Demurrer_to_amended_complaint

Demurrer

Cal. Super. - 4th Dist.June 11, 2018

Oo 0 NN O N Re W N = N O N NN N N N N N N e m e m e m em e m e m md j d ee ww d N n n BR W N = R , O Y N N BR W N e e OS Jeffery W. Grass, Bar No. 112251 Jennifer R. Koerner, Bar No. 203983 jennifer davis-grass.com DAVIS, GRASS, GOLDSTEIN & FINLAY 3105 Sedona Court Ontario, California 91764 (909) 476-2662 (Telephone) (909) 476-2335 (Facsimile) Attorneys for Defendant, Kristin Rodriguez, D.O. SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ORANGE CENTRAL JUSTICE CENTER NICOLAS GONCHAR, Case No.: 30-2018-00998148-CU-MM-CIC Plaintiff, Judge: Hon. Layne H. Melzer Dept.: C12 v. DEFENDANT KRISTIN RODRIGUEZ, PLACENTIA LINDA HOSPITAL, Christina D.0.’S DEMURRER TO PLAINTIFF'S Oh, Jennifer Skovseth, Kristen Rodriguez and THIRD AMENDED COMPLAINT; DOES 1 through 100, inclusive, MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT Defendants. THEREOF; DECLARATION OF JENNIFER R. KOERNER Date: April 16, 2020 Time: 2:00 p.m. Dept: C-12 Reserve ID: 73204880 Trial Date: December 14, 2020 TO ALL PARTIES AND ATTORNEYS OF RECORD HEREIN: PLEASE TAKE NOTICE that on April 16, 2020 at 2:00 p.m. or as soon thereafter as the matter may be heard in Department “C12" of the above-entitled court, located at 700 Civic Center Drive West, Santa Ana, California, defendant Kristin Rodriguez, D.O., will, and by this notice of motion and demurrer does, generally demurrer to plaintiff’s third amended complaint. Defendant’s demurrer is based on the grounds set forth in the accompanying demurrer to the third amended complaint. 1 DEFENDANT KRISTIN RODRIGUEZ, D.O.”S DEMURRER TO PLAINTIFF'S THIRD AMENDED COMPLAINT; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF; DECLARATION OF JENNIFER R. KOERNER a NO 0 N N W n 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 This demurrer will be based on this notice, the memorandum of points and authorities in support thereof, the complete files and records in this court concerning this action, on matters of which this court may take judicial notice, and upon such other and further oral and documentary evidence as may be presented at the time of hearing on the demurrer. Dated: January 16, 2020 DAVIS, GRASS, GOLDSTEIN & FINLAY lL a + VT — (etter W. Grass ennifer R. Koerner Attorneys for Defendant, Kristin Rodriguez, D.O. By: 2 DEFENDANT KRISTIN RODRIGUEZ, D.O.”S DEMURRER TO PLAINTIFF'S THIRD AMENDED COMPLAINT; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF; DECLARATION OF JENNIFER R. KOERNER BS L N NO 0 N N Wn 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DEMURRER TO THIRD AMENDED COMPLAINT Defendant Kristin Rodriguez, D.O. hereby demurrers to the third amended complaint on file herein on the following grounds: 1. The second cause of action fails to allege facts sufficient to state a cause of action against Kristin Rodriguez, D.O. under the Consumer Legal Remedies Act, Civil Code Section 1750 et seq. WHEREFORE, this moving defendant prays as follows: 1. That this demurrer to plaintiff’s third amended complaint be sustained without leave to amend; 2. That judgment be entered in favor of this moving defendant as to the above-referenced cause of action; and 3. For such other and further relief as this court deems just and proper. Dated: January 16, 2020 DAVIS, GRASS, GOLDSTEIN & FINLAY By: \ A d— ffery W. Grass Jennifer R. Koerner Attorneys for Defendant, Kristin Rodriguez, D.O. 3 DEFENDANT KRISTIN RODRIGUEZ, D.0.’S DEMURRER TO PLAINTIFF'S THIRD AMENDED COMPLAIN T; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF, DECLARATION OF JENNIFER R. KOERNER wn Ah W N NO 0 9 Sy 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MEMORANDUM OF POINTS AND AUTHORITIES LL INTRODUCTION Plaintiff Nicolas Gonchar filed his third amended complaint (TAC) on January 13,2020. The TAC generally alleges that plaintiff underwent prostate cancer surgery at Cedars-Sinai Medical Center on March 18, 2016. He was discharged home the following afternoon (March 19, 2016). That evening (March 19, 2016) he developed an inability to pass urine through a urinary catheter that had been placed following surgery. His son drove him to the emergency department at Placentia-Linda Hospital on March 19, 2016. Plaintiff alleges that he was seen by moving defendant, Kristin Rodriguez, D.O. in the emergency department at Placentia-Linda Hospital on March 19, 2016. He contends that he had one - 2 minute encounter with Dr. Rodriguez and then he never saw her again. Plaintiff alleges that Dr. Rodriguez delegated drainage of his blocked catheter to a nurse. The nurse allegedly made two unsuccessful attempts to unclog the catheter. After the attempts, plaintiff alleges that he was advised that he was having bladder spasms, but the hospital could not provide medication to relieve the bladder spasms because its pharmacy was closed. Plaintiff was then discharged home with a prescription for bladder spasms to be filled at an outside pharmacy. Plaintiff alleges that he would not have agreed to be discharged had he been advised of the dangers associated with a blocked urinary catheter. As a result of the alleged failure to address his blocked catheter, plaintiff now contends that he suffers from ongoing urinary incontinence. Based on the alleged facts, plaintiff's TAC asserts three different causes of action: medical malpractice negligence, violation of the California Legal Remedies Act, and gross negligence. A demurrer to the second cause of action for violation of the California Legal Remedies Act (as alleged in the SAC) was filed on behalf of defendant Kristin Rodriguez, D.O. Said demurrer similarly asserted that the SAC failed to assert sufficient facts to support a cause of action for violation of the Consumer Legals Remedy Act. That demurrer was heard by this court on December 12,2019. After considering the moving papers and oral arguments, the court sustained the demurrer with 30 days leave to amend. 4 DEFENDANT KRISTIN RODRIGUEZ, D.0.’S DEMURRER TO PLAINTIFF'S THIRD AMENDED COMPLAINT; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF; DECLARATION OF JENNIFER R. KOERNER wv A W N Oo 0 a 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 As will be set forth below, plaintiff’s TAC similarly fails to set forth a cause of action for violation of the California Legal Remedies Act (CLRA) against Dr. Rodriguez. IL. RULES ON DEMURRER A party against whom suit has been filed may, by demurrer, test the sufficiency of the complaint if it appears that the complaint fails to state a cause of action. (Code of Civil Procedure Section 430.10(e).) “‘A general demurrer searches the complaint’ or the particular count to which it is directed, for any and every failure to state a material fact. In other words, the absence of any allegation essential to the cause of action makes the complaint vulnerable to a general demurrer. The ruling on a general demurrer is thus a method of deciding the cause on the merits on assumed facts (those alleged) without atrial." (Banerian v. O'Malley (1974) 42 Cal.App.3d 604, 611.), citing to 3 Witkin, Cal. Procedure (2d ed. 1971) § 802, p. 2415.) It is well settled that, for purposes of testing the sufficiency of a cause of action, a demurrer admits all material facts properly pled, but not contentions or conclusions of facts or law. (Daar v. Yellow Cab Co. (1967) 67 Cal.2d 695, 713.) When these rules are applied to plaintiff’s TAC complaint, it is clear that this demurrer should be sustained without further leave to amend. IIL. PLAINTIFF’S THIRD CAUSE OF ACTION DOES NOT SET FORTH SUFFICIENT FACTS TO SUPPORT A CAUSE OF ACTION FOR VIOLATION OF THE CONSUMERS LEGAL REMEDIES ACT AGAINST DR. RODRIGUEZ In his second cause of action, plaintiff again attempts to set forth a cause of action against Dr. Rodriguez for violation of the Consumers Legal Remedy Act (CLRA) codified at Civil Code Section 1750, et seq. On its face, the act is not applicable to the facts alleged by plaintiff. "The Consumers Legal Remedies Act, enacted in 1970, ‘established a nonexclusive statutory remedy for "unfair methods of competition and unfair or deceptive acts or practices undertaken by any person in a transaction intended to result or which results in the sale or lease of goods or services to 5 DEFENDANT KRISTIN RODRIGUEZ, D.0.’S DEMURRER TO PLAINTIFF'S THIRD AMENDED COMPLAINT; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF; DECLARATION OF JENNIFER R. KOERNER Ww O L N N 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 any consumer. . . ." [Citation.]' " (Reveles v. Toyota by the Bay (1997) 57 Cal. App. 4th 1139, 1154.) "The self-declared purposes of the act are 'to protect consumers against unfair and deceptive business practices and to provide efficient and economical procedures to secure such protection.’ ( Civ. Code, § 1760... .)" (Citations omitted.) (Wang v. Massey Chevrolet (2002) 97 Cal. App.4th 856, 869.) In Broughton v. Cigna Health Plans (1999) 21 Cal.4th 1066, 1077, the Supreme Court further discussed the nature and purpose of the CLRA. In that regard, the court stated: The CLRA was enacted in an attempt to alleviate social and economic problems stemming from deceptive business practices, which were identified in the 1969 Report of the National Advisory Commission on Civil Disorders (i.e., the Kerner Commission). (See Reed, Legislating for the Consumer: An Insider's Analysis of the Consumers Legal Remedies Act (1971) 2 Pacific L.J. 1, 5-7.) Section 1760 contains an express statement of legislative intent: "This title shall be liberally construed and applied to promote its underlying purposes, which are to protect consumers against unfair and deceptive business practices and to provide efficient and economical procedures to secure such protection.” Specifically, the CLRA identifies as actionable certain deceptive business practices. (§1770.) The practices include, for example, "[r]epresenting that goods are original or new if they have deteriorated unreasonably or are altered, reconditioned, reclaimed, used, or secondhand” (§ 1770, subd. (a)(6)) or "[a]dvertising goods or services with intent not to sell them as advertised" (§ 1770, subd. (a)(9)). It permits a consumer who has been damaged by these deceptive practices to bring an action for actual damages, including a class action suit, as well as for "an order enjoining a method, act, or practice," and punitive damages. (§ 1780, subd. (a).) (Broughton v. Cigna Health Plans (1999) 21 Cal.4th 1066, 1077.) The legislative history behind the CLRA was further explored in Justice Chin’s dissent at page 1099 of the Broughton decision as follows: Similarly, an analysis by the Assembly Committee on the Judiciary stressed that the CLRA's purpose was "to provide consumers with remedies as against merchants" because "[n]o such remedies are presently available to the individual consumer in California law." (Assem. Com. on Judiciary, Analysis of Assem. Bill No. 292 (1970 Reg. Sess.) Apr. 20, 1970, p. 1, italics added.) (Broughton v. Cigna Health Plans (1999) 21 Cal.4th 1066, 1099.) The purpose behind the CLRA was also examined by the Supreme Court in Vasquez v. Superior Court (1971) 4 Cal.3d. 800, 808, as follows: Protection of unwary consumers from being duped by unscrupulous sellers is an exigency of the utmost priority in contemporary society. According to the report of the Kerner Commission, many persons who reside in low income neighborhoods experience grievous exploitation by vendors using such devices as high pressure salesmanship, bait advertising, misrepresentation of prices, exorbitant prices and 6 DEFENDANT KRISTIN RODRIGUEZ, D.0.’S DEMURRER TO PLAINTIFF'S THIRD AMENDED COMPLAINT, MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF; DECLARATION OF JENNIFER R. KOERNER NT 0 N o y nn RR W N N O N N O N N N N N N mm e e em em p m p m e m pe d ow N N nn Re W N = D O 0 N y E W N , credit charges, and sale of shoddy merchandise. State laws governing relations between consumers and merchants are generally utilized only by informed, sophisticated parties, affording little practical protection to low income families. (Report of National Advisory Commission on Civil Disorders (Bantam ed. 1968) pp. 275-276; Hester, Deceptive Sales Practices and Form Contracts -- Does the Consumer Have a Private Remedy? (1968) Duke L..J. 831.) The alternatives of multiple litigation (joinder, intervention, consolidation, the test case) do not sufficiently protect the consumer's rights because these devices "presuppose 'a group of economically powerful parties who are obviously able and willing to take care of their own interests individually through individual suits or individual decisions about joinder or intervention." (Citations omitted.) In these cases and their progenies, the courts recognize that the CLRA is targeted at merchants and applies to consumers with problems for which “no such remedies are presently available to the individual consumer in California law.” Plaintiff cannot establish, as an underlying basis for his CLRA cause of action, that relief from negligent medical malpractice is not otherwise available to him in California. The contrary is true. Medical malpractice actions against doctors for negligence, failing to provide informed consent, avoiding or withholding required services and a myriad of other breaches are filed daily. Thus, even if the demurrer to the CLLRA cause of action is sustained without leave to amend, plaintiff still has remedies available to him under the law. In summary, under cases such as Broughton and Vasquez, it is clear that the CLRA is not intended to be utilized in the manner in which plaintiff is attempting in this case. Unless plaintiff can demonstrate some case law, statutory construction, legislative comment, or other qualified basis to claim that the CLRA applies to the physician/patient relationship, then plaintiff has not sufficiently established that the cause of action for violation of the CLRA exists in a medical negligence context. For that reason, the demurrer to the second cause of action in plaintiff’s TAC should be sustained without any further leave to amend. IV. EVEN IF THE CLRA APPLIES TO A MEDICAL NEGLIGENCE CASE, THE TAC FAILS TO ALLEGE SPECIFIC FACTS AS TO HOW DR. RODRIGUEZ VIOLATED THE ACT. In order to set forth a cause of action for violation of the CLRA, plaintiff must demonstrate or allege violation of one of the over 25 unfair methods of competition and unfair and deceptive act 7 DEFENDANT KRISTIN RODRIGUEZ, D.O.’S DEMURRER TO PLAINTIFFS THIRD AMENDED COMPLAINT; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF; DECLARATION OF JENNIFER R. KOERNER or practices set forth in California Civil Code §1770. According to plaintiff’s TAC, Dr. Rodriguez has allegedly violated the following sections of California Civil Code §1770: (5) Representing that goods or services have sponsorship, approval, characteristics, ingredients, uses, benefits, or quantities that they do not have or that a person has a sponsorship, approval, status, affiliation, or connection that the person does not have. (7) Representing that goods or services are of a particular standard, quality, or grade, or that goods are of a particular style or model, if they are of another. As with the second amended complaint, there is absolutely no description in the TAC as to how Dr. Rodriguez misrepresented to plaintiff the quality or characteristics of the medical services she provided to him. On the contrary, plaintiff’s TAC states at page 15, lines10-13 that “the hospital independently holds and presents itself out to the public through advertising; as being a credible hospital which the general public can rely on for a variety of medical services, including that of its emergency room services.” In furtherance of that statement, plaintiff attaches two exhibits. The first exhibit appears to be one page of a brochure from Placentia Linda Hospital. The text states “We’re here to provide Emergency Care for your entire family.” Exhibit 2 contains three pages from an unknown source. The first page is a picture of the exterior of Placentia Linda Hospital which includes statistics about the number of patients treated annually, the number of employees the hospital has, the charitable contributions of the hospital and the amount of annual taxes the hospital pays. The second page of exhibit 2 is a printout from an unknown source regarding the history of Placentia Linda Hospital, the services it provides and its philosophy. The third page of exhibit 3 is another print out from an unknown source. It describes how to check in on-line to the Placentia Linda Hospital ER as well as what appears to be the hospital mission statement. None of the documents cited by plaintiff and none of the allegations in the TAC specifically reference Dr. Rodriguez or any misrepresentations SHE made that plaintiff then relied on to his detriment. At the very least, plaintiff's TAC contends that Placentia Linda Hospital made representations about the quality of care that they would provide to him. 8 ~ DEFENDANT KRISTIN RODRIGUEZ, D.0.”S DEMURRER TO PLAINTIFF'S THIRD AMENDED COMPLAINT; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF; DECLARATION OF JENNIFER R. KOERNER No 0 3 YN A L N ) N O N N N O N N N N N = e m e m e m e m e m p m p d p t p m 0 N N N Rh W N = O Y N D Y R W R At page 16, lines 24-27 of his TAC, plaintiff further alleges as follows: As a direct result of the intentional misrepresentations by Placentia Linda Hospital, that they were a credible hospital with a credible emergency room facilities, staff and pharmacy; the Plaintiff presented himself for treatment and relied upon their claims to manage his healthcare needs. The Plaintiff relied upon these same representations, to extend to the Defendant Rodriguez and the staff of nurses within her charge. (emphasis added.) This essentially concedes exactly what this demurrer is arguing - that there was no misrepresentation made by Dr. Rodriguez to which plaintiff relied to his detriment. Absent a misrepresentation about the quality or characteristics of the medical services she provided to plaintiff, there can be no violation of the CLRA by Dr. Rodriguez. The conduct of Placentia Linda Hospital is not attributable to Dr. Rodriguez. As set forth correctly by plaintiff, Dr. Rodriguez is an independent contractor providing emergency physician medical care at Placentia Linda Hospital. She is not an employee or spokesperson for the hospital. She did not make (nor has plaintiff alleged that she has made) any misrepresentations regarding the quality or characteristics of the medical care she provided to the plaintiff during his March 2016 ER presentation. Finally, even if the court finds that Dr. Rodriguez somehow made a representation about the quality or character of the medical care/treatment she was going to provide, to which plaintiff relied upon, plaintiff’s TAC does not set forth how said representation caused his alleged incontinence issues. At the most, plaintiff's second cause of action pleads a simple, straightforward claim for medical malpractice. Plaintiff's attempt to artfully plead his claims as falling under the CLRA is nothing more than an attempt by plaintiff to extort punitive damages from Dr. Rodriguez. Under these circumstances, the demurrer to plaintiff's second cause of action should be sustained without any further leave to amend. 1 111 11 1 If 9 DEFENDANT KRISTIN RODRIGUEZ, D.0O.’S DEMURRER TO PLAINTIFF'S THIRD AMENDED COMPLAINT; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF; DECLARATION OF JENNIFER R. KOERNER No 0 3 O N n n BA 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 V. CONCLUSION As set forth above, plaintiff has failed to state a cause of action against Dr. Rodriguez for violation of the CRLA. Plaintiff has already had several opportunities to amend his complaint and is still unable to demonstrate sufficient facts to support his second cause of action as to Dr. Rodriguez. As such, moving party respectfully requests that this demurrer be sustained without any further leave to amend. Dated: January 16, 2020 DAVIS, GRASS, GOLDSTEIN & FINLAY \ / 0 TT / Jeffery W. Grass ‘Jennifer R. Koerner Attorneys for Defendant, Kristin Rodriguez, D.O. By: 10 DEFENDANT KRISTIN RODRIGUEZ, D.0.’S DEMURRER TO PLAINTIFF'S THIRD AMENDED COMPLAINT; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF; DECLARATION OF JENNIFER R. KOERNER O e 3 ON 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DECLARATION OF JENNIFER R. KOERNER RE: MEET AND CONFER PRIOR TO FILING DEMURRER I, Jennifer R. Koerner, declare: 1. I am an attorney at law duly licensed to practice before the Courts of the State of California, and am an associate with the law firm Davis, Grass, Goldstein & Finlay, attorneys of record for the defendant Kristin Rodriguez, D.O., in the above-entitled action. I have personal knowledge of the following facts, and could and would testify completely thereto if called as a witness. 2. Prior to filing the instant demurrer to the third amended complaint on behalf of defendant Kristin Rodriguez, D.O., I contacted plaintiff Nicolas Gonchar. I spoke to Mr. Gonchar via telephone on January 16, 2020. After discussing the matter, it was determined that we could not agree and the instant motion was necessary to resolve the issues raised herein. 3. Based on the foregoing, I have made a good faith attempt to informally resolve my objections to plaintiff’s third amended complaint without filing a demurrer. Unfortunately, my meet and confer efforts were unsuccessful. I declare under the penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on this 16™ day of January, 2020 in Ontario, California. J \ A J enfhifer R. Koerner FAWPS\GRASS\ACUTE CARE\GONCHAR\PLEADINGS\Demurrer-TAC.wpd JRK/tg 11 DEFENDANT KRISTIN RODRIGUEZ, D.O.’S DEMURRER TO PLAINTIFF'S THIRD AMENDED COMPLAINT, MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF; DECLARATION OF JENNIFER R. KOERNER + NO 0 J O N Wn 10 11 12 13 14 15 16 17 18 19 20 21 22 24 25 26 27 28 23 PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF SAN BERNARDINO I am employed in the County of San Bernardino, State of California. Iam over the age of 18 and not a party to the within action; my business address is 3105 Sedona Court, Ontario, California 91764. I served on January 16, 2020 the within DEFENDANT KRISTIN RODRIGUEZ, D.O.’S DEMURRER TO PLAINTIFF'S THIRD AMENDED COMPLAINT; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT THEREOF; DECLARATION OF JENNIFER R. KOERNER addressed to the attorney(s) of record for the parties herein at the office address of said attorney(s) as follows: SEE ATTACHED MAILING LIST [X] By United States Mail (C.C.P. §1013a, et seq.): I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. Itis deposited with the U.S. Postal Service on this day in the ordinary course of business. I am aware that on motion of 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. [1 By Overnight Delivery/Express Mail Service (C.C.P. §1013(c)(d), et seq.): On this date I deposited sealed envelope into an overnight delivery carrier package at 3105 Sedona Court, Ontario, California 91764 designated by Federal Express for overnight service to be delivered the next day. [1 By Fax Transmission (C.R.C., Rule 2.306): On , I caused a facsimile transmission from the following number, (909) 476-2335. Upon completion ofthe said transmission, the transmitting machine issued a transmission report showing that it was complete and without error. [1 By Messenger Service (C.R.C., Rule 3.1300): I enclosed said document(s) in a sealed envelope or package to each addressee. 1 provided them to a professional messenger service (Bosco Legal Service) for service. [1 By Personal Service: I caused to be delivered such envelope by hand to the individuals(s) indicated on the service list. [1 By Electronic Service: I caused the documents to be sent to the persons indicated on the service list by e-mail. I hereby certify that I am employed in the office of a member of the Bar of this Court at whose direction the service was made. I declare under penalty of perjury under the laws of the State of California and of the United States that the foregoing is true and correct. Executed on January 16, 2020 at Ontario, yr a a (MBL, wi annia Gepzalep7 J NO 0 Na O N 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 MAILING LIST Nicolas Gonchar v. Placentia Linda Hospital. et al. Case No.: 30-2018-00998148-CU-MM-CJC Nicolas Gonchar PLAINTIFF IN PRO PER 265 Saint Crispen Avenue Brea, CA 92821-4048 714-883-4404