EXHIBIT 5 - Alliance for Patient · PDF fileothers are surreptitious and hidden under...

$: EXHIBIT 5 - Alliance for Patient · PDF fileothers are surreptitious and hidden under pretextual grounds for ... Program for mental and physical health c\*aluation. ... The failure$
EXHIBIT 5

B 168705

From orders of the Superior Court for Los Angeles Corrnt the Hon David Yaffee Judges Presiding LASC Case No BS 079 131

IN THE COURT OF APPEAL STATE OF CALIFORNIA

SECOND APPELLATE DISTRICT DIVISION FOUR

- GIL N MILEIKOWSKY MD

Petitioner and Appellant

vs

TENET HEALTHSYSTEM et al

Respondents

AMICUS BRIEF OF THE CONSUMER ATTORNEYS OF CALIFORNIA IN SUPPOIRT

OF PETITIONER AND APPELLANT

SHARON J ARKIN (State Bar No 154858) ROBINSON CALCAGNIE amp ROBINSON

620 Newport Center Drive 7Ih Floor Newport Beach California 92660

Telephone 9497201288 Facsimile 9497201292

Attorneys for Amicus Curiae Consumer Attorneys of California

TABLE OF CONTENTS

STATEMENT OF INTEREST OF THE AMICUS CURIAE 1

LEGALARGUMENT 2

1 DR MILEIKOWSKY MUST BE PROVIDED WITH HIS STATUTORY PROTECTIONS AND RIGHT TO A HEARING SO THAT THE HOSPITALS ILLEGITIMATE EFFORT TO PRECLUDE HIS LITIGATION TESTIMONY CAN BE UNMASKED 2

CONCLUSION g

I

1

TABLE OF AUTHORITIES

CASES

In re Gary J Lustgarten M D General Court of Justice Superior Court Division Case No 02CVS 12218 2

OTHERS

Damon Adarns ldquoNorth Carolina judge reverses doctor discipline license caserdquo AMNews June2-92003 wwwama-assnorg amedne~ws20030602prsd0602 htm 3

Elizabeth F Kuniholm and Lucy N Inman North Carolinarsquos Medical Review System Protecting Patients or Physicians Trial Briefs February 2003 httpvwv kuniholmlavcom articles-briefsqdfarticle_NCATL-efk-li-2003pdf 3 5

Stephanie Mencimer ldquoThe White Wall A new code of conduct is taking hold of the medical profession First do no harm - to your colleaguesrdquo Keepmedia Legal Affairs March 2004 wwwkeepmedia corn 3 4

Tanya Albert Amednewscom June 282004 wwwama-assnorgamednews20040628 Jpr110628htrn 5

William Parmely MD Journal of the Arnericajt CollegeofCardiology 2000 Vol 36 no 7 6

2

c

e

0

8

e

E

c

c

3

- STATEMENT OF INTEREST OF THE AMICUS CURIAE

Consumer Attorneys of California is a voluntary membership

organization of approximately 3000 consumer attorneys practicing

throughout California The organization was founded in 1962 and its

members predominately represent individuals subjected in a variety of ways

to consumer fraud practices personal injuries and insurance bad faith

Consumer Attorneys of California has taken a leading role in advancing and

protecting the rights of consumers in both the courts and the Legislature

One issue raised by petitioner and appellant in this action is the

effect ofretaliation by a medical review board against a physician who

testifies in support of a plaintiff in a medical malpractice action Although

the petitioner in this case was forestalled from reaching that issue because

of the improper termination of his peer review hearing it is an issue that

occurs with increasing frequency in various contexts Consumer Attorneysrsquo

members include numerous attorneys who represent victims injured by

medical malpractice The growing efforts by hospitals medical

associations and others to retaliate against doctors who testify on behalf of

those victims is of extreme importance to those members As such

Consumer Attorneys has a compelling interest in assuring that such

retaliatory practices are circumscribed and prohibited

1

LEGAL ARGUMENT

1

DR MILEIKOWSKY RIUST BE PROVIDED WITH HIS

STATUTORY PROTECTIONS AND RIGHT TO A HEARING

SO THAT THE HOSPITALrsquoS ILLEGITIMATE EFFORT TO

PRECLUDE HIS LITIGATION TESTIMONY CAN BE UNMASKED

In this case Dr Mileikowsky seeks the reversal of the suspension of

his hospital privileges Dr Mileikowsky contends in his action that the

hospitalrsquos effort to discipline him was motivated at least in part by his

agreement to be an expert witness in a malpractice case against the hospital

(See Appellantrsquos Opening Brief p 4 Appellantrsquos Reply Bricf pp 12 26)

There has recently been a growing wave of retaliatory actions

directed against physicians who agree to testify for plaintiffs in medical

malpractice actions Some of those retaliatory actions are direct while

others are surreptitious and hidden under pretextual grounds for challenging

the doctor and his right to practice medicine

For example in North Carolina Gary J Lustgarten MD has been

the subject of a direct attack by the medical board (See It1 re Gnry J

2

Liisrgwren MD Gencral Court of Justice Superior Court Diisioii (rsquoasc

Yo 02 CVS 1221 8 Stephaiiic Mcncinier ldquoThe llsquohitc irsquoall A iicn codc of

conduct is taking hold of the medical profession First do no h a m - to J ~ U I -

colleaguesrdquo Keepmedia Legal Affairs blarch 2004 Ix~ kccpnicd i I

com Danion Adams ldquoNorth Carolina judge reilsquoerscs doctor disciplinc

license caserdquo AMNews June2-9 2003 wnwama-

assnorgamedneus200306~02prsd0602htni) In that case thc Sorth

Carolina Medical Board is attempting to reoke Dr Lustgartenlsquos licensc to

practice medicine in that state The foundation for that action is tlic

assertion that Dr Lustgartenrsquos testimony in a nicdical nialpractice action to

the effect that the defendant doctor breached the standard of care was itself

a breach of the standard of care as testified to by another doctor i n thc

disciplinary proceedings That revocation as ultiiiiatcly recrscd bj thc

courts But the effect of these retaliatory actions remain idcsprcad

Similarly in 1998 the American Medical Association

ldquodeclared that testifying as an expert ainountcd to the practicc

of medicine and could be regulated by state medical boards

As a result doctors can now be sanctioned for +tiat thcy say

in lsquoa courtroom The AMA also encourages its mcmbcrs to

report instances of allegedly fraudulcnt testimony to those

3

boards As a result niore arid niore nicdical socictics 1iaLc

bcgun to sanction nicnibcrs it11 penalties like suspcnsioii or

rsrocation of thcir socicty membership Thcy h a x focuscd

their energies on doctors ho aid plaintiffs attorncys

(h4 en c i m er sup a )

4s objectionable as this frontal attack is the niorc insidious kind of

attack as alleged by Dr Mileikonsky in this action is far norsc - and Fir

more prevalent Indeed Debi Chaudhuri suffered a fate chillingly simillar to

Dr MiIeikonskys (See Elizabeth F Kuniholm and LUCY S Inman Sorth

Carolinas Medical Reiew System Protecting Patielits or Phj~ici(iis

Trial Briefs February 2 003 h t t D ti k uni 1101 m I ai co I 11 a 1-1 i c 1 cs hri cf

pdfiarticle - NCATL - efk - - l i 2003pdf)

Dr Debi Chaudhuri a trauma surgeon as discipliricd by a

hospital in Fayetteville where he treated patients aftcr hc

publically criticized the hospitals failure to hae a

neurosurgeon on call for its emergency department - a f i l I urc

Dr Chaudhuri said had affected one of his paticnts Vitl i in

weeks after a newspaper article regarding the staffing

shortage was published quoting Dr Chaudhur-i the hospitals

3

niledical execut1ic comniittec - uliich includcd two

neurosurgeons nho nrsquocrc nientioncd in thc ncivspapcr articlc -

laimched an investigation of Dr Chaudhuri Two nionths

later the committee unilatcrally dctemiined that Dr

Chaudhurirsquos continued practice in the emergency department

lsquopresented a risk to patient safetyrsquo and without so much as a

hearing relie~red him of his duties in the emergcncy

department and referred him to the Physicians Hcaltli

Program for mental and physical health caluation [lsquoI Dr

Chaudhuri sued the hospital and obtained a court ordcr

enjoining the disciplinary action He has resurncd practicing

in the hospital emergency departmentrdquo (Kuniholni pp 1-2)

What happened to Dr Chaudhuri is hauntingly siniilar to uliat

happened to Dr MiIcikovsky And as the Kuniholni articIe concludes

ldquo[tlhe message t o physicians is clear Donrsquot break the code of

silence 11 could cost you your hospital privileges or even your liccnserdquo

( Id p 2)

Even more recently John Fullerton MD sued the Florida h4edic8nl

Association over its efforts to suspend his licence (SCC Tanya Albcrt

5

4iItiediicwsCom June 28 2004

prl 106381itiii) As is now bwoniing a pattern Dr Fullcrton tcstificd for

the plaintiff in a medical nialpracticc action against thrcc physicians ftcr

the j u r y found no negligence in the case the three dcfcndant doctors askcd

the Florida Medical Association to rcciew the testimony and discipliiic Dr

Fullerton in order to ldquopremt the medical profession from bcing tcrroricd

in the future by similar lsquocspet-tsrdquorsquo

u aiiii-assnoro lsquomcd11c s ZOO4 00 2s -

Dr Fullerton who just rcceiired thc California Physician of tlic lsquoirsquocar

aneard from Congress is suing the FMA and the tlirce doctors for

defamation and damage to his reputation As the attorncy reprcscnting Dr

Fullerton questions if peer review and medical society rciicv progrmiis

directed at courtroom testimony are not intended to intimidate doctors v b ho

testify for plaintiffs why then do such programs disproportionally i n ie

the testimony of plaintiffsrsquo witnesses

Even William W Pamiley MD MACC he Editor-in-Chief of ilic

Joiowal qf the Ainericaii College of Ctlidiologjs has questioned the use of

peer review to intimidate experts as Ivitnesses or to decrease conipctitioii

In his 2000 editorial Vol 36 no 7 of that journal Dr Parniley discusscs

two cases in which he was personally involed as an independent reitvtw

that convinced him that the peer reviews bcing conductcd u w e dirccted at

6

e 1 i m i na t i ng competition not i ticoin pc t ciic c

The upshot of these disturbing cases is that hospital pccr rcic

boards and medical societics must be controlled in a meaningful my i n

order to assure that the attack on a doctors conduct is truly thc rcsult of thc

doctors alleged incompetence or other inappropriate conduct hen pccr

review decisions are issued without the assurance of a meaningful

opportunity to be heard i t causes untold hami to not only thc doctors

affected by it but to the profcssion itself

7

c 0 NC L US1 0 3

Dr iMileikowsky should hac becn proiided nith a meaningful due

process-based opportunity to challenge his acciiscrs and dcmonstrntc t11c

falsity ofthe allegations against him The failure to provide hini uith a

meaningful hearing on the chargcs made against him rcsults in the

inevitable conclusion that the hospitals only interest as to gct rid of Dr

bLlileikov~sky as a punishment for his testimony not ns an effort to protcct

patients o r staff

Accordingly the trial courts determination should be rciwscd and

Dr Mileikowsky provided n i th an opportunity to prcscnt his c3se in tlic

peer rei-iew process

Dated July 13 2004

SHARON J A R ~ Attorney for h i e i t s Cirriae Consumer Attorneys of California

8

CERTIFICATION REGARDIIVG L E N G T H OF R R l E F

I hercby certify that this brief contains 1505 words as cstablishcd by tlic

word count of the computer program utilized for prcparatiori of this brief

I declare and certify under the laws of the State of California that thc

foregoing statement is true and correct and that this certification as

executed on July 13 2004 at Newport Beach California

9

Mileikowsky v Tenent Healthsystem et a CA COURT OF APPEAL CASE NO 8168705

PROOF OF SERVICE

STATE OF CALIFORNIA COUNTY OF ORANGE

I am employed in the County of Orange State of California 1 am over the age of 18 and not a party to the within action my business address is 620 Newport Center Drive 7th Floor Newport Beach CA 92660 (949) 720-1288

On Julrsquoy 13 2004 I served the within document described as AMICUS BRIEF OlF THE CONSUMER ATTORNEYS OF CALIFORNIA IN SUPPORT OF PETITIONEWAPPELLANT on the interested parties in this action by placing true copies thereof enclosed in sealed envelopes addressed as follows

L

L

By Courier I caused the envelopes to be sent priority overnight by Federal Express to the parties as follows

Court of Appeal Second Appellate District Division 4 300 S Spring Street FI 2 N Tower Los Angeles CA 9001 3 (2 13) 830-7000

Orig + 4 copies

By Mail I am rdquoreadily familiarrdquo with the firmrsquos practice of collection and processing correspondence for mailing Under practice it would be deposited with the U S Postal Service on that same day with postage thereon fully prepaid (at Newport Beach CA in the ordinary course of business 1 am aware that on motion of the party served service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in (affidavit

Roger Jon Diamond Attorneys for PetitionerAppellant One copy 21 15 Main Street GIL N MILEIKOWSKY MD by mail Santa Monica CA 90405-221 5

Andrew J Kahn Davis Cowell amp Bowe 100 Van Ness Avenue 20Ih Floor San Francisco CA 94102

One copy by mail

Anna M Suda Attorneys for DefendanVRespondent One copy Christiansen amp Auer TEN ET HEALTH SY STEM by mail 225 South Lake Avenue 9Ih Floor Pasadena CA 91 101

Andrew J Kahn Attorneys for Amicus curiae for One copy Davis Cowell 8 Bowe appellant UNION OF AMERICAN by mail 595 Market Street 14rdquo Floor San Francisco CA 94105

PHYSICIANS AND DENTISTS

Steve lngram CAOC 770 L Street Suite 1200 Sacramento CA 95814

Consumer Attorneys of California One copy by mail

1 declare under penalty of perjury under the laws of the State of California that the aborsquove 1s true and correct

Executed on July 13 2004 at

7 Capazin Thornton

B 168705 ~



GIL N MILEIKOWSKY MD


vs TENET HEALTHSSSTEM et ai

Respomien ts

From orders of the Superior Court for Los Angeles County the Hon David Yaflee Judges Presiding LASC Case No BS 079 131

APPLICATION FOR LEAVE TO FILE AMICI CURIAE BRIEF OF THE CONSUMER ATTORNEYS OF CALIFORNIA I N

SUPPORT OF PETITIONER AND APPELLANT

SHARON J ARKIN (State Bar No 154858) ROBINSON CALCAGNIE 6 ROBINSON

620 Newport Center Drive 7 Floor Newport Beach California 92660

Teiephone 9497201288 Facsimile 9497201292


TO THE HONORABLE PRESIDING JUSTICE AND THE

HONOMBLE ASSOCIATE JUSTICES

Amicus Curiae CONSUMER ATTORNEYS OF CALIFORNIA

hereby respectfully requests permission to file its brief in support of

petitioner and appellant Gil N Mileikowsky MD This matter has not yet

been set for oral argument CONSUMER ATTORNEYS OF

CALIFORNIA only recently obtained the information necessary to present

its argument with regard to the issues to be considered in this action and has

prepared and presented this brief as expeditiously as possible

CONSUMER ATTORNEYS OF CALIFORNIA believes that the issues

presented are of utmost importance and that consideration of the analysis

presented in the brief will assist the Court in its determination

STATEMENT OF INTEREST OF THE AMICUS CURIAE

Consumer Attorneys of California is a voluntary menibership




to consumer fraud practices-personal injuries and insurance bad faith


1



effect of retaliation by a medical review board against a physician who







associations and others to retaIiate against doctors who testify on behalf of




Amicus has reviewed the briefs of the parties in this case Aiiiicirs is

therefore familiar with the issues in this case and the scope of their

presentation and believe that it can be of assistance to this Court by

providing additional briefing that materially adds to and complements the

partiesrsquo briefs (See Cal Rules of Court rule 14(b))

2

To properly inform the Court Amicus respectfully requests

pennissi-on io file the nnticits brief in support of petitioner that is submitted

concurrently herewith

Dated July 132004

4 I -

SHARON J A M Attorney for Amicus Curiae Consumer Attorneys of California

3

Mileikowsky v Tenent Healthsystem et a CA COURT OF APPEAL CASE NO B168705

PROOF OF SERVICE


I am employed in the County of Orange State of California I am over the age of 18 and not a party to the within action my business address is 620 Newport Center Drive 7th Floor Newport Beach CA 92660 (949) 720-1288

On July 13 2004 I served the within document described as APPLICATION FOR LEAVE TO FILE AMICI CURIAE BRIEF OF THE CONSUMER ATTORNEYS OF CALIFORNIA IN SUPPORT OF PETITIONEWAPPELLANT on the interested parties in this action by placing true copies thereof enclosed in sealed envelopes addressed as follows

L By Courier I caused the envelopes to be sent priority overnight by Federal Express to the parties as follows

Court of Appeal Second Appellate District Division 4 300 S Spring Street FI 2 N Tower Los Angeles CA 9001 3

(2 13) 830-7000

Orig + 4 copies

X By Mail I am readily familiar with the firms practice of collection and processing correspondence for mailing Under practice it would be deposited (with the U S Postal Service on that same day with postage thereon fully prepaid at Newport Beach CA in the ordinary course of business I am aware that on rnotiori of the party sewed service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit

Roger Jon Diamond Attorneys for PetitionerAppellant One copy 21 15 Main Street GIL N MILEIKOWSKY MD by mail Santa Monica CA 90405-2215

Andrew J Kahn Davis Cowell 8 Bowe 100 Van Ness Avenue 2Olh Floor San Francisco CA 941 02

One copy by mail

AnnaM Suda Attorneys for DefendanVRespondent One copy Christiansen 8 Auer TENET HEALTHSYSTEM by mail 225 South Lake Avenue 9Ih Floor Pasadena CA 91 101

Andrew J Kahn Attorneys for Amicus curiae for One copy Davis Cowell 8 Bowe appellant UNION OF AMERICAN by mall 595 Market Street 14 Floor San Francisco CA 94105



Consumer Attorneys of California One COPY by mail

I declare under penalty of perjury under the laws of the State of California that the above s vue

Executed on July 13 2004 at Newport Beach Californi3 and correct

_- -

--- Capazin Thornton v lt

B 168705

From orders of the Superior Court for Los Angeles Corrnt the Hon David Yaffee Judges Presiding LASC Case No BS 079 131



- GIL N MILEIKOWSKY MD


vs

TENET HEALTHSYSTEM et al

Respondents

AMICUS BRIEF OF THE CONSUMER ATTORNEYS OF CALIFORNIA IN SUPPOIRT

OF PETITIONER AND APPELLANT

SHARON J ARKIN (State Bar No 154858) ROBINSON CALCAGNIE amp ROBINSON

620 Newport Center Drive 7Ih Floor Newport Beach California 92660

Telephone 9497201288 Facsimile 9497201292


TABLE OF CONTENTS


LEGALARGUMENT 2


CONCLUSION g

I

1


CASES


OTHERS






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1

LEGAL ARGUMENT

1

















2





















3




















3

















( Id p 2)



5






















6









7

c 0 NC L US1 0 3







patients o r staff




Dated July 13 2004


8







9


PROOF OF SERVICE




L

L



Orig + 4 copies




One copy by mail








7 Capazin Thornton

B 168705 ~






Respomien ts



























1



















2




Dated July 132004

4 I -


3


PROOF OF SERVICE






(2 13) 830-7000

Orig + 4 copies




One copy by mail








_- -


TABLE OF CONTENTS


LEGALARGUMENT 2


CONCLUSION g

I

1


CASES


OTHERS






2

c

e

0

8

e

E

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c

3





















1

LEGAL ARGUMENT

1

















2





















3




















3

















( Id p 2)



5






















6









7

c 0 NC L US1 0 3







patients o r staff




Dated July 13 2004


8







9


PROOF OF SERVICE




L

L



Orig + 4 copies




One copy by mail








7 Capazin Thornton

B 168705 ~






Respomien ts



























1



















2




Dated July 132004

4 I -


3


PROOF OF SERVICE






(2 13) 830-7000

Orig + 4 copies




One copy by mail








_- -



CASES


OTHERS






2

c

e

0

8

e

E

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c

3





















1

LEGAL ARGUMENT

1

















2





















3




















3

















( Id p 2)



5






















6









7

c 0 NC L US1 0 3







patients o r staff




Dated July 13 2004


8







9


PROOF OF SERVICE




L

L



Orig + 4 copies




One copy by mail








7 Capazin Thornton

B 168705 ~






Respomien ts



























1



















2




Dated July 132004

4 I -


3


PROOF OF SERVICE






(2 13) 830-7000

Orig + 4 copies




One copy by mail








_- -


c

e

0

8

e

E

c

c

3





















1

LEGAL ARGUMENT

1

















2





















3




















3

















( Id p 2)



5






















6









7

c 0 NC L US1 0 3







patients o r staff




Dated July 13 2004


8







9


PROOF OF SERVICE




L

L



Orig + 4 copies




One copy by mail








7 Capazin Thornton

B 168705 ~






Respomien ts



























1



















2




Dated July 132004

4 I -


3


PROOF OF SERVICE






(2 13) 830-7000

Orig + 4 copies




One copy by mail








_- -


LEGAL ARGUMENT

1

















2





















3




















3

















( Id p 2)



5






















6









7

c 0 NC L US1 0 3







patients o r staff




Dated July 13 2004


8







9


PROOF OF SERVICE




L

L



Orig + 4 copies




One copy by mail








7 Capazin Thornton

B 168705 ~






Respomien ts



























1



















2




Dated July 132004

4 I -


3


PROOF OF SERVICE






(2 13) 830-7000

Orig + 4 copies




One copy by mail








_- -






















3




















3

















( Id p 2)



5






















6









7

c 0 NC L US1 0 3







patients o r staff




Dated July 13 2004


8







9


PROOF OF SERVICE




L

L



Orig + 4 copies




One copy by mail








7 Capazin Thornton

B 168705 ~






Respomien ts



























1



















2




Dated July 132004

4 I -


3


PROOF OF SERVICE






(2 13) 830-7000

Orig + 4 copies




One copy by mail








_- -





















3

















( Id p 2)



5






















6









7

c 0 NC L US1 0 3







patients o r staff




Dated July 13 2004


8







9


PROOF OF SERVICE




L

L



Orig + 4 copies




One copy by mail








7 Capazin Thornton

B 168705 ~






Respomien ts



























1



















2




Dated July 132004

4 I -


3


PROOF OF SERVICE






(2 13) 830-7000

Orig + 4 copies




One copy by mail








_- -


















( Id p 2)



5






















6









7

c 0 NC L US1 0 3







patients o r staff




Dated July 13 2004


8







9


PROOF OF SERVICE




L

L



Orig + 4 copies




One copy by mail








7 Capazin Thornton

B 168705 ~






Respomien ts



























1



















2




Dated July 132004

4 I -


3


PROOF OF SERVICE






(2 13) 830-7000

Orig + 4 copies




One copy by mail








_- -























6









7

c 0 NC L US1 0 3







patients o r staff




Dated July 13 2004


8







9


PROOF OF SERVICE




L

L



Orig + 4 copies




One copy by mail








7 Capazin Thornton

B 168705 ~






Respomien ts



























1



















2




Dated July 132004

4 I -


3


PROOF OF SERVICE






(2 13) 830-7000

Orig + 4 copies




One copy by mail








_- -










7

c 0 NC L US1 0 3







patients o r staff




Dated July 13 2004


8







9


PROOF OF SERVICE




L

L



Orig + 4 copies




One copy by mail








7 Capazin Thornton

B 168705 ~






Respomien ts



























1



















2




Dated July 132004

4 I -


3


PROOF OF SERVICE






(2 13) 830-7000

Orig + 4 copies




One copy by mail








_- -


c 0 NC L US1 0 3







patients o r staff




Dated July 13 2004


8







9


PROOF OF SERVICE




L

L



Orig + 4 copies




One copy by mail








7 Capazin Thornton

B 168705 ~






Respomien ts



























1



















2




Dated July 132004

4 I -


3


PROOF OF SERVICE






(2 13) 830-7000

Orig + 4 copies




One copy by mail








_- -








9


PROOF OF SERVICE




L

L



Orig + 4 copies




One copy by mail








7 Capazin Thornton

B 168705 ~






Respomien ts



























1



















2




Dated July 132004

4 I -


3


PROOF OF SERVICE






(2 13) 830-7000

Orig + 4 copies




One copy by mail








_- -



PROOF OF SERVICE




L

L



Orig + 4 copies




One copy by mail








7 Capazin Thornton

B 168705 ~






Respomien ts



























1



















2




Dated July 132004

4 I -


3


PROOF OF SERVICE






(2 13) 830-7000

Orig + 4 copies




One copy by mail








_- -


B 168705 ~






Respomien ts



























1



















2




Dated July 132004

4 I -


3


PROOF OF SERVICE






(2 13) 830-7000

Orig + 4 copies




One copy by mail








_- -





















1



















2




Dated July 132004

4 I -


3


PROOF OF SERVICE






(2 13) 830-7000

Orig + 4 copies




One copy by mail








_- -




















2




Dated July 132004

4 I -


3


PROOF OF SERVICE






(2 13) 830-7000

Orig + 4 copies




One copy by mail








_- -





Dated July 132004

4 I -


3


PROOF OF SERVICE






(2 13) 830-7000

Orig + 4 copies




One copy by mail








_- -



PROOF OF SERVICE






(2 13) 830-7000

Orig + 4 copies




One copy by mail








_- -


EXHIBIT 5 - Alliance for Patient · PDF fileothers are surreptitious and hidden under...

Documents

Transcript of EXHIBIT 5 - Alliance for Patient · PDF fileothers are surreptitious and hidden under...