On April 27, 2022 a
Conference
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.
Preview
NAME AND ADDRESS OF ATTORNEY OR PARTY WITHOUT ATTORNEY:
Scott B. McFaIl, Esq.) Haig Arabian Esq.
AGAJANIAN, McFALL, WEISS, TETREAULT & CRIST LLP
346 North Larchmont Blvd. Los Angeles, California
-
323 993-0198
E—Enh/EIFLH/ggRNEgéf hai;@agajanianlaw.com
ATTORNEY FOR (Name);Defs. HDMC & DRMC
FAX No. (Optional): (323)993-9509
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO
COURTHOUSEADDRESS: 247 W. Third
90004
Street,
TRIAL SETTING
UNLIMITED CASE:
UMlTED CASE;
San Bernardino, CA 92415
CONFERENCE DATE:
D
E
DEPT;
80396
sss
M
STATE BAR NUMBER
I 289861
Reserved
10/27/2023 4:32
for Clerk's File Stamp
ELECTRONICALLY FILED (AUtC
SUPERIOR COURT OF CALIFC RN IA
COU NTY OF SAN BERNARDIN 0
PM
V
PLAINTIFF: Louis Salas et al.
DEFENDANT: HDMC Holdings LLC et al.
CASE NUMBER:
INITIAL TRIAL SETTING CONFERENCE STATEMENT CIvs32215198
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. EThis statement is submitted by party (name); HDMC Holdings, L.L.C. dba Hi-Desert Medical Center D/P SNF; HDMC Holdings, L.L.C. dba Hi-
Defendants,
Desert Medical Center, Hi-Desert Continuing Care Center, and Desert Regional Medical Center, Inc. (DOE 1)
b. DThis statement is submitted jointly by parties (names):
2. Service of Complaint on all parties has been completed.
D has not been completed.
3. Service of Cross-Complaint on all parties D has been completed.
D has not been completed.
4. Description of case in Complaint: Louis Salas, by and through his Successor—in—lnterest, Elena Salas, and Elena Salas, individually, allege Decedent developed a
Plaintiffs,
pressure injury while under the care of Defendants, which caused him pain/suffering and his death on February 2, 2021. Plaintiffs assert causes
of action for Dependent Adult Abuse (Survival). Violation of Patient Rights (Survival). Negligence (Survival) and Wrongful Death.
5. Description of case in Cross—Complaint:
6. Has all discovery been completed: Yes D No Date discovery anticipated to be completed: Apr" 2024/ Per COde
7. Do you agree to mediation? Yes No D Please check type agreed to: Private: X Court—sponsored:
8. Related cases, consolidation, and coordination
a. D There are companion, underlying, or related cases.
(1) Name of case:
(2) Name of court
(3) Case number:
(4) Status:
b. D Amotionto D consolidate D coordinate will be filed by (name ofparty):
9. E Trial dates requested: Yes D No E Available dates: Time estimate: 15-20 days JTE COURTD
10. Other issues:
D The following additional matters are requested to be considered by the Court:
11. Meet and Confer:
The parties represent that they have met and conferred on all subjects required by California Rules of Court, Rule 3.724.
D The parties have entered into the following slipulation(s):
12. Total number of pages attached (if any): 0
| am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, as well as other issues raised by
this statement, and will possess the authority to enter into stipulations on these issues at the time of the Initial Trial Setting Conference, including the written authority
ofthe party where required.
I
Date: 10/27/2023
Haig Arabian Esq.
(TYPE 0R PRINT NAME) (SIGWUFtfi 0F PARTY 0R ATTORNEY
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY
Form # 13—09001—360
Rev. 11-2021 Mandatory
INITIAL TRIAL SETTING CONFERENCE STATEMENT
PROOF OF SERVICE
Louis Salas vs. Hi-Desert Medical Center
Case N0. CIVSB2215198
STATE OF CALIFORNIA )
) ss.
COUNTY OF LOS ANGELES )
I am employed in the County aforesaid; I am over the age 0f eighteen years and not a party to the
within action; my business address is 346 N. Larchmont B1Vd., Los Angeles, California 90004.
On October 27, 2023, I caused the service 0f the within INITIAL TRIAL SETTING
CONFERENCE STATEMENT on the interested parties in said action, by electronic service,
addressed as follows:
Steven C. Peck
Adam J. Peck
Peck Law Group APC
10 6454 Van Nuys Boulevard, Suite 150
Van Nuys, California 9 140 1 - 1 407
11 Tel: 818-908-0509
Fax: 818—643-4980
12 Email: eservice@thepecklawgroup.com;
stevenpeck@thepecklawgroup.com;
13 adampeck@thepecklawgroup.com
Attorneys for Plaintiff
14 Louis Salas
15
[] (BY U.S. MAIL) I enclosed the foregoing document(s) in a sealed envelope or package
16 addressed to the persons at the addresses listed on the attached service list and placed the
envelope 0r package for collection and mailing, following our ordinary business practices. I am
17 readily familiar With the firm's practice for collection and processing correspondence for mailing.
Under that practice, on the same day that correspondence is placed for collection and mailing, it
18 isdeposited in the ordinary course of business with the U.S. Postal Service, in a sealed envelope
of package With the postage fully prepaid.
19
[X] BY ELECTRONIC TRANSMISSION: I caused a copy 0f the document(s) above t0 be sent
20 from the e-mail address: gary@agajanianlaw.com to the persons at the e-mail addresses listed
above pursuant to California Rules of Court, Rule 2.251 (Proof of Electronic Service) and Code
21 of Civil Procedure §1010.6. No message 0r other indication that the transmission was
unsuccessful was received within a reasonable time following transmission
22
[X] (State) I declare under penalty 0f perjury under the laws of the State 0f California that the above
23 istrue and correct.
24 Executed 0n October 27, 2023, at Los Angeles, California.
25
26
Gary :gster
27
28
PR 00F OF RFRVIC‘F
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NAME AND ADDRESS OF ATTORNEY OR PARTY WITHOUT ATTORNEY: Scott B. McFaIl, Esq.) Haig Arabian Esq. AGAJANIAN, McFALL, WEISS, TETREAULT & CRIST LLP 346 North Larchmont Blvd. Los Angeles, California - 323 993-0198 E—Enh/EIFLH/ggRNEgéf hai;@agajanianlaw.com ATTORNEY FOR (Name);Defs. HDMC & DRMC FAX No. (Optional): (323)993-9509 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO COURTHOUSEADDRESS: 247 W. Third 90004 Street, TRIAL SETTING UNLIMITED CASE: UMlTED CASE; San Bernardino, CA 92415 CONFERENCE DATE: D E DEPT; 80396 sss M STATE BAR NUMBER I 289861 Reserved 10/27/2023 4:32 for Clerk's File Stamp ELECTRONICALLY FILED (AUtC SUPERIOR COURT OF CALIFC RN IA COU NTY OF SAN BERNARDIN 0 PM V PLAINTIFF: Louis Salas et al. DEFENDANT: HDMC Holdings LLC et al. CASE NUMBER: INITIAL TRIAL SETTING CONFERENCE STATEMENT CIvs32215198 INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. EThis statement is submitted by party (name); HDMC Holdings, L.L.C. dba Hi-Desert Medical Center D/P SNF; HDMC Holdings, L.L.C. dba Hi- Defendants, Desert Medical Center, Hi-Desert Continuing Care Center, and Desert Regional Medical Center, Inc. (DOE 1) b. DThis statement is submitted jointly by parties (names): 2. Service of Complaint on all parties has been completed. D has not been completed. 3. Service of Cross-Complaint on all parties D has been completed. D has not been completed. 4. Description of case in Complaint: Louis Salas, by and through his Successor—in—lnterest, Elena Salas, and Elena Salas, individually, allege Decedent developed a Plaintiffs, pressure injury while under the care of Defendants, which caused him pain/suffering and his death on February 2, 2021. Plaintiffs assert causes of action for Dependent Adult Abuse (Survival). Violation of Patient Rights (Survival). Negligence (Survival) and Wrongful Death. 5. Description of case in Cross—Complaint: 6. Has all discovery been completed: Yes D No Date discovery anticipated to be completed: Apr" 2024/ Per COde 7. Do you agree to mediation? Yes No D Please check type agreed to: Private: X Court—sponsored: 8. Related cases, consolidation, and coordination a. D There are companion, underlying, or related cases. (1) Name of case: (2) Name of court (3) Case number: (4) Status: b. D Amotionto D consolidate D coordinate will be filed by (name ofparty): 9. E Trial dates requested: Yes D No E Available dates: Time estimate: 15-20 days JTE COURTD 10. Other issues: D The following additional matters are requested to be considered by the Court: 11. Meet and Confer: The parties represent that they have met and conferred on all subjects required by California Rules of Court, Rule 3.724. D The parties have entered into the following slipulation(s): 12. Total number of pages attached (if any): 0 | am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution, as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time of the Initial Trial Setting Conference, including the written authority ofthe party where required. I Date: 10/27/2023 Haig Arabian Esq. (TYPE 0R PRINT NAME) (SIGWUFtfi 0F PARTY 0R ATTORNEY (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY Form # 13—09001—360 Rev. 11-2021 Mandatory INITIAL TRIAL SETTING CONFERENCE STATEMENT PROOF OF SERVICE Louis Salas vs. Hi-Desert Medical Center Case N0. CIVSB2215198 STATE OF CALIFORNIA ) ) ss. COUNTY OF LOS ANGELES ) I am employed in the County aforesaid; I am over the age 0f eighteen years and not a party to the within action; my business address is 346 N. Larchmont B1Vd., Los Angeles, California 90004. On October 27, 2023, I caused the service 0f the within INITIAL TRIAL SETTING CONFERENCE STATEMENT on the interested parties in said action, by electronic service, addressed as follows: Steven C. Peck Adam J. Peck Peck Law Group APC 10 6454 Van Nuys Boulevard, Suite 150 Van Nuys, California 9 140 1 - 1 407 11 Tel: 818-908-0509 Fax: 818—643-4980 12 Email: eservice@thepecklawgroup.com; stevenpeck@thepecklawgroup.com; 13 adampeck@thepecklawgroup.com Attorneys for Plaintiff 14 Louis Salas 15 [] (BY U.S. MAIL) I enclosed the foregoing document(s) in a sealed envelope or package 16 addressed to the persons at the addresses listed on the attached service list and placed the envelope 0r package for collection and mailing, following our ordinary business practices. I am 17 readily familiar With the firm's practice for collection and processing correspondence for mailing. Under that practice, on the same day that correspondence is placed for collection and mailing, it 18 isdeposited in the ordinary course of business with the U.S. Postal Service, in a sealed envelope of package With the postage fully prepaid. 19 [X] BY ELECTRONIC TRANSMISSION: I caused a copy 0f the document(s) above t0 be sent 20 from the e-mail address: gary@agajanianlaw.com to the persons at the e-mail addresses listed above pursuant to California Rules of Court, Rule 2.251 (Proof of Electronic Service) and Code 21 of Civil Procedure §1010.6. No message 0r other indication that the transmission was unsuccessful was received within a reasonable time following transmission 22 [X] (State) I declare under penalty 0f perjury under the laws of the State 0f California that the above 23 istrue and correct. 24 Executed 0n October 27, 2023, at Los Angeles, California. 25 26 Gary :gster 27 28 PR 00F OF RFRVIC‘F