Preview
cM-110
ATTORNEY OR PARTY WTHOUT ATTORNEY (NAME, StAtE BAT number, and address): FOR COURT USE ONLY
Timothy M. Hamilton [State Bar No. 90270] Clarissa E. Kearns [State Bar No.2447321
WALKER, HAMILTON & KEARNS, LLP
50 Francisco Street, Suite 460
San Francisco, CA 94133-2100
TELEeHoNET'ro: (415) 986-3339 FlxNI (optionat), (415) 986-1618
E-MAIL ADDRESS, tim@whk-law.COm; e-service@whk-law.Com
ArroRNEy FoR (ruame): PLAINTIFFS Richard Garza and Laura Maldonado
SUPERIOR COURT OF CALIFORNIA, COUNTY OF MONTEREY
STREETADDRESS: 1200 Aguajito Road
MAILING ADDRESS:
ctryAND zrp coDE: Monterey, CA 93940
BRANoH NAME: MOnterey DiviSiOn
PLAINTIFF/PETITIONER: Richard Garza and Laura Maldonado
DEFENDANT/RESPONDENT: Richard Ravalin, M.D., et al.
CASE MANAGEMENT STATEMENT CASE NUMBER:
LIMITED CASE 23CV000096
(Check one): UNLIMITED CASE
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: May 16,2023 Time: 9:00 a.m. Dept.: 14 Div Room:
Address of court (if different from the address above):
Notice of lntent to Appear by Telephone, by (name).' Clarissa E. Kearns, Esq.
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided
1. Party or parties (answer one):
a. x This statement is submitted by party (name): PLAINTIFFS Richard Garzaand Laura Maldonado
b. l---l This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date): January 10,2023
b. n The cross-complaint, if any, was filed on (dafe):
3. Service (to be answered by plaintiffs and cross-complainants only)
a x All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b The following parties named in the complaint or cross-complaint
(1)
(2) have been served but have not appeared and have not been dismissed (specify names)
(3)
c. The following additional parties may be added (specrfr names, nature of involvement in case, and date by which
they may be served):
4. Description of case
a. Type of case in x complaint l---l cross-complaint (Descibe, including causes of action):
Medical Malpractice
Page 1 of 5
Cal. Rules of Court,
Form Adopted for Mandatory Use
Judicial Council of California
CASE MANAGEMENT STATEMENT rules 3.72G-3.730
CM-1 10 [Rev. September 1, 2021] w.mufts.ca.gov
cM-110
PLAINTIFF/PETITIONER: Richard Garza and Laura Maldonado CASE NUMBER:
DEFENDANT/RESPONDENT: Richard Ravalin, M.D., et al. 23CV000096
4. b. Provide a brief statement of the case, including any damag es. (lf personal injury damages are sought, specify the injury and
damages claimed, including medicalexpenses to date [indicate source and amount], estimated future medical expenses, /osf
eamings to date, and estimated future lost eamings. lf equitable relief is sought, describe the nature of the relief.)
As a result of defendants' negligence, plaintiff Richard Gaza sustained injuries to his body causing emotional distress, pain,
suffering, anguish and loss of income. Plaintiff Laura Maldonado is the lawful spouse of plaintiff Richard Garza and has
suffered the loss of love, affection, comfort and monetary damages.
f-- (tf more space ls needed, check this box and attach a page designated as Aftachment 4b.)
5. Jury or nonjury trial
The party or parties request [Fl a jury trial
requesting a jury tial):
6. Trialdate
a Thetrialhas been selfor (date):
b x No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (ff
not, explain):
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain re_asons for unavailability):
January 29, 2024 [1 S-day Trial, Los Angeles County]; April 1 , 2024 l6-day Kaiser Arbitrationl
7. Estimated length of trial
The party or parties estimate that the trial will lake (check one):
a x days (specify number): 10-15 days
b hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial x by the attorney or party listed in the caption [-l by the following
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
l--l Additional representation is described in Attachment 8.
9. Preference
10. Alternative dispute resolution (ADR)
a. ADR information package. Please note that different ADR processes are available in different courts and communities; read
the ADR information package provided by the court under rule 3.221 ol the California Rules of Court for information about the
processes available through the court and community programs in this case.
(1) For parties represented by counsel: Counsel l--l has l---lhas not provided the ADR information package identifled
in rule 3.221 to the client and reviewed ADR options with the client.
(2) For self-represented parties: Party l---l
has l-_l
nas not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141 .11 or to civil action
mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
Civil Procedure section 1141 .11.
(3) l-a This case is exempt from judicial arbitration under rdle 3.811 of the California Rules of Court or from civil action
mediation under Code of Civil Procedure section 1775 el seq. (speclfy exemption):
Amount in controversy exceeds $50,000.00.
CMI 10 [R€v. September 1,2021] Page 2 of 5
CASE MANAGEMENT STATEMENT
cM-l10
PLAI NTI FF/PETITIONER: Richard Garza and Laura Maldonado CASE NUMBER:
DEFEN DANT/RESPONDENT: Richard Ravalin, M.D., et al. 23CV000096
10. c. lndicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or
have already participated in (check all that apply and provide the specified information):
The party or parties completing lf the party or parties completing this form in the case have agreed to
this form are willing to participate in or have already completed an ADR process or processes,
participate in the following ADR indicate the status of the processes (aftach a copy of the pafties' ADR
processes (check all that apply): stipulation):
Mediation session not yet scheduled
Mediation session scheduled for (date):
(1) Mediation x
Agreed to complete mediation by (dafe):
Mediation completed on (dafe):
Settlement conference not yet scheduled
(2) Settlement Settlement conference scheduled for (date):
x
conference Agreed to complete settlement conference by(dafe)
Settlement conference completed on (dafe):
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (dafe);
(3) Neutral evaluation
Agreed to complete neutral evaluation by (dafe);
Neutral evaluation completed on (dafe);
Judicial arbitration not yet scheduled
(4) Nonbinding judicial Judicial arbitration scheduled lor (date) :
arbitration l---l Agreed to complete judicial arbitration by (dafe);
l---l Judicial arbitration completed on (dafe):
Private arbitration not yet scheduled
(5) Binding private Private arbitration scheduled for (dafe);
arbitration Agreed to complete private arbitration by (date):
Private arbitration completed on (dafe);
[--l nOn session not yet scheduled
(6) Other (specify\
n ADR session scheduled for (dafe);
Agreed to complete ADR session by (dafe);
ADR completed on (dafe):
CMJ l0 [Rev. September 1, 2021 ] Page 3 of 5
CASE MANAGEMENT STATEMENT
cM-110
PLAI NTI FF/PETITIONER: Richard Gaza and Laura Maldonado CASE NUMBER:
DEFENDANT/RESPONDENT: Richard Ravalin, M.D., et al. 23CV000096
11. lnsurance
b. Reservation of rights: l---l Yes [--l No
12. Jurisdiction
lndicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
Status:
13. Related cases, consolidation, and coordination
a There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
Additional cases are described in Attachment 13a.
14. Bifurcation
The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of
action (specify moving party, type of motion, and reasons):
15. Other motions
16. Discovery
a. The party or parties have completed all discovery.
b. x The following discovery will be completed by the date specified (descibe all anticipated discovery):
Party Description Date
Plaintiffs Written Discovery July 2023
Plaintiffs Depositions of Defendants TBD
Plaintiffs Depositions of Treating Physicians TBD
Plaintiffs Expert Discovery Per Code
c. [--_l The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (sPecifY):
CM{ 10 [Rev. September 1, 2021 I Page 4 of 5
CASE MANAGEMENT STATEMENT
cM-110
PLAINTIFF/PETITIONER: Richard Garza and Laura Maldonado CASE NUMBER:
DEFENDANT/RESPONDENT: Richard Ravalin, M.D., et al. 23CV000096
1 7. Economic litigation
This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code
of Civil Procedure sections 90-98 will apply to this case.
b This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional
discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or tial
should not apply to this case):
18. Other issues
The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
19. Meet and confer
a The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of lhe California Rules
of Court (if not, explain):
(specify):
20. Total number of pages attached (if any) 0
I am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution,
as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of
the case management conference, including the written authority of the party where required.
Date: April25,2023
Timothy M. Hamilton
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
CM-1 10 [Rev. Septemb€r 1,2021] Page 5 of 5
CASE MANAGEMENT STATEMENT
1 PROOF OF SERVICE
Garza v. Ravalin, M.D., et al.
2
Monterey County Superior Court 23CV000096
J
My business address is 50 Francisco Street, Suite 460, San Francisco, Califomia94133. I am
4
in the County of San Francisco, where this mailing occurs. I am over the age of 18 years
5 not a party to the within cause. On the date set forth below, I served the foregoing document(s)
6 as the following:
7
PLAINTIFFS' CASE MANAGEMENT STATEMENT
(May 16,2023 CMC)
8
9
the following person(s) in this action by placing a true copy thereof enclosed in a sealed envelope
10 as listed below
11 or
l2
: ser e na(d.w hk- I aw. c om
13
I BY MESSENGER On April 25,2023, I caused such envelope to be delivered via personal
t4 to the office(s) of the addressee(s) stated below.
15
BY OVERNIGHT COURIER On April 25,2023,I deposited said envelope for delivery
I6 via overnight courier to the office of the addressee.
I7
James J. Zenere, Esq. Tel: (408) 430-3551
18 ZENERE COWDEN & STODDARD APC Fax:
2005 De La Cruz Blvd., Suite 240
t9 Santa CIara, CA 95050 E-mail:
E-mail:
20
Attorneys for Defendant Monterey Peninsula
2l Surgery Center (incorrectly sued herein os
Monterey Peninsulo S urgery Centers)
22
Michele Raley, Esq. Tel: (650) 543-2186
z) SCHMID & VOILES Fax: (925) 482-8128
100 Pringle Avenue, Suite 233
24
Walnut Creek, CA 94596 Email : Mralev(Eschmidvoi les.com
Email: Apedersen@schmidvoiles.com
25
Attorneys for Defendant Richard Ravolin, Email : i netrini@schmidvoi les.com
M.D.
26
27
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Barry C. Marsh, Esq. Tel: (408) 861-6500
HINSHAW, MARSH, STILL & HINSHAW, LLP Fax: (408) 257-6645
2
12901Saratoga Avenue
Saratoga, CA 95070 Email: w
J Email:
4
Attorneysfor Defendant Marc D. Johnson, M.D.
5 I declare under penalty of perjury under the laws of the State of Califomia that the foregoing
6
true and correct, and that this declaration was executed on April25' at San Francisco,
7
8 By:
7
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10
11
t2
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t6
t7
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r9
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2t
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Preview
cM-110 ATTORNEY OR PARTY WTHOUT ATTORNEY (NAME, StAtE BAT number, and address): FOR COURT USE ONLY Timothy M. Hamilton [State Bar No. 90270] Clarissa E. Kearns [State Bar No.2447321 WALKER, HAMILTON & KEARNS, LLP 50 Francisco Street, Suite 460 San Francisco, CA 94133-2100 TELEeHoNET'ro: (415) 986-3339 FlxNI (optionat), (415) 986-1618 E-MAIL ADDRESS, tim@whk-law.COm; e-service@whk-law.Com ArroRNEy FoR (ruame): PLAINTIFFS Richard Garza and Laura Maldonado SUPERIOR COURT OF CALIFORNIA, COUNTY OF MONTEREY STREETADDRESS: 1200 Aguajito Road MAILING ADDRESS: ctryAND zrp coDE: Monterey, CA 93940 BRANoH NAME: MOnterey DiviSiOn PLAINTIFF/PETITIONER: Richard Garza and Laura Maldonado DEFENDANT/RESPONDENT: Richard Ravalin, M.D., et al. CASE MANAGEMENT STATEMENT CASE NUMBER: LIMITED CASE 23CV000096 (Check one): UNLIMITED CASE (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: May 16,2023 Time: 9:00 a.m. Dept.: 14 Div Room: Address of court (if different from the address above): Notice of lntent to Appear by Telephone, by (name).' Clarissa E. Kearns, Esq. INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided 1. Party or parties (answer one): a. x This statement is submitted by party (name): PLAINTIFFS Richard Garzaand Laura Maldonado b. l---l This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): January 10,2023 b. n The cross-complaint, if any, was filed on (dafe): 3. Service (to be answered by plaintiffs and cross-complainants only) a x All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b The following parties named in the complaint or cross-complaint (1) (2) have been served but have not appeared and have not been dismissed (specify names) (3) c. The following additional parties may be added (specrfr names, nature of involvement in case, and date by which they may be served): 4. Description of case a. Type of case in x complaint l---l cross-complaint (Descibe, including causes of action): Medical Malpractice Page 1 of 5 Cal. Rules of Court, Form Adopted for Mandatory Use Judicial Council of California CASE MANAGEMENT STATEMENT rules 3.72G-3.730 CM-1 10 [Rev. September 1, 2021] w.mufts.ca.gov cM-110 PLAINTIFF/PETITIONER: Richard Garza and Laura Maldonado CASE NUMBER: DEFENDANT/RESPONDENT: Richard Ravalin, M.D., et al. 23CV000096 4. b. Provide a brief statement of the case, including any damag es. (lf personal injury damages are sought, specify the injury and damages claimed, including medicalexpenses to date [indicate source and amount], estimated future medical expenses, /osf eamings to date, and estimated future lost eamings. lf equitable relief is sought, describe the nature of the relief.) As a result of defendants' negligence, plaintiff Richard Gaza sustained injuries to his body causing emotional distress, pain, suffering, anguish and loss of income. Plaintiff Laura Maldonado is the lawful spouse of plaintiff Richard Garza and has suffered the loss of love, affection, comfort and monetary damages. f-- (tf more space ls needed, check this box and attach a page designated as Aftachment 4b.) 5. Jury or nonjury trial The party or parties request [Fl a jury trial requesting a jury tial): 6. Trialdate a Thetrialhas been selfor (date): b x No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (ff not, explain): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain re_asons for unavailability): January 29, 2024 [1 S-day Trial, Los Angeles County]; April 1 , 2024 l6-day Kaiser Arbitrationl 7. Estimated length of trial The party or parties estimate that the trial will lake (check one): a x days (specify number): 10-15 days b hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial x by the attorney or party listed in the caption [-l by the following a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: l--l Additional representation is described in Attachment 8. 9. Preference 10. Alternative dispute resolution (ADR) a. ADR information package. Please note that different ADR processes are available in different courts and communities; read the ADR information package provided by the court under rule 3.221 ol the California Rules of Court for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel l--l has l---lhas not provided the ADR information package identifled in rule 3.221 to the client and reviewed ADR options with the client. (2) For self-represented parties: Party l---l has l-_l nas not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141 .11 or to civil action mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of Civil Procedure section 1141 .11. (3) l-a This case is exempt from judicial arbitration under rdle 3.811 of the California Rules of Court or from civil action mediation under Code of Civil Procedure section 1775 el seq. (speclfy exemption): Amount in controversy exceeds $50,000.00. CMI 10 [R€v. September 1,2021] Page 2 of 5 CASE MANAGEMENT STATEMENT cM-l10 PLAI NTI FF/PETITIONER: Richard Garza and Laura Maldonado CASE NUMBER: DEFEN DANT/RESPONDENT: Richard Ravalin, M.D., et al. 23CV000096 10. c. lndicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or have already participated in (check all that apply and provide the specified information): The party or parties completing lf the party or parties completing this form in the case have agreed to this form are willing to participate in or have already completed an ADR process or processes, participate in the following ADR indicate the status of the processes (aftach a copy of the pafties' ADR processes (check all that apply): stipulation): Mediation session not yet scheduled Mediation session scheduled for (date): (1) Mediation x Agreed to complete mediation by (dafe): Mediation completed on (dafe): Settlement conference not yet scheduled (2) Settlement Settlement conference scheduled for (date): x conference Agreed to complete settlement conference by(dafe) Settlement conference completed on (dafe): Neutral evaluation not yet scheduled Neutral evaluation scheduled for (dafe); (3) Neutral evaluation Agreed to complete neutral evaluation by (dafe); Neutral evaluation completed on (dafe); Judicial arbitration not yet scheduled (4) Nonbinding judicial Judicial arbitration scheduled lor (date) : arbitration l---l Agreed to complete judicial arbitration by (dafe); l---l Judicial arbitration completed on (dafe): Private arbitration not yet scheduled (5) Binding private Private arbitration scheduled for (dafe); arbitration Agreed to complete private arbitration by (date): Private arbitration completed on (dafe); [--l nOn session not yet scheduled (6) Other (specify\ n ADR session scheduled for (dafe); Agreed to complete ADR session by (dafe); ADR completed on (dafe): CMJ l0 [Rev. September 1, 2021 ] Page 3 of 5 CASE MANAGEMENT STATEMENT cM-110 PLAI NTI FF/PETITIONER: Richard Gaza and Laura Maldonado CASE NUMBER: DEFENDANT/RESPONDENT: Richard Ravalin, M.D., et al. 23CV000096 11. lnsurance b. Reservation of rights: l---l Yes [--l No 12. Jurisdiction lndicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. Status: 13. Related cases, consolidation, and coordination a There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: Additional cases are described in Attachment 13a. 14. Bifurcation The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of action (specify moving party, type of motion, and reasons): 15. Other motions 16. Discovery a. The party or parties have completed all discovery. b. x The following discovery will be completed by the date specified (descibe all anticipated discovery): Party Description Date Plaintiffs Written Discovery July 2023 Plaintiffs Depositions of Defendants TBD Plaintiffs Depositions of Treating Physicians TBD Plaintiffs Expert Discovery Per Code c. [--_l The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (sPecifY): CM{ 10 [Rev. September 1, 2021 I Page 4 of 5 CASE MANAGEMENT STATEMENT cM-110 PLAINTIFF/PETITIONER: Richard Garza and Laura Maldonado CASE NUMBER: DEFENDANT/RESPONDENT: Richard Ravalin, M.D., et al. 23CV000096 1 7. Economic litigation This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code of Civil Procedure sections 90-98 will apply to this case. b This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or tial should not apply to this case): 18. Other issues The party or parties request that the following additional matters be considered or determined at the case management conference (specify): 19. Meet and confer a The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of lhe California Rules of Court (if not, explain): (specify): 20. Total number of pages attached (if any) 0 I am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of the case management conference, including the written authority of the party where required. Date: April25,2023 Timothy M. Hamilton (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. CM-1 10 [Rev. Septemb€r 1,2021] Page 5 of 5 CASE MANAGEMENT STATEMENT 1 PROOF OF SERVICE Garza v. Ravalin, M.D., et al. 2 Monterey County Superior Court 23CV000096 J My business address is 50 Francisco Street, Suite 460, San Francisco, Califomia94133. I am 4 in the County of San Francisco, where this mailing occurs. I am over the age of 18 years 5 not a party to the within cause. On the date set forth below, I served the foregoing document(s) 6 as the following: 7 PLAINTIFFS' CASE MANAGEMENT STATEMENT (May 16,2023 CMC) 8 9 the following person(s) in this action by placing a true copy thereof enclosed in a sealed envelope 10 as listed below 11 or l2 : ser e na(d.w hk- I aw. c om 13 I BY MESSENGER On April 25,2023, I caused such envelope to be delivered via personal t4 to the office(s) of the addressee(s) stated below. 15 BY OVERNIGHT COURIER On April 25,2023,I deposited said envelope for delivery I6 via overnight courier to the office of the addressee. I7 James J. Zenere, Esq. Tel: (408) 430-3551 18 ZENERE COWDEN & STODDARD APC Fax: 2005 De La Cruz Blvd., Suite 240 t9 Santa CIara, CA 95050 E-mail: E-mail: 20 Attorneys for Defendant Monterey Peninsula 2l Surgery Center (incorrectly sued herein os Monterey Peninsulo S urgery Centers) 22 Michele Raley, Esq. Tel: (650) 543-2186 z) SCHMID & VOILES Fax: (925) 482-8128 100 Pringle Avenue, Suite 233 24 Walnut Creek, CA 94596 Email : Mralev(Eschmidvoi les.com Email: Apedersen@schmidvoiles.com 25 Attorneys for Defendant Richard Ravolin, Email : i netrini@schmidvoi les.com M.D. 26 27 28 Page I of 2 Garza-POS 1 Barry C. Marsh, Esq. Tel: (408) 861-6500 HINSHAW, MARSH, STILL & HINSHAW, LLP Fax: (408) 257-6645 2 12901Saratoga Avenue Saratoga, CA 95070 Email: w J Email: 4 Attorneysfor Defendant Marc D. Johnson, M.D. 5 I declare under penalty of perjury under the laws of the State of Califomia that the foregoing 6 true and correct, and that this declaration was executed on April25' at San Francisco, 7 8 By: 7 9 10 11 t2 l3 I4 15 t6 t7 18 r9 20 2t 22 23 24 25 26 27 28 Page2 of 2 Garza- POS