Preview
TT
Joseph Lavi, Esq. (SBN 209776)
| Vincent C. Granberry, Esq. (SBN 276483)
LAVI & EBRAHIMIAN, LLP
8889 W. Olympic Blvd., Suite 200
Beverly Hills, California 90211
Telephone: 310) 432-0000
Facsimile: (310) 432-0001
Attorneys for PLAINTIFF REGINALD LYLE,
on behalf of himself and others similarly situated.
| SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN JOAQUIN.
| others siniilarly situated,
PLAINTIFE, CLASS ACTION
Holly, Department 41
DOCTORS HOSPITAL OF MANTECA, INC.;
SP OF MANTECA INC; TENET AMENDED COMPLA
HEALTHCARE CORPORATION; TENET
HEALTH INTEGRATED SERVICES, -INC.;
} TENET HEALTH; and DOES 1 to 100, Inclusive,
DEFENDANT SP OF MANTECA, INC.
1
“ILED
16 SEPlIg PH 12: 3G
ROSA JUNQUEIRO, CLERK
REGINALD LYLE, on behalf of himself and Case No.: STK-CV-UOE-2016-0006523
i vs. [Assigned for all purposes to the Hon: Carter
AUXILIARY OF DOCTORS HOSPITAL OF PLAINTIFF NOTICE OF FILING PROOF
MANTECA: DRS HOSP OF MANTECA INC; | OF SERVICE OF SUMMONS AND FIRST
ON
DEFENDANT SP OF MANTECA, INC.
DEFENDANTS.
| TO THE HONORABLE COURT, ALL PARTIES AND THEIR ATTORNEYS OF
RECORD: :
Plaintiff REGINALD LYLE hereby: submits the Proof of Service| of Summons and First
Amended Complaint on Defendant SP-OF MANTECA, INC. A true and correct copy of the Proof
of Service of Summons and First. Amended Complaint is attached hereto as Exhibit 1.
a
‘PLAINTIFF NOTICE OF FILING PROOF OF SERVICE OF SUMMONS AND FIRST AMENDED COMPLAINT ON
os
Xv4 Ad GalsCa WW
Dated: September 15, 2016 Respectfully submitted,
LAVI & EBRAHIMIAN, LLP
Vincent C, Granberry, Esq)
Attorneys for PLAINTIFF,
REGINALD LYLE on behalf of
himself and others similarly situated
| —$—S— $ .
PLAINTIFF NOTICE OF FILING PROOF OF SERVICE OF SUMMONS AND FIRST AMENDED.COMPLAINT ON
DEFENDANT SP OF MANTECA, INC.
2“Exhibit 1”JATTORNEY OR PARTY MATHOUT ATTORNEY (Nama and Addiess)
JOSEPH LAVI'SBN 209776
8889 W'Olympic Blvd
Beverly Hills cA 90211
ATTORNEY FOR Nae Plaintiff
Teted ef Cava Name of Jute Dickie and Branch Court any
SAN JOAQUIN SUPERIOR COURT, STOCKTON
‘TELERHONE KO. "
(310) 432-0000
SHORT TITLE GF CASE
LYLE v DOGTORS HOSPITAL
156 Numbqr.
3049374 (HEARING).Dale Time Dept STKCVU 920180008823
LYLE V8. 00
ORS. HOSPITAL
PROOF OF SERVICE OF SUMMONS
1. AT THE TIME OF SERVICE| WAS AT LEAST 48 YEARS OF AGE.AND NOTA PARTY TO THIS ACTION
2. 1 SERVED COPIES OF THE:
SUMMONS & COMPLAINT; FIRST AMENDED COMPLAINT,
CIVIL CASE COVER SHEET
NOTICE OF CASE ASSIGNMENT AND.SCHEDULING INFORMATION AND
NOTICE.OF HEARING
‘3.2, PARTY SERVED: = SP OF MANTECA, ING.
b. Ikerina Mmeje, MHSA, FACHE, Cfficer/Director
4, ADDRESS: 1206 E NORTH ST
MANTECA cA 95336
5. /SERVED THE PARTY IN 3A BY SUBSTITUTED SERVICE
ON 8/24/2016 AT 2:03:00. PM
b. BY LEAVING THE DOCUMENTS LISTED IN 2 WITH OR IN THE PRESENCE OF:
TAMMIE L. HELM, PERSON APPARENTLY IN CHARGE
-CAUCASIAN FEMALE S5YRS 5'8” 240LBS, BLOND HAIR
(1) (BUSINESS) A PERSON AT LEAST 18 YEARS OF AGE APPARENTLY IN CHARGE. AT
|THE OFFICE OR
USUAL PLACE OF BUSINESS OF THE PERSON TO BE SERVED. | INFORMED HIM OR HER OF THE
GENERAL NATURE OF THE PAPERS
(4) A DECLARATION OF MAILING.IS ATTACHED IF REQUIRED
{5) A DECLARATION OF DILIGENCE IS ATTACHED IF REQUIRED.
6. THE "NOTICE TO PERSON SERVED" WAS COMPLETED AS FOLLOWS:
d. ON BEHALF OF: = SP OF. MANTEGA, INC.
Ikenna Mmeje, MHSA, FACHE, Officer/Director
UNDER THE FOLLOWING CODE GF CIVIL PROCEDURE SECTION : 416.10 (CORPORATION)
Ta. Person Serving: Rigoberto Pulido a re fee for service was $50.00
b, DDS Legal Suppor. : (t) not a registered California process server:
2900 Biisto) Si {3} X registered Californla process server:
Costa Mesa, Ca'92626
@ independent Contractor
©. (714) 662-5555 (l) Registration No:
152
MERCED
8. | dedare under the penaily of perjury under the laws of the State of California thet the nee
|
foregoing fs true and correct, Rigoberto Putido x
9/16/2016.
pe
“OF fudictal
Cameha canis PROOF OF SERVICE
POS-O10 {REV Jan 1 2007]
CRC 982(A}(23)of mS
a VO \)
[ATTORNEY OR PARTY WATHOUT ATTORNEY (Nama and Adkcess) TELEPHONE NO.
JOSEPH LAVI SBN 209776 (816)-432-0000
6889 W Olympic Blvd
Beverly Hills CA
ATTORNEY FOR (lame Plaintiff
"son of Cour Namie, of iudica Diskac and Branch Cowtiteny +
SAN JOAQUIN SUPERIOR COURT, STOCKTON
‘SHORT NILE GF CASE
LYLE v DOCTORS HOSPITAL
ave nonber
4049374 (HEARING) Bate SrKEvuDE nn eoesz3
REFERENCE NG
LYLE VS, DOCTORS HOSPITAL
PROOF OF SERVICE BY MAIL
4, (AM EMPLOYED IN, OR A RESIDENT OF, THE COUNTY IN WHICH THE MAILING OCCURED,
AND NOT A PARTY TO THIS ACTION. AT THE TIME OF MAILING, { WAS AT LEAST 18 YEARS OF
AGEOR OLDER
ON 08/26/2016
5.b (4) AFTER SUBSTITUTED SERVICE UNDER SECTION 415.20 (a) or 415.20 (b) or
415.46 C.C.P, WAS MADE. | SERVED THE WITHIN:
SUMMONS & COMPLAINT; FIRST AMENDED COMPLAINT
CIVIL CASE COVER SHEET
NOTICE OF CASE ASSIGNMENT AND SCHEDULING INFORMATION AND
NOTICE OF HEARING
ON THE DEFENDANT IN SAID'ACTION BY PLACING A TRUE GOPY THEREOF ENCLOSED'}
ASEALED ENVELOPE WITH POSTAGE THEREON-PREPAID FOR FIRST CLASS IN THE
UNITED STATES MAIL AT: COSTA MESA, CALIFORNIA, ADDRESSED AS FOLLOWS:
SP OF MANTECA, INC.
Ikenna Mmeje, MHSA, FACHE, Officer/Director
1208 E NORTH ST
MANTECA CA 96336
DECLARANT: MONICA FIGUEROA
d. ‘The fee for service was $50.00
8, |.am:
(1) X hota registered Califomia process server:
DDS Legal-Support (3) a
2900 Bristol St . — & registered California process server:
Costa. Mesa, Ga 92626 () Employes:
(@ Registration No:
©. @14) 65: (@ County: Orange
8. | declare under the penelly of perjury under the laws of the State of California that the
foregoing is true and contest. MONICA FIGUEROA .
9512016 x t
PROOF OF SERVICEoo my
Nae XK
PROOE OF SERVICE
Beverly Hills, California 90211.
On September 15, 2016, I served the foregoing document, described as;
Lyle vs. Doctor Hospital Of Manteca, Inc., et al. SE NO. STK-CV-UOE-2016-0006523
STATE OF CALIFORNIA, COUNTY OF SAN JOAQUIN
Tam an employee in the County: of San Joaquin, State of California, 1 atn over the age of 18.
and not a party to the within action; my business addiess is 8889 W. Olympic Blvd., Suite 200,
“PLAINTIFF NOTICE OF FILING PROOF OF SERVICE OF SUMMONS AND FIRST
AMENDED COMPLAINT ON DEFENDANT SP OF MANTECA, INC."
on the parties and by the method listed below: ‘
Doctors Hospital of Manteca, Inc, ‘Auxiliary Of Doctors Hospital Of Manteca
c/o:CT Corporation Systema, |. fo Anne Ryslinge- Young
818 W. 7th Street, Suite 930 212 W. Yosemite Avenue
Los Angeles, CA-90017 Manteca, CA 95336
‘DRS Hosp Of Manteca, Inc. SP Of Manteca, Inc.
1205 E. North Street 1205 E. North Street
Manteca, CA 95336. Manteca, CA'95336
Tenet Healthcare Corporation Tenet Health Integrated Services, Inc.
e/o: CT Corporation System 1205 E. North Street
818 W. 7" Street, Suite 930 Manteca, CA 95336
Los Angeles, CA 90017
Tenet Health.
1205 E. North Street
Manteca, CA 95336
Ki = @Y MAIL) As follows:
I placed such envelope, with postage thereon prepaid, in the United
| Angeles, California.
for mailing. Under that practice, it would be deposited with the U.S..Px
course of business, I am aware that, on motion of the party served,
invalid if the postal cancellation or postage meter date is more than ore
deposit for mailing in this affidavit. “
thatthe above is true and correct.
Executed on September 15, 2016, at Beverly Hills, Californi
States mail at Los
Tam “readily familiar” with the firmn’s practice of collecting and fis Piste correspondence
stal Service on that
same day, with postage thereon fully prepaid, at Los Angeles, Californie, in the ordinary
rvice. is présurned
iday after the date of
&] (STATE) "declare, under penalty of perjury under the laws of the State of California,
PLAINTIFF NOTICE OF FILING PROOF OF SERVICE OF SUMMONS AND FIRST AM!
. DEFENDANT SP OF MANTECA, INC.
3
NDED COMPLAINT ON.
Preview
TT Joseph Lavi, Esq. (SBN 209776) | Vincent C. Granberry, Esq. (SBN 276483) LAVI & EBRAHIMIAN, LLP 8889 W. Olympic Blvd., Suite 200 Beverly Hills, California 90211 Telephone: 310) 432-0000 Facsimile: (310) 432-0001 Attorneys for PLAINTIFF REGINALD LYLE, on behalf of himself and others similarly situated. | SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN JOAQUIN. | others siniilarly situated, PLAINTIFE, CLASS ACTION Holly, Department 41 DOCTORS HOSPITAL OF MANTECA, INC.; SP OF MANTECA INC; TENET AMENDED COMPLA HEALTHCARE CORPORATION; TENET HEALTH INTEGRATED SERVICES, -INC.; } TENET HEALTH; and DOES 1 to 100, Inclusive, DEFENDANT SP OF MANTECA, INC. 1 “ILED 16 SEPlIg PH 12: 3G ROSA JUNQUEIRO, CLERK REGINALD LYLE, on behalf of himself and Case No.: STK-CV-UOE-2016-0006523 i vs. [Assigned for all purposes to the Hon: Carter AUXILIARY OF DOCTORS HOSPITAL OF PLAINTIFF NOTICE OF FILING PROOF MANTECA: DRS HOSP OF MANTECA INC; | OF SERVICE OF SUMMONS AND FIRST ON DEFENDANT SP OF MANTECA, INC. DEFENDANTS. | TO THE HONORABLE COURT, ALL PARTIES AND THEIR ATTORNEYS OF RECORD: : Plaintiff REGINALD LYLE hereby: submits the Proof of Service| of Summons and First Amended Complaint on Defendant SP-OF MANTECA, INC. A true and correct copy of the Proof of Service of Summons and First. Amended Complaint is attached hereto as Exhibit 1. a ‘PLAINTIFF NOTICE OF FILING PROOF OF SERVICE OF SUMMONS AND FIRST AMENDED COMPLAINT ON os Xv4 Ad GalsCa WW Dated: September 15, 2016 Respectfully submitted, LAVI & EBRAHIMIAN, LLP Vincent C, Granberry, Esq) Attorneys for PLAINTIFF, REGINALD LYLE on behalf of himself and others similarly situated | —$—S— $ . PLAINTIFF NOTICE OF FILING PROOF OF SERVICE OF SUMMONS AND FIRST AMENDED.COMPLAINT ON DEFENDANT SP OF MANTECA, INC. 2“Exhibit 1”JATTORNEY OR PARTY MATHOUT ATTORNEY (Nama and Addiess) JOSEPH LAVI'SBN 209776 8889 W'Olympic Blvd Beverly Hills cA 90211 ATTORNEY FOR Nae Plaintiff Teted ef Cava Name of Jute Dickie and Branch Court any SAN JOAQUIN SUPERIOR COURT, STOCKTON ‘TELERHONE KO. " (310) 432-0000 SHORT TITLE GF CASE LYLE v DOGTORS HOSPITAL 156 Numbqr. 3049374 (HEARING).Dale Time Dept STKCVU 920180008823 LYLE V8. 00 ORS. HOSPITAL PROOF OF SERVICE OF SUMMONS 1. AT THE TIME OF SERVICE| WAS AT LEAST 48 YEARS OF AGE.AND NOTA PARTY TO THIS ACTION 2. 1 SERVED COPIES OF THE: SUMMONS & COMPLAINT; FIRST AMENDED COMPLAINT, CIVIL CASE COVER SHEET NOTICE OF CASE ASSIGNMENT AND.SCHEDULING INFORMATION AND NOTICE.OF HEARING ‘3.2, PARTY SERVED: = SP OF MANTECA, ING. b. Ikerina Mmeje, MHSA, FACHE, Cfficer/Director 4, ADDRESS: 1206 E NORTH ST MANTECA cA 95336 5. /SERVED THE PARTY IN 3A BY SUBSTITUTED SERVICE ON 8/24/2016 AT 2:03:00. PM b. BY LEAVING THE DOCUMENTS LISTED IN 2 WITH OR IN THE PRESENCE OF: TAMMIE L. HELM, PERSON APPARENTLY IN CHARGE -CAUCASIAN FEMALE S5YRS 5'8” 240LBS, BLOND HAIR (1) (BUSINESS) A PERSON AT LEAST 18 YEARS OF AGE APPARENTLY IN CHARGE. AT |THE OFFICE OR USUAL PLACE OF BUSINESS OF THE PERSON TO BE SERVED. | INFORMED HIM OR HER OF THE GENERAL NATURE OF THE PAPERS (4) A DECLARATION OF MAILING.IS ATTACHED IF REQUIRED {5) A DECLARATION OF DILIGENCE IS ATTACHED IF REQUIRED. 6. THE "NOTICE TO PERSON SERVED" WAS COMPLETED AS FOLLOWS: d. ON BEHALF OF: = SP OF. MANTEGA, INC. Ikenna Mmeje, MHSA, FACHE, Officer/Director UNDER THE FOLLOWING CODE GF CIVIL PROCEDURE SECTION : 416.10 (CORPORATION) Ta. Person Serving: Rigoberto Pulido a re fee for service was $50.00 b, DDS Legal Suppor. : (t) not a registered California process server: 2900 Biisto) Si {3} X registered Californla process server: Costa Mesa, Ca'92626 @ independent Contractor ©. (714) 662-5555 (l) Registration No: 152 MERCED 8. | dedare under the penaily of perjury under the laws of the State of California thet the nee | foregoing fs true and correct, Rigoberto Putido x 9/16/2016. pe “OF fudictal Cameha canis PROOF OF SERVICE POS-O10 {REV Jan 1 2007] CRC 982(A}(23)of mS a VO \) [ATTORNEY OR PARTY WATHOUT ATTORNEY (Nama and Adkcess) TELEPHONE NO. JOSEPH LAVI SBN 209776 (816)-432-0000 6889 W Olympic Blvd Beverly Hills CA ATTORNEY FOR (lame Plaintiff "son of Cour Namie, of iudica Diskac and Branch Cowtiteny + SAN JOAQUIN SUPERIOR COURT, STOCKTON ‘SHORT NILE GF CASE LYLE v DOCTORS HOSPITAL ave nonber 4049374 (HEARING) Bate SrKEvuDE nn eoesz3 REFERENCE NG LYLE VS, DOCTORS HOSPITAL PROOF OF SERVICE BY MAIL 4, (AM EMPLOYED IN, OR A RESIDENT OF, THE COUNTY IN WHICH THE MAILING OCCURED, AND NOT A PARTY TO THIS ACTION. AT THE TIME OF MAILING, { WAS AT LEAST 18 YEARS OF AGEOR OLDER ON 08/26/2016 5.b (4) AFTER SUBSTITUTED SERVICE UNDER SECTION 415.20 (a) or 415.20 (b) or 415.46 C.C.P, WAS MADE. | SERVED THE WITHIN: SUMMONS & COMPLAINT; FIRST AMENDED COMPLAINT CIVIL CASE COVER SHEET NOTICE OF CASE ASSIGNMENT AND SCHEDULING INFORMATION AND NOTICE OF HEARING ON THE DEFENDANT IN SAID'ACTION BY PLACING A TRUE GOPY THEREOF ENCLOSED'} ASEALED ENVELOPE WITH POSTAGE THEREON-PREPAID FOR FIRST CLASS IN THE UNITED STATES MAIL AT: COSTA MESA, CALIFORNIA, ADDRESSED AS FOLLOWS: SP OF MANTECA, INC. Ikenna Mmeje, MHSA, FACHE, Officer/Director 1208 E NORTH ST MANTECA CA 96336 DECLARANT: MONICA FIGUEROA d. ‘The fee for service was $50.00 8, |.am: (1) X hota registered Califomia process server: DDS Legal-Support (3) a 2900 Bristol St . — & registered California process server: Costa. Mesa, Ga 92626 () Employes: (@ Registration No: ©. @14) 65: (@ County: Orange 8. | declare under the penelly of perjury under the laws of the State of California that the foregoing is true and contest. MONICA FIGUEROA . 9512016 x t PROOF OF SERVICEoo my Nae XK PROOE OF SERVICE Beverly Hills, California 90211. On September 15, 2016, I served the foregoing document, described as; Lyle vs. Doctor Hospital Of Manteca, Inc., et al. SE NO. STK-CV-UOE-2016-0006523 STATE OF CALIFORNIA, COUNTY OF SAN JOAQUIN Tam an employee in the County: of San Joaquin, State of California, 1 atn over the age of 18. and not a party to the within action; my business addiess is 8889 W. Olympic Blvd., Suite 200, “PLAINTIFF NOTICE OF FILING PROOF OF SERVICE OF SUMMONS AND FIRST AMENDED COMPLAINT ON DEFENDANT SP OF MANTECA, INC." on the parties and by the method listed below: ‘ Doctors Hospital of Manteca, Inc, ‘Auxiliary Of Doctors Hospital Of Manteca c/o:CT Corporation Systema, |. fo Anne Ryslinge- Young 818 W. 7th Street, Suite 930 212 W. Yosemite Avenue Los Angeles, CA-90017 Manteca, CA 95336 ‘DRS Hosp Of Manteca, Inc. SP Of Manteca, Inc. 1205 E. North Street 1205 E. North Street Manteca, CA 95336. Manteca, CA'95336 Tenet Healthcare Corporation Tenet Health Integrated Services, Inc. e/o: CT Corporation System 1205 E. North Street 818 W. 7" Street, Suite 930 Manteca, CA 95336 Los Angeles, CA 90017 Tenet Health. 1205 E. North Street Manteca, CA 95336 Ki = @Y MAIL) As follows: I placed such envelope, with postage thereon prepaid, in the United | Angeles, California. for mailing. Under that practice, it would be deposited with the U.S..Px course of business, I am aware that, on motion of the party served, invalid if the postal cancellation or postage meter date is more than ore deposit for mailing in this affidavit. “ thatthe above is true and correct. Executed on September 15, 2016, at Beverly Hills, Californi States mail at Los Tam “readily familiar” with the firmn’s practice of collecting and fis Piste correspondence stal Service on that same day, with postage thereon fully prepaid, at Los Angeles, Californie, in the ordinary rvice. is présurned iday after the date of &] (STATE) "declare, under penalty of perjury under the laws of the State of California, PLAINTIFF NOTICE OF FILING PROOF OF SERVICE OF SUMMONS AND FIRST AM! . DEFENDANT SP OF MANTECA, INC. 3 NDED COMPLAINT ON.