Preview
Michele Ballard Miller (SBN 104198) F LE
mbmiller@cozen. com
I
SUPERIOR COURT op c D
Ethan w. Chemin (SBN) 273906 COSXNNEYEQ;WBER
”033'“
ARD'NO D'STR'CT
echernin@cozen. com
COZEN O'CONNOR
401 Wilshire Boulevard, suite 850 JUL 2 6 2023
Santa Monica, California 90401
Telephgne: 310.393.4000
FaCSImlle. 3 10.394.4700 By;
gio Wu” a. Depmy
Attorneys for Defendants
KAISER FOUNDATION HOSPITALS, KAISER
FOUNDATION HEALTH PLAN, INC.,
SOUTHERN CALIFORNIA PERMANENTE
\OOONQ MEDICAL GROUP, and TAWNA BRUUN
SUPERIOR COURT OF THE STATE OF CALIFORNIA
10
11
COUNTY OF SAN BERNARDINO
12
90401
ESPERANZA PEREZ, Case No.: CIVDSl920836
CONNOR
BOULEVARD
13
CA
850
0’ SUITE
MONICA.
Plaintiff, [Assigned t0 the Hon. Hon. Thomas S Garza,
WILSHIRE
14 Dept. $28]
COZEN
SANTA
401 vs.
15 PROOF OF SERVICE
KAISER FOUNDATION HOSPITALS, a
16 California Corporation; KAISER Action Filed: March 20, 2019
FOUNDATION HEALTH PLAN, INC., a Trial Date: September 11, 2023
17 California Corporation; and SOUTHERN
CALIFORNIA PERMANENTE MEDICAL
18 GROUP, INC., a California Corporation;
flN/AN
TAWNA BRUUN, an Individual; and DOES 1
19 through 50, Inclusive, ,
20 Defendants.
OR“
21
22
PROOF OF SERVICE
23
At the time of service, I was over 18 years of age and not a party to this action. I am
24 employed in the County of San Diego, State of California. My business address is 501 West
Broadway, Suite 1610, San Diego, CA 92101; sbutterworth@cozen.com
25
On July 25, 2023, I served true copies of the following document(s) described as:
26
1. DEFENDANT KAISER FOUNDATION HOSPITALS’S NOTICE OF MOTION
27
AND MOTION TO COMPEL RESPONSES, WITHOUT OBJECTIONS, TO
28 REQUESTS FOR PRODUCTION OF DOCUMENTS, SET NO. 2; REQUEST
I
PROOF OF SERVICE
FOR MONETARY SANCTIONS AGAINST PLAINTIFF AND HER COUNSEL
IN THE SUM OF $1,508.20
. DEFENDANT KAISER FOUNDATION HOSPITALS’S MEMORANDUM OF
POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO COMPEL
UI-PUJN
RESPONSES, WITHOUT OBJECTIONS, TO REQUESTS FOR PRODUCTION
OF DOCUMENTS, SET NO. 2; REQUEST FOR MONETARY SANCTIONS
AGAINST PLAINTIFF AND HER COUNSEL IN THE SUM OF $1,508.20
. DECLARATION OF ETHAN CHERNIN IN SUPPORT OF DEFENDANT
KAISER FOUNDATION HOSPITALS’S MOTION TO COMPEL RESPONSES,
WITHOUT OBJECTIONS, TO REQUESTS FOR PRODUCTION OF
OWNQ
DOCUMENTS, SET NO. 2; REQUEST FOR MONETARY SANCTIONS
AGAINST PLAINTIFF AND HER COUNSEL IN THE SUM OF $1,508.20
[PROPOSED] ORDER GRANTING DEFENDANT KAISER FOUNDATION
10 HOSPITALS’S MOTION TO COMPEL PLAINTIFF’S RESPONSES,
WITHOUT OBJECTIONS, TO REQUESTS FOR PRODUCTION OF
11 DOCUMENTS, SET NO. 2; REQUEST FOR MONETARY SANCTIONS
AGAINST PLAINTIFF AND HER COUNSEL IN THE SUM OF $1,508.20
12
90401
. DEFENDANT KAISER FOUNDATION HOSPITALS’S NOTICE OF MOTION
13
AND MOTION TO COMPEL RESPONSES, WITHOUT OBJECTIONS, TO
CONNOR
BOULEVARD
CA
850
O'
WILSHIRE
SUITE
MONICA.
14
SPECIAL INTERROGATORIES, SET NO. 1; REQUEST FOR MONETARY
COZEN
401
SANTA
SANCTIONS AGAINST PLAINTIFF AND HER COUNSEL IN THE SUM OF
15 $1,508.20
16 . DEFENDANT KAISER FOUNDATION HOSPITALS’S MEMORANDUM OF
POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO COMPEL
17
RESPONSES, WITHOUT OBJECTIONS, TO SPECIAL INTERROGATORIES,
18
SET NO. l; REQUEST FOR MONETARY SANCTIONS AGAINST PLAINTIFF
AND HER COUNSEL IN THE SUM OF $1,508.20
19
. DECLARATION OF ETHAN CHERNIN IN SUPPORT OF DEFENDANT
20 KAISER FOUNDATION HOSPITALS’S MOTION TO COMPEL RESPONSES,
WITHOUT OBJECTIONS, TO SPECIAL INTERROGATORIES, SET NO. 1;
21 REQUEST FOR MONETARY SANCTIONS AGAINST PLAINTIFF AND HER
COUNSEL IN THE SUM OF $1,508.20
22
23
[PROPOSED] ORDER GRANTING DEFENDANT KAISER FOUNDATION
HOSPITALS’S MOTION TO COMPEL PLAINTIFF’S RESPONSES,
24 WITHOUT OBJECTIONS, TO SPECIAL INTERROGATORIES, SET NO. l;
REQUEST FOR MONETARY SANCTIONS AGAINST PLAINTIFF AND HER
25 COUNSEL IN THE SUM OF $1,508.20
26 . DEFENDANT KAISER FOUNDATION HOSPITALS’S NOTICE OF MOTION
27
AND MOTION TO COMPEL PRODUCTION OF PLAINTIFF’S MEDICAL
RECORDS; REQUEST FOR MONETARY SANCTIONS AGAINST
28 PLAINTIFF AND HER COUNSEL IN THE SUM OF $3,739.60
2
PROOF OF SERVICE
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Michele Ballard Miller (SBN 104198) F LE mbmiller@cozen. com I SUPERIOR COURT op c D Ethan w. Chemin (SBN) 273906 COSXNNEYEQ;WBER ”033'“ ARD'NO D'STR'CT echernin@cozen. com COZEN O'CONNOR 401 Wilshire Boulevard, suite 850 JUL 2 6 2023 Santa Monica, California 90401 Telephgne: 310.393.4000 FaCSImlle. 3 10.394.4700 By; gio Wu” a. Depmy Attorneys for Defendants KAISER FOUNDATION HOSPITALS, KAISER FOUNDATION HEALTH PLAN, INC., SOUTHERN CALIFORNIA PERMANENTE \OOONQ MEDICAL GROUP, and TAWNA BRUUN SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 11 COUNTY OF SAN BERNARDINO 12 90401 ESPERANZA PEREZ, Case No.: CIVDSl920836 CONNOR BOULEVARD 13 CA 850 0’ SUITE MONICA. Plaintiff, [Assigned t0 the Hon. Hon. Thomas S Garza, WILSHIRE 14 Dept. $28] COZEN SANTA 401 vs. 15 PROOF OF SERVICE KAISER FOUNDATION HOSPITALS, a 16 California Corporation; KAISER Action Filed: March 20, 2019 FOUNDATION HEALTH PLAN, INC., a Trial Date: September 11, 2023 17 California Corporation; and SOUTHERN CALIFORNIA PERMANENTE MEDICAL 18 GROUP, INC., a California Corporation; flN/AN TAWNA BRUUN, an Individual; and DOES 1 19 through 50, Inclusive, , 20 Defendants. OR“ 21 22 PROOF OF SERVICE 23 At the time of service, I was over 18 years of age and not a party to this action. I am 24 employed in the County of San Diego, State of California. My business address is 501 West Broadway, Suite 1610, San Diego, CA 92101; sbutterworth@cozen.com 25 On July 25, 2023, I served true copies of the following document(s) described as: 26 1. DEFENDANT KAISER FOUNDATION HOSPITALS’S NOTICE OF MOTION 27 AND MOTION TO COMPEL RESPONSES, WITHOUT OBJECTIONS, TO 28 REQUESTS FOR PRODUCTION OF DOCUMENTS, SET NO. 2; REQUEST I PROOF OF SERVICE FOR MONETARY SANCTIONS AGAINST PLAINTIFF AND HER COUNSEL IN THE SUM OF $1,508.20 . DEFENDANT KAISER FOUNDATION HOSPITALS’S MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO COMPEL UI-PUJN RESPONSES, WITHOUT OBJECTIONS, TO REQUESTS FOR PRODUCTION OF DOCUMENTS, SET NO. 2; REQUEST FOR MONETARY SANCTIONS AGAINST PLAINTIFF AND HER COUNSEL IN THE SUM OF $1,508.20 . DECLARATION OF ETHAN CHERNIN IN SUPPORT OF DEFENDANT KAISER FOUNDATION HOSPITALS’S MOTION TO COMPEL RESPONSES, WITHOUT OBJECTIONS, TO REQUESTS FOR PRODUCTION OF OWNQ DOCUMENTS, SET NO. 2; REQUEST FOR MONETARY SANCTIONS AGAINST PLAINTIFF AND HER COUNSEL IN THE SUM OF $1,508.20 [PROPOSED] ORDER GRANTING DEFENDANT KAISER FOUNDATION 10 HOSPITALS’S MOTION TO COMPEL PLAINTIFF’S RESPONSES, WITHOUT OBJECTIONS, TO REQUESTS FOR PRODUCTION OF 11 DOCUMENTS, SET NO. 2; REQUEST FOR MONETARY SANCTIONS AGAINST PLAINTIFF AND HER COUNSEL IN THE SUM OF $1,508.20 12 90401 . DEFENDANT KAISER FOUNDATION HOSPITALS’S NOTICE OF MOTION 13 AND MOTION TO COMPEL RESPONSES, WITHOUT OBJECTIONS, TO CONNOR BOULEVARD CA 850 O' WILSHIRE SUITE MONICA. 14 SPECIAL INTERROGATORIES, SET NO. 1; REQUEST FOR MONETARY COZEN 401 SANTA SANCTIONS AGAINST PLAINTIFF AND HER COUNSEL IN THE SUM OF 15 $1,508.20 16 . DEFENDANT KAISER FOUNDATION HOSPITALS’S MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF MOTION TO COMPEL 17 RESPONSES, WITHOUT OBJECTIONS, TO SPECIAL INTERROGATORIES, 18 SET NO. l; REQUEST FOR MONETARY SANCTIONS AGAINST PLAINTIFF AND HER COUNSEL IN THE SUM OF $1,508.20 19 . DECLARATION OF ETHAN CHERNIN IN SUPPORT OF DEFENDANT 20 KAISER FOUNDATION HOSPITALS’S MOTION TO COMPEL RESPONSES, WITHOUT OBJECTIONS, TO SPECIAL INTERROGATORIES, SET NO. 1; 21 REQUEST FOR MONETARY SANCTIONS AGAINST PLAINTIFF AND HER COUNSEL IN THE SUM OF $1,508.20 22 23 [PROPOSED] ORDER GRANTING DEFENDANT KAISER FOUNDATION HOSPITALS’S MOTION TO COMPEL PLAINTIFF’S RESPONSES, 24 WITHOUT OBJECTIONS, TO SPECIAL INTERROGATORIES, SET NO. l; REQUEST FOR MONETARY SANCTIONS AGAINST PLAINTIFF AND HER 25 COUNSEL IN THE SUM OF $1,508.20 26 . DEFENDANT KAISER FOUNDATION HOSPITALS’S NOTICE OF MOTION 27 AND MOTION TO COMPEL PRODUCTION OF PLAINTIFF’S MEDICAL RECORDS; REQUEST FOR MONETARY SANCTIONS AGAINST 28 PLAINTIFF AND HER COUNSEL IN THE SUM OF $3,739.60 2 PROOF OF SERVICE