Estate of Jimmy Ray Hatfield et al v. County of Lake et al

Filing 65

ORDER Granting 58 Proposed Order filed by KC Grigsby, Robin Briggs, California Forensic Medical Group, Inc., F. Antonio. Parties appearing by phone must contact Brenda Tolbert, at 415-522-4708, 48 hours prior to hearing with a local/toll-free number. Signed by Judge Chief Magistrate Judge MARIA-ELENA JAMES on 3/6/12. (bjtS, COURT STAFF) (Filed on 3/6/2012)

TRIMBLE, SHERINIAN & VARANINI
2500 VENTURE OAKS WAY, SUITE 350 • P.O. BOX 590 95812-0590
SACRAMENTO, CALIFORNIA 95833
TELEPHONE [phone]
FACSIMILE [phone]
E-Mail [e-mail]
JEROME M. VARANINI-Direct Line [phone]

February 24, 2012

Chief Magistrate Judge Maria-Elena James
United State District Court
Courtroom B, 15th Floor
450 Golden Gate Avenue
San Francisco, California 94102
Re:

Hatfield v. County of Lake, et al.
Case No.: 11-2396

Dear Chief Magistrate James:
The undersigned represents the following defendants in this matter: the
California Forensic Medical Group, Inc. (“CFMG”), Robin Briggs, L.V.N., K.C.
Grigsby, FNP, and Fairin Antonio, L.V.N. This case is currently set for an early
settlement conference on March 9, 2012.
This letter is to request permission from the court for telephone standby
for nursing defendants Grigsby, Antonio, and Briggs. A representative from
defendant CFMG with full authority for CFMG will attend the settlement conference
as will a representative of the insurance carrier for the defendants.
Although there have been multiple depositions taken by plaintiffs’ counsel
and counsel for the co-defendants in anticipation of this early settlement
conference, the only jail medical defendant to have been deposed has been LVN
Robin Briggs. Ms. Briggs had contact with the decedent after he had been booked
at the jail and after noting that he had been treated for a broken arm and
cleared for incarceration by Adventist Clearlake Hospital, Ms. Briggs asked the
hospital to fax a copy of the records so that the records would be in the chart
to be used as deemed appropriate by the mid-level provider, the FNP, who would
be following the patient’s orthopedic status at the jail. Mr. Hatfield
subsequently committed suicide.
Apparently the theory as to Ms. Briggs is that she did not read the
hospital chart that she had placed in the chart for the FNP’s use. It is unknown
atthis point what the theory of the case is as to nurse Antonio or FNP Grigsby.
In any event, this request is made both for the convenience of the court in terms
of the numbers of persons to attend the MSC as well as with the knowledge that
representatives from CFMG and the carrier will be present fully prepared to
participate in the MSC.
Very truly yours,
/s/ Jerome M. Varanini
JEROME M. VARANINI
JMV:jm
cc: All counsel via ECF

February 24, 2012
Page 2
_____________________________________
[PROPOSED] ORDER GRANTING TELEPHONIC APPEARANCE
I hereby grant telephonic appearance for nursing defendants Robin Briggs,
L.V.N., K.C. Grigsby, FNP, and Fairin Antonio, L.V.N.

3/6/12
Dated: ________________

___________________________________
Honorable Judge Maria-Elena James