, with his superior knowledge of chiropractic medicine could analyze and treat my client without necessity of any medical diagnoses or treatment. And even though my client had no accidents, medical treatment for neck and back complaints for over 12 years before the accident, he testified that she was symptomatic with these complaints at the time of the incident. Notwithstanding these objective findings all three defense experts testified that she had low back pathology due to the accidents from 12 years before and that her 2017 accident had nothing to do with her need for medical treatment she underwent due to the rear end accident. My client testified she never had a problem with her hip for 12 years before the accident and no problems for 3 years after her two visits to the chiropractor in 2013. Tauber diagnosed my client’s injury as an aggravation of a pre-existing propensity to the condition due to her visit with the chiropractor 3 years before, and that her condition was chronic. The three experts basically testified she was symptomatic at the time of the incident, that this was a nothing burger injury which would have healed in 3 to 6 weeks with standard PT. Due to the delays caused by her many bathroom breaks, the hearing went from 4 to 6 hours, and because of that, Bruguera forced us to do our closings in writing. During the hearing, defense counsel was all over Tauber about his felony conviction and forced him to admit that he was testifying from his home on house arrest. He virtually ignored all other empirical evidence which supported Tauber’s testimony or contradicted his experts. Defense counsel also extolled Dr. Rosen as a paragon of spine surgery and the founder of some medical ethics society, although I caught him openly lying during the hearing, a matter I brought to the attention of judge Bruguera who ignored this fact and who resolved all objections by repeatedly saying you boys stop fighting “you are arguing before a judge, not a jury.” During his case in chief and in his closing, defense counsel spent most of his argument condemning Tauber as a felon and therefore should not be believed while praising the eminent Dr. Rosen as a god of spine surgery. I should point out the Rosen repeatedly testifies that he is a spine surgeon, and any other medical practitioner is something, well, less. In her written award Bruguera ignored any evidence of objective injury, whether it came from Tauber or the defense experts. The defense experts testified that the tests Tauber ordered to determine my client’s condition were justified. Tauber testified that the therapy she received from her chiropractor as reasonable and necessary. While I thought that there was a possibility that Bruguera would not give away the farm on general damages, I thought she would at least acknowledge the 16 weeks of treatment, pain, and suffering, and the cost my client’s medical specials. Based on my experience with her, I refused to believe that she would paint my client’s case with Tauber’s misconduct. I was dead wrong. I did not anticipate her petty animus towards Tauber. Judge Bruguera justified her minuscule award by spending nearly the entirety of her written award castigating Tauber’s credibility as a physician and bought lock, stock, and barrel everything defense counsel wrote in his closing about Tauber, while extoling the ever-arrogant Dr. Charles Rosen, who is as deep a snake as any you will ever encounter. She virtually ignored any evidence of my client’s injury in favor of her very lucrative benefactor State Farm. Ok, list mates, if you think this is sour grapes so be it. I can handle the disappointment in both Bruguera and her award. I lost plenty on depositions and the hearings but that is the nature of our profession and in the scheme of things have done very well this year, so I’ve moved on. I will certainly take nothing from this case and give my client the entirety of Bruguera’s paltry award. If you want to make an insurance carrier happy, by all means chose Judge Bruguera for your next UM or UIM case. I am certain defense counsel and the carriers they represent will be more than happy to oblige you. David B. Shapiro From: Soheil Bahari (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Friday, September 9, 2022 1:10 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: [caala-workproduct] Arbitrator List List: caala-workproduct Sent by: Soheil Bahari (Reply Privately) Search Dear All, Defense is proposing the following arbitrators for a UIM case. Your opinions would be greatly appreciated. Thomas Friedman; Christopher Warner; Mitchell Green; Christopher Conway; Frederick Aguirre; Alan Goodman; Jill Sperber; Darrell Forgey; Martin Handweiler; and Suzanne Bruguera.
AI Analysis:
This message makes no mention of Judge Goodman whatsoever. It discusses Judge Aguirre and arbitrator Darrell Forgey in the context of UIM arbitrations. There is no reference to Goodman in any form, and the content is entirely about a different judge's behavior and tendencies.
I did an Arbitration with Judge Aguirre, and he is way too friendly towards the insurance company. I had great facts, a good Plaintiff and an annular tear in a Lumbar MRI, but he rejected my pain management meds. He tried to compensate by over-awarding general damages for the amount of meds that he did accept, but it was obvious he was trying to keep Allstate in his good graces so they will continue to hire him. He is the cousin of one of my best friends, has a great family history and story, but just another example why UIM Arbs are generally stacked against the Plaintiffs because the Arbitrators know who their golden goose, and it is not us. On that list, I would suggest Darrell Forgey.
AI Analysis:
This message does not mention Judge Goodman at all. It is a discussion about retired Judge Suzanne Bruguera and arbitrator Darrell Forgey, with attorneys sharing experiences about arbitration proceedings. The name 'goodman' does not appear anywhere in the message, and there is no substantive information that would help evaluate Judge Goodman.
nhou651519@aol.com Date: September 14, 2022 12:35:00 PM Subject: Re: Arbitrator List Reply to list Reply to sender Print List: caala-workproduct Sent by: Nancy Houchen (Reply Privately) Search Dear David, Thanks for letting all of us know this. I haven't heard Ret. Judge Bruguera on a mediation or arbitration in quite some time, and it is certainly possible that she has changed from pro-plaintiff to pro-defense. Probably a $ issue for her, if she thinks more carriers will agree to her if she slants their way. Sorry to hear this, as she was great as a judge, as many of you know. Nancy Houchen. -----Original Message----- From: David Shapiro (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Sent: Tue, Sep 13, 2022 5:03 pm Subject: RE: [caala-workproduct] Arbitrator List List: caala-workproduct Sent by: David Shapiro (Reply Privately) Search Ms. Bahari: I just completed an arbitration with Suzanne Bruguera few weeks ago. Do not use her or use her at your own risk. She is not the judge she used to be. She is defense oriented and friendly to the insurance carrier (in my case State Farm). In addition to her bias, the hearing is problematic. She is elderly (not healthy) and had to stop the hearing so she could visit the restroom every hour, extending the arbitration hearing from 4 to 6 hours. She prefers you to do closing argument in writing. She is with ADR and their hearing rooms are not conducive to digital projection, you will have to have hard copies available for impeachment if the witness is on zoom. Email me privately if you want more. I have always liked Darrell Forgey (if you have a decent case, he is fair, but will not give you a huge number). David B. Shapiro From: Soheil Bahari (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Friday, September 9, 2022 1:10 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: [caala-workproduct] Arbitrator List List: caala-workproduct Sent by: Soheil Bahari (Reply Privately) Search Dear All, Defense is proposing the following arbitrators for a UIM case. Your opinions would be greatly appreciated. Thomas Friedman; Christopher Warner; Mitchell Green; Christopher Conway; Frederick Aguirre; Alan Goodman; Jill Sperber; Darrell Forgey; Martin Handweiler; and Suzanne Bruguera.
AI Analysis:
This message does not mention Judge Goodman at all. It discusses Judge Bruguera (positively, regarding mediation and compassion) and Mitch Green (negatively, called a 'defense shill'). There is no reference to Goodman in any form, and no information that would help evaluate Goodman as a judge.
I like Judge Bruguera. I have not used her as an arbitrator, but have had several successful mediations with her. She is compassionate and I expect will be fair in making awards for pain and suffering.Mitch Green is a defense shill.
AI Analysis:
This message discusses Judge Bruguera and Mitch Green. There is no mention of 'goodman' anywhere in the message. The message is entirely about other individuals and contains no information useful for evaluating Judge Goodman.
I like Judge Bruguera. I have not used her as an arbitrator, but have had several successful mediations with her. She is compassionate and I expect will be fair in making awards for pain and suffering.Mitch Green is a defense shill.
AI Analysis:
This message thread is entirely about a SCIF vocational rehabilitation expert named Rob Liebman and an AME named Hasday. There is no mention of Judge Goodman anywhere in the message. The conversation is between attorneys Anthony Polakov and Jeffrey Linnetz discussing a claimant's work capacity and a VR expert's conclusions. This message contains no information useful for evaluating Judge Goodman.
Anthony Polakov Date: December 14, 2021 3:29:00 PM Subject: RE: SCIF VR Expert-Rob Liebman Reply to list Reply to sender Print List: lawnet Sent By: Anthony S. Polakov Reply To Sender Reply To List Search Settings Will Do. Anthony S. Polakov, Esq. Stoll, Nussbaum & Polakov, APC 11620 Wilshire Blvd. Suite 500 Los Angeles, CA 90025 (310)996-7500 (310)575-4353 Fax apolakov@stolllaw.com Please take notice that Stoll, Nussbaum & Polakov is under a mandatory work from home order due to the Covid-19 pandemic. As a result, our physical office is closed and all employees are working remotely in hopes of doing our part to slow the spread of COVID-19. We ask that all correspondence, pleadings, discovery and/or other communications be electronically sent via email, dropbox, or other electronic means to mail@stolllaw.com until further notice. Any communications sent via U.S. Mail, and/or personal or overnight delivery will encounter significant delays in receipt because all mail will be forwarded and remotely processed . These delays can be avoided by sending all communications by email, dropbox and/or other electronic means to the following address: mail@stolllaw.com . PLEASE NOTE OUR NEW ADDRESS : 11620 Wilshire Blvd., Suite 500 Los Angeles, CA 90025 310.996.7500 office 310.575.4353 fax From: Jeffrey Linnetz (lawnet listserver) [mailto:listsender@lawnet.caaa.org] Sent: Tuesday, December 14, 2021 1:25 PM To: Statewide List Service <lawnet@lawnet.caaa.org> Subject: Re: [lawnet] SCIF VR Expert-Rob Liebman List: lawnet Sent By: Jeffrey Linnetz Reply To Sender Reply To List Search Settings Tony, Please let me know what Mr. Liebman concludes. Jeff Linnetz Los Angeles On Tue, Dec 14, 2021 at 1:19 PM Anthony S. Polakov (lawnet listserver) < listsender@lawnet.caaa.org > wrote: List: lawnet Sent By: Anthony S. Polakov Reply To Sender Reply To List Search Settings Ok, well my guy cannot be a parking attendant. THE AME Hasday found him 100% not capable of working in the open labor market. Anthony S. Polakov, Esq. Stoll, Nussbaum & Polakov, APC 11620 Wilshire Blvd. Suite 500 Los Angeles, CA 90025 (310)996-7500 (310)575-4353 Fax apolakov@stolllaw.com Please take notice that Stoll, Nussbaum & Polakov is under a mandatory work from home order due to the Covid-19 pandemic. As a result, our physical office is closed and all employees are working remotely in hopes of doing our part to slow the spread of COVID-19. We ask that all correspondence, pleadings, discovery and/or other communications be electronically sent via email, dropbox, or other electronic means to mail@stolllaw.com until further notice. Any communications sent via U.S. Mail, and/or personal or overnight delivery will encounter significant delays in receipt because all mail will be forwarded and remotely processed . These delays can be avoided by sending all communications by email, dropbox and/or other electronic means to the following address: mail@stolllaw.com . PLEASE NOTE OUR NEW ADDRESS : 11620 Wilshire Blvd., Suite 500 Los Angeles, CA 90025 310.996.7500 office 310.575.4353 fax From: Jeffrey Linnetz (lawnet listserver) [mailto: listsender@lawnet.caaa.org ] Sent: Tuesday, December 14, 2021 1:17 PM To: Statewide List Service < lawnet@lawnet.caaa.org > Subject: Re: [lawnet] SCIF VR Expert-Rob Liebman List: lawnet Sent By: Jeffrey Linnetz Reply To Sender Reply To List Search Settings Tony, He usually finds that the injured employee can return to work as a parking lot attendant. Years ago Judge Goodman warned him, "Don't tell me that the Applicant can work as a parking lot attendant." Nevertheless that is exactly what his testimony was. The Judge was flabbergasted and awarded my client 100% . Jeff Linnetz Los Angeles On Tue, Dec 14, 2021 at 12:34 PM Anthony S. Polakov (lawnet listserver) < listsender@lawnet.caaa.org > wrote: List: lawnet Sent By: Anthony S. Polakov Reply To Sender Reply To List Search Settings He is SCIF’s expert. Not mine. Anthony S. Polakov, Esq. Stoll, Nussbaum & Polakov, APC 11620 Wilshire Blvd. Suite 500 Los Angeles, CA 90025 (310)996-7500 (310)575-4353 Fax apolakov@stolllaw.com Please take notice that Stoll, Nussbaum & Polakov is under a mandatory work from home order due to the Covid-19 pandemic. As a result, our physical office is closed and all employees are working remotely in hopes of doing our part to slow the spread of COVID-19. We ask that all correspondence, pleadings, discovery and/or other communications be electronically sent via email, dropbox, or other electronic means to mail@stolllaw.com until further notice. Any communications sent via U.S. Mail, and/or personal or overnight delivery will encounter significant delays in receipt because all mail will be forwarded and remotely processed . These delays can be avoided by sending all communications by email, dropbox and/or other electronic means to the following address: mail@stolllaw.com . PLEASE NOTE OUR NEW ADDRESS : 11620 Wilshire Blvd., Suite 500 Los Angeles, CA 90025 310.996.7500 office 310.575.4353 fax From: Jeffrey Linnetz (lawnet listserver) [mailto: listsender@lawnet.caaa.org ] Sent: Tuesday, December 14, 2021 12:30 PM To: Statewide List Service < lawnet@lawnet.caaa.org > Subject: Re: [lawnet] SCIF VR Expert-Rob Liebman List: lawnet Sent By: Jeffrey Linnetz Reply To Sender Reply To List Search Settings Tony, I would not use him. He was appointed by Judge Spoeri on a case. He issued a report which concluded my client could return to work. His opinions were not well supported on cross examination. Jeff Linnetz Los Angeles On Tue, Dec 14, 2021 at 11:52 AM Anthony S. Polakov (lawnet listserver) < listsender@lawnet.caaa.org > wrote: List: lawnet Sent By: Anthony S. Polakov Reply To Sender Reply To List Search Settings Netsters: Anyone familiar with this VR expert. I have a 100% case that we have used a VR expert to confirm the 100%. SCIF has advised that they are using Rob Liebman as their expert. Is he fair, or very defense oriented? Credibility? thank you, Anthony S. Polakov Los Angeles, CA
AI Analysis:
This message makes no mention of Judge Goodman whatsoever. It is a brief communication between Jeffrey Linnetz and Tony regarding a vocational rehabilitation expert named Rob Liebman and SCIF (State Compensation Insurance Fund). The message contains no information about any judge, let alone Goodman, and is entirely unrelated to evaluating a judge's conduct, rulings, or courtroom behavior.
Tony, Please let me know what Mr. Liebman concludes. Jeff Linnetz Los Angeles
AI Analysis:
This message is entirely about email organization methods and saving legal posts/cases/articles into folders. It does not mention Judge Goodman by name, does not reference any rulings, decisions, or courtroom behavior, and contains no information whatsoever that would help evaluate Goodman as a judge. The message is completely unrelated to the judge being evaluated.
For about 20 years I have done what Arthur does...create emails of good posts, cases and Lexis articles, and save them to about 25 folders covering different topics. This method has proved invaluable over the years. The QME folder has over 1000 entries.
AI Analysis:
This message is entirely about legal research organization techniques and file management strategies shared by attorney Arthur Csillag. It discusses saving articles, cases, and motions in labeled email folders for future reference. There is no mention of Judge Goodman, any judge by name, any rulings, courtroom behavior, or any information that would be useful for evaluating Judge Goodman as a workers' compensation judge.
Your welcome Bruce. What I have done through the years is keep my eye on articles and cases that I believe I might be of use in the future and save it for when I need it. I do this religiously in my personal injury practice and have literally written whole motions or oppositions based upon a saved article or case. If someone has written a great motion in limine I copy that motion and save it as well. For example, let's say a new TD earnings earnings decision or article comes down today that I may not have any use for in the moment. However, my instincts tell me that the case/article is important enough that I just may need it in the future. I then copy and paste the case/article into an email and label that email. Let's just call it TD EARNINGS CAPACITY - ARTICLE. I then forward that email to my TEMPORARY DISABILITY E-mail folder and save it for some rainy day in the future. Then months - even years later an issue comes up for example on TD earnings capacity that I need to research. The first thing I do is read through the topics I have saved in my TEMPORARY DISABILITY FOLDER email and lo and behold more often than not I find that treasure article I saved months or years earlier. It a great feeling when you don't have to reinvent the wheel! (That is exactly how I found the article you were referring to). The key is to devise a system - whatever system works for you and start today. You can simply print out the case and instead of an email you place it in a folder you have created. As the nike add says JUST DO IT! lol. As I write this I will copy and paste Jim Harvey's email into my Old law versus new law email folder to save for the future. I cannot tell you how powerful this home-made research tool I created is. It has saved by derriere on more than many an occasion! Arthur Csillag Burbank
AI Analysis:
This message does not mention 'goodman' or any judge by that name at all. The message is a discussion between attorneys Greg Jackson and Nareg Kitsinian about neuropsychological DME raw data, a recusal matter, and a minute order compelling a neuropsychologist named Filoteo to produce raw data. The conversation is on the CAALA Work Product Discussion List and pertains to a Superior Court (LASC) matter, not a workers' compensation case before Judge Goodman. There is no reference to Judge Goodman in any form.
"Greg Jackson" Date: November 20, 2025 5:28:00 PM Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal Reply to list Reply to sender Print Added! Greg Jackson Partner and Managing Attorney The Simon Law Group p : (855) 855-8910 f : (310) 914-5401 m : (714) 617-2180 a : 2916 W 164th Street Torrance CA 90504 w : www.JusticeTeam.com e : greg@justiceteam.com Orange County | Los Angeles | Arizona | Texas This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of the company. Finally, the recipient should check this email and any attachments for the presence of viruses. The company accepts no liability for any damage caused by any virus transmitted by this email. From: Nareg Kitsinian (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Thursday, November 20, 2025 3:21 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Nareg Kitsinian (Reply Privately) Search Greg, attached is our LASC minute order from 3/25 compelling Filoteo who did produce. Please add to your folder. -- LATLC 2025 Secretary – 2029 President Nareg S. Kitsinian, Esq. Attorney at Law nareg@kitsinianlaw.com www.kitsinianlaw.com Tel: (818)786-5777 | Fax: (818)786-5778 16501 Ventura Blvd., Ste. 506, Encino, CA 91436 From: Gregory Jackson (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Thursday, November 20, 2025 3:01 PM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Gregory Jackson (Reply Privately) Search No problem! You’ll see specific subfolders for a number of experts, some oppositions, lot of stuff in there to use. For that huge declaration defense is listing now, a number of those experts who signed off on it have actually produced raw data anyway – so you can use these minute orders and stipulations in the Dropbox to impeach it. Greg Jackson Partner and Managing Attorney The Simon Law Group p : (855) 855-8910 f : (310) 914-5401 m : (714) 617-2180 a : 2916 W 164th Street Torrance CA 90504 w : www.JusticeTeam.com e : greg@justiceteam.com Orange County | Los Angeles | Arizona | Texas This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of the company. Finally, the recipient should check this email and any attachments for the presence of viruses. The company accepts no liability for any damage caused by any virus transmitted by this email. From: Nareg Kitsinian (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Thursday, November 20, 2025 2:45 PM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Nareg Kitsinian (Reply Privately) Search Greg, This - is awesome! I will send you the minute order when I have it. This dropbox folder you have compiled is a treasure - really the nail in the coffin. Everyone should be sharing their minute orders on this issue moving forward. Thank you! -- LATLC 2025 Secretary – 2029 President Nareg S. Kitsinian, Esq. Attorney at Law nareg@kitsinianlaw.com www.kitsinianlaw.com Tel: (818)786-5777 | Fax: (818)786-5778 16501 Ventura Blvd., Ste. 506, Encino, CA 91436 From: Gregory Jackson (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Thursday, November 20, 2025 2:10 PM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Gregory Jackson (Reply Privately) Search Nareg, Thank you for sharing this! Please keep us posted if Dr. Hungerford proceeds with the exam and complies/produces the raw data so we can add him to the list, and once you get the final minute order please circulate that as well. Here is the Dropbox of neuropsych dirt I’ve compiled, check out the ‘Minute Orders’ subfolder and there are at least a dozen in there including 8 from this year. If you send me your final minute order once the court posts it I’ll add it to the Dropbox! https://www.dropbox.com/scl/fo/c0pued3e3ftj4j0x88qji/ALFU7MTTieoSk3Dud4IyfHc?rlkey=67d52jz1uxzspr3mol96dfbkr&st=2kghiflq&dl=0 Greg Jackson Partner and Managing Attorney The Simon Law Group p : (855) 855-8910 f : (310) 914-5401 m : (714) 617-2180 a : 2916 W 164th Street Torrance CA 90504 w : www.JusticeTeam.com e : greg@justiceteam.com Orange County | Los Angeles | Arizona | Texas This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of the company. Finally, the recipient should check this email and any attachments for the presence of viruses. The company accepts no liability for any damage caused by any virus transmitted by this email. From: Nareg Kitsinian (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Thursday, November 20, 2025 11:25 AM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Nareg Kitsinian (Reply Privately) Search We successfully opposed a motion to compel a mental exam with Dr. Lars Hungerford today in San Bernardino Superior Court with Judge Joseph Widman. He made all the right calls in line with Randys Trucking and compelled that the raw data be turned over and plaintiff can record the examination. This hearing was different then past hearings. The defense play now is to use this declaration that they say 94% of neuropsychs have signed attesting they would recuse themselves if compelled to turn over data. It's persuasive, but not enough to circumvent the law. In my motion I attached two minute orders/tentative rulings where LASC courts also ruled in line with Randy Trucking. Concerningly, this prompted the defense to argue at the hearing that he would like to lodge 10 other recent orders throughout CA that he has collected that went in the opposite direction and did not compel disclosure. Judge Widman did not buy the argument. But I raise this because if 10 other courtrooms are still ruling against disclosure, it can be problematic given the judge and we should begin collecting orders in all superior courts where a judge rules with Randy Trucking so that they can be Judicially Noticed in these motions. This is the second motion I have won in the last 5 months on a TBI case. The law is with us, but it is striking to me that 10 other courts recently ruled in another direction. Attached is our tentative ruling from this morning. I hope others will share over time so we can use them as time passes. -- LATLC 2025 Secretary – 2029 President Nareg S. Kitsinian, Esq. Attorney at Law nareg@kitsinianlaw.com www.kitsinianlaw.com Tel: (818)786-5777 | Fax: (818)786-5778 16501 Ventura Blvd., Ste. 506, Encino, CA 91436 From: Kane Handel (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Tuesday, November 4, 2025 11:05 AM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Kane Handel (Reply Privately) Search file a motion!!! On 11/4/25 9:44 AM, Nareg Kitsinian (caala-workproduct listserver) wrote: List: caala-workproduct Sent by: Nareg Kitsinian (Reply Privately) Search I have a TBI case where Dr. Hungerford has refused to provide the raw data to me and is claiming in his declaration to withdraw if the court orders him to turn over the data, citing this same declaration signed by 180 other NeuroPsychs. Does anyone have any prior experience with Dr. Lars Hungerford, perhaps agreeing to turn over raw data in the past that I can use in our opposition? Nareg -----Original Message----- From: antonio@ac3law.com Sent: September 29, 2025 3:43:00 PM To: caala-workproduct@lists.trialsmith.com Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal Interestingly, Delis isn't a signatory. On Fri, Sep 19, 2025 at 3:57 PM Delavar Omidfar (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> wrote: > *List:* caala-workproduct * Sent by:* Delavar Omidfar (Reply Privately) > <domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > Search <http://www.caala.org/index.cfm?pg=search> > Andrew - Do you have the case information or copies of the App Case? > > > -----Original Message----- > > From: andrew@a2zlegal.com > Sent: September 17, 2025 6:35:00 PM > To: caala-workproduct@lists.trialsmith.com > Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal > > This is nonsense. I had to take up a writ where the judge would not allow > them to turn over the data to us and my writ was granted, court order > reversed. If I remember correctly they included this garbage in their > opposition as well but the Appellate Court did not buy it. > > > Andrew Zeytuntsyan > > Founder / Trial Attorney > > [ > https://storage-use.letsignit.com/62705ddc173a9394d8bcc888/logo_62705ddc173a9394d8bcc888_e895719889494628d401a7b8776c8039.png > ] > > 1306 W. Magnolia Blvd. > > Burbank, CA 91506 > > T. (323) 882-6500 > > F. (800) 506-7176 > > a2zlegal.com< > https://cloud.letsignit.com/collect/bc/627076c3c8565ddc6ca471ae?p=L3lrFhURv2eXFz8AUdcQMg7oZ5M7umbVf2WSzpdzFq7D1iSXrK3ZaujaqDpZOQqyzyjZl0xri-GrOODYWlP3QLZm0iplL-zlOXM4lSHQ28oSIcbvk9_JHfvcYEayMxKfUiuqgPOYkIcclIOWPouVUq8U-TmlvnN27_c7uQRHayw= > > > > [ > https://storage-use.letsignit.com/62705ddc173a9394d8bcc888/253796901116998898398879131612511431317.png > ] > > The information in this electronic mail message is confidential and for > use of only the named recipient. The information may be protected by > privilege, work product immunity or other applicable law. If you are not > the intended recipient the retention, dissemination, distribution or > copying of this e-mail message is strictly prohibited. If you receive this > message in error please notify us immediately. > > ________________________________ > From: Delavar Omidfar (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com > > Sent: Friday, September 12, 2025 3:15 PM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com > > Subject: [caala-workproduct] Neuropsych Declaration re DME Raw Data and > Recusal > > List: caala-workproduct Sent by: Delavar Omidfar (Reply Privately)< mailto: > domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal > > Search <http://www.caala.org/index.cfm?pg=search> > > Mates, > I was recently provided with the attached declaration signed by over 180 > neuropsychologists and psychologists regarding the protection of > psychological testing materials. Most importantly, all signatories have > declared: > > "I would not agree to releasing protected test information that would > jeopardize future use of tests to a non-psychologist, including attorneys, > even under a protective order. If this stipulation cannot be met, I would > recuse myself from a case." > > My suspicion is that some of these same psychologists have previously > agreed to perform mental examinations and released raw data under > protective orders. If true, this creates a significant inconsistency that > could be used to challenge their credibility and position. > > I'm reaching out to see if any of you have: > > 1. Documentation of any of these 185 signatories previously agreeing to > release raw test data under protective order > 2. Thoughts on strategies for overcoming this collective stance in future > cases > 3. Legal precedents, other than Randy's Trucking, that could compel > production despite this declaration > 4. Counter Declaration by psychs who can counter their arguments about > test security > > The complete list of 185 signatories is below. Notable names include many > prominent California neuropsychologists who regularly serve as defense > experts, i.e. Hinkin, Boone, Kopald, Lechuga, Hooker, Bondi, Elliot, Zamora. > > List of Signatories > Catherine Marreiro, PhD, ABPP-CN > Kyle Boone, PhD, ABPP-CN > William McMullen Jr., PhD, ABPP-CN > Delia M. Silva, Psy.D., ABPP-CN, Neuropsychologist > Lauren Drag, PhD, ABPP-CN > Maya Yutsis, PhD, ABPP-CN > Katherine Kruser, Psy.D., Neuropsychologist > Jeffrey Wertheimer, PhD, ABPP-CN > Jay Rosen, PhD > Michelle Zeller, Psy.D., ABPP-CN > Deborah Cahn-Weiner, Ph.D., ABPP-CN > Mi-Yeoung Jo, PsyD, ABPP-CN > Talin Babikian, PhD, ABPP-CN > Molly Memel, PhD, ABPP-CN > Rebecca Goodman, PhD, ABPP-CN > Haygoush Kalinian, PhD, Clinical Neuropsychologist > Robert M. Bilder, PhD, ABPP-CN > Robert Gray, PhD, ABPP-CN > Amir Ramezani, PhD > Leah Ellenberg, Ph. D., ABPP-CN > Charles Filanosky, PhD, ABPP-RP > Po-Haong Lu, PsyD > Angela Eastvold, PhD, ABPP-CN > Maura Mitrushina, Ph.D., ABPP-CN > Ann Gottuso, PhD, ABPP-CN > Gayle Deutsch, PhD, ABPP-CN > Simon Tan PsyD, ABPP-CN > Andrew Levine, PhD, ABPP-CN > Ernest T. Bryant, PhD, ABPP-CN > John Wager, PhD, ABPP-CN > Dominique Kinney, PhD, ABPP-CN > Brandon Kopald, Psy.D., ABPP-CN > Frederick Hives II, PhD, ABPP-CN > Lars Hungerford, PhD, ABPP-CN > Karen L. Schiltz, PhD, Neuropsychologist > Tara L. Victor, PhD, ABPP-CN > Shelley Peery, PhD > Karen Lau, PhD, ABPP-CN > Robert Tomaszewski, PhD, ABPP-CN > David M. Lechuga, PhD, ABPP, ABN > Elma Chidekel, PhD, ABN, ABPdN > William D. Hooker, Ph.D., ABN > Dale Sherman, PhD, QME > June Paltzer, PhD, ABPP-CN > Karen Earnest, PhD, ABPP-CN > John Bellone, PhD, ABPP-CN > Erin Green-Krogmann, PhD, ABPP-CN > Virginia Zuverza-Chavarria, PhD, ABPP-CN > Kimberly Lanni, PhD, ABPP, Board Certified in Clinical Neuropsychology > Mark Alfano, Ph.D., ABPP CN, RP > Steve Nitch, Ph. D., ABPP-CN > Kristina Agbayani, PhD, ABPP-CN > Andrew L. Wong, PhD, ABPP-CN > Jessica Foley, PhD, ABPP-CN > Andrew Dean, Ph. D., ABPP-CN > Allison R. Kaup, PhD > Mark W. Bondi, PhD, ABPP-CN > Jose M. Lafosse, Ph.D., ABPP-CN > Philip Sayegh, PhD, MPH > Sara Mason, PsyD > Kimberly Miller, PhD, ABPP-CN > Hayley Kristinsson, PsyD, ABPP-CN > Michael H. Kabat, Ph.D., ABPP-CN > Brigid Rose, PhD, ABPP-CN > Roger Light, PhD, ABPP-CN > Jeremy Jinkerson, PhD > David D. O'Grady, Ph.D., ABPP-CN > Anneliese Radke, Psy.D. > Joanne M. Hamilton, ABPP-CN > Travis G. Fogel, Ph.D., ABPP-CN > Sarah Tomaszewski Farias, Ph.D. ABPP-CN > Allyson C. Rosen, PhD, ABPP-CN > Sabine Gysens, PhD > George Kahle Henry, PhD. ABPP-CN > Kirsty Bortnik, PhD, ABPP-CN > Joelle Broffman, PsyD, ABPP-CN > Kristin K. Jacobson, PsyD, ABPP-CN > Alice Ruzicka, Ph.D., ABN > Renee Low, Ph.D., ABN > Stacy S Wilkins, PhD, ABPP/CN > Christine M. Naber, PhD > Aura Barragan, Psy.D. > Richard L. Delmonico, PhD, Licensed Psychologist CA PSY12604, Clinical > Neuropsychologist > Lauren Bennett, PhD, ABPP-CN > William J. Lynch, Ph.D., ABPP/CN, Licensed Psychologist [PSY 5151] > Rujvi Kamat, PhD, ABPP-CN > Krista Freeze, PhD, ABN > Carrie R. McDonald, Ph.D., ABPP-CN > Nancy A. Blum, Ph.D. > Travis Shivley-Scott, PhD > Karen Mikolic, PhD, ABN > Talia Seider, PhD, ABPP-CN > Heather Pedersen, PhD, ABPP-CN > Michael DeBellis Psy.D., ABN > Nicholas Thaler, PhD, ABPP-CN > Caroline J. Grantz, PhD > Philip K. Stenquist, Ph.D., ABPP-CN > Brian Yochim, PhD, ABPP-CN > Olivia Harner, PhD, ABPP > David Anderson, PhD, ABPP-CN/CI > Alexis D. Kulick, Ph.D., ABPP > Lori Holt, PhD, ABPP-CN > Joel S. Eppig, Ph.D. > Delany Thrasher, Ph.D., ABPP-CN > Annie Reader Murray, Ph.D., ABPP-CN > Jeffrey M. Zulow, Ph.D. > Kaitlin B. Casaletto, PhD, ABPP-CN > Alexandra Apple, PhD > Hope Goldberg, PhD, ABPP-CN > William C. Hochberger, PhD > Paul Mangal, PhD > Virdette L. Brumm, Ph.D. > Christy Hom, PhD, ABPdN > Eric J. Freitag, PsyD, FACPN > Howard J. Friedman, ABPP (CN), ABN > Jonathan E. Romain, PhD, MS, ABPP-CN > Patricia Gross, PhD, ABPP-CN > Katie Denny PhD, ABPP-CN > Katherine Bangen, PhD, ABPP-CN > Lisa Graves, PhD > John Knippa, PhD, ABN > Ashley K. Miller, PhD, ABPP-CN > Karen Hanson Bondi, Ph.D. > Lori Alasantro, PhD, ABPP-CN > Amanda Gooding, PhD, ABPP-CN > Anita Herrera-Hamilton, Ph.D ABPP > Caitlin Moore, PHD, ABPP > William Britt, PhD, ABN > Janet K. Brewer, JD, PsyD > Mimi Wong, PhD, ABPP-CN > Charles Furst, PhD, ABPP-CN > Robert W. Elliott, PhD, ABCN, ABN > Amy M. Schonfeld, PhD, Clinical Neuropsychologist > Brian A. Osterweil, Ph.D., ABPP > Duke Han, PhD, ABPP-CN > Lisa Delano-Wood, PhD > Kimberly Alfano, PhD, ABPP (CN, RP) > Alena Stasenko, PhD > Inna Fishman, PhD > Annette Swain PhD ABPP-CN > Monica Smith, PhD, ABN > Mili Parikh, PhD, ABPP > Charles H. Hinkin, Ph.D., ABPP-CN > R. Dempsey, PsyD, ABPP, QME > Margaret A. Donohue, PhD > Samantha O'Bannon, Psy.D., Clinical Neuropsychologist PSY 32564 > William T.J. Johnson, Ph.D., ABPP-CN > Tony L. Strickland, MS, PhD, ABN, FNAN > Emmanuel A. Zamora, Psy.D., Neuropsychologist > Joshua McKeever, PhD, Clinical Neuropsychologist > Carmen C. Velazquez, Ph.D. > Anne Nolty, PhD, ABPP-CN > Grace Mucci, PhD, ABPdN > Tom Kiely, PhD > Joel Kramer, PsyD, ABPP-CN > Andrea Alioto, PhD, ABPP-CN > Johanna Rengifo, PhD > Ruth Serepca, PhD > Abigail Kramer, PhD > Sarah Banks, PhD, ABPP-CN > Arnold D. Purisch, Ph.D., ABPP-CN, ABN > Yuri Rassovsky, PhD, ABPP-CN > Lauren Keats, PsyD > Saskia DeVaughn, PhD, ABPP-CN > Katie Beckwith, PhD, ABPP-CN > Ashley Whitaker, PhD, ABPP-CN > Christian Carter, Ph.D., ABPP-CN > Melissa Balderrama, PsyD, ABPP > Hannah Brunet, PhD, ABPP-CN > Garima Lupas, PhD, ABPP, Board Certified in Clinical Neuropsychology > James A. Moses, Ph.D., ABPP-CN/CL > Bianca Georgescu, Psy.D., ABPP > Brandon Gavett, Ph.D. ABPP-CN > April Thames, PhD > Michelle Conover, Ph.D., QME > Daniel Jacobson, PhD, ABPP-CN > Carlos Saucedo, PhD, ABPP-CN > Sharon H. O'Neil, PhD, ABPP-CN > Audrey Khatchikia, PhD > Natalie C. Kelly, PhD, ABPP-CN > Shital Pavawalla, Ph.D., ABPP-CN > Alexander Tan, Ph.D., ABPP-CN > Phuong M. Chau, PhD ABPP-CN > Deborah Budding, Ph.D., ABN > > > > > CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
AI Analysis:
This message does not mention Judge Goodman at all. It is an email exchange between Greg Jackson and Nareg Kitsinian discussing neuropsychological DME raw data, a Dropbox folder of minute orders related to neuropsych exams, and a Dr. Hungerford. There is no reference to Judge Goodman by name or any variation thereof, no rulings or decisions by Goodman, and no context that would help evaluate Goodman as a judge.
"Greg Jackson" Date: November 20, 2025 4:12:00 PM Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal Reply to list Reply to sender Print Nareg, Thank you for sharing this! Please keep us posted if Dr. Hungerford proceeds with the exam and complies/produces the raw data so we can add him to the list, and once you get the final minute order please circulate that as well. Here is the Dropbox of neuropsych dirt I’ve compiled, check out the ‘Minute Orders’ subfolder and there are at least a dozen in there including 8 from this year. If you send me your final minute order once the court posts it I’ll add it to the Dropbox! https://www.dropbox.com/scl/fo/c0pued3e3ftj4j0x88qji/ALFU7MTTieoSk3Dud4IyfHc?rlkey=67d52jz1uxzspr3mol96dfbkr&st=2kghiflq&dl=0 Greg Jackson Partner and Managing Attorney The Simon Law Group p : (855) 855-8910 f : (310) 914-5401 m : (714) 617-2180 a : 2916 W 164th Street Torrance CA 90504 w : www.JusticeTeam.com e : greg@justiceteam.com Orange County | Los Angeles | Arizona | Texas This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of the company. Finally, the recipient should check this email and any attachments for the presence of viruses. The company accepts no liability for any damage caused by any virus transmitted by this email. From: Nareg Kitsinian (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Thursday, November 20, 2025 11:25 AM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Nareg Kitsinian (Reply Privately) Search We successfully opposed a motion to compel a mental exam with Dr. Lars Hungerford today in San Bernardino Superior Court with Judge Joseph Widman. He made all the right calls in line with Randys Trucking and compelled that the raw data be turned over and plaintiff can record the examination. This hearing was different then past hearings. The defense play now is to use this declaration that they say 94% of neuropsychs have signed attesting they would recuse themselves if compelled to turn over data. It's persuasive, but not enough to circumvent the law. In my motion I attached two minute orders/tentative rulings where LASC courts also ruled in line with Randy Trucking. Concerningly, this prompted the defense to argue at the hearing that he would like to lodge 10 other recent orders throughout CA that he has collected that went in the opposite direction and did not compel disclosure. Judge Widman did not buy the argument. But I raise this because if 10 other courtrooms are still ruling against disclosure, it can be problematic given the judge and we should begin collecting orders in all superior courts where a judge rules with Randy Trucking so that they can be Judicially Noticed in these motions. This is the second motion I have won in the last 5 months on a TBI case. The law is with us, but it is striking to me that 10 other courts recently ruled in another direction. Attached is our tentative ruling from this morning. I hope others will share over time so we can use them as time passes. -- LATLC 2025 Secretary – 2029 President Nareg S. Kitsinian, Esq. Attorney at Law nareg@kitsinianlaw.com www.kitsinianlaw.com Tel: (818)786-5777 | Fax: (818)786-5778 16501 Ventura Blvd., Ste. 506, Encino, CA 91436 From: Kane Handel (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > Sent: Tuesday, November 4, 2025 11:05 AM To: CAALA Work Product Discussion List < caala-workproduct@lists.trialsmith.com > Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Kane Handel (Reply Privately) Search file a motion!!! On 11/4/25 9:44 AM, Nareg Kitsinian (caala-workproduct listserver) wrote: List: caala-workproduct Sent by: Nareg Kitsinian (Reply Privately) Search I have a TBI case where Dr. Hungerford has refused to provide the raw data to me and is claiming in his declaration to withdraw if the court orders him to turn over the data, citing this same declaration signed by 180 other NeuroPsychs. Does anyone have any prior experience with Dr. Lars Hungerford, perhaps agreeing to turn over raw data in the past that I can use in our opposition? Nareg -----Original Message----- From: antonio@ac3law.com Sent: September 29, 2025 3:43:00 PM To: caala-workproduct@lists.trialsmith.com Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal Interestingly, Delis isn't a signatory. On Fri, Sep 19, 2025 at 3:57 PM Delavar Omidfar (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> wrote: > *List:* caala-workproduct * Sent by:* Delavar Omidfar (Reply Privately) > <domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> > Search <http://www.caala.org/index.cfm?pg=search> > Andrew - Do you have the case information or copies of the App Case? > > > -----Original Message----- > > From: andrew@a2zlegal.com > Sent: September 17, 2025 6:35:00 PM > To: caala-workproduct@lists.trialsmith.com > Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal > > This is nonsense. I had to take up a writ where the judge would not allow > them to turn over the data to us and my writ was granted, court order > reversed. If I remember correctly they included this garbage in their > opposition as well but the Appellate Court did not buy it. > > > Andrew Zeytuntsyan > > Founder / Trial Attorney > > [ > https://storage-use.letsignit.com/62705ddc173a9394d8bcc888/logo_62705ddc173a9394d8bcc888_e895719889494628d401a7b8776c8039.png > ] > > 1306 W. Magnolia Blvd. > > Burbank, CA 91506 > > T. (323) 882-6500 > > F. (800) 506-7176 > > a2zlegal.com< > https://cloud.letsignit.com/collect/bc/627076c3c8565ddc6ca471ae?p=L3lrFhURv2eXFz8AUdcQMg7oZ5M7umbVf2WSzpdzFq7D1iSXrK3ZaujaqDpZOQqyzyjZl0xri-GrOODYWlP3QLZm0iplL-zlOXM4lSHQ28oSIcbvk9_JHfvcYEayMxKfUiuqgPOYkIcclIOWPouVUq8U-TmlvnN27_c7uQRHayw= > > > > [ > https://storage-use.letsignit.com/62705ddc173a9394d8bcc888/253796901116998898398879131612511431317.png > ] > > The information in this electronic mail message is confidential and for > use of only the named recipient. The information may be protected by > privilege, work product immunity or other applicable law. If you are not > the intended recipient the retention, dissemination, distribution or > copying of this e-mail message is strictly prohibited. If you receive this > message in error please notify us immediately. > > ________________________________ > From: Delavar Omidfar (caala-workproduct listserver) < > listsender-caala-workproduct@lists.trialsmith.com > > Sent: Friday, September 12, 2025 3:15 PM > To: CAALA Work Product Discussion List < > caala-workproduct@lists.trialsmith.com > > Subject: [caala-workproduct] Neuropsych Declaration re DME Raw Data and > Recusal > > List: caala-workproduct Sent by: Delavar Omidfar (Reply Privately)< mailto: > domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal > > Search <http://www.caala.org/index.cfm?pg=search> > > Mates, > I was recently provided with the attached declaration signed by over 180 > neuropsychologists and psychologists regarding the protection of > psychological testing materials. Most importantly, all signatories have > declared: > > "I would not agree to releasing protected test information that would > jeopardize future use of tests to a non-psychologist, including attorneys, > even under a protective order. If this stipulation cannot be met, I would > recuse myself from a case." > > My suspicion is that some of these same psychologists have previously > agreed to perform mental examinations and released raw data under > protective orders. If true, this creates a significant inconsistency that > could be used to challenge their credibility and position. > > I'm reaching out to see if any of you have: > > 1. Documentation of any of these 185 signatories previously agreeing to > release raw test data under protective order > 2. Thoughts on strategies for overcoming this collective stance in future > cases > 3. Legal precedents, other than Randy's Trucking, that could compel > production despite this declaration > 4. Counter Declaration by psychs who can counter their arguments about > test security > > The complete list of 185 signatories is below. Notable names include many > prominent California neuropsychologists who regularly serve as defense > experts, i.e. Hinkin, Boone, Kopald, Lechuga, Hooker, Bondi, Elliot, Zamora. > > List of Signatories > Catherine Marreiro, PhD, ABPP-CN > Kyle Boone, PhD, ABPP-CN > William McMullen Jr., PhD, ABPP-CN > Delia M. Silva, Psy.D., ABPP-CN, Neuropsychologist > Lauren Drag, PhD, ABPP-CN > Maya Yutsis, PhD, ABPP-CN > Katherine Kruser, Psy.D., Neuropsychologist > Jeffrey Wertheimer, PhD, ABPP-CN > Jay Rosen, PhD > Michelle Zeller, Psy.D., ABPP-CN > Deborah Cahn-Weiner, Ph.D., ABPP-CN > Mi-Yeoung Jo, PsyD, ABPP-CN > Talin Babikian, PhD, ABPP-CN > Molly Memel, PhD, ABPP-CN > Rebecca Goodman, PhD, ABPP-CN > Haygoush Kalinian, PhD, Clinical Neuropsychologist > Robert M. Bilder, PhD, ABPP-CN > Robert Gray, PhD, ABPP-CN > Amir Ramezani, PhD > Leah Ellenberg, Ph. D., ABPP-CN > Charles Filanosky, PhD, ABPP-RP > Po-Haong Lu, PsyD > Angela Eastvold, PhD, ABPP-CN > Maura Mitrushina, Ph.D., ABPP-CN > Ann Gottuso, PhD, ABPP-CN > Gayle Deutsch, PhD, ABPP-CN > Simon Tan PsyD, ABPP-CN > Andrew Levine, PhD, ABPP-CN > Ernest T. Bryant, PhD, ABPP-CN > John Wager, PhD, ABPP-CN > Dominique Kinney, PhD, ABPP-CN > Brandon Kopald, Psy.D., ABPP-CN > Frederick Hives II, PhD, ABPP-CN > Lars Hungerford, PhD, ABPP-CN > Karen L. Schiltz, PhD, Neuropsychologist > Tara L. Victor, PhD, ABPP-CN > Shelley Peery, PhD > Karen Lau, PhD, ABPP-CN > Robert Tomaszewski, PhD, ABPP-CN > David M. Lechuga, PhD, ABPP, ABN > Elma Chidekel, PhD, ABN, ABPdN > William D. Hooker, Ph.D., ABN > Dale Sherman, PhD, QME > June Paltzer, PhD, ABPP-CN > Karen Earnest, PhD, ABPP-CN > John Bellone, PhD, ABPP-CN > Erin Green-Krogmann, PhD, ABPP-CN > Virginia Zuverza-Chavarria, PhD, ABPP-CN > Kimberly Lanni, PhD, ABPP, Board Certified in Clinical Neuropsychology > Mark Alfano, Ph.D., ABPP CN, RP > Steve Nitch, Ph. D., ABPP-CN > Kristina Agbayani, PhD, ABPP-CN > Andrew L. Wong, PhD, ABPP-CN > Jessica Foley, PhD, ABPP-CN > Andrew Dean, Ph. D., ABPP-CN > Allison R. Kaup, PhD > Mark W. Bondi, PhD, ABPP-CN > Jose M. Lafosse, Ph.D., ABPP-CN > Philip Sayegh, PhD, MPH > Sara Mason, PsyD > Kimberly Miller, PhD, ABPP-CN > Hayley Kristinsson, PsyD, ABPP-CN > Michael H. Kabat, Ph.D., ABPP-CN > Brigid Rose, PhD, ABPP-CN > Roger Light, PhD, ABPP-CN > Jeremy Jinkerson, PhD > David D. O'Grady, Ph.D., ABPP-CN > Anneliese Radke, Psy.D. > Joanne M. Hamilton, ABPP-CN > Travis G. Fogel, Ph.D., ABPP-CN > Sarah Tomaszewski Farias, Ph.D. ABPP-CN > Allyson C. Rosen, PhD, ABPP-CN > Sabine Gysens, PhD > George Kahle Henry, PhD. ABPP-CN > Kirsty Bortnik, PhD, ABPP-CN > Joelle Broffman, PsyD, ABPP-CN > Kristin K. Jacobson, PsyD, ABPP-CN > Alice Ruzicka, Ph.D., ABN > Renee Low, Ph.D., ABN > Stacy S Wilkins, PhD, ABPP/CN > Christine M. Naber, PhD > Aura Barragan, Psy.D. > Richard L. Delmonico, PhD, Licensed Psychologist CA PSY12604, Clinical > Neuropsychologist > Lauren Bennett, PhD, ABPP-CN > William J. Lynch, Ph.D., ABPP/CN, Licensed Psychologist [PSY 5151] > Rujvi Kamat, PhD, ABPP-CN > Krista Freeze, PhD, ABN > Carrie R. McDonald, Ph.D., ABPP-CN > Nancy A. Blum, Ph.D. > Travis Shivley-Scott, PhD > Karen Mikolic, PhD, ABN > Talia Seider, PhD, ABPP-CN > Heather Pedersen, PhD, ABPP-CN > Michael DeBellis Psy.D., ABN > Nicholas Thaler, PhD, ABPP-CN > Caroline J. Grantz, PhD > Philip K. Stenquist, Ph.D., ABPP-CN > Brian Yochim, PhD, ABPP-CN > Olivia Harner, PhD, ABPP > David Anderson, PhD, ABPP-CN/CI > Alexis D. Kulick, Ph.D., ABPP > Lori Holt, PhD, ABPP-CN > Joel S. Eppig, Ph.D. > Delany Thrasher, Ph.D., ABPP-CN > Annie Reader Murray, Ph.D., ABPP-CN > Jeffrey M. Zulow, Ph.D. > Kaitlin B. Casaletto, PhD, ABPP-CN > Alexandra Apple, PhD > Hope Goldberg, PhD, ABPP-CN > William C. Hochberger, PhD > Paul Mangal, PhD > Virdette L. Brumm, Ph.D. > Christy Hom, PhD, ABPdN > Eric J. Freitag, PsyD, FACPN > Howard J. Friedman, ABPP (CN), ABN > Jonathan E. Romain, PhD, MS, ABPP-CN > Patricia Gross, PhD, ABPP-CN > Katie Denny PhD, ABPP-CN > Katherine Bangen, PhD, ABPP-CN > Lisa Graves, PhD > John Knippa, PhD, ABN > Ashley K. Miller, PhD, ABPP-CN > Karen Hanson Bondi, Ph.D. > Lori Alasantro, PhD, ABPP-CN > Amanda Gooding, PhD, ABPP-CN > Anita Herrera-Hamilton, Ph.D ABPP > Caitlin Moore, PHD, ABPP > William Britt, PhD, ABN > Janet K. Brewer, JD, PsyD > Mimi Wong, PhD, ABPP-CN > Charles Furst, PhD, ABPP-CN > Robert W. Elliott, PhD, ABCN, ABN > Amy M. Schonfeld, PhD, Clinical Neuropsychologist > Brian A. Osterweil, Ph.D., ABPP > Duke Han, PhD, ABPP-CN > Lisa Delano-Wood, PhD > Kimberly Alfano, PhD, ABPP (CN, RP) > Alena Stasenko, PhD > Inna Fishman, PhD > Annette Swain PhD ABPP-CN > Monica Smith, PhD, ABN > Mili Parikh, PhD, ABPP > Charles H. Hinkin, Ph.D., ABPP-CN > R. Dempsey, PsyD, ABPP, QME > Margaret A. Donohue, PhD > Samantha O'Bannon, Psy.D., Clinical Neuropsychologist PSY 32564 > William T.J. Johnson, Ph.D., ABPP-CN > Tony L. Strickland, MS, PhD, ABN, FNAN > Emmanuel A. Zamora, Psy.D., Neuropsychologist > Joshua McKeever, PhD, Clinical Neuropsychologist > Carmen C. Velazquez, Ph.D. > Anne Nolty, PhD, ABPP-CN > Grace Mucci, PhD, ABPdN > Tom Kiely, PhD > Joel Kramer, PsyD, ABPP-CN > Andrea Alioto, PhD, ABPP-CN > Johanna Rengifo, PhD > Ruth Serepca, PhD > Abigail Kramer, PhD > Sarah Banks, PhD, ABPP-CN > Arnold D. Purisch, Ph.D., ABPP-CN, ABN > Yuri Rassovsky, PhD, ABPP-CN > Lauren Keats, PsyD > Saskia DeVaughn, PhD, ABPP-CN > Katie Beckwith, PhD, ABPP-CN > Ashley Whitaker, PhD, ABPP-CN > Christian Carter, Ph.D., ABPP-CN > Melissa Balderrama, PsyD, ABPP > Hannah Brunet, PhD, ABPP-CN > Garima Lupas, PhD, ABPP, Board Certified in Clinical Neuropsychology > James A. Moses, Ph.D., ABPP-CN/CL > Bianca Georgescu, Psy.D., ABPP > Brandon Gavett, Ph.D. ABPP-CN > April Thames, PhD > Michelle Conover, Ph.D., QME > Daniel Jacobson, PhD, ABPP-CN > Carlos Saucedo, PhD, ABPP-CN > Sharon H. O'Neil, PhD, ABPP-CN > Audrey Khatchikia, PhD > Natalie C. Kelly, PhD, ABPP-CN > Shital Pavawalla, Ph.D., ABPP-CN > Alexander Tan, Ph.D., ABPP-CN > Phuong M. Chau, PhD ABPP-CN > Deborah Budding, Ph.D., ABN > > > > > CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
AI Analysis:
This message does not mention Judge Goodman at all. It is a brief comment by Antonio Castillo III about 'Delis' not being a signatory, likely referencing a neuropsychologist or expert in the context of a DME raw data or recusal matter. There is no reference to Judge Goodman, their rulings, courtroom behavior, or any other information that would be useful for evaluating them as a judge.
Interestingly, Delis isn't a signatory.
AI Analysis:
This message does not mention Judge Goodman at all. It is a discussion between attorneys (Delavar Omidfar and Andrew Zeytuntsyan) about neuropsychological DME raw data disclosure, a writ that was granted reversing a court order, and a request for case information. While it involves a judge's ruling, that judge is not identified as Goodman. There is no reference to Judge Goodman by name or any variation thereof, and no information that would help evaluate Goodman as a judge.
"Delavar Omidfar" Date: September 19, 2025 5:58:00 PM Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal Reply to list Reply to sender Print List: caala-workproduct Sent by: Delavar Omidfar (Reply Privately) Search Andrew - Do you have the case information or copies of the App Case? -----Original Message----- From: andrew@a2zlegal.com Sent: September 17, 2025 6:35:00 PM To: caala-workproduct@lists.trialsmith.com Subject: Re: Neuropsych Declaration re DME Raw Data and Recusal This is nonsense. I had to take up a writ where the judge would not allow them to turn over the data to us and my writ was granted, court order reversed. If I remember correctly they included this garbage in their opposition as well but the Appellate Court did not buy it. Andrew Zeytuntsyan Founder / Trial Attorney [https://storage-use.letsignit.com/62705ddc173a9394d8bcc888/logo_62705ddc173a9394d8bcc888_e895719889494628d401a7b8776c8039.png] 1306 W. Magnolia Blvd. Burbank, CA 91506 T. (323) 882-6500 F. (800) 506-7176 a2zlegal.com<https://cloud.letsignit.com/collect/bc/627076c3c8565ddc6ca471ae?p=L3lrFhURv2eXFz8AUdcQMg7oZ5M7umbVf2WSzpdzFq7D1iSXrK3ZaujaqDpZOQqyzyjZl0xri-GrOODYWlP3QLZm0iplL-zlOXM4lSHQ28oSIcbvk9_JHfvcYEayMxKfUiuqgPOYkIcclIOWPouVUq8U-TmlvnN27_c7uQRHayw=> [https://storage-use.letsignit.com/62705ddc173a9394d8bcc888/253796901116998898398879131612511431317.png] The information in this electronic mail message is confidential and for use of only the named recipient. The information may be protected by privilege, work product immunity or other applicable law. If you are not the intended recipient the retention, dissemination, distribution or copying of this e-mail message is strictly prohibited. If you receive this message in error please notify us immediately. ________________________________ From: Delavar Omidfar (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Friday, September 12, 2025 3:15 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal List: caala-workproduct Sent by: Delavar Omidfar (Reply Privately)<mailto:domidfar@makkabilaw.com?subject=Re%3A%20Neuropsych%20Declaration%20re%20DME%20Raw%20Data%20and%20Recusal> Search<http://www.caala.org/index.cfm?pg=search> Mates, I was recently provided with the attached declaration signed by over 180 neuropsychologists and psychologists regarding the protection of psychological testing materials. Most importantly, all signatories have declared: "I would not agree to releasing protected test information that would jeopardize future use of tests to a non-psychologist, including attorneys, even under a protective order. If this stipulation cannot be met, I would recuse myself from a case." My suspicion is that some of these same psychologists have previously agreed to perform mental examinations and released raw data under protective orders. If true, this creates a significant inconsistency that could be used to challenge their credibility and position. I'm reaching out to see if any of you have: 1. Documentation of any of these 185 signatories previously agreeing to release raw test data under protective order 2. Thoughts on strategies for overcoming this collective stance in future cases 3. Legal precedents, other than Randy's Trucking, that could compel production despite this declaration 4. Counter Declaration by psychs who can counter their arguments about test security The complete list of 185 signatories is below. Notable names include many prominent California neuropsychologists who regularly serve as defense experts, i.e. Hinkin, Boone, Kopald, Lechuga, Hooker, Bondi, Elliot, Zamora. List of Signatories Catherine Marreiro, PhD, ABPP-CN Kyle Boone, PhD, ABPP-CN William McMullen Jr., PhD, ABPP-CN Delia M. Silva, Psy.D., ABPP-CN, Neuropsychologist Lauren Drag, PhD, ABPP-CN Maya Yutsis, PhD, ABPP-CN Katherine Kruser, Psy.D., Neuropsychologist Jeffrey Wertheimer, PhD, ABPP-CN Jay Rosen, PhD Michelle Zeller, Psy.D., ABPP-CN Deborah Cahn-Weiner, Ph.D., ABPP-CN Mi-Yeoung Jo, PsyD, ABPP-CN Talin Babikian, PhD, ABPP-CN Molly Memel, PhD, ABPP-CN Rebecca Goodman, PhD, ABPP-CN Haygoush Kalinian, PhD, Clinical Neuropsychologist Robert M. Bilder, PhD, ABPP-CN Robert Gray, PhD, ABPP-CN Amir Ramezani, PhD Leah Ellenberg, Ph. D., ABPP-CN Charles Filanosky, PhD, ABPP-RP Po-Haong Lu, PsyD Angela Eastvold, PhD, ABPP-CN Maura Mitrushina, Ph.D., ABPP-CN Ann Gottuso, PhD, ABPP-CN Gayle Deutsch, PhD, ABPP-CN Simon Tan PsyD, ABPP-CN Andrew Levine, PhD, ABPP-CN Ernest T. Bryant, PhD, ABPP-CN John Wager, PhD, ABPP-CN Dominique Kinney, PhD, ABPP-CN Brandon Kopald, Psy.D., ABPP-CN Frederick Hives II, PhD, ABPP-CN Lars Hungerford, PhD, ABPP-CN Karen L. Schiltz, PhD, Neuropsychologist Tara L. Victor, PhD, ABPP-CN Shelley Peery, PhD Karen Lau, PhD, ABPP-CN Robert Tomaszewski, PhD, ABPP-CN David M. Lechuga, PhD, ABPP, ABN Elma Chidekel, PhD, ABN, ABPdN William D. Hooker, Ph.D., ABN Dale Sherman, PhD, QME June Paltzer, PhD, ABPP-CN Karen Earnest, PhD, ABPP-CN John Bellone, PhD, ABPP-CN Erin Green-Krogmann, PhD, ABPP-CN Virginia Zuverza-Chavarria, PhD, ABPP-CN Kimberly Lanni, PhD, ABPP, Board Certified in Clinical Neuropsychology Mark Alfano, Ph.D., ABPP CN, RP Steve Nitch, Ph. D., ABPP-CN Kristina Agbayani, PhD, ABPP-CN Andrew L. Wong, PhD, ABPP-CN Jessica Foley, PhD, ABPP-CN Andrew Dean, Ph. D., ABPP-CN Allison R. Kaup, PhD Mark W. Bondi, PhD, ABPP-CN Jose M. Lafosse, Ph.D., ABPP-CN Philip Sayegh, PhD, MPH Sara Mason, PsyD Kimberly Miller, PhD, ABPP-CN Hayley Kristinsson, PsyD, ABPP-CN Michael H. Kabat, Ph.D., ABPP-CN Brigid Rose, PhD, ABPP-CN Roger Light, PhD, ABPP-CN Jeremy Jinkerson, PhD David D. O'Grady, Ph.D., ABPP-CN Anneliese Radke, Psy.D. Joanne M. Hamilton, ABPP-CN Travis G. Fogel, Ph.D., ABPP-CN Sarah Tomaszewski Farias, Ph.D. ABPP-CN Allyson C. Rosen, PhD, ABPP-CN Sabine Gysens, PhD George Kahle Henry, PhD. ABPP-CN Kirsty Bortnik, PhD, ABPP-CN Joelle Broffman, PsyD, ABPP-CN Kristin K. Jacobson, PsyD, ABPP-CN Alice Ruzicka, Ph.D., ABN Renee Low, Ph.D., ABN Stacy S Wilkins, PhD, ABPP/CN Christine M. Naber, PhD Aura Barragan, Psy.D. Richard L. Delmonico, PhD, Licensed Psychologist CA PSY12604, Clinical Neuropsychologist Lauren Bennett, PhD, ABPP-CN William J. Lynch, Ph.D., ABPP/CN, Licensed Psychologist [PSY 5151] Rujvi Kamat, PhD, ABPP-CN Krista Freeze, PhD, ABN Carrie R. McDonald, Ph.D., ABPP-CN Nancy A. Blum, Ph.D. Travis Shivley-Scott, PhD Karen Mikolic, PhD, ABN Talia Seider, PhD, ABPP-CN Heather Pedersen, PhD, ABPP-CN Michael DeBellis Psy.D., ABN Nicholas Thaler, PhD, ABPP-CN Caroline J. Grantz, PhD Philip K. Stenquist, Ph.D., ABPP-CN Brian Yochim, PhD, ABPP-CN Olivia Harner, PhD, ABPP David Anderson, PhD, ABPP-CN/CI Alexis D. Kulick, Ph.D., ABPP Lori Holt, PhD, ABPP-CN Joel S. Eppig, Ph.D. Delany Thrasher, Ph.D., ABPP-CN Annie Reader Murray, Ph.D., ABPP-CN Jeffrey M. Zulow, Ph.D. Kaitlin B. Casaletto, PhD, ABPP-CN Alexandra Apple, PhD Hope Goldberg, PhD, ABPP-CN William C. Hochberger, PhD Paul Mangal, PhD Virdette L. Brumm, Ph.D. Christy Hom, PhD, ABPdN Eric J. Freitag, PsyD, FACPN Howard J. Friedman, ABPP (CN), ABN Jonathan E. Romain, PhD, MS, ABPP-CN Patricia Gross, PhD, ABPP-CN Katie Denny PhD, ABPP-CN Katherine Bangen, PhD, ABPP-CN Lisa Graves, PhD John Knippa, PhD, ABN Ashley K. Miller, PhD, ABPP-CN Karen Hanson Bondi, Ph.D. Lori Alasantro, PhD, ABPP-CN Amanda Gooding, PhD, ABPP-CN Anita Herrera-Hamilton, Ph.D ABPP Caitlin Moore, PHD, ABPP William Britt, PhD, ABN Janet K. Brewer, JD, PsyD Mimi Wong, PhD, ABPP-CN Charles Furst, PhD, ABPP-CN Robert W. Elliott, PhD, ABCN, ABN Amy M. Schonfeld, PhD, Clinical Neuropsychologist Brian A. Osterweil, Ph.D., ABPP Duke Han, PhD, ABPP-CN Lisa Delano-Wood, PhD Kimberly Alfano, PhD, ABPP (CN, RP) Alena Stasenko, PhD Inna Fishman, PhD Annette Swain PhD ABPP-CN Monica Smith, PhD, ABN Mili Parikh, PhD, ABPP Charles H. Hinkin, Ph.D., ABPP-CN R. Dempsey, PsyD, ABPP, QME Margaret A. Donohue, PhD Samantha O'Bannon, Psy.D., Clinical Neuropsychologist PSY 32564 William T.J. Johnson, Ph.D., ABPP-CN Tony L. Strickland, MS, PhD, ABN, FNAN Emmanuel A. Zamora, Psy.D., Neuropsychologist Joshua McKeever, PhD, Clinical Neuropsychologist Carmen C. Velazquez, Ph.D. Anne Nolty, PhD, ABPP-CN Grace Mucci, PhD, ABPdN Tom Kiely, PhD Joel Kramer, PsyD, ABPP-CN Andrea Alioto, PhD, ABPP-CN Johanna Rengifo, PhD Ruth Serepca, PhD Abigail Kramer, PhD Sarah Banks, PhD, ABPP-CN Arnold D. Purisch, Ph.D., ABPP-CN, ABN Yuri Rassovsky, PhD, ABPP-CN Lauren Keats, PsyD Saskia DeVaughn, PhD, ABPP-CN Katie Beckwith, PhD, ABPP-CN Ashley Whitaker, PhD, ABPP-CN Christian Carter, Ph.D., ABPP-CN Melissa Balderrama, PsyD, ABPP Hannah Brunet, PhD, ABPP-CN Garima Lupas, PhD, ABPP, Board Certified in Clinical Neuropsychology James A. Moses, Ph.D., ABPP-CN/CL Bianca Georgescu, Psy.D., ABPP Brandon Gavett, Ph.D. ABPP-CN April Thames, PhD Michelle Conover, Ph.D., QME Daniel Jacobson, PhD, ABPP-CN Carlos Saucedo, PhD, ABPP-CN Sharon H. O'Neil, PhD, ABPP-CN Audrey Khatchikia, PhD Natalie C. Kelly, PhD, ABPP-CN Shital Pavawalla, Ph.D., ABPP-CN Alexander Tan, Ph.D., ABPP-CN Phuong M. Chau, PhD ABPP-CN Deborah Budding, Ph.D., ABN
AI Analysis:
This message does not mention 'goodman' at all. The subject line references 'Neuropsych Declaration re DME Raw Data and Recusal' and the message appears to be from the CAALA Work Product Discussion List, authored by Andrew Zeytuntsyan and Delavar Omidfar. There is no mention of Judge Goodman, no rulings, no courtroom behavior, and no context related to the judge being evaluated. The message is entirely unrelated to evaluating Judge Goodman.
From: Delavar Omidfar (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Friday, September 12, 2025 3:15 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal
AI Analysis:
The 'Goodman' mentioned in this message is Todd Goodman, an attorney (caala-workproduct listserver member) recommending a case management software called 'PIP' from Hipersoft. This is not a judge named Goodman. The message is entirely about PI case management software recommendations and has no substantive information about any judge's rulings, courtroom behavior, demeanor, or case management style that would be useful for evaluating a workers' compensation judge.
"William Mitchell Margolin Attorney at Law" Date: February 28, 2024 6:47:00 PM Subject: Re: INQUIRY: NON CLOUD BASED EASY PI CASE MANAGEMENT PROGRAM Reply to list Reply to sender Print List: caala-workproduct Sent by: William Margolin (Reply Privately) Search TY John From: John Rosenberg (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Date: Wednesday, February 28, 2024 at 12:10 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re: [caala-workproduct] INQUIRY: NON CLOUD BASED EASY PI CASE MANAGEMENT PROGRAM List: caala-workproduct Sent by: John Rosenberg (Reply Privately) Search I used PIP for about twelve years. It was a good program and John Maxwell worked very hard to support it. I switched to Filevine about 5 years ago. I don't know about the changes and improvements that John has made to PIP in the interim, but when I switched to Filevine the increased power and functionality was amazing. One of the things I like about having a cloud based solution is my access to case information from anywhere. This includes while in court, in mediations, in depositions or on vacation. I find that being cloud based is a valuable asset. I have not had any problems with a cloud based solution, although I admit that any cloud solution could be hacked and cause interruptions of service and security breaches or other problems, but so far, this has not happened either with Filevine or other cloud based systems that I use and rely on to run my practice. On Wed, Feb 28, 2024 at 10:35 AM Todd Goodman (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: Todd Goodman (Reply Privately) Search I use for more than 20 years a program called "PIP" PRACTICE INFORMATION POWERTOOL from Hipersoft. It is a non-cloud based PI case management program, based on Filemaker Pro. Runs on a Mac, and also I believe on a PC. Fairly inexpensive, around 390.00 per year, a bit more if you want it to share with other computers in the office. It can also be used via the cloud, but I don't like that kind of information floating out in the cloud, so if I want to have it with me on say my laptop, I scan the file to a thumb drive and take it with me with the needed info. You can contact the owner of Hipersoft, John Maxwell, at 951-840-7624 or go to www.hipersoft.com Call me if you have any further questions Todd Goodman William Margolin (caala-workproduct listserver) wrote on 2/28/24 10:13 AM: List: caala-workproduct Sent by: William Margolin (Reply Privately) Search DEAR CAALA: What Case Management programs are inexpensive for small/or solo practice for PI Primary Practice that works with MAC and PC..that you can recommend? I used to go to “Legaltech” at Bonaventure Hotel and get the rundown on new ones but I don’t think they do that convention anymore since Covid. TY BILL William Mitchell Margolin Attorney at Law- A Professional Law Corporation 23548 Calabasas Road, Suite 202 Calabasas, California 91302 (818) 999-4LAW (4529) Fax: (818) 999-1956 email: legalhelpforyou@msn.com 2010 Candidate for California Superior Court Judge, Los Angeles County SUPER LAWYERS (SOUTHERN CALIFORNIA) 2009, 2010, 2011, 2012, 2015, 2016, 2017, 2018, 2019, 2020, 2021, 2022, 2023, 2024 MARTINDALE HUBBLE - AMERICAN REGISTRY--Congratulations on being in the top 1% of more than 900,000 attorneys in the U.S.! 30 year Member-Consumer Attorney Association of Los Angeles & California. This electronic mail (email) message, including any attachments, is intended for the use of the person or entity to which it is addressed and may contain information that is privileged and confidential, the disclosure of which is governed by applicable law. If the reader of this message is not the intended recipient, or the employee or agent responsible to deliver it to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this information is STRICTLY PROHIBITED. -- Todd W. Goodman, APC P.O. Box 3094 Thousand Oaks, CA 91359 T: 805-494-4615 F: 805-494-4618 law@toddgoodman.com -- John P. Rosenberg, Esq. Law Offices of John P. Rosenberg, PLC 6355 Topanga Canyon Boulevard, Suite 515 Woodland Hills, CA 91367 818 716 6400 jrosenberg@jrosenberg.com This message is a confidential communication from a law firm. Interception of this message is a violation of the Electronic Communications Privacy Act, 18 U.S.C. 2510-2521 and 2707-2709. This message may be protected by the attorney-client privilege and/or the attorney work-product doctrine. If you are not the intended recipient of this message, any disclosure, copying, distribution or use of the information contained in or attached to this message is prohibited. If you have received this message in error, please immediately delete the message and any attachments, and notify me at 818 716-6400. Thank you.
AI Analysis:
The 'Goodman' mentioned in this message is Todd Goodman, an attorney on the CAALA work product listserv, not a judge. The message is part of a thread discussing non-cloud-based PI case management software programs. There is no mention of any judge named Goodman, no discussion of judicial rulings, courtroom behavior, or any information that would help evaluate a workers' compensation judge named Goodman.
"William Mitchell Margolin Attorney at Law" Date: February 28, 2024 6:46:00 PM Subject: Re: INQUIRY: NON CLOUD BASED EASY PI CASE MANAGEMENT PROGRAM Reply to list Reply to sender Print List: caala-workproduct Sent by: William Margolin (Reply Privately) Search Thank you HO From: Howard Blumenthal (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Date: Wednesday, February 28, 2024 at 12:47 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re: [caala-workproduct] INQUIRY: NON CLOUD BASED EASY PI CASE MANAGEMENT PROGRAM List: caala-workproduct Sent by: Howard Blumenthal (Reply Privately) Search CASEpeer is less than 100 bucks a month Howard S. Blumenthal Blumenthal Law 424-260-1816 On Feb 28, 2024, at 12:10 PM, John Rosenberg (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> wrote: List: caala-workproduct Sent by: John Rosenberg (Reply Privately) Search I used PIP for about twelve years. It was a good program and John Maxwell worked very hard to support it. I switched to Filevine about 5 years ago. I don't know about the changes and improvements that John has made to PIP in the interim, but when I switched to Filevine the increased power and functionality was amazing. One of the things I like about having a cloud based solution is my access to case information from anywhere. This includes while in court, in mediations, in depositions or on vacation. I find that being cloud based is a valuable asset. I have not had any problems with a cloud based solution, although I admit that any cloud solution could be hacked and cause interruptions of service and security breaches or other problems, but so far, this has not happened either with Filevine or other cloud based systems that I use and rely on to run my practice. On Wed, Feb 28, 2024 at 10:35 AM Todd Goodman (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote: List: caala-workproduct Sent by: Todd Goodman (Reply Privately) Search I use for more than 20 years a program called "PIP" PRACTICE INFORMATION POWERTOOL from Hipersoft. It is a non-cloud based PI case management program, based on Filemaker Pro. Runs on a Mac, and also I believe on a PC. Fairly inexpensive, around 390.00 per year, a bit more if you want it to share with other computers in the office. It can also be used via the cloud, but I don't like that kind of information floating out in the cloud, so if I want to have it with me on say my laptop, I scan the file to a thumb drive and take it with me with the needed info. You can contact the owner of Hipersoft, John Maxwell, at 951-840-7624 or go to www.hipersoft.com Call me if you have any further questions Todd Goodman William Margolin (caala-workproduct listserver) wrote on 2/28/24 10:13 AM: List: caala-workproduct Sent by: William Margolin (Reply Privately) Search DEAR CAALA: What Case Management programs are inexpensive for small/or solo practice for PI Primary Practice that works with MAC and PC..that you can recommend? I used to go to “Legaltech” at Bonaventure Hotel and get the rundown on new ones but I don’t think they do that convention anymore since Covid. TY BILL William Mitchell Margolin Attorney at Law- A Professional Law Corporation 23548 Calabasas Road, Suite 202 Calabasas, California 91302 (818) 999-4LAW (4529) Fax: (818) 999-1956 email: legalhelpforyou@msn.com 2010 Candidate for California Superior Court Judge, Los Angeles County SUPER LAWYERS (SOUTHERN CALIFORNIA) 2009, 2010, 2011, 2012, 2015, 2016, 2017, 2018, 2019, 2020, 2021, 2022, 2023, 2024 MARTINDALE HUBBLE - AMERICAN REGISTRY--Congratulations on being in the top 1% of more than 900,000 attorneys in the U.S.! 30 year Member-Consumer Attorney Association of Los Angeles & California. This electronic mail (email) message, including any attachments, is intended for the use of the person or entity to which it is addressed and may contain information that is privileged and confidential, the disclosure of which is governed by applicable law. If the reader of this message is not the intended recipient, or the employee or agent responsible to deliver it to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this information is STRICTLY PROHIBITED. -- Todd W. Goodman, APC P.O. Box 3094 Thousand Oaks, CA 91359 T: 805-494-4615 F: 805-494-4618 law@toddgoodman.com -- John P. Rosenberg, Esq. Law Offices of John P. Rosenberg, PLC 6355 Topanga Canyon Boulevard, Suite 515 Woodland Hills, CA 91367 818 716 6400 jrosenberg@jrosenberg.com This message is a confidential communication from a law firm. Interception of this message is a violation of the Electronic Communications Privacy Act, 18 U.S.C. 2510-2521 and 2707-2709. This message may be protected by the attorney-client privilege and/or the attorney work-product doctrine. If you are not the intended recipient of this message, any disclosure, copying, distribution or use of the information contained in or attached to this message is prohibited. If you have received this message in error, please immediately delete the message and any attachments, and notify me at 818 716-6400. Thank you.
AI Analysis:
This message is about SoCal hearing loss and urology strikes, and contains no mention of Judge Goodman by name or any variation thereof. The message header only shows sender/recipient information and a subject line unrelated to any judge evaluation. There is no substantive content visible that references Goodman or any rulings, decisions, or courtroom behavior relevant to evaluating this judge.
From: Ibrahim Ellahib (lawnet listserver) <listsender-lawnet@lawnet.caaa.org> Sent: Thursday, October 6, 2022 4:39:53 PM To: Statewide List Service <lawnet@lawnet.caaa.org> Subject: [lawnet] SoCal hearing loss and urology strikes
AI Analysis:
The message contains no substantive information about Judge Goodman. It is merely an email header/metadata showing a forwarded digest email from the California Applicants' Attorneys Association, with no body content that mentions or discusses the judge in any way. There is no ruling, opinion, case reference, or any other evaluative information present.
On Dec 8, 2021, at 2:43 AM, California Applicants' Attorneys Association <listsender@lawnet.caaa.org> wrote:
AI Analysis:
This message does not mention Judge Goodman at all. It is a discussion about TTD rate calculation methodology, earning capacity, and SDI payments in workers' compensation cases. The only judge mentioned by name is 'WCJ Kosta' in the attached case law excerpt. The message contains no information about Judge Goodman's rulings, behavior, demeanor, or any cases before them.
"M. Hollie Rutkowski" Date: June 28, 2021 4:54:00 PM Subject: Re: Do EDD payments count as wages in TTD rate calculation? Reply to list Reply to sender Print List: lawnet Sent By: Hollie Rutkowski Reply To Sender Reply To List Search Settings You are correct about the earning capacity for TD should not take into account the 3 months she was out because she normally worked these months in the past. You don't count SDI that she received while off work as equivalent to wages she would have received. I would tally all her actual wages for period of a year, NOT counting the 3 months off, so count one year and three months (15 months) of earnings, but divide actual earnings by 12 months. Also try it another way - one year of earnings and divide by 9 months. See which one comes out higher. Then use the calculation that comes out higher. Don't forget to recalculate if hourly rate rose in the middle of the pay period you are using. I find that WCJ's will accept whatever calculation you have and WCJ is not going to sit there and re-calculate to see if your calculations are correct. I can assure you that the DA will raise arguments for which DA has no statutory or case law. So, I have attached case law on Earnings Capacity for TD: ARGUMENT AND APPLICABLE LAW Earnings capacity for the purposed of temporary disability is determined at the time of injury. The parties stipulated that Applicant’s earnings were $840.00 per week. Normally, this would take care of the issue of earning capacity. WCJ Kosta either overlooked or disregarded this stipulation in her determination. Earning capacity for the purposes of temporary disability is determined at the time of injury. Case law has developed the preeminence of “earning capacity” and the factors that are considered in its determination. All facts relevant and helpful to making an estimate of earning capacity must be considered; Grossmont Hospital v. WCAB (Kyllonen), (1997)59 CA4th 1348, 62 CCC 1649. In Argonaut Ins. Co. v. Industrial Acc. Com. (1962) 57 Cal.2d 589, 21 Cal.Rptr. 545, 371 P.2d 281 (referred to as the Montana decision), The California Supreme Court found that earning capacity at the time of injury is composed of the ability, willingness and opportunity to work. The purpose of the “earning capacity” provision is to equalize the position of the full-time, regularly employed worker and that of the worker whose wage may be a distorted basis for estimating true earning power. The Court in Montana stated “[a]n estimate of earning capacity is a prediction of what an employee's earnings would have been had he not been injured. The applicant's ability to work, his age and health, his willingness and opportunities to work, his skill and education, the general condition of the labor market, and employment opportunities for persons similarly situated are all relevant.” All facts relevant and helpful to making an estimate of earning capacity must be considered. The question is whether an applicant would have continued working at a given wage for the duration of the disability. In Grossmont Hospital v. WCAB (Kyllonen) (supra),the fourth District Court of Appeal held that temporary disability benefits must be calculated with reference to circumstances which are known or could reasonably be anticipated at the time of injury. In deciding what temporary disability benefits to pay an injured worker, an employer must consider both the anticipated duration of the disability, a function of the nature of the injury and the normal duration of the disability associated with that injury, and any factors which reasonably would affect the worker's earning capacity during the anticipated period of disability. In the instant case, the parties stipulated that Applicant’s earnings were $840.00 per week. This stipulations, it is inferred, took into consideration the applicant's ability to work, his age and health, his willingness and opportunities to work, his skill and education, the general condition of the labor market, and employment opportunities for persons similarly situated. In addition to the stipulated earnings, the Defense Witness admitted that modified work was available and continued to be available. The Defense Witness admitted that the two people who could have offered modified work had no opportunity to do so because the Defense Witness failed to inform them that Applicant was restricted to modified work because of his industrial injury. The Defense did not prove any factor which would indicate that Applicant had an earning capacity of zero on January 26, 2015. There is no allegation by the Defense that Applicant was a seasonal worker and the season ended or that he worked sporadically and he commonly chose not to work or he that he was generally unemployed and unemployable. The Defense did not claim that Applicant was a bad worker such that he was chronically on the verge of being fired. The Defense did not claim that Applicant was about to retire and remove himself from the workforce. The Defense did not claim that the Employer was going out or business so no work would ever be available again or that the condition of the labor market in construction was so dismal that no carpenter could find work. The sole factor that the Defense produced concerning earning capacity was a temporary work slow-down occurring sometime in December 2014 necessitating the lay off of some of the employer’s workforce and that some of those people had since been hired back. Applicant avers that this was a temporary work slow-down because the Employer was obviously still in business at the time of Trial on April 28, 2015; Doug Albright testified that he had been with the Employer for 21 years. As evidence that this was a temporary work slow down, Applicant testified that the foreman of the West Sacramento job, Mike Pinola, laid Applicant off on December 12, 2014 and told Applicant to take a week off. Applicant testified that the next job was in Fairfield and Applicant was to show up on December 31, 2014, then Applicant was told to show up on January 7, 2015. Considering the time of the year, a work slow down was inevitable. December 12, 2014 was a Friday. Applicant took the week off to the next Friday, December 19, 2014. The next Monday was December 22, 2014, three days before Christmas. Presumably, the West Sacramento job was completed before Christmas and no jobs were scheduled during the Christmas holiday. Apparently, the Fairfield job was delayed – Applicant got a call on December 23, 2014 telling him not to show up for the Fairfield job until January 7, 2015. The Defendant did not produce any evidence about the Fairfield job and why Applicant was laid off on January 6, 2015. The Defense witness admitted that he was not involved in hiring or lay offs, so getting accurate information from him about the Fairfield job and why Applicant was laid off the day before he was supposed to start the Fairfield job would have been futile. Applicant does not presume to know why he was laid off instead of returning to work at the Fairfield job. In addition, from the time of the injury on October 9, 2014 until the MRI on December 16, 2014, Applicant harbored a clandestine medical condition that would eventually be revealed to disable him. During this time that Applicant was released to full duty, Dr. Heilke did not perform any diagnostic studies. Dr. Stephanie Hawkins requested a lumbar MRI on November 14, 2014. The MRI was not done until more than a month later, on December 16, 2014. Dr. Jane Wang, did not interpret the MRI until 41 days later. At that time, January 26, 2015, Dr. Wang realized that Applicant should not have been working full duty all that time but should have been restricted to light work. It is Applicant’s information and belief Applicant’s pre-injury earning capacity was $840.00 per week. This was Applicant’s burden to prove; indeed, the Defendant stipulated to it. The Defendant’s burden was to prove that Applicant’s earning capacity was utterly and completely extinguished before January 26, 2015, and not because of his industrial injury. The Defendant did not produce any evidence of that. Lay off due to work slowdown does not extinguish the employee’s earning capacity. Post-injury earning capacity can be extinguished where the injured worker retires from the open labor market and in fact has demonstrated no intent to return to active employment; Liberty Mutual Insurance v. WCAB (Reimers) (W/D-2002) 67 CCC 1637. The employer can also disqualify himself from temporary disability benefits if the employee demonstrates that he is no longer incapacitated by his injury (e.g. working part-time or becoming a full-time student; Yates v. WCAB (W/D-1974) 39 CCC 653), or where the employer proves that the employee would have continued to be employed in suitable modified work but for misconduct by the employee resulting in his termination for cause; ( Butterball Turkey Co. v. WCAB (Esquivel) (W/D-1999) 65 CCC 61. The burden of proof is on the employer to prove that the employee did something to extinguish his earnings capacity. The Appeals Board should note that case law suggests it is not the employer who extinguishes the employee’s earning capacity. It is the employee who takes action to negate his earnings capacity by removing himself from the work force by choice or by misconduct. Applicant could find no case law that a temporary work slow down or a lay off means that the injured worker no longer has any earnings capacity. In the instant case, Applicant was laid off due to a work slowdown around the time of the Christmas holiday. The employer offered Applicant a job in Fairfield starting in January 2015. Applicant was laid off, but then some employees were hired back. Dr. Wang determined that Applicant’s medical condition restricted him to modified work in her report dated January 24, 2015. Applicant’s supervisor called him on April 29, 2015 asking Applicant if he wanted to work. These facts, and the stipulation to earnings of $840.00 per week, establish earnings capacity at $840.00 per week for the purposes of temporary disability commencing January 26, 2015. The Defendant did not produce any evidence to prove that Applicant’s earnings capacity went from $840.00 per week to zero because he would have remained laid off during the entirety of his anticipated disability, however long that would be. The Defendant did not produce any Defense witness who had that information. By failing to decide earnings capacity for the purposes of temporary disability, WCJ Kosta acted without or in excess of her powers. WCJ Kosta seemed to focus her attention on whether the Applicant self-restricted his work or whether he was working full duty. This is a red herring. What work activities Applicant was performing after October 9, 2014 was a distraction that mislead WCJ Kosta into looking at Applicant’s work as something other than a factor in Applicant’s earnings capacity. What Doug Albright and Applicant proved is that Applicant continued working after his injury without complaint. This demonstrates Applicant’s work ethic and his willingness and desire to work, factors in earnings capacity. Working without complaint is not a bad thing in an employee. WCJ Kosta chose to view this evidence of Applicant’s work ethic and desire and willingness to work as her test for credibility, not as a factor proving the existence of earnings capacity. WCJ Kosta also did not recognize that it is common sense that an injured worker who is released to full duty is not going to admit to the Safety guy that he is working less than full duty. Likewise, the injured worker’s foreman is not going to admit to the Safety guy that he is letting Applicant work less than full duty. This type of “slacking” just might cause the Safety guy to alert Mrs. Scanlon and Goodman that both the injured worker and his foreman ought to be canned. WCJ Kosta then focused on the lay off, but relied on wayward case law to support her position that “modified duty would have been extended to applicant but for the fact that applicant was laid off”. She relied on Huston v. WCAB (1979) 44 CCC 708. In Huston , the employee had back surgery in 1975 and again in 1976. In 1977, Huston went to Venezuela looking into a work opportunity for a potential employer. The Defendant agreed to continue paying temporary disability; the WCJ memorialized the agreement in the Minutes of Hearing: "Good Cause Appearing Therefor: It Is Ordered that the above entitled case be taken off calendar. Defendant to pick up temporary disability and will file a Petition to Terminate." Thereafter, Applicant commenced self-employment driving truck from Long Beach and Lompoc three or four days a week. The Defendant petitioned to terminate temporary disability and asserted a temporary disability overpayment for temporary disability paid, despite the Order. The issues in Huston were whether the agreement constituted a Stipulation, whether the Defendant got credit for a temporary disability overpayment, and the percentage of permanent disability. WCJ Kosta chose to rely on this item in Huston: “If the partially disabled worker can perform some type of work but chooses not to, his ‘probable earning ability’ will be used to compute wage-loss compensation for partial disability. If the temporary partial disability is such that it effectively prevents the employee from performing any duty for which the worker is skilled or there is no showing by the employer that work is available and offered , the wage loss is deemed total and the injured worker is entitled to temporary total disability payments (emphasis by WCJ Kosta, not in the original).” Applicant is not sure what to make of WCJ Kosta’s reliance on this case, on this passage and especially on WCJ’s Kosta’s emphasis “ or there is no showing by the employer that work is available and offered ”. There is no dispute in the instant case that modified work was available. There is no dispute in the instant case that the people who could have offered Applicant modified work did not even know that Applicant had work restrictions. What Applicant does glean from WCJ Kosta’s analysis is that she did not look at any of the factors that determine earnings capacity for the purpose of temporary disability. WCJ Kosta did not mention that the Defendant stipulated that Applicant’s earnings were $840.00 per week; see first paragraph of Opinion on Decision . WCJ Kosta believed that Applicant was laid off before a doctor imposed work restrictions was dispositive; see last paragraph of Opinion on Decision . In between the first and the last paragraphs of the Opinion on Decision, WCJ Kosta did not consider the circumstances which are known or could reasonably be anticipated at the time of the injury. Applicant’s injury was much more severe than the doctor who returned Applicant to full duty, Dr. Heilke, ever considered; this was shown by the MRI on December 16, 2014 and Dr. Wang’s work restrictions on January 26, 2015. Obviously, if the annular fissure had torn or one of the disc bulges had turned into a herniated disc because Applicant was working full duty, this would have proved that Dr. Heilke should have performed a diagnostic test before returning Applicant to regular duty. The employer was fortunate that Applicant did not suffer a reinjury due to the clandestine disc protrusions and annular fissure that were only discovered by Dr. Wang three and a half months after the injury. WCJ Kosta ignored the anticipated duration of the disability or the nature of the injury and the normal duration of the disability associated with that injury. WCJ Kosta did not mention any doctors’ reports in her Opinion on Decision except to note in passing that Dr. Wang established work restrictions on January 26, 2015 and Applicant had been laid of by that time. WCJ Kosta ignored the reporting of Dr. Wang, Dr. Shin and Dr. Jennings entirely. All three doctors stated that Applicant’s condition would not be permanent and stationary until he received further treatment, variously suggested as medical branch blocks, physical and chiropractic therapy, medications and exercise. The salient point for WCJ Kosta to consider was whether the work slowdown would have lasted as long as the Applicant’s disability, but WCJ Kosta missed that point. WCJ Kosta also failed to consider that the Defendant did not attempt to prove, and did not prove, that Applicant would never have been hired back after he was laid off. The Defense witness that Defendant relied upon was not, by his own admission, involved in hiring and lay offs. The people who were involved in hiring and lay offs were not called to testify. WCJ Kosta did not consider “all facts relevant and helpful to making an estimate of earning capacity” and she did not answer the question, “Whether this applicant would have continued working at a given wage for the duration of his disability,” as she was required to do. She ignored the evidence that the work slowdown occurred during the Christmas holiday, that the Fairfield job was to start in January and that the employer had hired back some laid off employees. The newly discovered evidence that Foreman Mike Pinacola asked Applicant whether he wanted to work strengthens the implication that the work slowdown was not permanent, as WCJ Kosta appears to have deduced. By failing to decide earnings capacity for the purposes of temporary disability, WCJ Kosta acted without or in excess of her powers. The evidence does not justify the findings of fact. On the evidence presented, WCJ Darcy Kosta concluded, “[D]efendant has proven that modified duties would have been offered had applicant not been laid off.” WCJ Kosta opined that “the preponderance of the evidence” of this conclusion, “ that modified duties would have been offered had applicant not been laid off,” was supplied by the “credible testimony” of Doug Albright. WCJ Kosta misconstrued the evidence and assumed facts not in evidence. Even if this finding was dispositive of earnings capacity, which it is not, the evidence does not justify this findings of fact. Doug Albright did not testify that modified duties would have been extended to Applicant but for the fact that Applicant was laid off. In the first place, Doug Albright did not have the authority to hire Applicant or offer him modified duty; Mark Scanlon and Greg Goodman had that authority and they were not present to testify what they would do. In the second place, Doug Albright never apprised Mark Scanlon and Greg Goodman about Applicant’s change of work status, so they never had the opportunity to offer Applicant modified work, or decline to offer Applicant modified work, or say what they would do had they known that Dr. Wang imposed work restrictions. Doug Albright testified that he does not know if people are still employees after they are laid off; Mr. Scanlon would know if people who are laid off are no longer employees. Thus, the question of whether Applicant was an employee on January 26, 2015 is still up in the air, but he could have been. If Applicant was still an employee entitled to modified work, Doug Albright said all employees who need modified work get modified work, so had Doug Albright informed Mark Scanlon and Greg Goodman that Applicant needed modified work, Applicant would have been given modified work. This scenario is just as likely as the scenario WCJ Kosta picked using exactly the same evidence, yet coming to a an entirely different outcome. The facts presented demonstrate that WCJ Kosta’s finding, “modified duties would have been extended to Applicant but for the fact that Applicant was laid off,” is surmise and speculation. Hollie Rutkowski, RN, JD, MBA, Esq. The Compensation Law Center Sacramento, CA 95834 T:916.974.0424 F:916.974.0428 From: "Jennifer Ryan (lawnet listserver)" <listsender@lawnet.caaa.org> To: "Statewide List Service" <lawnet@lawnet.caaa.org> Sent: Monday, June 28, 2021 2:30:09 PM Subject: [lawnet] Do EDD payments count as wages in TTD rate calculation? List: lawnet Sent By: Jennifer Ryan Reply To Sender Reply To List Search Settings Hi all, I have a client who has been employed for about 3 years by the present employer. She was out of work from July to October of 2020 due to an injury at home. She received EDD payments. When she returned to work in October 2020 she had an admitted work related injury. The insurance company is paying her TTD but calculated her AWW by including no wages from July to October when she was out. My argument is she 2 fold, first - her earning capacity should not take into account the 3 months she was out because she normally worked these months in the past; and second, she received EDD so at the minimum the EDD payments should count towards her AWW. Defense will not adjust her rate. Is there any controlling case law on this issue? Thanks Jen
AI Analysis:
This message appears to be about a SoCal ENT (ear, nose, and throat) panel, likely referring to a medical panel or QME panel discussion. The message does not mention Judge Goodman by name, does not contain any rulings, decisions, courtroom behavior, or attorney opinions about the judge. The subject matter is entirely unrelated to evaluating Judge Goodman as a workers' compensation judge.
From: Kimberley J. Pryor (lawnet listserver) <listsender-lawnet@lawnet.caaa.org> Sent: Wednesday, June 3, 2026 1:33 PM To: Statewide List Service <lawnet@lawnet.caaa.org> Subject: [lawnet] SoCal ENT panel
AI Analysis:
This message is essentially just an email signature block from attorney Samer Habbas. It contains no substantive content about Judge Goodman — no rulings, decisions, courtroom behavior, opinions, or case references. The subject line mentions 'Neuropsych Declaration re DME Raw Data and Recusal' which could potentially relate to a case before Judge Goodman, but the body of the message contains zero information about the judge. There is nothing here that would help evaluate Goodman as a judge.
Samer Habbas LAW OFFICES OF SAMER HABBAS 200 Spectrum Center Drive Suite 1230 Irvine, CA 92618 Tel: (949) 727-9300 Fax: (949) 727-9308 ssh@habbaspilaw.com www.habbaspilaw.com This communication, including attachments, is confidential, may be subject to legal privileges, and is intended for the sole use of the addressee. Any use, duplication, disclosure or dissemination of this communication, other than by the addressee, is prohibited. If you have received this communication in error, please notify the sender immediately and delete or destroy this communication and all copies.
AI Analysis:
This message does not mention 'goodman' or any variation of that judge's name. The message appears to be about a neuropsychology declaration related to DME (Defense Medical Examination) raw data and recusal, exchanged on the CAALA Work Product Discussion List. There is no substantive information about Judge Goodman in this message — the judge's name does not appear at all. The message is not relevant for evaluating goodman as a judge.
From: Gregory Jackson (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Thursday, November 20, 2025 3:27 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal
AI Analysis:
This message does not mention 'goodman' at all. It appears to be an email thread from the CAALA Work Product Discussion List regarding a topic about 'Neuropsych Declaration re DME Raw Data and Recusal.' The message only contains sender/recipient information and a subject line, with no substantive content visible, and no reference to Judge Goodman in any form.
From: Gregory Jackson (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Thursday, November 20, 2025 3:01 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal
AI Analysis:
This message does not mention 'goodman' or any variation of that judge's name. The message appears to be about a neuropsychology declaration related to DME (Defense Medical Examination) raw data and recusal, exchanged on the CAALA Work Product Discussion List. There is no substantive information about Judge Goodman in this message — the judge's name does not appear anywhere in the content provided.
From: Gregory Jackson (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Thursday, November 20, 2025 2:10 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal
AI Analysis:
This message does not mention 'goodman' or any variation of that judge's name. The message appears to be about a neuropsychology declaration related to DME raw data and recusal, forwarded through the CAALA work product listserver. There is no substantive information about Judge Goodman in this message — the judge's name does not appear at all. The content is entirely unrelated to evaluating goodman as a judge.
From: Kane Handel (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Tuesday, November 4, 2025 11:05 AM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re: [caala-workproduct] Neuropsych Declaration re DME Raw Data and Recusal
AI Analysis:
While Hon. Geoffrey A. Goodman, Ret. is mentioned by name in the list of arbitrators, the message contains no substantive information about him. The message is simply a request for comments on a list of arbitrators — it does not include any opinions, experiences, rulings, demeanor descriptions, or evaluations of Goodman. There is no actionable information to help determine whether he is a good or bad judge/arbitrator. The name appears only in passing as part of a numbered list.
"Samar Hellar" Date: September 29, 2025 12:22:00 PM Subject: Arbitrators Reply to list Reply to sender Print List: caala-workproduct Sent by: Samar Hellar (Reply Privately) Search Comments on the following arbitrators for an uber case for strike list purposes: 1) Melissa B. Aliotti, Esq. 2) Hon. David De Alba, Ret. 3) Hon. Geoffrey A. Goodman, Ret. 4) Hon. Russell Hom, Ret. 5) Robert Jacobs, Esq. 6) Hon. Donald J. Sullivan, Ret. 7) Hon. Emily E. Vasquez, Ret. Thank you!
AI Analysis:
This message does not mention 'goodman' at all. It is a partial email thread about choosing arbitrators from a strike and rank list, authored by Kenneth Stern in reply to Aimee Kirby. The message body contains no substantive content beyond the reply header and attribution line — there is no mention of Judge Goodman, no rulings, no opinions, and no relevant context about the judge being evaluated. Additionally, this appears to be from a civil litigation listserver (CAALA), not a workers' compensation context.
On Mon, Mar 3, 2025, 1:00 PM Aimee Kirby (caala-workproduct listserver) < listsender-caala-workproduct@lists.trialsmith.com > wrote:
AI Analysis:
The message references 'Goodman v. Staples The Off. Superstore, LLC, 644 F.3d 817 (9th Cir. 2011)' as a legal case citation, not as a judge named Goodman. This is a federal appellate court case being cited as legal authority on the topic of expert witness disclosure rules. The 'Goodman' here is a party/litigant in a lawsuit, not a judge being evaluated. There is no substantive information about a judge named Goodman's rulings, behavior, demeanor, or case management that would be useful for evaluating them from a California workers' compensation attorney's perspective.
"Christian Contreras" Date: December 15, 2024 11:38:00 AM Subject: Re: Is there a federal version of Kennemur? Reply to list Reply to sender Print List: caala-workproduct Sent by: Christian Contreras (Reply Privately) Search Hi Chris, Both Fed. R. Civ. Proc. Rule 26(a) and Rule 37(c) are sufficient basis to exclude expert opinions outside the scope of an expert report. Rule 37(c)(1) provides in relevant part: If a party fails to provide information or identify a witness as required by Rule 26(a) or (e), the party is not allowed to use that information or witness to supply evidence on a motion, at a hearing, or at trial, unless the failure was substantially justified or is harmless. The Ninth Circuit has explained that explained that "Rule 37(c)(1) gives teeth to [this requirement] by forbidding the use at trial of any information required to be disclosed by Rule 26(a) that is not properly disclosed." Yeti by Molly, Ltd. v. Deckers Outdoor Corp., 259 F.3d 1101, 1106 (9th Cir.2001). In terms of non-retained treaters, their opinions are limited to opinions formed during the course of treatment pursuant to Rule 26(a)(2)(C). See Goodman v. Staples The Off. Superstore, LLC, 644 F.3d 817, 825 (9th Cir. 2011). Any additional information which falls outside the scope of the Rule 26(a)(2)(C) disclosure and would only be allowed at trial had an expert report been provided. Fed.R.Civ.P. 26(a)(2)(B); see also Goodman, 644 F.3d at 826 (holding that expert reports were required for those opinions provided by treating physicians that went "beyond the scope of the treatment rendered"). Most of these issues are resolved pretrial but if an expert is testifying outside the scope of their report during trial, the objection would merely be Rule 26 outside the scope of the expert's disclosed opinions. CHRISTIAN CONTRERAS ATTORNEY AT LAW 360 E. 2nd St., 8th Floor Los Angeles, Ca 90012 Tel: (323) 435-8000; Fax: (323) 597-0101 Website: www.Contreras-Law.com -----Original Message----- From: chris@carrazcolawapc.com Sent: December 14, 2024 3:44:00 PM To: caala-workproduct@lists.trialsmith.com Subject: Is there a federal version of Kennemur? Mates, Is anyone aware of a federal court / case version of Kennemur? Thanks. Regards, Chris Holm [cid:image001.png@01DB4E2E.3D7C4CA0]Christopher L. Holm, Esq. CARRAZCO LAW, A.P.C. 18301 Irvine Boulevard Tustin, CA 92780 Telephone: 714.541.8600 Facsimile: 714.541.8601 ** Please note that my email address has recently changed to chris@carrazcolawapc.com<mailto:chris@carrazcolawapc.com> STRICTLY CONFIDENTIAL/SUBJECT TO ATTORNEY-CLIENT PRIVILEGE/ATTORNEY WORK PRODUCT Confidentiality Note: This e-mail (and any attachments hereto) is intended only for the person or entity to which it is addressed and may contain information that is privileged, confidential or otherwise protected from disclosure. Dissemination, distribution or copying of this e-mail or the information contained herein by anyone other than the intended recipient, or an employee or agent responsible for delivering this message to the intended recipient, is prohibited. If you have received this e-mail in error, please notify us immediately at 714-541-8600 (U.S.A.) and destroy the original message and all copies. Thank you.
AI Analysis:
The 'Goodman' mentioned in this message is Todd Goodman, a CAALA member attorney recommending a PI case management software program called 'PIP' by Hipersoft. This is not a workers' compensation judge named Goodman. The message contains no information about any judge's rulings, courtroom behavior, demeanor, or case management style. It is entirely about legal practice management software recommendations on a CAALA listserv.
"William Mitchell Margolin Attorney at Law" Date: February 28, 2024 6:47:00 PM Subject: Re: INQUIRY: NON CLOUD BASED EASY PI CASE MANAGEMENT PROGRAM Reply to list Reply to sender Print List: caala-workproduct Sent by: William Margolin (Reply Privately) Search Ty Mr G From: Todd Goodman (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Date: Wednesday, February 28, 2024 at 10:35 AM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: Re: [caala-workproduct] INQUIRY: NON CLOUD BASED EASY PI CASE MANAGEMENT PROGRAM List: caala-workproduct Sent by: Todd Goodman (Reply Privately) Search I use for more than 20 years a program called "PIP" PRACTICE INFORMATION POWERTOOL from Hipersoft. It is a non-cloud based PI case management program, based on Filemaker Pro. Runs on a Mac, and also I believe on a PC. Fairly inexpensive, around 390.00 per year, a bit more if you want it to share with other computers in the office. It can also be used via the cloud, but I don't like that kind of information floating out in the cloud, so if I want to have it with me on say my laptop, I scan the file to a thumb drive and take it with me with the needed info. You can contact the owner of Hipersoft, John Maxwell, at 951-840-7624 or go to www.hipersoft.com Call me if you have any further questions Todd Goodman William Margolin (caala-workproduct listserver) wrote on 2/28/24 10:13 AM: List: caala-workproduct Sent by: William Margolin (Reply Privately) Search DEAR CAALA: What Case Management programs are inexpensive for small/or solo practice for PI Primary Practice that works with MAC and PC..that you can recommend? I used to go to “Legaltech” at Bonaventure Hotel and get the rundown on new ones but I don’t think they do that convention anymore since Covid. TY BILL William Mitchell Margolin Attorney at Law- A Professional Law Corporation 23548 Calabasas Road, Suite 202 Calabasas, California 91302 (818) 999-4LAW (4529) Fax: (818) 999-1956 email: legalhelpforyou@msn.com 2010 Candidate for California Superior Court Judge, Los Angeles County SUPER LAWYERS (SOUTHERN CALIFORNIA) 2009, 2010, 2011, 2012, 2015, 2016, 2017, 2018, 2019, 2020, 2021, 2022, 2023, 2024 MARTINDALE HUBBLE - AMERICAN REGISTRY--Congratulations on being in the top 1% of more than 900,000 attorneys in the U.S.! 30 year Member-Consumer Attorney Association of Los Angeles & California. This electronic mail (email) message, including any attachments, is intended for the use of the person or entity to which it is addressed and may contain information that is privileged and confidential, the disclosure of which is governed by applicable law. If the reader of this message is not the intended recipient, or the employee or agent responsible to deliver it to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this information is STRICTLY PROHIBITED. -- Todd W. Goodman, APC P.O. Box 3094 Thousand Oaks, CA 91359 T: 805-494-4615 F: 805-494-4618 law@toddgoodman.com
AI Analysis:
This message is from 'Todd Goodman,' an attorney (not a judge) who is responding to a listserv inquiry about PI case management software. The message contains no information about a judge named Goodman, no rulings, no courtroom behavior, no opinions about judicial conduct, and no workers' compensation context. Todd Goodman appears to be a plaintiff's attorney sharing a software recommendation. This message provides zero useful information for evaluating a workers' compensation judge named Goodman.
"Todd Goodman" Date: February 28, 2024 12:35:00 PM Subject: Re: INQUIRY: NON CLOUD BASED EASY PI CASE MANAGEMENT PROGRAM Reply to list Reply to sender Print List: caala-workproduct Sent by: Todd Goodman (Reply Privately) Search I use for more than 20 years a program called "PIP" PRACTICE INFORMATION POWERTOOL from Hipersoft. It is a non-cloud based PI case management program, based on Filemaker Pro. Runs on a Mac, and also I believe on a PC. Fairly inexpensive, around 390.00 per year, a bit more if you want it to share with other computers in the office. It can also be used via the cloud, but I don't like that kind of information floating out in the cloud, so if I want to have it with me on say my laptop, I scan the file to a thumb drive and take it with me with the needed info. You can contact the owner of Hipersoft, John Maxwell, at 951-840-7624 or go to www.hipersoft.com Call me if you have any further questions Todd Goodman William Margolin (caala-workproduct listserver) wrote on 2/28/24 10:13 AM: List: caala-workproduct Sent by: William Margolin (Reply Privately) Search DEAR CAALA: What Case Management programs are inexpensive for small/or solo practice for PI Primary Practice that works with MAC and PC..that you can recommend? I used to go to “Legaltech” at Bonaventure Hotel and get the rundown on new ones but I don’t think they do that convention anymore since Covid. TY BILL William Mitchell Margolin Attorney at Law- A Professional Law Corporation 23548 Calabasas Road, Suite 202 Calabasas, California 91302 (818) 999-4LAW (4529) Fax: (818) 999-1956 email: legalhelpforyou@msn.com 2010 Candidate for California Superior Court Judge, Los Angeles County SUPER LAWYERS (SOUTHERN CALIFORNIA) 2009, 2010, 2011, 2012, 2015, 2016, 2017, 2018, 2019, 2020, 2021, 2022, 2023, 2024 MARTINDALE HUBBLE - AMERICAN REGISTRY--Congratulations on being in the top 1% of more than 900,000 attorneys in the U.S.! 30 year Member-Consumer Attorney Association of Los Angeles & California. This electronic mail (email) message, including any attachments, is intended for the use of the person or entity to which it is addressed and may contain information that is privileged and confidential, the disclosure of which is governed by applicable law. If the reader of this message is not the intended recipient, or the employee or agent responsible to deliver it to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this information is STRICTLY PROHIBITED. -- Todd W. Goodman, APC P.O. Box 3094 Thousand Oaks, CA 91359 T: 805-494-4615 F: 805-494-4618 law@toddgoodman.com
AI Analysis:
The 'Todd Goodman' mentioned in this message is an attorney (Todd W. Goodman, APC) based in Thousand Oaks, CA, not a judge. The message is about his experience with a defense counsel named Carmin Shaffer (USAA in-house counsel) in a dog bite case. There is no mention of any judge named Goodman, and no information about judicial rulings, courtroom behavior, or judge evaluation. Todd Goodman is the sender/author of the message, not a judge being evaluated.
"Todd Goodman" Date: December 15, 2023 1:29:00 PM Subject: Re: ATTORNEY CARMIN SHAFFER (USAA IN HOUSE COUNSEL_ Reply to list Reply to sender Print List: caala-workproduct Sent by: Todd Goodman (Reply Privately) Search I resolved a dog bite case with her last year. She knows her stuff, but runs hot and cold. Came across as overworked, took it almost to the courtroom steps and then resolved for way more than the offers that had been coming out of USAA. I think the only reason it went as far as it did were a strange set of facts and a very different type of injury. Todd Goodman Joseph Golian (caala-workproduct listserver) December 15, 2023 at 11:18 AM List: caala-workproduct Sent by: Joseph Golian (Reply Privately) Search Hi Mates: Any experience with this defense counsel? Appreciate any heads up in advance. Thanks! Best, Joseph Golian, Esq. Golian Law Group 3580 Wilshire Blvd., #1260 Los Angeles, CA 90010 (P): 310-801-3028 (F): 310-693-6681 -- ------ Todd W. Goodman, APC P.O. Box 3094 Thousand Oaks, CA 91359 805-494-4615 Voice 805-494-4618 Fax law@toddgoodman.com
AI Analysis:
The mention of 'Goodman' in this message refers to a case citation ('Williams v. Goodman'), not a judge named Goodman. The message is about rules regarding opening statements in civil trials, and the reference is to a legal case used as precedent. There is no substantive information about a Judge Goodman's rulings, behavior, demeanor, or courtroom practices that would help evaluate them as a workers' compensation judge.
Sandeep Agarwal Date: June 13, 2022 3:48:00 PM Subject: Re: RE: Rules Regarding Openings Reply to list Reply to sender Print List: caala-workproduct Sent by: Sandeep Agarwal (Reply Privately) Search Mike - Page 4 of the attachment [page 16 of the article] is cut off at the bottom. Do you happen to have a more complete copy you don't mind sharing? Many thanks in advance. Sandeep -----Original Message----- From: michael@jtlegalgroup.com Sent: June 13, 2022 2:45:00 PM To: caala-workproduct@lists.trialsmith.com Subject: RE: Rules Regarding Openings The attached is a must read. I also highly recommend CAALA's PTA or something similar. Even if allowed, the general thought is that discussing the law is better to be saved for the closing. If you want to talk about common sense, do that but you don't need to go through 5009. "This is common sense folks, he was stopped at a red light and he was rear ended!" -M From: Justin Shimizu (caala-workproduct listserver) Sent: Monday, June 13, 2022 12:37 PM To: CAALA Work Product Discussion List Subject: [caala-workproduct] Rules Regarding Openings List: caala-workproduct Sent by: es%20Regarding%20Openings> Justin Shimizu (Reply Privately) Search Can someone please point me to specific case law or codes that directly discuss what is and is not allowed in an opening statement? The only one I'm familiar with is Williams v. Goodman. I've usually been able to talk about applicable jury instructions as it relates to the viewing or understanding of the evidence. (Caci 5009- Common sense, caci 200- burden of proof) However, my last trial, Defense objected to "discussing the law" and "relevance". I didn't have any specific case law or codes that allowed such statements and the judge continually sustained the objections. I'm hoping to be better prepared next time. Best, Justin Shimizu
AI Analysis:
The mention of 'Goodman' in this message refers to a case citation ('Williams v. Goodman'), not a judge named Goodman. The message is about rules governing opening statements in civil trials, and the reference is to a legal case used as precedent. There is no substantive information about a Judge Goodman's rulings, behavior, demeanor, or courtroom practices that would help evaluate them as a workers' compensation judge.
Michael Avanesian Date: June 13, 2022 2:45:00 PM Subject: RE: Rules Regarding Openings Reply to list Reply to sender Print Attachments: 2000-01-00_bp_opening_statement_article_consumer_attorneys_of_california_forum_bjp.pdf (2918 K) The attached is a must read. I also highly recommend CAALA’s PTA or something similar. Even if allowed, the general thought is that discussing the law is better to be saved for the closing. If you want to talk about common sense, do that but you don’t need to go through 5009. “This is common sense folks, he was stopped at a red light and he was rear ended!” -M From: Justin Shimizu (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Monday, June 13, 2022 12:37 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: [caala-workproduct] Rules Regarding Openings List: caala-workproduct Sent by: Justin Shimizu (Reply Privately) Search Can someone please point me to specific case law or codes that directly discuss what is and is not allowed in an opening statement? The only one I'm familiar with is Williams v. Goodman. I've usually been able to talk about applicable jury instructions as it relates to the viewing or understanding of the evidence. (Caci 5009- Common sense, caci 200- burden of proof) However, my last trial, Defense objected to "discussing the law" and "relevance". I didn't have any specific case law or codes that allowed such statements and the judge continually sustained the objections. I'm hoping to be better prepared next time. Best, Justin Shimizu
AI Analysis:
The mention of 'Goodman' in this message refers to a case citation ('Williams v. Goodman') used as a legal reference for rules regarding opening statements. This is not a reference to a workers' compensation judge named Goodman. The message contains no substantive information about a judge named Goodman's rulings, courtroom behavior, demeanor, or case management style. The reference is purely a legal case citation in the context of a civil litigation question about opening statement rules.
Justin Shimizu Date: June 13, 2022 2:36:00 PM Subject: Rules Regarding Openings Reply to list Reply to sender Print List: caala-workproduct Sent by: Justin Shimizu (Reply Privately) Search Can someone please point me to specific case law or codes that directly discuss what is and is not allowed in an opening statement? The only one I'm familiar with is Williams v. Goodman. I've usually been able to talk about applicable jury instructions as it relates to the viewing or understanding of the evidence. (Caci 5009- Common sense, caci 200- burden of proof) However, my last trial, Defense objected to "discussing the law" and "relevance". I didn't have any specific case law or codes that allowed such statements and the judge continually sustained the objections. I'm hoping to be better prepared next time. Best, Justin Shimizu
AI Analysis:
The message does not mention Judge Goodman by name or any variation thereof. The subject line references an 'ENT Panel' and the message appears to be a reply on a listserv thread, but the visible content contains no substantive information about Judge Goodman — no rulings, courtroom behavior, opinions, or case references involving this judge. The message is either about a different topic entirely or the relevant content was not included in the excerpt provided.
From: Miranda Condra (lawnet listserver) <listsender@lawnet.caaa.org> Sent: Tuesday, December 7, 2021 8:04 PM To: Statewide List Service <lawnet@lawnet.caaa.org> Subject: Re: [lawnet] ENT Panel
AI Analysis:
While 'Allan J. Goodman' appears in the list of Kaiser arbitrators, the message contains no substantive information about Goodman specifically. The name appears only as one item in a list of 12 arbitrators. The only substantive opinion offered in the thread is about Fred Morrison, not Goodman. There is no discussion of Goodman's rulings, demeanor, fairness, or any attorney experience with him. The mention is purely a name in passing with zero evaluative context.
John Rapillo Date: April 10, 2023 4:36:00 PM Subject: Re: KAISER LIST OF ARBITRATORS - NEED HELP. DO NOT RECOGNIZE OF THE INDIVIDUALS Reply to list Reply to sender Print List: caala-workproduct Sent by: John Rapillo (Reply Privately) Search Fred Morrison was my first year criminal law professor in law school. Later he became a Federal Judge. Very nice man. I would think he'd be fair. John Rapillo Newport Beach -----Original Message----- From: dcunningham@injuryatwork.com Sent: April 10, 2023 4:29:00 PM To: caala-workproduct@lists.trialsmith.com Subject: KAISER LIST OF ARBITRATORS - NEED HELP. DO NOT RECOGNIZE OF THE INDIVIDUALS This is the list of arbitrators that I received from the Kaiser list: I do not recognize any of the individuals and need your input. I can reject up to 4 individuals. Would love your input. Maurice J. Attie Joseph F. Biafore Rosalyn M. Chapman Gary S. Davis Allan J. Goodman David Allen Horowitz Fred K. Morrison Natalie PanossianBassler Ronald Steven Prager H. Stuart Waxman Charlotte Walter Woolard David M. Wright Thank you in advance for your input. Sincerely, Darla A. Cunningham Attorney at Law dcunningham@injuryatwork.com<mailto:dcunningham@injuryatwork.com> Lerner, Moore, Silva, Cunningham and Rubel 3333 Concours Bldg 4 , Ste. 4203 Ontario, CA 91764 https://linkprotect.cudasvc.com/url?a=https%3a%2f%2fwww.injuryatwork.com&c=E,1,yWBn7eSkd3__DxbjFPojQGh0acCu2A-jvINVQFeizNm0fWB8ncswsc0BcMdZxGFdlFkdQlfVcxVWsyF4ZzhvnyZkUZPsdSzFMs4VM6j_SVKBDcOc&typo=1<https://linkprotect.cudasvc.com/url?a=http%3a%2f%2fwww.injuryatwork.com%2f&c=E,1,OV0jlEmHGzFI8fxprglUNRb46w05wtbcuICHRf3lK4E6g5Qj43izPXoWX2aMDFO_pf3pjA8Rqb8WLgZ118US0zoZoUtASKCCv2dCL3buLwUYu34,&typo=1> Main (909) 889-1131 Direct (909) 677-8301 Fax (909) 884-5326 *This communication, including any attachments, is confidential information and is intended only for the individual or entity to whom it is addressed. The transmission of this document is protected by the attorney-client privilege. Any review, dissemination or copying of this communication by anyone other than the intended recipient is strictly prohibited.*
AI Analysis:
While the subject line mentions 'Judge Allan Goodman from ADR' which matches the judge being evaluated, the message body contains no substantive information about the judge. The message appears to be a reply header/quote attribution line only, with no actual content discussing the judge's rulings, demeanor, fairness, or any other evaluative information. There is nothing in the body that would help determine if Goodman is a good or bad judge from a workers' compensation attorney's perspective.
On Mar 27, 2025, at 1:40 PM, Alexander Larian (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> wrote:
AI Analysis:
While 'Hon. Allan J. Goodman' is mentioned by name in the arbitrator list, the message contains no substantive information about Goodman specifically. The message is a request for recommendations about which arbitrators to strike or rank, but no one has yet provided any opinions, experiences, or evaluations of Goodman or any other arbitrator on the list. The name appears only as a list entry with no accompanying context, rulings, demeanor descriptions, or attorney opinions that would help evaluate Goodman as a judge.
Mates, I need to strike 3 names from this ADR list and then order the remaining. Who would you strike and recommend? Thank you NEUTRAL Hon. Paul Bacigalupo Hon. Victoria Gerrard Chaney Hon. Jacqueline A. Connor Hon. Elizabeth R. Feffer Hon. Allan J. Goodman Hon. Gregory Keosian Robert S. Mann, Esq. Hon. Margaret Oldendorf Hon. Gerald Rosenberg Hon. Thomas L. Willhite, Jr.
AI Analysis:
While 'Paul Goodman' is mentioned in the subject line, this appears to be a reference to an ENT (Expert/Evaluating physician or similar medical professional named Paul Goodman), not a workers' compensation judge named Goodman. The subject line groups 'Paul Goodman & Lorenzo Brown' together as ENTs, suggesting these are medical evaluators or experts, not judicial officers. The message body contains no substantive information about a judge named Goodman's rulings, demeanor, or courtroom behavior. This appears to be a different 'Goodman' than the judge being evaluated.
From: ron ehrman (lawnet listserver) <listsender-lawnet@lawnet.caaa.org> Sent: Monday, July 29, 2024 10:13 PM To: Statewide List Service <lawnet@lawnet.caaa.org> Subject: [lawnet] ENT's Paul Goodman & Lorenzo Brown
AI Analysis:
While the message does mention 'Hon. Alan Goodman, Ret.' by name, it contains no substantive information about him as a judge. The message is a request for input about proposed arbitrators for a UIM (Uninsured Motorist) case, not a workers' compensation matter. Goodman's name appears only in a list of proposed arbitrators with zero context, opinions, descriptions, or evaluations provided. There is no information about his rulings, demeanor, fairness, or case management style that would help evaluate him as a workers' compensation judge. The Synthesis Analyzer would gain nothing useful from this message.
Good Morning Listmates: Allstate has proposed the following ARBITRATORS for a UIM case. Hon. Norman P. Tarle, Ret. Hon. Michael Johnson, Ret. Hon. Howard Halm, Ret. Hon. Alan Goodman, Ret. I would appreciate your input on these persons as arbitrators only please. TIA -- Margarit K. Mardirosian Mardirosian & Mardirosian, A PLC 1155 N. Central Ave., Suite 201 Glendale, CA 91202 Tel (818) 244-8166 Fax (818) 244-0796
AI Analysis:
While 'Hon. Allan J. Goodman' is mentioned by name in this message, it is only a passing reference in a list of available mediators with their rates and availability dates. There is no substantive information about Judge Goodman's rulings, courtroom behavior, demeanor, fairness, or any attorney opinions/experiences that would help evaluate him as a judge. The message is a mediator availability inquiry for a DV/defamation case, not a workers' compensation matter, and Goodman appears solely as one entry in a roster of neutral mediators. This provides no actionable evaluative information.
I'm looking around for someone available on short notice for kind of a unique DV/ defamation case on the eve of trial. These folks are available but I've only heard of one of them. Would anyone speak very highly of any of these mediators who are available? Thanks, LE NEUTRAL AVAILABILITY Daniel Ben-Zvi, Esq. * $ 900 /hour October 31 Hon. Jacqueline A. Connor * $ 7,000 /half day $10,000 /full day October 27 Jake Courtney, Esq. * $ 800 /hour Oct ober 24 ( 1 pm -9 pm) , 26, 27 ( 1 pm -9 pm) Hon. Elizabeth R. Feffer * $ 850 /hour October 25*, 26*, 27 *Available by Zoom only on these dates. Judge Feffer is available by Zoom or in person on all other dates. Mayra M. Fornos, Esq. * $625/hour October 25, 27, 28, 31 November 1 Hon. Allan J. Goodman * $ 750 /hour October 26, 27 Stacie Feldman Hausner , Esq. * $ 800 /hour October 25, 26 Hon. Susan Lopez-Giss * $800/hour October 31 November 1 Michael Maguire, Esq. * $600/hour October 26, 27, 31 November 1 Hon. Rita “Sunny” Miller * $ 1,000 /hour October 26 * **** *note new mailing address* Lincoln Ellis, Esq. Law Office of Lincoln W. Ellis 2525 Main St. #204 Santa Monica, CA 90405 Tel: 213-207-6692 e-mail: lincoln.lawyer.ca@gmail.com CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it, may contain confidential information that is legally privileged and may be protected by the Electronic Communications Privacy Act, 18 USC §§2510-2521. It is intended solely for the recipient addressee listed above and may not be forwarded or sent to any other recipient in any form. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that any disclosure, copying, distribution or use of any of the information contained in or attached to this transmission is prohibited. If you have received this transmission in error, please immediately advise by reply e-mail to lincoln.lawyer.ca@gmail.com and destroy the original transmission and its attachments without reading or saving in any manner. Thank you.
AI Analysis:
While Hon. Allan J. Goodman is mentioned by name in this message, it is only in passing as part of a list of available mediators with their rates and availability dates. There is no substantive information about his rulings, courtroom behavior, demeanor, fairness, or any attorney opinions/experiences that would help evaluate him as a judge. Additionally, this message is about civil mediation (DV/defamation case), not California workers' compensation, making it even less useful for evaluating him from a workers' comp attorney's perspective. The mention is purely logistical (name, rate of $750/hour, available October 26-27).
I'm looking around for someone available on short notice for kind of a unique DV/ defamation case on the eve of trial. These folks are available but I've only heard of one of them. Would anyone speak very highly of any of these mediators who are available? Thanks, LE NEUTRAL AVAILABILITY Daniel Ben-Zvi, Esq. * $ 900 /hour October 31 Hon. Jacqueline A. Connor * $ 7,000 /half day $10,000 /full day October 27 Jake Courtney, Esq. * $ 800 /hour Oct ober 24 ( 1 pm -9 pm) , 26, 27 ( 1 pm -9 pm) Hon. Elizabeth R. Feffer * $ 850 /hour October 25*, 26*, 27 *Available by Zoom only on these dates. Judge Feffer is available by Zoom or in person on all other dates. Mayra M. Fornos, Esq. * $625/hour October 25, 27, 28, 31 November 1 Hon. Allan J. Goodman * $ 750 /hour October 26, 27 Stacie Feldman Hausner , Esq. * $ 800 /hour October 25, 26 Hon. Susan Lopez-Giss * $800/hour October 31 November 1 Michael Maguire, Esq. * $600/hour October 26, 27, 31 November 1 Hon. Rita “Sunny” Miller * $ 1,000 /hour October 26 * **** *note new mailing address* Lincoln Ellis, Esq. Law Office of Lincoln W. Ellis 2525 Main St. #204 Santa Monica, CA 90405 Tel: 213-207-6692 e-mail: lincoln.lawyer.ca@gmail.com CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it, may contain confidential information that is legally privileged and may be protected by the Electronic Communications Privacy Act, 18 USC §§2510-2521. It is intended solely for the recipient addressee listed above and may not be forwarded or sent to any other recipient in any form. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that any disclosure, copying, distribution or use of any of the information contained in or attached to this transmission is prohibited. If you have received this transmission in error, please immediately advise by reply e-mail to lincoln.lawyer.ca@gmail.com and destroy the original transmission and its attachments without reading or saving in any manner. Thank you.
AI Analysis:
While 'Alan Goodman' is mentioned by name in the arbitrator list proposed by defense counsel, the message contains no substantive information about Goodman specifically. The message's substantive content focuses on evaluations of Suzanne Bruguera (negative) and Darrell Forgey (positive). Goodman appears only as one of ten names in a list, with no opinions, experiences, rulings, demeanor descriptions, or any other evaluative information provided about him. This is insufficient to help evaluate Goodman as a judge.
"David Shapiro" Date: September 13, 2022 7:03:00 PM Subject: RE: Arbitrator List Reply to list Reply to sender Print List: caala-workproduct Sent by: David Shapiro (Reply Privately) Search Ms. Bahari: I just completed an arbitration with Suzanne Bruguera few weeks ago. Do not use her or use her at your own risk. She is not the judge she used to be. She is defense oriented and friendly to the insurance carrier (in my case State Farm). In addition to her bias, the hearing is problematic. She is elderly (not healthy) and had to stop the hearing so she could visit the restroom every hour, extending the arbitration hearing from 4 to 6 hours. She prefers you to do closing argument in writing. She is with ADR and their hearing rooms are not conducive to digital projection, you will have to have hard copies available for impeachment if the witness is on zoom. Email me privately if you want more. I have always liked Darrell Forgey (if you have a decent case, he is fair, but will not give you a huge number). David B. Shapiro From: Soheil Bahari (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Friday, September 9, 2022 1:10 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: [caala-workproduct] Arbitrator List List: caala-workproduct Sent by: Soheil Bahari (Reply Privately) Search Dear All, Defense is proposing the following arbitrators for a UIM case. Your opinions would be greatly appreciated. Thomas Friedman; Christopher Warner; Mitchell Green; Christopher Conway; Frederick Aguirre; Alan Goodman; Jill Sperber; Darrell Forgey; Martin Handweiler; and Suzanne Bruguera.
AI Analysis:
While 'Alan Goodman' appears in the message as part of a proposed arbitrator list for a UIM (Uninsured Motorist) case, there is no substantive information provided about Goodman specifically. The message only lists him as one of ten proposed arbitrators. The responding attorney (Sanford Jossen) recommends Forgey, Bruguera, and Aguirre, but makes no comment about Goodman. There are no opinions, experiences, rulings, or evaluations of Goodman provided. Additionally, this appears to be a civil arbitration context (UIM case via CAALA), not a California workers' compensation context, making it less relevant for evaluating Goodman as a workers' comp judge. The name mention is purely incidental with no actionable evaluative information.
jossenlaw@aol.com Date: September 09, 2022 5:31:00 PM Subject: Re: Arbitrator List Reply to list Reply to sender Print Attachments: ~wrd1984.jpg (1 K) List: caala-workproduct Sent by: Sanford Jossen (Reply Privately) Search Go with Darrel Forgey, Judge Bruguerra or Judge Aguirre. Sanford Law Offices of Sanford Jossen 136 Main Street, Suite E El Segundo, CA 90245 Telephone No.: (310) 546-9118 Facsimile No.: (310) 546-3806 Email: Jossenlaw@aol.com http://www.jossenlawfirm.com -----Original Message----- From: Tom Allen (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Sent: Fri, Sep 9, 2022 1:13 pm Subject: RE: [caala-workproduct] Arbitrator List List: caala-workproduct Sent by: Tom Allen (Reply Privately) Search I think Marty Handweiler retired From: Soheil Bahari (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Friday, September 9, 2022 1:11 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: [caala-workproduct] Arbitrator List List: caala-workproduct Sent by: Soheil Bahari (Reply Privately) Search Dear All, Defense is proposing the following arbitrators for a UIM case. Your opinions would be greatly appreciated. Thomas Friedman; Christopher Warner; Mitchell Green; Christopher Conway; Frederick Aguirre; Alan Goodman; Jill Sperber; Darrell Forgey; Martin Handweiler; and Suzanne Bruguera. I think Marty Handweiler retired From: Soheil Bahari (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Friday, September 9, 2022 1:11 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: [caala-workproduct] Arbitrator List List: caala-workproduct Sent by: Soheil Bahari (Reply Privately) Search Dear All, Defense is proposing the following arbitrators for a UIM case. Your opinions would be greatly appreciated. Thomas Friedman; Christopher Warner; Mitchell Green; Christopher Conway; Frederick Aguirre; Alan Goodman; Jill Sperber; Darrell Forgey; Martin Handweiler; and Suzanne Bruguera.
AI Analysis:
While 'Alan Goodman' is mentioned by name in the arbitrator list proposed by defense counsel, the message contains no substantive information about Goodman specifically. The only opinion shared in the thread is about Suzanne Bruguera (described as excellent and good for plaintiffs). Goodman is merely listed as one of ten proposed arbitrators with no commentary, evaluation, or context provided about him. Additionally, this appears to be a CAALA (California Association for Justice) civil litigation list, not a workers' compensation context, and the discussion is about a UIM (Uninsured Motorist) arbitration case. There is insufficient substantive information to evaluate Goodman as a judge or arbitrator.
nhou651519@aol.com Date: September 09, 2022 3:35:00 PM Subject: Re: Arbitrator List Reply to list Reply to sender Print Attachments: ~wrd1984.jpg (1 K) List: caala-workproduct Sent by: Nancy Houchen (Reply Privately) Search Suzanne Brugera, retired judge was excellent on the bench. I had a trial with her. Turned out quite well. Good for plaintiffs. Get her if you can. -----Original Message----- From: Tom Allen (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Sent: Fri, Sep 9, 2022 1:13 pm Subject: RE: [caala-workproduct] Arbitrator List List: caala-workproduct Sent by: Tom Allen (Reply Privately) Search I think Marty Handweiler retired From: Soheil Bahari (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Friday, September 9, 2022 1:11 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: [caala-workproduct] Arbitrator List List: caala-workproduct Sent by: Soheil Bahari (Reply Privately) Search Dear All, Defense is proposing the following arbitrators for a UIM case. Your opinions would be greatly appreciated. Thomas Friedman; Christopher Warner; Mitchell Green; Christopher Conway; Frederick Aguirre; Alan Goodman; Jill Sperber; Darrell Forgey; Martin Handweiler; and Suzanne Bruguera. I think Marty Handweiler retired From: Soheil Bahari (caala-workproduct listserver) <listsender-caala-workproduct@lists.trialsmith.com> Sent: Friday, September 9, 2022 1:11 PM To: CAALA Work Product Discussion List <caala-workproduct@lists.trialsmith.com> Subject: [caala-workproduct] Arbitrator List List: caala-workproduct Sent by: Soheil Bahari (Reply Privately) Search Dear All, Defense is proposing the following arbitrators for a UIM case. Your opinions would be greatly appreciated. Thomas Friedman; Christopher Warner; Mitchell Green; Christopher Conway; Frederick Aguirre; Alan Goodman; Jill Sperber; Darrell Forgey; Martin Handweiler; and Suzanne Bruguera.
AI Analysis:
While this message does mention Judge Alan Goodman by name, it contains no substantive information ABOUT the judge that would help evaluate him. The message is a request FOR information about Goodman, not a response containing intel or experience. Additionally, the context is business litigation mediation, not California workers' compensation, making it irrelevant to evaluating Goodman as a workers' compensation judge. There are no rulings, opinions, experiences, or assessments shared about the judge's behavior, fairness, or competence.
Shane Greenberg Date: April 13, 2022 2:59:00 PM Subject: Any intel on Judge Alan Goodman as a business litigation mediator or any other good judge mediators for business litigation case? Reply to list Reply to sender Print List: caala-workproduct Sent by: Shane Greenberg (Reply Privately) Search Does anyone have any Intel on judge Alan Goodman? I am looking to use him as a business litigation mediator and just wanna know if anyone's had any experience with him. Any input would be greatly appreciated. Does anyone have any other ideas for a judge that has done business litigation as well? Please let me know
AI Analysis:
This message refers to Karen Goodman, who is described as a civil attorney in Sacramento, President of Cal-ABOTA, and an Employment Law practitioner — not a workers' compensation judge. She is mentioned as a potential co-counsel referral, not as a WCJ or hearing officer. There is no information about her role as a judge in the workers' compensation system, and the context (Legal Malpractice verdict, Employment Law, Cal-ABOTA) confirms this is a different person from the 'goodman' being evaluated as a workers' comp judge.
You might try Karen Goodman. she is in Sac ramento. I think she just became President of Cal-ABOTA. I believe she does some Employment Law. I met her when I was a Non-Retained Expert witness in a Legal Malpractice Case where she won a $500K Verdict. kgoodman@goodman-law.com Good luck.
AI Analysis:
This message is from Todd Goodman, a California plaintiff's attorney (Todd W. Goodman, APC based in Thousand Oaks, CA), not a workers' compensation judge. The message is a forwarded news story about a Geico insurance arbitration case in Missouri involving an HPV transmission claim. It contains no information about a judge named Goodman, no rulings or decisions by a WCJ named Goodman, and no courtroom behavior or case management information relevant to evaluating a workers' compensation judge. The 'goodman' referenced here is an attorney, not a judge.
Todd Goodman Date: June 08, 2022 6:28:00 PM Subject: Weird Geico story Reply to list Reply to sender Print List: caala-life Sent by: Todd Goodman (Reply Privately) Search Byron Hurd Wed, June 8, 2022, 10:03 AM · 1 min read We're barely more than a week into June and it's already a banner month for  weird car sex stories . This week's comes way out of left field (which is somewhere near Kansas City, apparently) thanks to a ruling by the Missouri Court of Appeals ordering  insurance juggernaut Geico to pay a woman $5.2 million in damages after being infected with HPV during intimate activities that took place in an insured personal vehicle. Look, we warned you. Per  The Kansas City Star , the woman initiated a claim with Geico in February 2021 after learning that she'd contracted the sexually transmitted infection from a partner who knew but did not disclose his status. Since the incident in question happened in her partner's car, she argued that his liability insurance was responsible for damages. A settlement was reportedly offered to Geico, whose lawyers declined. As anybody who's had legal entanglements with an insurance company can probably guess, the case went to arbitration. In what we're certain was a surprise to Geico's legal team, arbitration did not go their way. The woman's partner was found liable and the arbitrator approved an award of $5.2 million in damages to be paid out by the insurer despite requests by Geico for a new hearing. The insurance company appealed to the courts on several grounds, claiming that the process denied it the ability to have its day in court. The company's appeal was  denied on all points . For anyone who's ever emerged from arbitration feeling that the process leaves something to be desired, this time it's an insurance company who feels that way. -- Todd W. Goodman, APC P.O. Box 3094 Thousand Oaks, CA 91359 T: 805-494-4615 F: 805-494-4618 law@toddgoodman.com