Party Discovery: PEREZ-V-KAISER FOUNDATION HOSPITALS ET AL Print

• 
• 
• 
• 

						
                                
Preview
                                \x
                                                                                      FELEQ
                                                                           SUPERIOR COURT OF CALIFORNIF
                                                                            -'?OUNTY OF SAN BERNARDINC-
          Twila   S.   White, State Bar N0. 207424   LAW                     9m rar-mmprmn ngq-rmb'r
          LAW OFFICE OF TWILA S. WHITE
          2615 Pacific Coast Highway, Suite 325                                      3C? 2 2     202?
          Hermosa Beach,   CA 90254
          Telephone: (213) 381-8749
          Facsimile: (213) 381-8799                                       BY      th WWQM}
                                                                                émeRI/A.nmmM PORTIUQ

          Attorney for Plaintiff ESPERANZA       PEREZ

                                 SUPERIOR COURT OF THE STATE OF CALIFORNIA
 OO\]O\

                                         FOR THE COUNTY OF SAN BERNARDINO


          ESPERANZA PEREZ,                                         Case No.1   CIVDS 1 920836
 KO




10                          Plaintiff,                             PROOF OF SERVICE
11                vs.


12
          KAISER FOUNDATION HOSPITALS,                 a
13        California Corporation; KAISER
          FOUNDATION HEALTH PLAN, INC., a
14        California Corporation; and SOUTHERN
          CALIFORNIA PERMANENTE MEDICAL
15
          GROUP, INC, a California Corporation;
16
          TAWNA BRUUN; an Individual; and DOES             1

          through 50, Inclusive,
17
                           Defendants.
18


19

20

21

22

23

24

25

26

27

28                                                             1


                                                     PROOF OF SERVICE
                                                              PROOF OF SERVICE
          The undersigned           declares:


                    I   am employed            in the   County of Los Angeles,    State of California.    I am over the age of 18

          and    am     not a party to the within action;            my   business address    is   c/o   Law Office of Twila S.
          White, 2615 Pacific Coast Highway, Suite 325, Hermosa Beach,                         CA    90254.


          On October 22,           2021,   I   served the foregoing:


          PLAINTIFF’S NOTICE AND MOTION TO COMPEL DEFENDANT TAWNA
 OOOQON   BRUUN’S OBJECTIONS AND RESPONSES TO PLAINTIFF’S DISCOVERY
          REQUESTS
          PLAINTIFF’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL
          DEFENDANT TAWNA BRUUN’S OBJECTIONS AND RESPONSES TO PLAINTIFF’S
10        FORM INTERROGATORIES — GENERAL, SET ONE
11
                             STATEMENT IN SUPPORT OF MOTION TO COMPEL
          PLAINTIFF’S SEPARATE
12
          DEFENDANT TAWNA BRUUN’S OBJECTIONS AND RESPONSES TO PLAINTIFF’S
          REQUEST FOR PRODUCTION, SET ONE
13
          on parties     to the within action as follows:
14
          SEE ATTACHED SERVICE LIST
15


16        __X__ ONLY BY ELECTRONIC TRANSMISSION.                                     Only by e-mailing the document(s) to
          the persons at the e-mail address(es) listed based                  on notice provided 0n March 21, 2020 that,
17        during the Coronavirus (COVID-19) pandemic, the     Law Office of Twila S. White will be
          working remotely, not able to send physical mail as usual, and are therefore using only electronic
18
          mails. No electronic message or other indication that the transmission was unsuccessfifl was
          received within a reasonable time after the transmission.
19

20        I   declare under penalty ofperjury under the laws of the State of California that the foregoing                  is

          true   and    correct.
21

22
          Executed on October 22, 2021
23

24

25

26
                                                                                KW pm
                                                                               KAREN PARRA
27

28                                                                        2

                                                                PROOF OF SERVICE