Trejo v. California Forensic Medical Group

District Court, S.D. California·Decided September 12, 2024·No. 3:20-cv-01465·Unknown

Opinion

1 2 3 4 5

7 UNITED STATES DISTRICT COURT 8 SOUTHERN DISTRICT OF CALIFORNIA 9

10 JOSE TREJO, et al., Case No.: 20-cv-1465-DDL 11 Plaintiffs, FINAL PRETRIAL CONFERENCE 12 v. ORDER 13 CALIFORNIA FORENSIC MEDICAL 14 GROUP, 15 Defendant. 16 17 Pursuant to Federal Rule of Civil Procedure 16(e), Local Civil Rule 16.1(f) and the 18 Court’s Amended Scheduling Order (Dkt. No. 185), IT IS ORDERED: 19 I. 20 STATEMENT OF THE CASE 21 From October 27, 2018 to February 23, 2019, Jose Banda Pichardo was an inmate 22 incarcerated at the Imperial County Sheriff’s Department, Regional Adult Detention 23 Facility. During this time, Defendant California Forensic Medical Group was responsible 24 for administering medical and mental health care to inmates incarcerated at the Imperial 25 County Sheriff’s Department, Regional Adult Detention Facility. On February 23, 2019, 26 Jose Banda Pichardo died by suicide in his cell by asphyxiating himself with a bedsheet. 27 The parties in this case are Plaintiff Estate of Jose Banda Pichardo, Plaintiff Jose 28 Trejo, who is the father of decedent Jose Banda Pichardo, Plaintiff Susana Banda, who is 1 the mother of decedent Jose Banda Pichardo, and Defendant California Forensic Medical 2 Group (hereinafter also “CFMG”). 3 II. 4 CAUSES OF ACTION 5 The pleadings that raise the issues are Plaintiff’s Fourth Amended Complaint, filed 6 on January 30, 2024 (Dkt. No. 175); and Defendant’s Answer, filed March 1, 2024 7 (Dkt. No. 176). 8 The causes of action against Defendant CFMG are the third cause of action, which 9 is a survival cause of action for negligence brought on behalf of Plaintiff Estate of Jose 10 Banda Pichardo, and the fifth cause of action, which is a wrongful death cause of action 11 brought on behalf of Plaintiffs Jose Trejo and Susana Banda pursuant to California Code 12 of Civil Procedure § 377.60. 13 III. 14 WITNESSES 15 A. Expect to Call 16 1. Plaintiffs 17 1. Plaintiff Jose Trejo: Plaintiff in this case who will testify as to damages. 18 2. Plaintiff Susana Banda: Plaintiff in this case who will testify as to damages. 19 3. Michael Jay Dibble: Independent witness who will testify as to events 20 perceived relative to underlying incident. 21 4. Joshua Lee Greene: Independent witness who will testify as to events 22 perceived relative to underlying incident. 23 5. Dagoberto Conde: Independent witness who will testify as to events perceived 24 relative to underlying incident. 25 6. Plaintiffs’ Forensic Psychiatrist Expert Nicole Johnson, M.D.: Plaintiff’s 26 retained expert witness relative to psychiatry. 27 7. Plaintiffs’ Corrections Expert Tim Gravette: Plaintiff’s retained expert 28 witness relative to correctional practices. 1 8. Imperial County Sheriff’s Office Deputy Chief Jamie Clayton (Ret.): County 2 employee who will testify as to underlying incident and provide testimony relative to the 3 jail. 4 9. Imperial County Sheriff’s Office Watch Commander Colby Stewart: County 5 employee who will testify as to underlying incident and provide testimony relative to the 6 jail. 7 10. Imperial County Sheriff’s Office Correctional Officer Arthur Aguilar: County 8 employee who will testify as to underlying incident and provide testimony relative to the 9 jail. 10 11. Imperial County Sheriff’s Office Correctional Officer Dominic Aguirre: 11 County employee who will testify as to underlying incident and provide testimony relative 12 to the jail. 13 12. Imperial County Sheriff’s Office County FRCP 30(b)(6) Person Most 14 Knowledgeable Juan Chavarin: County employee who will testify as to underlying incident 15 and provide testimony relative to the jail. 16 13. CFMG Health Services Administrator and FRCP 30(b)(6) Person Most 17 Knowledgeable Linda Corfman, R.N.: CFMG employee who will testify about CFMG’s 18 role at the jail as well as services administered by CFMG. This witness will also testify 19 concerning the underlying incident. 20 14. CFMG Psychiatrist Taylor Fithian, M.D.: CFMG employee who will testify 21 about CFMG’s role at the jail as well as services administered by CFMG. 22 15. CFMG Nurse Dorina Armenta, R.N.: CFMG employee who will testify about 23 CFMG’s role at the jail as well as services administered by CFMG. This witness will also 24 testify concerning the underlying incident. 25 16. CFMG Nurse Norma Franco, L.V.N.: CFMG employee who will testify about 26 CFMG’s role at the jail as well as services administered by CFMG. This witness will also 27 testify concerning the underlying incident. 28 1 17. CFMG Miguel Duarte, R.N.: CFMG employee who will testify about 2 CFMG’s role at the jail as well as services administered by CFMG. This witness will also 3 testify concerning the underlying incident. 4 18. CFMG Independent Contracting Tele Psychiatrist Michael Salib, M.D.: 5 CFMG employee who will testify about CFMG’s role at the jail as well as services 6 administered by CFMG. This witness will also testify concerning the underlying incident. 7 19. Imperial County Sheriff’s Office Investigator Marco Lopez: County 8 employee who will testify as to the investigation of the death. 9 20. Imperial County Coroner’s Office Forensic Pathologist Darryl J. Garber, 10 M.D.: County employee who will testify as to the autopsy of Mr. Pichardo. 11 21. CFMG Richard Shunnarah, R.N: CFMG employee who will testify about 12 CFMG’s role at the jail as well as services administered by CFMG. 13 22. Board of State and Community Corrections Custodian of Records: Custodian 14 of records to authenticate Board of State and Community Corrections records. 15 2. Defendant 16 Defendant expects to call the above witnesses at numbers 1-2 and 8-21. In addition, 17 defendant expects to call: 18 1. Kim Pearson, R.N.: Defendant’s retained expert witness on the standard of 19 care, policies and causation. 20 2. Robert Fonzi: Imperial County’s retained expert witness relative to 21 correctional practices. 22 3. Vanessa Alvarado: CFMG employee and percipient witness regarding 23 decedent’s care and treatment at the Imperial County Jail. 24 4. Antenela Barron, LVN: CFMG employee and percipient witness regarding 25 decedent’s care and treatment at the Imperial County Jail. 26 5. Jaime Daleth, L.V.N.: CFMG employee and percipient witness regarding 27 decedent’s care and treatment at the Imperial County Jail. 28 / / / 1 6. Ivan Martin: CFMG employee and percipient witness regarding decedent’s 2 care and treatment at the Imperial County Jail. 3 7. Julio Martinez, M.D.: CFMG contractor and Percipient witness regarding 4 decedent’s care and treatment at the Imperial County Jail and CFMG’s medical and mental 5 health program at Imperial County Jail during the relevant time frame. 6 B. Reserve the Right to Call 7 1. Plaintiffs 8 Plaintiffs intend to call all aforementioned witnesses at trial. 9 2. Defendant 10 Defendant intends to call all aforementioned witnesses at trial. Defendant reserves 11 the right to call impeachment witnesses as necessary. 12 IV. 13 EXHIBITS 14 A. Expect to Offer 15 1. Plaintiffs 16 1. Imperial County Sheriff’s Office (hereinafter “ICSO”) Watch Commander 17 Colby Stewart Standard Diary/Daily Logs (IMP001231-1351) 18 2. ICSO Jail Logs re: Jose Banda Pichardo (IMP000117-118) 19 3. ICSO Jail Events/Summary Reports re: Jose Banda Pichardo (IMP000034- 20 52) 21 4. CFMG Medical Records re: Jose Banda Pichardo (CFMG-JBP 000001-89) 22 5. ICSO Guard 1-Plus Round Tracker Module H (IMP000080-82) 23 6. ICSO Incident Report re: Jose Banda Pichardo Suicide (IMP000010-33) 24 7. Board of State and Community Corrections (IMP001352-1488) 25 8. ICSO Command Staff Email Authored by Inv. Lopez (IMP001112) 26 9. ICSO Inv.

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