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V
N. Nick Ebrahimian, Esq. (State Bar No. 219270)
SUPER.OR§3UkT§FaL,FORN.A
nebrahimian@lelawfirm.com COUNTY 0F SAN BERNARDINO
Victoria Carthom, Esq. (State Bar No. 322505) SAN BERNARD'NO D'STR'CT
vcarthom@lelawfirm.com -
LAVI & EBRAHIMIAN, LLP JUN 1 6 2921
8889 W. Olympic Blvd., Ste. 200
Beverly Hills, California 90211 -
r
gt
Telephone (3 432-0000
1 0) BY 3349’ ‘
FaCSimile (3 1 0) 432-0001 NATHAméfler-MON, berm
Attorneys for Plaintiffs
MARIA ORNELAS
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
MARIA ORNELAS, Case No.2 CIVDSZOI 1754
PLAINTIFFS> [Assignedfor all purposes 1'0 l‘he Hon.
Brian S. McCarville, Dept. S30]
VS-
12 PLAINTIFF MARIA ORNELAs’s
PRIME HEALTHCARE SERVICES — NOTICE 0F MOTION AND
13
GARDEN GROVE, LLC.; PRIME MOTION T0 COMPEL FURTHER
HEALTHCARE SERVICES, INC; PRIME RESPONSES FROM DEFENDANT
14
HEALTHCARE GARDEN GROVE, LLC PRIME HEALTHCARE SERVICES,
.7
D/B/A GARDEN GROVE HOSPITAL INC TO PLAINTIFF'S FORM
1‘ MEDICAL CENTER; GARDEN GROVE INTERROGATORIES, GENERAL,
HOSPITAL; LIZA MARTINEZ; and DOES 1 to
SET ONE, NOS 1.1, 3.1, 3.2, 3.3, 3.4,
w 100’ Ineluswe' 3.5, 3.6, 3.7, 4.1, 4.2, 12.1, 12.2, 12.3,
“a ,
12.4, 12.5, 12.6, 12.7, 13.1, 13.2, 14.1,
l7 14.2, and 15.1; REQUEST FOR
DEFENDANTS. SANCTIONS IN THE AMOUNT OF
. '18 $5,011.00; MEMORANDUM OF
POINTS AND AUTHORITIES;
DECLARATION OF VICTORIA
CARTHORN; EXHIBITS
20
[Filed concurrently Separate Statement
21 in Support and [Proposed] Order]
22 Hearing Information:
Date: September3e, 2021
23 Time: 9:00 a.m.
Dept: S30
24
25 TO THE HONORABLE COURT, ALL PARTIES AND THEIR ATTORNEYS OF
26 RECORD:
27 PLEASE TAKE NOTICE that on September 39, 2021 at 9:00 am. or as soon thereafter as
PLAINTIFF MARIA ORNELAS’S NOTICE OF MOTION AND MOTION T0 COMPEL FURTHER
28 RESPONSES FROM
DEFENDANT PRIME HEALTHCARE SERVICES, INC TO PLAINTIFF'S FORM INTERROGATORIES, GENERAL,
SET ONE, NOS 1.1, 3.1, 3.2, 3.3, 3.4, 3.5, 3.6, 3.7, 4.l, 4.2, 12.1, 12.2, 12.3, 12.4, 12.5, [2.6, 12.7, 13.1,
13.2, 14.1, 14.2, and 15.1;
REQUEST FOR SANCTIONS IN THE AMOUNT OF $5,011.00; MEMORANDUM OF POINTS AND AUTHORITIES;
DECLARATION OF VICTORIA CARTHORN; EXHIBITS
l
matter can be heard, in Department 830 0f the above
entitled Court located at 247 W 3rd St, San
Bernardino, CA 92415, Plaintiff MARIA ORNELAS will move for an order compelling Defendant
PRIME HEALTHCARE SERVICES, INC to provide further complete written responses, without
obj ection, to Plaintiff MARIA ORNELAS’S Form Interrogatories-General, set one, NOS 1.1, 3.1,
3.2, 3.3, 3.4, 3.5, 3.6, 3.7, 4.1, 4.2, 12.1,
12.2, 12.3, 12.4, 12.5, 12.6, 12.7, 13.1, 13.2,
14.1, 14.2, and
15.1 which were propounded by Plaintiff MARIA ORNELAS.
Plaintiff will also move this Court to order Defendant PRIME HEALTHCARE SERVICES,
INC and/or its attorneys of records Emily Patajo, Esq., Helen Braginsky, Esq, and their firm Littler
Mendelson, P.C. to pay $5,01 1.00 in sanctions for forcing the present request for judicia
10 l
intervention by failing to provide adequate answers to the interrogatories.
11
This Motion is made pursuant to California Code of Civil Procedure (“C.C.P”)
12 §§ 2030.010 er
seq., 2030.300 and 2023.01 0 et seq. on the ground that: Defendant has refused t0 provide complete
(1)
13
or code-compliant responses to the interrogatories
at issue in this Motion,
I4 (2) the objections made by
Defendant as to Plaintiff‘s interrogatories are withou
t merit or too general and (3) despite extensive
15
meeting and conferring, Defendant refuses to correct the discovery. This motion is made on the further
16
grounds that the discovery should be required and
l7
the refusal of Defendant PRIME HEALTHCARE
SERVICES, INC and its attorneys of record permit discovery as to Plaintiff’s
18
to
FORM
INTERROGATORIES, GENERAL, SET ONE, NOS 1.1, 3.1, 3.2, 3.3, 3.4, 3.5, 3.6, 3.7, 4.1,
19 4.2,
12.1, 12.2, 12.3, 12.4, 12.5, 12.6, 12.7,
13.1, 13.2, 14.1, 14.2, and 15.1, was without
20 substantial
justification and the court must order the Defen
dant and its attorneys of record to pay monetary
21
sanctions to reimburse Plaintiff for the cost 0f
bringing this motion.
22
This motion will be based on this notice, pleadings, entire court
23
file for this action, and the
attached memorandum of points and authorities, supporting declaration of Victor
24 ia Carthorn, Esq.,
exhibits and any evidence that may be presented at the hearing.
25
///
26
27
PLAINTIFF MARIA ORNELAS’S NOTICE OF MOTION AND
28 MOTION TO COMPEL FURTHER RESPONSES FROM
DEFENDANT PRIME HEALTHCARE SERVICES, INC TO PLAINTIFF'S
SET ONE, NOS 1.1, 3.1, 3.2, 3.3, 3.4, 3.5, 3.6, 3.7, 4.1, 4.2, 12.1, FORM INTERROGATORIES, GENERAL,
12.2, 12.3,
12.4, 12.5, 12.6, 12.7, 13.1, 13.2, 14.1, 14.2, and
REQUEST FOR SANCTIONS IN THE AMOUNT OF $5,011.00; MEMO 15.1;
RANDUM 0F POINTS AND AUTHORITIES;
DECLARATION OF VICTORIA CARTHORN; EXHIBITS
u
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V N. Nick Ebrahimian, Esq. (State Bar No. 219270) SUPER.OR§3UkT§FaL,FORN.A nebrahimian@lelawfirm.com COUNTY 0F SAN BERNARDINO Victoria Carthom, Esq. (State Bar No. 322505) SAN BERNARD'NO D'STR'CT vcarthom@lelawfirm.com - LAVI & EBRAHIMIAN, LLP JUN 1 6 2921 8889 W. Olympic Blvd., Ste. 200 Beverly Hills, California 90211 - r gt Telephone (3 432-0000 1 0) BY 3349’ ‘ FaCSimile (3 1 0) 432-0001 NATHAméfler-MON, berm Attorneys for Plaintiffs MARIA ORNELAS SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO MARIA ORNELAS, Case No.2 CIVDSZOI 1754 PLAINTIFFS> [Assignedfor all purposes 1'0 l‘he Hon. Brian S. McCarville, Dept. S30] VS- 12 PLAINTIFF MARIA ORNELAs’s PRIME HEALTHCARE SERVICES — NOTICE 0F MOTION AND 13 GARDEN GROVE, LLC.; PRIME MOTION T0 COMPEL FURTHER HEALTHCARE SERVICES, INC; PRIME RESPONSES FROM DEFENDANT 14 HEALTHCARE GARDEN GROVE, LLC PRIME HEALTHCARE SERVICES, .7 D/B/A GARDEN GROVE HOSPITAL INC TO PLAINTIFF'S FORM 1‘ MEDICAL CENTER; GARDEN GROVE INTERROGATORIES, GENERAL, HOSPITAL; LIZA MARTINEZ; and DOES 1 to SET ONE, NOS 1.1, 3.1, 3.2, 3.3, 3.4, w 100’ Ineluswe' 3.5, 3.6, 3.7, 4.1, 4.2, 12.1, 12.2, 12.3, “a , 12.4, 12.5, 12.6, 12.7, 13.1, 13.2, 14.1, l7 14.2, and 15.1; REQUEST FOR DEFENDANTS. SANCTIONS IN THE AMOUNT OF . '18 $5,011.00; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF VICTORIA CARTHORN; EXHIBITS 20 [Filed concurrently Separate Statement 21 in Support and [Proposed] Order] 22 Hearing Information: Date: September3e, 2021 23 Time: 9:00 a.m. Dept: S30 24 25 TO THE HONORABLE COURT, ALL PARTIES AND THEIR ATTORNEYS OF 26 RECORD: 27 PLEASE TAKE NOTICE that on September 39, 2021 at 9:00 am. or as soon thereafter as PLAINTIFF MARIA ORNELAS’S NOTICE OF MOTION AND MOTION T0 COMPEL FURTHER 28 RESPONSES FROM DEFENDANT PRIME HEALTHCARE SERVICES, INC TO PLAINTIFF'S FORM INTERROGATORIES, GENERAL, SET ONE, NOS 1.1, 3.1, 3.2, 3.3, 3.4, 3.5, 3.6, 3.7, 4.l, 4.2, 12.1, 12.2, 12.3, 12.4, 12.5, [2.6, 12.7, 13.1, 13.2, 14.1, 14.2, and 15.1; REQUEST FOR SANCTIONS IN THE AMOUNT OF $5,011.00; MEMORANDUM OF POINTS AND AUTHORITIES; DECLARATION OF VICTORIA CARTHORN; EXHIBITS l matter can be heard, in Department 830 0f the above entitled Court located at 247 W 3rd St, San Bernardino, CA 92415, Plaintiff MARIA ORNELAS will move for an order compelling Defendant PRIME HEALTHCARE SERVICES, INC to provide further complete written responses, without obj ection, to Plaintiff MARIA ORNELAS’S Form Interrogatories-General, set one, NOS 1.1, 3.1, 3.2, 3.3, 3.4, 3.5, 3.6, 3.7, 4.1, 4.2, 12.1, 12.2, 12.3, 12.4, 12.5, 12.6, 12.7, 13.1, 13.2, 14.1, 14.2, and 15.1 which were propounded by Plaintiff MARIA ORNELAS. Plaintiff will also move this Court to order Defendant PRIME HEALTHCARE SERVICES, INC and/or its attorneys of records Emily Patajo, Esq., Helen Braginsky, Esq, and their firm Littler Mendelson, P.C. to pay $5,01 1.00 in sanctions for forcing the present request for judicia 10 l intervention by failing to provide adequate answers to the interrogatories. 11 This Motion is made pursuant to California Code of Civil Procedure (“C.C.P”) 12 §§ 2030.010 er seq., 2030.300 and 2023.01 0 et seq. on the ground that: Defendant has refused t0 provide complete (1) 13 or code-compliant responses to the interrogatories at issue in this Motion, I4 (2) the objections made by Defendant as to Plaintiff‘s interrogatories are withou t merit or too general and (3) despite extensive 15 meeting and conferring, Defendant refuses to correct the discovery. This motion is made on the further 16 grounds that the discovery should be required and l7 the refusal of Defendant PRIME HEALTHCARE SERVICES, INC and its attorneys of record permit discovery as to Plaintiff’s 18 to FORM INTERROGATORIES, GENERAL, SET ONE, NOS 1.1, 3.1, 3.2, 3.3, 3.4, 3.5, 3.6, 3.7, 4.1, 19 4.2, 12.1, 12.2, 12.3, 12.4, 12.5, 12.6, 12.7, 13.1, 13.2, 14.1, 14.2, and 15.1, was without 20 substantial justification and the court must order the Defen dant and its attorneys of record to pay monetary 21 sanctions to reimburse Plaintiff for the cost 0f bringing this motion. 22 This motion will be based on this notice, pleadings, entire court 23 file for this action, and the attached memorandum of points and authorities, supporting declaration of Victor 24 ia Carthorn, Esq., exhibits and any evidence that may be presented at the hearing. 25 /// 26 27 PLAINTIFF MARIA ORNELAS’S NOTICE OF MOTION AND 28 MOTION TO COMPEL FURTHER RESPONSES FROM DEFENDANT PRIME HEALTHCARE SERVICES, INC TO PLAINTIFF'S SET ONE, NOS 1.1, 3.1, 3.2, 3.3, 3.4, 3.5, 3.6, 3.7, 4.1, 4.2, 12.1, FORM INTERROGATORIES, GENERAL, 12.2, 12.3, 12.4, 12.5, 12.6, 12.7, 13.1, 13.2, 14.1, 14.2, and REQUEST FOR SANCTIONS IN THE AMOUNT OF $5,011.00; MEMO 15.1; RANDUM 0F POINTS AND AUTHORITIES; DECLARATION OF VICTORIA CARTHORN; EXHIBITS u