On April 27, 2022 a
Order to Show Cause
was filed
involving a dispute between
Olmedo, Jazlyn,
Salas, Elena,
Salas, Louis,
and
Desert Regional Medical Center, Inc,
Does 2 Through 200,
Hdmc Holdings, L.L.C.,
Hi-Desert Continuing Care Center,
for Other non-PI/PD/WD Tort Unlimited
in the District Court of San Bernardino County.
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PECK LAW GROUP, APC
Steven C. Peck (SBN 097343)
Adam J. Peck (SBN 262549)
‘
6454 Van Nuys Boulevard, Suite 150
H
*
2 2
Van Nuys, California 91401-1407 3
Telephone: 8 1 8-908-0509 .. f,;¢;,,), V
V
Facs1mile:818-643-4980 w
spencerpeck@thepecklawgroup.com “~ I
"
wmflamhwtvw
Attorneys for Plaintiffs
SUPERIOR COURT 0F THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO
LOUIS SALAS, by and through his Successor- CASE NO.: CIVSB2215198
in—Interest, Elena Salas, ELENA SALAS,
Individually Assignedfor All Purposes t0: Hon. Winston
Keh
Plaintiffs, Department S33
vs_ DECLARATION 0F STEVEN C. PECK RE
ORDER To SHOW CAUSE RE:
HDMC HOLDINGS, L.L.C. dba Hi—Desert SANCTIONS FOR FAILURE T0 APPEAR
Medical D/P
Center SNF; HDMC 2023 TRIAL SETTING
égNg/égNé’E
HOLDINGS, L.L.C. dba Hi-Desert Medical
Center; HI—DESERT CONTINUING CARE DATE: June 7’ 2023
CENTER and Does 1 through 200, inclusive,
TIME:
NNNNNNNNNb—Ir—Ir—Ab—nr—tr—It—IHt—IH
8:30 mm.
DEPT.: SS3
WVONMAUJNHONOOONQUIhWNF-‘O
Defendants,
Action Filed: April 27, 2022
LOUIE SALAS, NACHITO SALAS, Trial Date: None Set
BRIANNA CORTEZ, BECCA SALAS
Nominal Defendants. 4f?” A
- J— '-
///
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1
DECLARATION OF STEVEN C. PECK RE ORDER TO SHOW CAUSE RE: SANCTIONS FOR FAILURE TO
APPEAR AT MAY 4. 2023 TRIAL SETTING CONFERENCE
1. I am an attorney at law licensed to practice before all the courts of the State of California and
an attorney of the Peck Law Group, APC, attorneys of record for Plaintiffs in the within action. The
facts set forth are of my own personal knowledge, and if sworn I could and would competently testify
thereto.
2. The reason counsel for Plaintiffs did not appear at the May 4, 2023, Trial Setting Conference
\OOONQUIAWNr—a
was that the hearing was, for reasons unknown, inadvertently omitted from our office’s calendaring
system, despite out best efforts to calendar all court appearances.
3. Counsel for Plaintiffs respectfully requests that sanctions not be imposed for its failure to
appear, as such failure was the result of inadvertence and not as a result of any deliberate action on the
part of counsel.
4. Again, my office offers its sincerest apologies to the court, its staff, and the other parties in this
action for any inconvenience caused by my office’s failure to appear.
I declare under penalty of peljury under the laws of the State of California that
the foregoing is
true and correct.
This declaration was signed on May 12, 2023 at Van Nuys, California.
NNNNNNNNNHHHHp—nn—p—tv—Hr—n
WQQM¥WNHOQWNQMhWNHO
Steven C. Peck, Declarant
2
DECLARATION OF STEVEN C. PECK RE ORDER TO SHOW CAUSE RE: SANCTIONS FOR FAILURE TO
APPEAR AT MAY 4. 2023 TRIAL SETTFNG CONFERENCE
Document Filed Date
May 12, 2023
Case Filing Date
April 27, 2022
Category
Other non-PI/PD/WD Tort Unlimited
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PECK LAW GROUP, APC Steven C. Peck (SBN 097343) Adam J. Peck (SBN 262549) ‘ 6454 Van Nuys Boulevard, Suite 150 H * 2 2 Van Nuys, California 91401-1407 3 Telephone: 8 1 8-908-0509 .. f,;¢;,,), V V Facs1mile:818-643-4980 w spencerpeck@thepecklawgroup.com “~ I " wmflamhwtvw Attorneys for Plaintiffs SUPERIOR COURT 0F THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO LOUIS SALAS, by and through his Successor- CASE NO.: CIVSB2215198 in—Interest, Elena Salas, ELENA SALAS, Individually Assignedfor All Purposes t0: Hon. Winston Keh Plaintiffs, Department S33 vs_ DECLARATION 0F STEVEN C. PECK RE ORDER To SHOW CAUSE RE: HDMC HOLDINGS, L.L.C. dba Hi—Desert SANCTIONS FOR FAILURE T0 APPEAR Medical D/P Center SNF; HDMC 2023 TRIAL SETTING égNg/égNé’E HOLDINGS, L.L.C. dba Hi-Desert Medical Center; HI—DESERT CONTINUING CARE DATE: June 7’ 2023 CENTER and Does 1 through 200, inclusive, TIME: NNNNNNNNNb—Ir—Ir—Ab—nr—tr—It—IHt—IH 8:30 mm. DEPT.: SS3 WVONMAUJNHONOOONQUIhWNF-‘O Defendants, Action Filed: April 27, 2022 LOUIE SALAS, NACHITO SALAS, Trial Date: None Set BRIANNA CORTEZ, BECCA SALAS Nominal Defendants. 4f?” A - J— '- /// /// // /// /// /// 1 DECLARATION OF STEVEN C. PECK RE ORDER TO SHOW CAUSE RE: SANCTIONS FOR FAILURE TO APPEAR AT MAY 4. 2023 TRIAL SETTING CONFERENCE 1. I am an attorney at law licensed to practice before all the courts of the State of California and an attorney of the Peck Law Group, APC, attorneys of record for Plaintiffs in the within action. The facts set forth are of my own personal knowledge, and if sworn I could and would competently testify thereto. 2. The reason counsel for Plaintiffs did not appear at the May 4, 2023, Trial Setting Conference \OOONQUIAWNr—a was that the hearing was, for reasons unknown, inadvertently omitted from our office’s calendaring system, despite out best efforts to calendar all court appearances. 3. Counsel for Plaintiffs respectfully requests that sanctions not be imposed for its failure to appear, as such failure was the result of inadvertence and not as a result of any deliberate action on the part of counsel. 4. Again, my office offers its sincerest apologies to the court, its staff, and the other parties in this action for any inconvenience caused by my office’s failure to appear. I declare under penalty of peljury under the laws of the State of California that the foregoing is true and correct. This declaration was signed on May 12, 2023 at Van Nuys, California. NNNNNNNNNHHHHp—nn—p—tv—Hr—n WQQM¥WNHOQWNQMhWNHO Steven C. Peck, Declarant 2 DECLARATION OF STEVEN C. PECK RE ORDER TO SHOW CAUSE RE: SANCTIONS FOR FAILURE TO APPEAR AT MAY 4. 2023 TRIAL SETTFNG CONFERENCE