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NAME AND ADDRESS OF ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR NUMBER Reserved Tm Clark’s FileS‘amp
Scott B. McFalI, Esq. l Haig Arabian Esq. .'
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AGAJANIAN, McFALL, WEISS, TETREAULT a CRIST LLP 30395 / 259361
346 North Larchmont Blvd. Los Angeles, California 90004
TELEPHONE NO.: (323)993-0198 ‘ W
.
E-MAIL ADDRESS: haig@agajanian|aw.com TRIAL SETTING CONFERENCE DATE: 06/07/2023 ~" x '
.
ATTORNEY F0R(Name);Defs.HDMC&DRMC UNLIMITED CASE;
V
FAX No.(0ptionan:(323)993-9509 LIMHEDCASE: DDEPT: $33 5-1;.
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rs
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b; ‘6.
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO
COURTHOUSE ADDRESS: 247 w. Third Street, San Bernardino, CA 92415 *3
PLAINT'FF? Louis Salas et a1.
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i
DEFENDANT: HDMC Holdings LLC et al.
CASE NUMBER:
INITIAL TRIAL SETTING CONFERENCE STATEMENT CIvs32215198
INSTRUCTIONS: All applicable boxes must be checked, and the specified information mus! be provided.
1. Party or parties (answer one):
a. EThis statement is submitted by party (name); Defendants, HDMC Holdings, L.L.C. dba Hi-Desert Medical Center D/P SNF; HDMC Holdings, L.L.C. dba Hi-
Desert Medical Center, Hi-Desert Continuing Care Center, and Desert Regional Medical Center, Inc. (DOE 1)
b. DThis statement is submitted jointly by parties (names):
2. Service of Complaint on all parties E has been completed.
E] has not been completed.
I [FAAXIE
DD
3. Service of Cross-Complaint on all parties D has been completed.
[ 1 has not been completed.
4. Description of case in ComplaintPlaintiffs, Louis Salas, by and ‘hrough his Successor-in-lnterest, Elena Salas, and Elena Salas, individually, allege Decadent developed a
pressure injury while under the care of Defendants, which caused him pain/suffering and his death on February 2, 2021. Plaintiffs assert causes
of action for Dependent Adult Abuse (Survival), Violation of Patient Rights (Survival), Negligence (Survival) and Wrongful
Death,
5. Description of case in Cross-Complaint;
6. Has all discovery been completed: Yes D No E Date discovery anticipated to be completed: Per COde
7. Do you agree to mediation? Yes m No E] Please check type agreed to: Private: x Court-sponsored:
8. Related cases, consolidation, and coordination
a. D There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court:
(3) Case number:
(4) Status:
b. DA motion to D consolidate D coordinate will be filed by (name ofparty):
9. E Trialdates requestedz‘lesD No E Available dates: Time estimate: 15-20 days JTE COURTD
10. Other issues:
fl The following additional matters are requested to be considered by the Court:
11‘ Meet and Confer:
mThe parties represent that they have met and conferred on all subjects required by California Rules of Court, Rule 3.724.
D The parties have entered into the following stipulation(s):
12. Total number of pages attached (Ifany): 0
| 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 statemem, and will possess the authority to enter into stipulations on these issues at the time of the Initial Trial Setting Conference, including the written authority
of the party where required.
Dam 05/19/2023
Haig Arabian Esq.
(TYPE OR PRINT NAME) (SIquv OF PARTY OR ATTORNEY
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY
Form# 13-09001-360
Rev. 1l-2021 Mandatory
INITIAL TRIAL SETTING CONFERENCE STATEMENT
PROOF OF SERVICE
Louis Salas vs. Hi-Desert Medical Center
Case No. CIV832215198
STATE OF CALIFORNIA )
) ss.
COUNTY OF LOS ANGELES )
I am employed in the County 1am over the age of eighteen years and not a party to the
aforesaid;
within action; my business address is 346 N. Larchmont B]Vd., Los Angeles, California 90004.
On May 19, 2023, I caused the service of the within INITIAL TRIAL SETTING
CONFERENCE STATEMENT on the interested parties in said action, by electronic service,
addressed as follows:
Steven C. Peck
Adam J. Peck
Peck Law Group APC
lO 6454 Van Nuys Boulevard, Suite 150
Van Nuys, California 91401-1407
11 Tel: 818—908-0509
Fax: 818-643-4980
12 Email: eservice@thepeck1awgroup.com;
stevenpeck@thepecklawgroup.com;
l3 adampeck@thepecklawgroup.com
Attorneys for Plaintiff
l4 Louis Salas
15
[] (BY U.S. MAIL) I enclosed the foregoing document(s) in a sealed envelope or package
l6 addressed to the persons at the addresses listed on the attached service list and placed the
envelope or package for collection and mailing, following our ordinary business practices. I am
l7 readily familiar with the firm's practice for collection and processing correspondence for mailing.
Under that practice, on the same day that correspondence is placed for collection and mailing, it
l8 isdeposited in the ordinary course of business with the U.S. Postal Service, in a sealed envelope
of package with the postage fully prepaid.
l9
[X] BY ELECTRONIC TRANSMISSION: I caused a copy of the document(s) above to be sent
20 from the e-mail address: gary@agajanianlaw.com t0 the persons at the e-mail addresses listed
above pursuant to California Rules of Court, Rule 2.251 (Proof 0f Electronic Service) and Code
21 of Civil Procedure §1010.6. No message or other indication that the transmission was
unsuccessful was received within a reasonable time following transmission
22
[X] (State) I declare under penalty of perjury under the laws of the State of California that the above
23 istrue and correct.
24 Executed 0n May 19, 2023, at Los Angeles, California.
25
26
Gary Easter
27
28
PR 00F OF QFRVIFF
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NAME AND ADDRESS OF ATTORNEY OR PARTY WITHOUT ATTORNEY: STATE BAR NUMBER Reserved Tm Clark’s FileS‘amp Scott B. McFalI, Esq. l Haig Arabian Esq. .' ‘ - AGAJANIAN, McFALL, WEISS, TETREAULT a CRIST LLP 30395 / 259361 346 North Larchmont Blvd. Los Angeles, California 90004 TELEPHONE NO.: (323)993-0198 ‘ W . E-MAIL ADDRESS: haig@agajanian|aw.com TRIAL SETTING CONFERENCE DATE: 06/07/2023 ~" x ' . ATTORNEY F0R(Name);Defs.HDMC&DRMC UNLIMITED CASE; V FAX No.(0ptionan:(323)993-9509 LIMHEDCASE: DDEPT: $33 5-1;. ‘ _ rs ~ u , b; ‘6. SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO COURTHOUSE ADDRESS: 247 w. Third Street, San Bernardino, CA 92415 *3 PLAINT'FF? Louis Salas et a1. ‘ i DEFENDANT: HDMC Holdings LLC et al. CASE NUMBER: INITIAL TRIAL SETTING CONFERENCE STATEMENT CIvs32215198 INSTRUCTIONS: All applicable boxes must be checked, and the specified information mus! be provided. 1. Party or parties (answer one): a. EThis statement is submitted by party (name); Defendants, HDMC Holdings, L.L.C. dba Hi-Desert Medical Center D/P SNF; HDMC Holdings, L.L.C. dba Hi- Desert Medical Center, Hi-Desert Continuing Care Center, and Desert Regional Medical Center, Inc. (DOE 1) b. DThis statement is submitted jointly by parties (names): 2. Service of Complaint on all parties E has been completed. E] has not been completed. I [FAAXIE DD 3. Service of Cross-Complaint on all parties D has been completed. [ 1 has not been completed. 4. Description of case in ComplaintPlaintiffs, Louis Salas, by and ‘hrough his Successor-in-lnterest, Elena Salas, and Elena Salas, individually, allege Decadent developed a pressure injury while under the care of Defendants, which caused him pain/suffering and his death on February 2, 2021. Plaintiffs assert causes of action for Dependent Adult Abuse (Survival), Violation of Patient Rights (Survival), Negligence (Survival) and Wrongful Death, 5. Description of case in Cross-Complaint; 6. Has all discovery been completed: Yes D No E Date discovery anticipated to be completed: Per COde 7. Do you agree to mediation? Yes m No E] Please check type agreed to: Private: x Court-sponsored: 8. Related cases, consolidation, and coordination a. D There are companion, underlying, or related cases. (1) Name of case: (2) Name of court: (3) Case number: (4) Status: b. DA motion to D consolidate D coordinate will be filed by (name ofparty): 9. E Trialdates requestedz‘lesD No E Available dates: Time estimate: 15-20 days JTE COURTD 10. Other issues: fl The following additional matters are requested to be considered by the Court: 11‘ Meet and Confer: mThe parties represent that they have met and conferred on all subjects required by California Rules of Court, Rule 3.724. D The parties have entered into the following stipulation(s): 12. Total number of pages attached (Ifany): 0 | 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 statemem, and will possess the authority to enter into stipulations on these issues at the time of the Initial Trial Setting Conference, including the written authority of the party where required. Dam 05/19/2023 Haig Arabian Esq. (TYPE OR PRINT NAME) (SIquv OF PARTY OR ATTORNEY (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY Form# 13-09001-360 Rev. 1l-2021 Mandatory INITIAL TRIAL SETTING CONFERENCE STATEMENT PROOF OF SERVICE Louis Salas vs. Hi-Desert Medical Center Case No. CIV832215198 STATE OF CALIFORNIA ) ) ss. COUNTY OF LOS ANGELES ) I am employed in the County 1am over the age of eighteen years and not a party to the aforesaid; within action; my business address is 346 N. Larchmont B]Vd., Los Angeles, California 90004. On May 19, 2023, I caused the service of the within INITIAL TRIAL SETTING CONFERENCE STATEMENT on the interested parties in said action, by electronic service, addressed as follows: Steven C. Peck Adam J. Peck Peck Law Group APC lO 6454 Van Nuys Boulevard, Suite 150 Van Nuys, California 91401-1407 11 Tel: 818—908-0509 Fax: 818-643-4980 12 Email: eservice@thepeck1awgroup.com; stevenpeck@thepecklawgroup.com; l3 adampeck@thepecklawgroup.com Attorneys for Plaintiff l4 Louis Salas 15 [] (BY U.S. MAIL) I enclosed the foregoing document(s) in a sealed envelope or package l6 addressed to the persons at the addresses listed on the attached service list and placed the envelope or package for collection and mailing, following our ordinary business practices. I am l7 readily familiar with the firm's practice for collection and processing correspondence for mailing. Under that practice, on the same day that correspondence is placed for collection and mailing, it l8 isdeposited in the ordinary course of business with the U.S. Postal Service, in a sealed envelope of package with the postage fully prepaid. l9 [X] BY ELECTRONIC TRANSMISSION: I caused a copy of the document(s) above to be sent 20 from the e-mail address: gary@agajanianlaw.com t0 the persons at the e-mail addresses listed above pursuant to California Rules of Court, Rule 2.251 (Proof 0f Electronic Service) and Code 21 of Civil Procedure §1010.6. No message or other indication that the transmission was unsuccessful was received within a reasonable time following transmission 22 [X] (State) I declare under penalty of perjury under the laws of the State of California that the above 23 istrue and correct. 24 Executed 0n May 19, 2023, at Los Angeles, California. 25 26 Gary Easter 27 28 PR 00F OF QFRVIFF