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1 TIMOTHY J. LONG (STATE BAR NO. 137591) FILED
tjlong@orrick.com ' ENDORSED
2 ORRICK, HERRINGTON & SUTCLIFFE LLP
2018 APR-3 PM 2=09
400 Capitol Mall, Suite 3000
3 Sacramento, CA 95814-4497 SUPERIGR COURT 'O' CAllFGR'JIliH
Telephone: -fl 916 447 9200 CSUviTY Of SACRAHLKVO
4 Facsimile: -)-l 916 329 4900
5 STEPHANIE GAIL LEE (STATE BAR NO. 285379)
stephanie.lee@orrick.com
6 ORRICK, HERRINGTON & SUTCLIFFE LLP
777 South Figueroa Street, Suite 3200
7 Los Angeles, CA 90017-5855
Telephone: -1-1-213-629-2020
8 Facsimile: -f 1-213-612-2499
9 Attomeys for Defendant
HEALTH NET OF CALIFORNIA, INC.
10
11 SUPERIOR COURT OF THE STATE OF CALIFORNIA
12 COUNTY OF SACRAMENTO
13
ANDREA SPEARS, an individual, on behalf Consolidated Case No. 34-2017-00210560-
14 of herself and on behalf of all persons similarly CU-OE-GDS
situated,
15 Plaintiff, PROOF OF SERVICE
16 Date: April 16,2018
Time: 9:00 a.m.
17 HEALTH NET OF CALIFORNIA, INC., a Judge: Hon. Christopher E. Krueger
California Corporation; and Does 1 through 50, Dept.: 54
18 inclusive,
19 Defendants.
20 TOMAS R. ARANA, on behalf of himself, all Complaint Filed: April 5,2017
others similarly situated, FAC Filed: June 29,2017
0) 21 Consolidated Complaint Filed: Dec. 21, 2017
22 Plaintiff,
Complaint Filed: August 1, 2017
<
z 23
24 HEALTH OF CALIFORNIA, INC., a
Califomia corporation; and DOES 1-50,
25 inclusive,
0 26 Defendant.
27
28
PROOF OF SERVICE
1 PROOF OF SERVICE
2
3 I am more than eighteen years old and not a party to this action. My business address is
4 Orrick, Herrington & Sutcliffe LLP, 400 Capitol Mall, Suite 3000, Sacramento, Califomia
5 95814.
6 On April 3, 2018,1 served the following document(s):
7 DEFENDANT'S MEMORANDUM IN OPPOSITION T O
PLAINTIFF'S MOTION TO C O M P E L F U R T H E R
8 RESPONSES TO DOCUMENT R E Q U E S T S ; R E Q U E S T FOR
SANCTIONS;
y
DEFENDANT'S RESPONSE S E P A R A T E STATEMENT IN
10 SUPPORT OF ITS OPPOSITION TO PLAINTIFF'S MOTION
T O C O M P E L R E Q U E S T FOR PRODUCTION; R E Q U E S T
11 FOR SANCTIONS;
12 D E C L A R A T I O N OF STEPHANIE G A I L L E E IN SUPPORT
O F DEFENDANT'S OPPOSITIONS TO PLAINTIFF'S
13 MOTIONS TO C O M P E L F U R T H E R RESPONSES T O H E R
S P E C I A L I N T E R R O G A T O R I E S AND R E Q U E S T S F O R
14 PRODUCTION; S E T ONE
15 D E C L A R A T I O N OF T I M O T H Y J . LONG IN SUPPORT O F
DEFENDANT'S OPPOSITIONS TO PLAINTIFF'S MOTIONS
16 T O C O M P E L F U R T H E R RESPONSES TO DOCUMENT
R E Q U E S T S AND S P E C I A L I N T E R R O G A T O R I E S ;
17 R E Q U E S T FOR SANCTIONS.
18
I I (BY MAIL) By placing a tme copy of the foregoing document(s) in a sealed
19
envelope addressed as set forth below. I placed each such envelope for collection and mailing
20
following ordinary business practices. I am readily familiar with this Firm's practice for
21
collection and processing of correspondence for mailing. Under that practice, the correspondence
22
would be deposited with the United States Postal Service on that same day, with postage thereon
23
fiilly prepaid at Sacramento, Califomia, in the ordinary course ofbusiness, on the interested
24
parties in this action by placing tme and correct copies thereof in sealed envelope(s) addressed as
25
follows:
26
27
28
PROOF OF SERVICE
1 Norman B. Blumenthal Attorneys for Plaintiff Andrea Spears
Kyle R. Nordrehaug
2 Aparajit Bhowmik Telephone: (858) 551-1223
3 Piya Mukherjee Facsimile: (858) 551-1232
Victoria B. Rivapalacio
4 BLUMENTHAL, NORDREHAUG «&
BHOMIK
5 2255 Calle Clara
La Jolla, CA 92037
6
y Shaun Setareh Attomeys for Plaintiff Tomas R. Arana
H. Scott Leviant
8 SETAREH LAW GROUP Telephone: (310) 888-7771
9454 Wilshire Boulevard, Suite 907 Facsimile: (310) 888-0109
9 Beverly Hills, CA 90212
10
• (BY EMAIL AS A MATTER OF COURTESY) By transmitting a tme pdf copy
11
of the foregoing document(s) by e-mail transmission from pheath@orrick.com to the interested
12
parties only as indicated on the below service list at the e-mail addresses set forth on said service
13
list. Said transmission(s) were completed on the aforesaid date at the time stated on declarant's e-
14
mail.transmission record. Each such transmission was reported as complete and without error.
15
• (BY ELECTRONIC FILING VIA CASE MANAGEMENT/ELECTRONIC
16
CASE FILING: By transmitting via e-filing through the Case Management/Electronic Case
17
Filing ("CM/ECF") system, to be sent electronically and simultaneously to the registered
18
participants as identified on the Notice of Electronic Filing ("NEF"), including the following:
19
13 (BY OVERNIGHT DELIVERY) I deposited in a box or other facility regularly
20
maintained by UPS, a tme copy ofthe foregoing document(s) in a sealed envelope or package
21
designated by UPS, addressed as set forth on the attached mailing list, with fees for ovemight
22
delivery paid or provided for:
23
24
25
26
27
28
PROOF OF SERVICE
1 Norman B. Blumenthal Attomeys for Plaintiff Andrea Spears
Kyle R. Nordrehaug
2 Aparaj it Bhowmik Telephone: (858) 551-1223
3 Piya Mukherjee Facsimile: (858) 551-1232
Victoria B. Rivapalacio
4 BLUMENTHAL, NORDREHAUG &
BHOMIK
5 2255 Calle Clara
La Jolla, CA 92037
6
y Shaun Setareh Attomeys for Plaintiff Tomas R. Arana
H. Scott Leviant
8 SETAREH LAW GROUP Telephone: (310) 888-7771
9454 Wilshire Boulevard, Suite 907 Facsimile: (310) 888-0109
9 Beverly Hills, CA 90212
10
11 O (BY FACSIMILE) By transmitting a tme copy of the foregoing document(s) via
12 facsimile transmission from this Firm's sending facsimile machine, whose telephone number is
13 (916) 329-4900, to each interested party at the facsimile machine telephone number(s) set forth
14 on the attached mailing list. Said transmission(s) were completed on the aforesaid date at the time
15 stated on the transmission record issued by this Firm's sending facsimile machine. Each such
16 transmission was reported as complete and without error and a transmission report was properly
17 issued by this Firm's sending facsimile machine for each interested party served. A tme copy of
18 each transmission report is attached to the office copy of this proof of service and will be
19 provided upon request.
20 I declare under penalty of perjury under the laws of the State of Califomia that the above
21 is tme and correct.
22
23 Executed on April 3, 2018, at Sacramento, California.
24
25
Patricia M. Heath
26
27
28
PROOF OF SERVICE
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1 TIMOTHY J. LONG (STATE BAR NO. 137591) FILED tjlong@orrick.com ' ENDORSED 2 ORRICK, HERRINGTON & SUTCLIFFE LLP 2018 APR-3 PM 2=09 400 Capitol Mall, Suite 3000 3 Sacramento, CA 95814-4497 SUPERIGR COURT 'O' CAllFGR'JIliH Telephone: -fl 916 447 9200 CSUviTY Of SACRAHLKVO 4 Facsimile: -)-l 916 329 4900 5 STEPHANIE GAIL LEE (STATE BAR NO. 285379) stephanie.lee@orrick.com 6 ORRICK, HERRINGTON & SUTCLIFFE LLP 777 South Figueroa Street, Suite 3200 7 Los Angeles, CA 90017-5855 Telephone: -1-1-213-629-2020 8 Facsimile: -f 1-213-612-2499 9 Attomeys for Defendant HEALTH NET OF CALIFORNIA, INC. 10 11 SUPERIOR COURT OF THE STATE OF CALIFORNIA 12 COUNTY OF SACRAMENTO 13 ANDREA SPEARS, an individual, on behalf Consolidated Case No. 34-2017-00210560- 14 of herself and on behalf of all persons similarly CU-OE-GDS situated, 15 Plaintiff, PROOF OF SERVICE 16 Date: April 16,2018 Time: 9:00 a.m. 17 HEALTH NET OF CALIFORNIA, INC., a Judge: Hon. Christopher E. Krueger California Corporation; and Does 1 through 50, Dept.: 54 18 inclusive, 19 Defendants. 20 TOMAS R. ARANA, on behalf of himself, all Complaint Filed: April 5,2017 others similarly situated, FAC Filed: June 29,2017 0) 21 Consolidated Complaint Filed: Dec. 21, 2017 22 Plaintiff, Complaint Filed: August 1, 2017 < z 23 24 HEALTH OF CALIFORNIA, INC., a Califomia corporation; and DOES 1-50, 25 inclusive, 0 26 Defendant. 27 28 PROOF OF SERVICE 1 PROOF OF SERVICE 2 3 I am more than eighteen years old and not a party to this action. My business address is 4 Orrick, Herrington & Sutcliffe LLP, 400 Capitol Mall, Suite 3000, Sacramento, Califomia 5 95814. 6 On April 3, 2018,1 served the following document(s): 7 DEFENDANT'S MEMORANDUM IN OPPOSITION T O PLAINTIFF'S MOTION TO C O M P E L F U R T H E R 8 RESPONSES TO DOCUMENT R E Q U E S T S ; R E Q U E S T FOR SANCTIONS; y DEFENDANT'S RESPONSE S E P A R A T E STATEMENT IN 10 SUPPORT OF ITS OPPOSITION TO PLAINTIFF'S MOTION T O C O M P E L R E Q U E S T FOR PRODUCTION; R E Q U E S T 11 FOR SANCTIONS; 12 D E C L A R A T I O N OF STEPHANIE G A I L L E E IN SUPPORT O F DEFENDANT'S OPPOSITIONS TO PLAINTIFF'S 13 MOTIONS TO C O M P E L F U R T H E R RESPONSES T O H E R S P E C I A L I N T E R R O G A T O R I E S AND R E Q U E S T S F O R 14 PRODUCTION; S E T ONE 15 D E C L A R A T I O N OF T I M O T H Y J . LONG IN SUPPORT O F DEFENDANT'S OPPOSITIONS TO PLAINTIFF'S MOTIONS 16 T O C O M P E L F U R T H E R RESPONSES TO DOCUMENT R E Q U E S T S AND S P E C I A L I N T E R R O G A T O R I E S ; 17 R E Q U E S T FOR SANCTIONS. 18 I I (BY MAIL) By placing a tme copy of the foregoing document(s) in a sealed 19 envelope addressed as set forth below. I placed each such envelope for collection and mailing 20 following ordinary business practices. I am readily familiar with this Firm's practice for 21 collection and processing of correspondence for mailing. Under that practice, the correspondence 22 would be deposited with the United States Postal Service on that same day, with postage thereon 23 fiilly prepaid at Sacramento, Califomia, in the ordinary course ofbusiness, on the interested 24 parties in this action by placing tme and correct copies thereof in sealed envelope(s) addressed as 25 follows: 26 27 28 PROOF OF SERVICE 1 Norman B. Blumenthal Attorneys for Plaintiff Andrea Spears Kyle R. Nordrehaug 2 Aparajit Bhowmik Telephone: (858) 551-1223 3 Piya Mukherjee Facsimile: (858) 551-1232 Victoria B. Rivapalacio 4 BLUMENTHAL, NORDREHAUG «& BHOMIK 5 2255 Calle Clara La Jolla, CA 92037 6 y Shaun Setareh Attomeys for Plaintiff Tomas R. Arana H. Scott Leviant 8 SETAREH LAW GROUP Telephone: (310) 888-7771 9454 Wilshire Boulevard, Suite 907 Facsimile: (310) 888-0109 9 Beverly Hills, CA 90212 10 • (BY EMAIL AS A MATTER OF COURTESY) By transmitting a tme pdf copy 11 of the foregoing document(s) by e-mail transmission from pheath@orrick.com to the interested 12 parties only as indicated on the below service list at the e-mail addresses set forth on said service 13 list. Said transmission(s) were completed on the aforesaid date at the time stated on declarant's e- 14 mail.transmission record. Each such transmission was reported as complete and without error. 15 • (BY ELECTRONIC FILING VIA CASE MANAGEMENT/ELECTRONIC 16 CASE FILING: By transmitting via e-filing through the Case Management/Electronic Case 17 Filing ("CM/ECF") system, to be sent electronically and simultaneously to the registered 18 participants as identified on the Notice of Electronic Filing ("NEF"), including the following: 19 13 (BY OVERNIGHT DELIVERY) I deposited in a box or other facility regularly 20 maintained by UPS, a tme copy ofthe foregoing document(s) in a sealed envelope or package 21 designated by UPS, addressed as set forth on the attached mailing list, with fees for ovemight 22 delivery paid or provided for: 23 24 25 26 27 28 PROOF OF SERVICE 1 Norman B. Blumenthal Attomeys for Plaintiff Andrea Spears Kyle R. Nordrehaug 2 Aparaj it Bhowmik Telephone: (858) 551-1223 3 Piya Mukherjee Facsimile: (858) 551-1232 Victoria B. Rivapalacio 4 BLUMENTHAL, NORDREHAUG & BHOMIK 5 2255 Calle Clara La Jolla, CA 92037 6 y Shaun Setareh Attomeys for Plaintiff Tomas R. Arana H. Scott Leviant 8 SETAREH LAW GROUP Telephone: (310) 888-7771 9454 Wilshire Boulevard, Suite 907 Facsimile: (310) 888-0109 9 Beverly Hills, CA 90212 10 11 O (BY FACSIMILE) By transmitting a tme copy of the foregoing document(s) via 12 facsimile transmission from this Firm's sending facsimile machine, whose telephone number is 13 (916) 329-4900, to each interested party at the facsimile machine telephone number(s) set forth 14 on the attached mailing list. Said transmission(s) were completed on the aforesaid date at the time 15 stated on the transmission record issued by this Firm's sending facsimile machine. Each such 16 transmission was reported as complete and without error and a transmission report was properly 17 issued by this Firm's sending facsimile machine for each interested party served. A tme copy of 18 each transmission report is attached to the office copy of this proof of service and will be 19 provided upon request. 20 I declare under penalty of perjury under the laws of the State of Califomia that the above 21 is tme and correct. 22 23 Executed on April 3, 2018, at Sacramento, California. 24 25 Patricia M. Heath 26 27 28 PROOF OF SERVICE