Party Notice: Andrea Spears vs. Health Net of California Inc

• 
• 
• 
• 
• 
• 
• 
• 

						
                                
Preview
                                1   Timothy J. Long (SBN CA 137591)
     GREENBERG TRAURIG, LLP
 2   1201 K Street, Suite 1100                                     FiLEO/E^DORSiED
     Sacramento, Califomia 95814
 3   Telephone: 916.442.1111
     Facsimile: 916.448.1709                                              SEP - h 2019
 4   longt@gtlaw.com
                                                                   By:      M. Ruhglcaba
                                                                             Depijt>- Clerk
 5   Jonathan S. Sack (SBN CA 271286)
     GREENBERG TRAURIG, LLP
 6   Four Embarcadero Center, Suite 3000
     San Francisco, Califomia 94111
 7   Telephone: 415.655.1300
     Facsimile: 415.707.2010
 8   sackj@gtlaw.com

 9   Attomeys for Defendants HEALTH NET OF CALIFORNIA, INC.
10
11
12                        SUPERIOR COURT OF THE STATE OF CALIFORNIA
13                                     COUNTY OF SACRAMENTO
14
15   ANDREA SPEARS, an individual, on behalf of       CASE NO. 34-2017-00210560-CU-OE-GDS
     herself and on behalf of all persons similarly
16   situated.                                        NOTICE OF CONFORMED ORDER
                                                      GRANTING APPLICATION TO SEAL
17                        Plaintiff,                  EXHIBITS FILED IN SUPPORT OF
                                                      MOTIONS WHY PLAINTIFFS' CASES
18                                                    SHOULD NOT PROCEED AS PAGA
                                                      REPRESENTATIVE ACTIONS
19   HEALTH NET OF CALIFORNIA, m C , a
     Califomia corporation; and DOES 1 through 50, DATE: April 11,2019
20   inclusive,                                    TIME:  10:00 a.m.
                                                   JUDGE: Hon. Alan G. Perkins
21                        Defendants.              DEPT:  35
22                                                    Complaint Filed:     April 5, 2017
                                                      FAC Filed:           June 29, 2017
23
                                                      Complaint Filed:    August!, 2017
24                                                    Consolidated Complaint File: Dec. 21, 2017
25
26
27
28
                                              1             CASE NO. 34-2017-00210560-CU-OE-GDS
               NOTICE OF CONFORMED ORDER GRANTING APPLICATION TO SEAL EXHIBITS FILED
 1   TOMAS R. ARANA, on behalf of himself, all
     others similarly situated,
 2
                        Plaintiff,
 3

 4

 5   HEALTH NET OF CALIFORNIA, INC., a
     Califomia corporation; and DOES 1-50,
 6   inclusive,

 7                      Defendant
 8

 9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28
                                                           CASE NO. 34-2017-00210560-CU-OE-GDS
              NOTICE OF CONFORMED ORDER GRANTING APPLICATION TO SEAL EXHIBITS FILED
 1          PLEASE TAKE NOTICE that upon reviewing the Order Granting Application to Seal Exhibits
 2 Filed in Support of Motions Why Plaintiffs' Cases Should Not Proceed as Paga Representative Actions,
 3 Judge Alan G. Perkins signed the Order on August 30, 2019. A copy of the Order is attached hereto as
 4 Exhibit "A".
 5 DATED: September 4, 2019                      GREENBERG TRAURIG, LLP
 6
 7                                          By
                                                       Timothy J. Long
 8
                                                 Attomeys for Defendants HEALTH NET OF
 9                                               CALIFORNL\, INC.
10
11
12
13
14
15
16
17

IS
19
20
21
22
23
24
25
26
27
28
                                                            CASE NO. 34-2017-00210560-CU-OE-GDS
               NOTICE OF CONFORMED ORDER GRANTING APPLICATION TO SEAL EXHIBITS FILED
EXHIBIT A
  1 TIMOTHY J. LONG (STATE BAR NO. 137591),
       tjlong@orrick.com
 . 2 NICHOLAS J. HORTON (STATE BAR NO. 289417)
      nhorton@orrick.com
  3' ORRICK, HERRINGTON & SUTCLIFFE LLP
     .400 Capitol MaU, Suite 3000                               FILED / pflDORSED
 ,4 Sacramento, CA 95814-4497
      Telephone: +1 916447 8299
  5 Facsimile: +1 916 3294900                                          AUG 3 0 2019
                                                                   •
  6 Attomeys for Defendant '
    HEALTH NET OF CALIFORNIA. INC.                               By a tasMey. Oeputy Clerti.
  7
  8                        SUPERIOR COURT OF THE STATE OF CALIFORNIA
  9                                      COUNTY OF SACRAMENTO
 10 ANDREA SPEARS, an individual, on behalf          Consolidated Case No. 34-2017-00210560-
       of herself and on behalf of all persons ^'    CU-OE-GDS
 n     similariy situated.
                           Plaintiff,                  OaiOPOSEIIl ORDER GRANTING
 12                                               ''^"'^PLICATION TO SEAL EXHIBrrS
                                                       FILED IN SUPPORT OF MOTIONS
 13                                                    WHY PLAINTIFFS' CASES SHOULD
       HEALTH NET OF CALIFORNL\, INC., a               NOT PROCEED AS PAGA
       California Coiporation; and Does 1 through      REPRESENTATIVE ACTIONS
       50, inclusive,    ,
 15                                                    Date: April 11,2019     .
                         Defendants.                   Time: 10:00 a.m.
 16                                                    Dq)t:.35
                                                       Judge: Hon. Alan G. Perkins
 17
                                                     Complaint Filed: April 5,2017
 18                                                  FAC Filed:       June 29,2017

 19 TOMAS R. ARANA, on behalf of himself, all
                                                     Complaint Filed: August 1,2017
 20 others similarly situated,                       Consolidated Complaint Filed: Dec. 21,2017
 21                       Plaintiff,

 22           v.

 23 HEALTH NET OF CALIFORNIA, INC., a
     California cdipoiatipn; and DOES 1-50,
 24. inclusive^
 25                       Defendaiit

 26
 27.
' 28

                                       [PROPOSED] ORDER GRANTING
                                APPLICATION TO FILE DOCUMENTS UNDER SEAL
  1             Defendant Health Net ofCalifoniia,Inc.'s.("HNCA'^ Application to Seal Exhibits Filed
  2    in Support of Motions Why Plaintiffs'Cases Should Not Proceed as PAGA Representative
  3    Actionscanaebeforethis Court on April Hi 2019, at 10:00 ajn.
  4             The Court, after considering the motion, all materials filed in support and in response
                               •      I.      • •
  5 . thereto, the oral argument of counsel for the parties, and the pleadings andfileherein, hereby
  6    finds thait that (1) There exists an overriding interest that overcomes therightof public acce^ to
  7    therecordsought to be sealed; (2)tiieoverriding interest supjports sealing therecord;(3) a
  8.   substantial probability exists that the overriding interest will be prejudiced if therecordis not
  9    sealed; (4) the sealing is narrowly tailored; and (5) no less restrictive means exist to achieve the
 10    overriding interest
 11             Accordingly, HNCA's Application to Seal Exhibits Filed in Support of Motions Why
 12    PlaintiEfe* Cases Should Not Proceed as PAGA Representative Actions is GRANTED. The
. 13   following documents, whidi were lodged with the Court, shall befiledas sealed records with the
 14    Clerk:
 15             1,             HNCA's "Associate Policy: Timekeeping," submitted as Exhibit A to both the
 16    Declaration of Diane Rodes in Support of Motion as to Why Arana's Case Should Not Proceed as
 17    a PAGA Representative Action and the Declaration of Diane k<>d