On July 06, 2021 a
Motion-Secondary
was filed
involving a dispute between
Howard Sonya,
and
Clinica Medica General,
Lucero Peter,
Valencia Patty,
for Other Professional Health Care Malpractice (General Jurisdiction)
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 03/25/2022 04:24 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Bolden,Deputy Clerk
CIV-141
ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR NO: 211808 FOR COURT USE ONLY
NAME: Eric J. Medel
FIRM NAME: MEDEL LAW GROUP, APC
STREET ADDRESS: 2030 Main Street, Suite 1300
CITY: Irvine STATE: CA ZIP CODE: 92614
TELEPHONE NO.: (949) 553-1260 FAX NO.: (949) 553-1271
E-MAIL ADDRESS: ejm@medellawgroup.com
ATTORNEY FOR (Name): PATTY VALENCIA
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
STREET ADDRESS: 111 N. Hill St.
MAILING ADDRESS:
CITY AND ZIP CODE: Los Angeles 90012
BRANCH NAME: Stanley Mosk Courthouse
PLAINTIFF/PETITIONER: SONYA HOWARD
DEFENDANT/RESPONDENT: CLINICA MEDICA GENERAL, ET AL.
CASE NUMBER:
DECLARATION OF DEMURRING OR MOVING PARTY 21STCV24997
IN SUPPORT OF AUTOMATIC EXTENSION
1. (Name of party): Patty Valencia was served with
a complaint an amended complaint a cross-complaint
an answer other (specify):
in the above-titled action.
2. For a demurrer or motion to strike, a responsive pleading is due on (date): March 30, 2022
DECLARATION
I intend to file a demurrer, motion to strike, or motion for judgment on the pleadings in this action. Before I can do so, I am required to
meet and confer with the party who filed the pleading that I am responding to at least five days before the date when the responsive
pleading is due (if I am filing a demurrer or motion to strike) and at least five days before the last day a motion for judgment on the
pleadings may be filed (if I am filing a motion for judgment on the pleadings). We have not been able to meet and confer. I have not
previously requested an automatic extension of time. Therefore, on timely filing and serving a declaration that meets the requirements
of Code of Civil Procedure sections 430.41, 435.5, or 439, I am entitled to an automatic 30-day extension of time within which to file a
responsive pleading or motion for judgment on the pleadings.
I made a good faith attempt to meet and confer with the party who filed the pleading at least five days before the date the responsive
pleading was due (if I am filing a demurrer or motion to strike) and at least five days before the last day a motion for judgment on the
pleadings may be filed (if I am filing a motion for judgment on the pleadings). I was unable to meet with that party because
(the reasons why the parties could not meet and confer are stated):
below on form MC-031, Attached Declaration
My office was just retained by Patty Valencia within the time period to initially meet and confer prior to filing a demurrer. On March
24, 2022, I contacted plaintiff, Sonya Howard, by telephone informing her that I am in the process of being retained for Patty
Valencia and requested an extension of the Answer date given that a demurrer was recently sustained and a First Amended
Complaint is being filed. Alternatively I requested a meet and confer regarding a demurrer. Per Ms. Howard's request I also left
her a voice message with the same request. I have not received a response to date.
I declare under penalty of perjury under the laws of the State of California that the information above is true and correct.
Date: March 25, 2022
Eric J. Medel, Esq.
(NAME OF PARTY OR ATTORNEY FOR PARTY) (SIGNATURE OF PARTY OR ATTORNEY FOR PARTY)
Page 1 of 1
Form Approved for Optional Use
Judicial Council of California
DECLARATION OF DEMURRING OR MOVING PARTY Code of Civil Procedure,
§§ 430.41, 435.5, 439
CIV-141 [Rev. January 1, 2019] www.courts.ca.gov
IN SUPPORT OF AUTOMATIC EXTENSION
Document Filed Date
March 25, 2022
Case Filing Date
July 06, 2021
Category
Other Professional Health Care Malpractice (General Jurisdiction)
Status
Court-Ordered Dismissal - Other (Other) 08/11/2022
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 03/25/2022 04:24 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Bolden,Deputy Clerk CIV-141 ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR NO: 211808 FOR COURT USE ONLY NAME: Eric J. Medel FIRM NAME: MEDEL LAW GROUP, APC STREET ADDRESS: 2030 Main Street, Suite 1300 CITY: Irvine STATE: CA ZIP CODE: 92614 TELEPHONE NO.: (949) 553-1260 FAX NO.: (949) 553-1271 E-MAIL ADDRESS: ejm@medellawgroup.com ATTORNEY FOR (Name): PATTY VALENCIA SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES STREET ADDRESS: 111 N. Hill St. MAILING ADDRESS: CITY AND ZIP CODE: Los Angeles 90012 BRANCH NAME: Stanley Mosk Courthouse PLAINTIFF/PETITIONER: SONYA HOWARD DEFENDANT/RESPONDENT: CLINICA MEDICA GENERAL, ET AL. CASE NUMBER: DECLARATION OF DEMURRING OR MOVING PARTY 21STCV24997 IN SUPPORT OF AUTOMATIC EXTENSION 1. (Name of party): Patty Valencia was served with a complaint an amended complaint a cross-complaint an answer other (specify): in the above-titled action. 2. For a demurrer or motion to strike, a responsive pleading is due on (date): March 30, 2022 DECLARATION I intend to file a demurrer, motion to strike, or motion for judgment on the pleadings in this action. Before I can do so, I am required to meet and confer with the party who filed the pleading that I am responding to at least five days before the date when the responsive pleading is due (if I am filing a demurrer or motion to strike) and at least five days before the last day a motion for judgment on the pleadings may be filed (if I am filing a motion for judgment on the pleadings). We have not been able to meet and confer. I have not previously requested an automatic extension of time. Therefore, on timely filing and serving a declaration that meets the requirements of Code of Civil Procedure sections 430.41, 435.5, or 439, I am entitled to an automatic 30-day extension of time within which to file a responsive pleading or motion for judgment on the pleadings. I made a good faith attempt to meet and confer with the party who filed the pleading at least five days before the date the responsive pleading was due (if I am filing a demurrer or motion to strike) and at least five days before the last day a motion for judgment on the pleadings may be filed (if I am filing a motion for judgment on the pleadings). I was unable to meet with that party because (the reasons why the parties could not meet and confer are stated): below on form MC-031, Attached Declaration My office was just retained by Patty Valencia within the time period to initially meet and confer prior to filing a demurrer. On March 24, 2022, I contacted plaintiff, Sonya Howard, by telephone informing her that I am in the process of being retained for Patty Valencia and requested an extension of the Answer date given that a demurrer was recently sustained and a First Amended Complaint is being filed. Alternatively I requested a meet and confer regarding a demurrer. Per Ms. Howard's request I also left her a voice message with the same request. I have not received a response to date. I declare under penalty of perjury under the laws of the State of California that the information above is true and correct. Date: March 25, 2022 Eric J. Medel, Esq. (NAME OF PARTY OR ATTORNEY FOR PARTY) (SIGNATURE OF PARTY OR ATTORNEY FOR PARTY) Page 1 of 1 Form Approved for Optional Use Judicial Council of California DECLARATION OF DEMURRING OR MOVING PARTY Code of Civil Procedure, §§ 430.41, 435.5, 439 CIV-141 [Rev. January 1, 2019] www.courts.ca.gov IN SUPPORT OF AUTOMATIC EXTENSION