On March 20, 2019 a
Stipulation,Agreement
was filed
involving a dispute between
Perez, Esperanza,
and
Brown, Tawna,
Bruun, Tawna,
Does 1 Through 50,
Kaiser Foundation Health Plan Inc A California Corporation,
Kaiser Foundation Hospitals A California Corporation,
Southern California Permanente Medical Group Inc., A Caifornia Corporation,
for Wrongful Termination Unlimited
in the District Court of San Bernardino County.
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Michele Ballard Miller (SBN 104198)
mbmiller@cozen.com SUPER rer oe
Ethan W. Chernin (SBN 273906) ALIFORNIA
echernin@cozen.com SAN RER; SAN
NARDING Di NC
COZEN O'CONNOR
401 Wilshire Boulevard, Suite 850 MAY 22 U2]
Santa Monica, California 90401-1000
Telephone: (310) 393-4000 By.
Facsimile: (310) 394-4700 ea
BLAYALTWADENS
Attorneys for Defendants
KAISER FOUNDATION HOSPITALS,
KAISER FOUNDATION HEALTH PLAN, INC
SOUTHERN CALIFORNIA PERMANENTE
MEDICAL GROUP, and TAWNA BRUUN
Twila White SBN 207424
LAW OFFICE OF TWILA WHITE
10 2615 Pacific Coast Highway, Suite 325
Hermosa Beach, CA 90254
11 Tel: 213-381-8749
Fax: 213-381-8799
12
wig Attorney for Plaintiff ESPERANZA PEREZ
g35
Za
13
Bes
oo
14
SUPERIOR COURT OF THE STATE OF CALIFORNIA
15
IN AND FOR THE COUNTY OFSAN BERNARDINO
16
17 Case No.:CIVDS 1920836
ESPERANZA PEREZ,
18 Plaintiff, JOINT STIPULATION TO CONTINUE
TRIAL AND ALL RELATED
19 DEADLINES; AN!
vs.
ORDER THEREON
20
KAISER FOUNDATION HOSPITALS, a
California Corporation; KAISER
21
FOUNDATION HEALTH PLAN, INC., a
Se vay ?
22 California Corporation; and SOUTHERN ) lian
CALIFORNIA PERMANENTE MEDICAL )
23 GROUP, INC., a California Corporation; )
TAWNA BRUUN:; an Individual; and DOES 1
24 through 50, Inclusive,
)
25 Defendants. )
)
26
27
28 4
NES; AND [PROPOSED]
JOINT STIPULATION TO CONTINUE TRIAL AND ALL RELATED DEADLI
ORDER THEREON
LEGAL\S2117760\1
~
Perez (‘Plaintiff’) and Defendants Kaiser Foundation
Plaintiff Esperanza
Foundation Health Plan, Inc., Southern California
Hospitals (“Hospitals”), Kaiser
(collectively, “Defendants,” and
Permanente Medical Group, and Tawna Bruun (‘Bruun’)
signed counsel of record, hereby
with Plaintiff, the “Parties”), by and through their under
STIPULATE and AGREE as follows:
March
4 Plaintiff initially filed her Complaint in this action on or about
20, 2019 in Los Angeles County Superior Court;
the Parties,
10 2 On or about May 22, 2019, pursuant to the stipulation of
venue;
11 this action was transferred to this Court as the appropriate
12
On or about September 3, 2019, Hospitals served Plaintiff with a
gue
ges 13 3
ges but the
8a Bs 14 Notice of Deposition, scheduling Plaintiffs deposition for November 4, 2019,
o8s
Zi3
Be on a medical leave of
8 15 deposition did not go forward because Plaintiff's counsel was
16 absence that lasted several months;
17
in this
18 4 On or about December 2, 2019, the Court scheduled trial
Conference set for March 25,
19 matter to begin on March 29, 2021, with a Trial Readiness
20 2021;
21
20, 2020, Hospitals served Plaintiff with an Amended
22 5 On October
10, 2020, but Plaintiff
23 Notice of Dep ‘osition, scheduling Plaintiff's deposition for November
at least January 19, 2021;
24 and her counsel were not available for deposition until
25
26
27
28 2
ED DEADLINES; AND [PROPOSED]
JOINT STIPULATION TO CONTINUE TRIAL AND ALL RELAT
ORDER THEREON
LEGAL\S2117760\L
Document Filed Date
May 12, 2021
Case Filing Date
March 20, 2019
Category
Wrongful Termination Unlimited
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Michele Ballard Miller (SBN 104198) mbmiller@cozen.com SUPER rer oe Ethan W. Chernin (SBN 273906) ALIFORNIA echernin@cozen.com SAN RER; SAN NARDING Di NC COZEN O'CONNOR 401 Wilshire Boulevard, Suite 850 MAY 22 U2] Santa Monica, California 90401-1000 Telephone: (310) 393-4000 By. Facsimile: (310) 394-4700 ea BLAYALTWADENS Attorneys for Defendants KAISER FOUNDATION HOSPITALS, KAISER FOUNDATION HEALTH PLAN, INC SOUTHERN CALIFORNIA PERMANENTE MEDICAL GROUP, and TAWNA BRUUN Twila White SBN 207424 LAW OFFICE OF TWILA WHITE 10 2615 Pacific Coast Highway, Suite 325 Hermosa Beach, CA 90254 11 Tel: 213-381-8749 Fax: 213-381-8799 12 wig Attorney for Plaintiff ESPERANZA PEREZ g35 Za 13 Bes oo 14 SUPERIOR COURT OF THE STATE OF CALIFORNIA 15 IN AND FOR THE COUNTY OFSAN BERNARDINO 16 17 Case No.:CIVDS 1920836 ESPERANZA PEREZ, 18 Plaintiff, JOINT STIPULATION TO CONTINUE TRIAL AND ALL RELATED 19 DEADLINES; AN! vs. ORDER THEREON 20 KAISER FOUNDATION HOSPITALS, a California Corporation; KAISER 21 FOUNDATION HEALTH PLAN, INC., a Se vay ? 22 California Corporation; and SOUTHERN ) lian CALIFORNIA PERMANENTE MEDICAL ) 23 GROUP, INC., a California Corporation; ) TAWNA BRUUN:; an Individual; and DOES 1 24 through 50, Inclusive, ) 25 Defendants. ) ) 26 27 28 4 NES; AND [PROPOSED] JOINT STIPULATION TO CONTINUE TRIAL AND ALL RELATED DEADLI ORDER THEREON LEGAL\S2117760\1 ~ Perez (‘Plaintiff’) and Defendants Kaiser Foundation Plaintiff Esperanza Foundation Health Plan, Inc., Southern California Hospitals (“Hospitals”), Kaiser (collectively, “Defendants,” and Permanente Medical Group, and Tawna Bruun (‘Bruun’) signed counsel of record, hereby with Plaintiff, the “Parties”), by and through their under STIPULATE and AGREE as follows: March 4 Plaintiff initially filed her Complaint in this action on or about 20, 2019 in Los Angeles County Superior Court; the Parties, 10 2 On or about May 22, 2019, pursuant to the stipulation of venue; 11 this action was transferred to this Court as the appropriate 12 On or about September 3, 2019, Hospitals served Plaintiff with a gue ges 13 3 ges but the 8a Bs 14 Notice of Deposition, scheduling Plaintiffs deposition for November 4, 2019, o8s Zi3 Be on a medical leave of 8 15 deposition did not go forward because Plaintiff's counsel was 16 absence that lasted several months; 17 in this 18 4 On or about December 2, 2019, the Court scheduled trial Conference set for March 25, 19 matter to begin on March 29, 2021, with a Trial Readiness 20 2021; 21 20, 2020, Hospitals served Plaintiff with an Amended 22 5 On October 10, 2020, but Plaintiff 23 Notice of Dep ‘osition, scheduling Plaintiff's deposition for November at least January 19, 2021; 24 and her counsel were not available for deposition until 25 26 27 28 2 ED DEADLINES; AND [PROPOSED] JOINT STIPULATION TO CONTINUE TRIAL AND ALL RELAT ORDER THEREON LEGAL\S2117760\L