Opinion
2:19-cv-01722-JAM-DB
05-23-2023
RANDALL SCOTT JOHNSON, DECEASED, by and through his Successor in Interest, KATHERINE JOHNSON, KATHERINE JOHNSON, Individually, Plaintiff, v. CALIFORNIA FORENSIC MEDICAL GROUP, INCORPORATED, a California corporation; CORRECTIONAL MEDICAL GROUP COMPANIES, INC., a Delaware Corporation; WELLPATH INC., a Delaware corporation; WELLPATH MANAGEMENT, INC., a Delaware Corporation; WELLPATH LLC, a Delaware Limited Liability Company; DOE Defendant 1; KERI RUBALCAVA, R.N.; AMANDA REAM, R.N.; LINDA SMITH, R.N.; JOHN MAIKE, Psychiatric R.N.; CYNTHIA COLLINS, L.V.N.; SHELBY CALLAHAN, L.V.N.; DEBORAH SAEGER, MFT; THOMAS HAMMOND, L.V.N.; and DOES 7-20; individually, jointly, and severally, Defendants. ADDRESS
MICHAEL J. HADDAD (SBN 189114) JULIA SHERWIN (SBN 189268) TERESA ALLEN (SBN 264865) HADDAD & SHERWIN LLP Attorneys for Plaintiff
MICHAEL J. HADDAD (SBN 189114)
JULIA SHERWIN (SBN 189268)
TERESA ALLEN (SBN 264865)
HADDAD & SHERWIN LLP
Attorneys for Plaintiff
PLAINTIFF'S AMENDED TRIAL WITNESS LIST
Plaintiff, by and through her attorneys, HADDAD & SHERWIN LLP, submit the following trial witness list:
| NAME AND NATURE OF TESTIMONY | ADDRESS | |
| 1. | Plaintiff Katherine Johnson- Decedent's sister; Personal background and history; damages, including relationship with brother; redirect. | Available through counsel |
| 2. | Defendant Amanda Ream, RN - Liability, Wellpath training and policies; knowledge of standards of care; contact with, and assessment of, Randall Johnson; involvement in incident(s); reporting; impeachment; re-cross. | Available through counsel |
| 3. | Defendant Keri Rubalcava, RN - Liability, Wellpath training and policies; knowledge of standards of care; supervision and scheduling of nursing staff; implementation of contract and staffing plan; involvement in incident(s); reporting; impeachment; re-cross. | Available through counsel |
| 4. | Defendant Linda Smith, RN - Liability, Wellpath training and policies; knowledge of standards of care; contact with, and assessment of, Randall Johnson; involvement in incident(s); reporting; impeachment; re-cross. | Available through counsel |
| 5. | Defendant John Maike, RN - Liability, Wellpath training and policies; knowledge of standards of care; contact with, and assessment of, Randall Johnson; involvement in incident(s); reporting; impeachment; re-cross. | Available through counsel |
| 6. | Defendant Cynthia Collins, LVN - Liability, Wellpath training and policies; knowledge of standards of care; contact with, and assessment of, Randall Johnson; involvement in incident(s); reporting; impeachment; re-cross. | Available through counsel |
| 7. | Defendant Shelby Callahan, LVN - Liability, Wellpath training and policies; knowledge of standards of care; contact with, and assessment of, Randall Johnson; involvement in incident(s); reporting; impeachment; re-cross. | Available through counsel |
| 8. | Defendant Deborah Saeger, MFT - Liability, Wellpath training and policies; knowledge of standards of care; contact concerning Randall Johnson; involvement in incident(s); reporting; impeachment; re-cross. | Available through counsel |
| 9. | Defendant Thomas Hammond, LVN - Liability, Wellpath training and policies; knowledge of standards of care; contact | Available through counsel |
| with, and assessment of, Randall Johnson; involvement in incident(s); reporting; impeachment; re-cross. | ||
| 10. | Raymond Herr, M.D. - Liability, Wellpath training and policies; CFMG/Wellpath entities; CFMG/Wellpath contract and financial condition; CFMG tax returns; knowledge of standards of care; impeachment; re-cross | Available through counsel |
| 11. | Sinecio Cordero - Defendants' Fed. Rule 30(b)(6) person most knowledgeable re: the financial management of the Wellpath entities; impeachment; re-cross. | Available through counsel |
| 12. | Carin Kottraba, Ph.D - Defendants' Fed. Rule 30(b)(6) person most knowledgeable re: policies, procedures, and training provided to jail health care staff assigned to work in Shasta County concerning clearance of patient inmates into the jail with respect to mental health issues; Wellpath entities, policies, and training; impeachment; re-cross. | Available through counsel |
| 13. | Brooke McGee - Defendants' Fed. Rule 30(b)(6) person most knowledgeable re: the relationship between, and formation of, the CFMG/CMGC/Wellpath entities; impeachment; re-cross. | Available through counsel |
| 14. | Tabitha Vanns - Defendants' Fed. Rule 30(b)(6) person most knowledgeable re: the corporate Defendants' financial condition, including but not limited to assets, liabilities, revenue, cash flow, profit, expenses, loss, gross income, net income, net worth, value, loans, mortgages, lines of credit, solvency, and financial stability, from January 1, 2018, to the present. | Available through counsel |
| 15. | Jail Captain Dave Kent- Liability; Shasta County Sheriffs Office training and policies; knowledge of standards of care; investigation and review of incident(s); impeachment; re-cross. | Shasta County Sheriff's Office; 300 Park Marina Circle; Redding, CA 96001 |
| 16. | Sergeant Brandon Rodgers- Liability; Shasta County Sheriff's Office training and policies; knowledge of standards of care; involvement in incident(s); reporting; impeachment; re-cross. | Shasta County Sheriff's Office; 300 Park Marina Circle; Redding, CA 96001 |
| 17. | Deputy Wyatt Mason - Liability; Shasta County Sheriff's Office training and policies; involvement in incident(s); reporting; impeachment; re-cross. | Shasta County Sheriff's Office; 300 Park Marina Circle; Redding, CA 96001 |
| 18. | Deputy Hector Cortez - Liability; Shasta County Sheriff's Office training and policies; involvement in incident(s); reporting; impeachment; re-cross. | Shasta County Sheriff's Office; 300 Park Marina Circle; Redding, CA 96001 |
| 19. | Deputy Miguel Espinoza - Liability; Shasta County Sheriff's Office training and policies; involvement in incident(s); reporting; impeachment; re-cross. | Shasta County Sheriff's Office; 300 Park Marina Circle; Redding, CA 96001 |
| 20. | Deputy Richard Ochoa - Liability; Shasta County Sheriff's Office training and policies; involvement in incident(s); reporting; impeachment; re-cross. | Shasta County Sheriff's Office; 300 Park Marina Circle; Redding, CA 96001 |
| 21. | Deputy Joseph Grady - Liability; Shasta County Sheriff's Office training and policies; involvement in incident(s); reporting; impeachment; re-cross. | Shasta County Sheriff's Office; 300 Park Marina Circle; Redding, CA 96001 |
| 22. | Deputy Brandon Alido - Liability; Shasta County Sheriff's Office training and policies; involvement in incident(s); reporting; impeachment; re-cross. | Shasta County Sheriff's Office; 300 Park Marina Circle; Redding, CA 96001 |
| 23. | Deputy Arik Amaya - Liability; Shasta County Sheriff's Office training and policies; involvement in incident(s); reporting; impeachment; re-cross. | Shasta County Sheriff's Office 300 Park Marina Circle, Redding, CA 96001 |
| 24. | Deputy Christopher Murrill - Liability; Shasta County Sheriff's Office training and policies; involvement in incident(s); reporting; impeachment; re-cross. | Shasta County Sheriff's Office 300 Park Marina Circle Redding, CA 96001 |
| 25. | Deputy Orlando Rabon - Liability; Shasta County Sheriff's Office training and policies; involvement in incident(s); reporting; impeachment; re-cross. | Shasta County Sheriff's Office 300 Park Marina Circle, Redding, CA 96001 |
| 26. | Sergeant Chase Reed - Liability; Shasta County Sheriff's Office training and policies; involvement in incident(s); reporting; impeachment; re-cross. | Shasta County Sheriff's Office 300 Park Marina Circle, Redding, CA 96001 |
| 27. | Deputy Joshua Dorstad - Liability; Shasta County Sheriff's Office training and policies; involvement in incident(s); reporting; impeachment; re-cross. | Shasta County Sheriff's Office 300 Park Marina Circle, Redding, CA 96001 |
| 28. | Deputy Dustin McQuillan - Liability; Shasta County Sheriff's Office training and policies; involvement in incident(s); reporting; impeachment; re-cross. | Shasta County Sheriff's Office 300 Park Marina Circle, Redding, CA 96001 |
| 29. | Deputy Zachary Jurkiewicz - Liability; Shasta County Sheriff's Office training and policies; involvement in incident(s); reporting; impeachment; re-cross. | Shasta County Sheriff's Office 300 Park Marina Circle, Redding, CA 96001 |
| 30. | Lieutenant Dale Marler - Liability; Shasta County Sheriff's Office training and policies; involvement in incident(s); reporting; impeachment; re-cross. | Shasta County Sheriff's Office 300 Park Marina Circle, Redding, CA 96001 |
| 31. | Sergeant Joe Danis - Defendant Shasta County's Fed. Rule 30(b)(6) person most knowledgeable re: policies, procedures and training provided to jail staff: clearing of patient inmates into the jail, drug intoxication and overdoses, observations of inmates, suicide safety cell observation, mentally disordered or emotionally disturbed inmates, rhabdomyolysis, and medical emergencies. | Shasta County Sheriff's Office 300 Park Marina Circle, Redding, CA 96001 |
| 32. | Redding Officer Darren Hull - Redding Police Department training and policies; involvement in incident(s); reporting; impeachment; re-cross. | Redding Police Department 777 Cypress Ave, Redding, CA 96001 |
| 33. | Yutta Johnson - Plaintiff's hairstylist and friend; Plaintiff's relationship with her brother; damages; redirect. | 9750 Newport Highway, Spokane, WA 99218 |
| 34. | Caitlin Merriman - Plaintiff's daughter; family history; Plaintiff's relationship with her brother; damages; redirect. | Available through counsel |
| 35. | Jacob Caputo - Plaintiff's son; family history; Plaintiff's relationship with her brother; damages; redirect. | Available through counsel |
| 36. | Sarah Blume - Plaintiff's friend and co-worker; family history; Plaintiff's relationship with her brother; damages; redirect. | 2 Pine Lane, Kettle Falls, WA 99141 |
| 37. | Barbara Burns -- Plaintiff's friend, family history; Plaintiff's relationship with her brother; damages; redirect. | 303 E. Glass Ave. Spokane, WA 99207 |
| 38. | Deirdre Amaro, M.D. -- Forensic Pathologist, Shasta County Sheriffs-Coroner's Office; will testify concerning decedent's autopsy, liability, causation, damages. | Shasta County Sheriffs-Coroner's Office |
| 4555 Veterans Ln, Redding, CA 96001 | ||
| 39. | Michael E. Lamb, Toxicologist - Will testify concerning decedent's toxicology results, liability, causation, damages. | NMS Labs 200 Welsh Road Horsham, PA 19044 |
| 40. | Ann Shuman, R.N., Nursing Education Consultant, Board of Vocational Nursing and Psychiatric Technicians - will testify concerning notice to CFMG/CMGC/Wellpath about the LVN scope of practice and Wellpath's improper staffing and patient care practices | 2535 Capitol Oaks Drive, Suite 205 Sacramento, CA 95833 |
| 41. | Richard Hayward, M.D. - Plaintiff's expert in clinical, correctional, and forensic psychology | 1296 Woodside Road Redwood City, CA 94061 |
| 42. | Larissa Mooney, M.D. - Plaintiff's expert in addiction medicine and psychiatry; Director, UCLA Addiction Medicine Clinic, UCLA Integrated Substance Abuse Programs, Department of Psychiatry and Biobehavioral Sciences, David Geffen School of Medicine at UCLA | David Geffen School of Medicine at UCLA 760 Westwood Plaza, Suite 37370 Los Angeles, CA 90095 |
| 43. | Denise Panosky, D.N.P., R.N., C.N.E., C.C.H.P., F.C.N.S. - Plaintiff's expert in clinical and forensic nursing and correctional nursing | University of Connecticut School of Nursing Storrs Hall, Room 101C 231 Glenbrook Rd. U-4026 Storrs, CT 06269 |
| 44. | Martin Chenevert, M.D. - Plaintiff's expert in emergency medicine | Santa Monica-UCLA Medical Center 2633 Lincoln Blvd., #722 Santa Monica, CA 90405 |
| 45. | Annette M. Stalker, C.P.A. - Plaintiff's expert in forensic accounting | Stalker Forensics 4120 Douglas Blvd. 306-117 |
| Granite Bay, CA 95746 | ||
| 46. | Paul Endo - Plaintiff's expert in Forensic Audio/Video Analysis | Think Twice Legal 611 Gateway Blvd., Suite 120 South San Francisco, CA 94080 |
| 47. | Loretta Melby, R.N., M.S.N., Executive Officer Board of Registered Nursing - California Board of Registered Nursing Accusation against Defendant Amanda Ream, R.N. | 2535 Capitol Oaks Drive Suite 205 Sacramento, CA 95833 |
| 48. | Custodian of Records for the Board of Registered Nursing | 1747 N. Market Blvd, Sacramento, CA 95834 |
| 49. | Custodian of Records for the Board of Vocational Nursing and Psychiatric Technicians | 2535 Capitol Oaks Drive Suite 205 Sacramento, CA 95833 |
| 50. | Abigail Hamilton, Paralegal - Authenticating summary of voluminous documents | Available through counsel |
| 51. | Johnna Spikes, Paralegal - Authenticating summary of voluminous documents | Available through counsel |
Plaintiff reserves the right to call all witnesses listed by Defendants, and reserves the right to call witnesses in rebuttal.