Motion,Ex Parte: Andrea Spears vs. Health Net of California Inc

• 
• 
• 
• 

						
                                
Preview
                                FILEO
 I BLUIMENTHAL, NORDREHAUG i& BHOWMIK             ENDORSED
    Norman B. Blumenthai (State Bar #068687)
 2  Kyle R. Nordrehaug (State Bar #205975)   2017DEC-f, 4H2:23
     Aparaiit Bhowmik (State Bar #248066)
 3   Piya Mukherjee (State Bar #274217)                 .SUPERIOR CGUiirCFC^! lfG=r-A
     Victoria B. Rivapalacio (State Bar #275115)
 4 2255 Calle Clara
   La JoUa, CA 92037
 5 Telephone: (858)551-1223
   Facsimile: (858) 551-1232
 6
   Attomeys for Plaintiff
 7
 8
 9
10
                  SUPERIOR COURT OF THE STATE OF CALIFORNIA
,11
                      IN AND FOR THE COUNTY OF SACRAMENTO
12
13
14    ANDREA SPEARS, an individual, on         CaseNo. 34-20I7-002I0560-CU-OE-GDS
      behalf of herself ana on behalf of all
15    persons similarly situated,              CLASS ACTION

16                Plaintiff,                   PLAINTIFF'S AMENDED NOTICE OF
17                                             MOTION AND MOTION TO COMPEL
      vs.                                      FURTHER RESPONSES TO REQUESTS
18                                             FOR PRODUCTION OF DOCUMENTS
      HEALTH NET OF CALIFORNIA,
19    INC., a California Corporation; and      Telephone Appearance
      Does 1 through 50, Inclusive,
20                                             Hearing Date:   January 4, 2018
                  Defendants.                  Hearing Time:   9:00 a.m.
21                                             Judge: Raymond M. Cadei
                                               Dept.: 54
22
                                               Action Filed:       April 5, 2017
23
24
25
26
27
28
                  AMENDED NOTICE MOTION TO COMPEL FURTHER RESPONSES TO DISCOVERY
                                                                     CASE No. 34-2017-00210560
 1 TO ALL PARTIES AND THEIR RESPECTIVE ATTORNEYS OF RECORD:
2           Please be advised that on January 4, 2018 at 9:00 a.m. in Department 54 ofthe above entitied
3 Court, Plaintiff ANDREA SPEARS ("Plaintiff) will move to compel Defendant HEALTH NET OF
4 CALIFORNIA, INC. ("Defendant") to provide further responses to Plaintiffs Requests for Production
5 of Documents, Set One. This motion will be heard before the Honorable Raymond M. Cadei, Judge of
6 the Superior Court of Califomia, County of Sacramento. This Amended Notice of Motion serves to
7 correct a typographical error in the prior Notice of Motion that listed the date for the hearing for January
 8 4, 2017.
9           This motion will be made pursuant to Code of Civil Procedure Sections 2031.310 on the grounds
10 that the said discovery requests are relevant to the subject matter of this action and that Defendant's
11 objections are improper and without merit. The motion will be based upon this notice of motion and
12 motion, the memorandum of points and authorities, the separate statement, the declaration of Victoria B.
13 Rivapalacio, the lodged exhibits, filed and served herewith, the complete files and records in this case
14 and such oral and documentary evidence as may be presented at or before the hearing of this motion.
15          Pursuant to Local Rule L06(A), the court will make a tentative ruling on the merits of this
16 matter by 2:00 p.m., the court day before the hearing. The complete text ofthe tentative rulings
17 for the department may be downloaded off the court's website. If the party does not have online
18 access, they may call the dedicated phone number for the department as referenced in the local
19 telephone directory between the hours of 2:00 p.m. and 4:00 p.m. on the court day before the
20 hearing and receive the tentative ruling. If you do not call the court and opposing party on the
21 court day before the hearing, no hearing will be held.
22
23 Dated: December 4, 2017                BLUMENTHAL NORDREHAUG & BHOWMIK, LLP
24
25                                                        Victoria B. Rivaf)alacio, Bsq.
                                                          Attomeys for Plaintiff
26
27
28
                     AMENDED NOTICE MOTION TO COMPEL FURTHER RESPONSES TO DISCOVERY
                                                 1                      CASE No. 34-2017-00210560