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IfTVLOR, SCOTT & NICHOLS�/'�/►1ii� <br />A PROFESSIONAL LAW CORPORATION V� 1 <br />RICHARD W. TAYLOR MICHAEL J. MATTEUCCI <br />W. STEPHEN SCOTT 120 N. HUNTER STREET - SECOND FLOOR OF COUNSEL <br />KENNETH A. NICMOLS STOCKTON, CA 95202 -- <br />POST OFFICE BOX 1930 TELEPHONE <br />MARK E. TRIBBLE STOCKTON. CALIFORNIA 95201 - 12091 942-4300 <br />MICHELE M. LARSON August 26, 1987 <br />Dr. Jogi Khana, M.D. <br />San Joaquin Local Health District <br />1601 East Hazelton Avenue AUG 27 1987 <br />Stockton, CA 95202 <br />SAN JOAQUIN LOCAL <br />HEALTH DISTRICT; <br />Insured San Joaquin Local Health District <br />File No. : C4435 <br />Clamaint : Schlueter <br />D/Loss 2/15/86 <br />Dear Dr. Khana: <br />Three days of hearings in this matter have concluded with only <br />slight progess. <br />The court has permitted amendments to the complaint which <br />essentially give the defendants more notice of the content of <br />the plaintiff's claims. Be that as it may, I anticipate that <br />demurrers will be filed necessitating further hearings before <br />we have the complaint in final form. <br />Additionally, two defense Summary Judgment motions along with <br />a Summary Judgment motion from the plaintiffs which do not <br />directly involve San Joaquin Local Health District have been <br />set for hearing September 22nd and 23rd. We will attend these <br />hearings only as necessary to protect the interest of the Health <br />District. <br />Finally, the judge met with defense counsel and expressed his <br />feelings that plaintiff's attorney has no concept of the cost <br />to him to try this case and also indicated that settlement would <br />appear appropriate. The major defendants have apparently agreed <br />to contribute to a fund for appraisers fees with the intention <br />of minimizing the settlement value of this case as I discussed <br />in my previous letter. The estimated cost per defendant is in <br />the $5,000 range and we have indicated that the Health District <br />probably would not be able to contribute that amount. Please <br />advise. <br />As to our Summary Judgment motion, I expect to receive supporting <br />documents within the next three weeks or, in the alternative, <br />take Jeff Hennings deposition as I discussed in my previous <br />letter. <br />