Preview
1 Bruce G. Fagel, SBN 103674
Bronislav M. Draganov, SBN 119695
2 LAW OFFICES OF BRUCE G. FAGEL
& ASSOCIATES
3 9200 West Sunset Boulevard, Suite 670
West Hollywood, California 90069
4
Telephone: (310) 516-9035
Facsimile: (310) 928-7763
5 Attorneys for Plaintiffs
6
7 SUPERIOR COURT OF THE STATE OF CALIFORNIA
8 FOR THE COUNTY OF SANTA CRUZ
9
10 JAIME VICTORY, ANITA VICTORY , CASE NO. 21CV02121
[Case Filed 8/31/2021]
11 Plaintiffs,
NOTICE OF TRIAL
12
vs.
13 DATE: APRIL 8, 2024
WATSONVILLE HOSPITAL TIME: 9:00 A.M.
CORPORATION, a Delaware Corporation, DEPT: 5
14 doing business as WATSONVILLE
COMMUNITY HOSPITAL;
15 LOUIS C. LEE, M.D., DOES 1 to 250,
inclusive,
16
Defendants.
17
18 TO; ALL PARTIES HEREIN AND TO THEIR RESPECTIVE COUNSEL OF RECORD:
19 PLEASE TAKE NOTICE that a Case Management Conference came on for hearing at
20
8:30 am on 3/7/23 in Department 5 of the within Court. Appearances were made by all parties,
except for Defendant, Louis C. Lee, M.D. The parties agree and the Court issued the following
21
Order:
22
1) Trial Calendar Call: 1:30 p.m. on March 28, 2024, in Department 5
23
2) Jury Trial (5 day estimate) 9:00 a.m. on April 8, 2024
24
3) Plaintiffs to give Notice.
25
Law Offices DATED: March 7, 2023 LAW OFFICES OF BRUCE G. FAGEL
of 26 AND ASSOCIATES
Bruce G. Fagel
& 27 By: Bronislav M. Draganov
Associates Bronislav M. Draganov
28 Attorneys for Plaintiffs
1
L:\VICTORY, JAIME\TRIAL\NOTICE OF TRIAL.wpd NOTICE OF TRIAL
1 PROOF OF SERVICE
2 STATE OF CALIFORNIA )
) ss
3 COUNTY OF LOS ANGELES )
4 I am employed in the County of Los Angeles. I am over the age of eighteen years and not
a party to the within action. My business address is 9200 West Sunset Boulevard, Suite 670,
5 West Hollywood, California 90069. My electronic business address is pam@fagellaw.com.
6 On March 7, 2023, I electronically served the foregoing documents described as:
7 NOTICE OF TRIAL
8 on the interested parties in this action by electronically sending a true and correct copy thereof
envelope addressed as follows:
9
10 SEE ATTACHED SERVICE LIST
11 [] [BY REGULAR U.S. MAIL]
12 [ ] BY NEXT DAY DELIVERY TO
13 [] I deposited such envelope in the mail at West Hollywood, California. The envelope was
mailed with postage thereon fully prepaid.
14
[] As follows: I am "readily familiar" with the firm's practice of collection and processing
15 correspondence for mailing. Under that practice it would be deposited with the U.S.
Postal Service on that same day with postage thereon fully prepaid at West Hollywood,
16 California in the ordinary course of business. I am aware that on motion of the party
served, service is presumed invalid if postal cancellation date or postage meter date is
17 more than one day after date of deposit for mailing in affidavit.
18 [ ] [BY FAX] At FAX No.: See attached Service List.
19 [ ] [BY HAND] I delivered such envelope by hand to the offices of the addressee.
20 [X] By electronic service – see attached service list
21 [X] (STATE) I declare under penalty of perjury under the laws of the State of California that
the above is true and correct.
22
[ ] (FEDERAL) I declare under penalty of perjury under the laws of the United States that
23 the above is true and correct.
24 Digitally executed on March 7, 2023, at West Hollywood, California.
25
Law Offices Pamela Barondess
of 26 Pamela Barondess
Bruce G. Fagel
& 27
Associates
28
2
NOTICE OF TRIAL
1 SERVICE LIST
2 Jaime Victory, Anita Victory vs. Watsonville Hospital Corporation, etc., et al.
_____________________________________________________________________________
3
Cyrus A. Tabari
4 Jennifer Wagster
Sheuerman, Martini, Tabari, Zenere & Garvin
5 A Professional corporation
1033 Willow Street
6 San Jose, California 95125
7 Attorneys for Defendant, Louis C. Lee, M.D.
8 Telephone: (408) 288-9700
Facsimile: (408) 295-9900
9 ctabari@smtlaw.com
nobey@smtlaw.com
10
11
Marc G. Cowden
12 Adam Stoddard
Zenere Cowden & Stoddard APC
13 2005 De La Cruz Boulevard, Suite 240
Santa Clara, California 95050
14 Attorneys for defendant, Watsonville Hospital Corporation, dba Watsonville Community
Hospital
15 Telephone No. (408) 430-3551
mcowden@zcslawfirm.com
16 astoddard@zslawfirm.com
dpoint@zcslawfirm.com
17 ogarcia@zcslawfirm.com
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25
Law Offices
of 26
Bruce G. Fagel
& 27
Associates
28
3
NOTICE OF TRIAL
Preview
1 Bruce G. Fagel, SBN 103674 Bronislav M. Draganov, SBN 119695 2 LAW OFFICES OF BRUCE G. FAGEL & ASSOCIATES 3 9200 West Sunset Boulevard, Suite 670 West Hollywood, California 90069 4 Telephone: (310) 516-9035 Facsimile: (310) 928-7763 5 Attorneys for Plaintiffs 6 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 FOR THE COUNTY OF SANTA CRUZ 9 10 JAIME VICTORY, ANITA VICTORY , CASE NO. 21CV02121 [Case Filed 8/31/2021] 11 Plaintiffs, NOTICE OF TRIAL 12 vs. 13 DATE: APRIL 8, 2024 WATSONVILLE HOSPITAL TIME: 9:00 A.M. CORPORATION, a Delaware Corporation, DEPT: 5 14 doing business as WATSONVILLE COMMUNITY HOSPITAL; 15 LOUIS C. LEE, M.D., DOES 1 to 250, inclusive, 16 Defendants. 17 18 TO; ALL PARTIES HEREIN AND TO THEIR RESPECTIVE COUNSEL OF RECORD: 19 PLEASE TAKE NOTICE that a Case Management Conference came on for hearing at 20 8:30 am on 3/7/23 in Department 5 of the within Court. Appearances were made by all parties, except for Defendant, Louis C. Lee, M.D. The parties agree and the Court issued the following 21 Order: 22 1) Trial Calendar Call: 1:30 p.m. on March 28, 2024, in Department 5 23 2) Jury Trial (5 day estimate) 9:00 a.m. on April 8, 2024 24 3) Plaintiffs to give Notice. 25 Law Offices DATED: March 7, 2023 LAW OFFICES OF BRUCE G. FAGEL of 26 AND ASSOCIATES Bruce G. Fagel & 27 By: Bronislav M. Draganov Associates Bronislav M. Draganov 28 Attorneys for Plaintiffs 1 L:\VICTORY, JAIME\TRIAL\NOTICE OF TRIAL.wpd NOTICE OF TRIAL 1 PROOF OF SERVICE 2 STATE OF CALIFORNIA ) ) ss 3 COUNTY OF LOS ANGELES ) 4 I am employed in the County of Los Angeles. I am over the age of eighteen years and not a party to the within action. My business address is 9200 West Sunset Boulevard, Suite 670, 5 West Hollywood, California 90069. My electronic business address is pam@fagellaw.com. 6 On March 7, 2023, I electronically served the foregoing documents described as: 7 NOTICE OF TRIAL 8 on the interested parties in this action by electronically sending a true and correct copy thereof envelope addressed as follows: 9 10 SEE ATTACHED SERVICE LIST 11 [] [BY REGULAR U.S. MAIL] 12 [ ] BY NEXT DAY DELIVERY TO 13 [] I deposited such envelope in the mail at West Hollywood, California. The envelope was mailed with postage thereon fully prepaid. 14 [] As follows: I am "readily familiar" with the firm's practice of collection and processing 15 correspondence for mailing. Under that practice it would be deposited with the U.S. Postal Service on that same day with postage thereon fully prepaid at West Hollywood, 16 California in the ordinary course of business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is 17 more than one day after date of deposit for mailing in affidavit. 18 [ ] [BY FAX] At FAX No.: See attached Service List. 19 [ ] [BY HAND] I delivered such envelope by hand to the offices of the addressee. 20 [X] By electronic service – see attached service list 21 [X] (STATE) I declare under penalty of perjury under the laws of the State of California that the above is true and correct. 22 [ ] (FEDERAL) I declare under penalty of perjury under the laws of the United States that 23 the above is true and correct. 24 Digitally executed on March 7, 2023, at West Hollywood, California. 25 Law Offices Pamela Barondess of 26 Pamela Barondess Bruce G. Fagel & 27 Associates 28 2 NOTICE OF TRIAL 1 SERVICE LIST 2 Jaime Victory, Anita Victory vs. Watsonville Hospital Corporation, etc., et al. _____________________________________________________________________________ 3 Cyrus A. Tabari 4 Jennifer Wagster Sheuerman, Martini, Tabari, Zenere & Garvin 5 A Professional corporation 1033 Willow Street 6 San Jose, California 95125 7 Attorneys for Defendant, Louis C. Lee, M.D. 8 Telephone: (408) 288-9700 Facsimile: (408) 295-9900 9 ctabari@smtlaw.com nobey@smtlaw.com 10 11 Marc G. Cowden 12 Adam Stoddard Zenere Cowden & Stoddard APC 13 2005 De La Cruz Boulevard, Suite 240 Santa Clara, California 95050 14 Attorneys for defendant, Watsonville Hospital Corporation, dba Watsonville Community Hospital 15 Telephone No. (408) 430-3551 mcowden@zcslawfirm.com 16 astoddard@zslawfirm.com dpoint@zcslawfirm.com 17 ogarcia@zcslawfirm.com 18 19 20 21 22 23 24 25 Law Offices of 26 Bruce G. Fagel & 27 Associates 28 3 NOTICE OF TRIAL