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CM-110
ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY
Kevin E. Gilbert, Esq. (SBN: 209236)/Nicholas D. Fine, Esq. (SBN: 285017)
ORBACH HUFF & HENDERSON LLP
6200 Stoneridge Mall Road, Suite 225
Pleasanton, CA 94588
(510) 999-7908
TELEPHONE NO.: FAX NO. (Optional): (510) 999-7918
kgilbert@ohhlegal.com/nfine@ohhlegal.com
E-MAIL ADDRESS:
ATTORNEY FOR (Name): Defendant Local Initiative Health Authority for
Los Angeles, operating and doing business as L.A. CARE HEALTH PLAN
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
STREET ADDRESS: 111 North Hill Street
MAILING ADDRESS:
Los Angeles, CA 90012
CITY AND ZIP CODE:
Stanley Mosk Courthouse
BRANCH NAME:
PLAINTIFF/PETITIONER: LAKEWOOD REGIONAL MEDICAL CENTER, INC., et
al.
DEFENDANT/RESPONDENT: L.A. CARE HEALTH PLAN
CASE MANAGEMENT STATEMENT CASE NUMBER:
(Check one): UNLIMITED CASE LIMITED CASE
23STCV28454
(Amount demanded (Amount demanded is $25,000
exceeds $25,000) or less)
A CASE MANAGEMENT CONFERENCE is scheduled as follows:
Date: February 2, 2024 Time: 8:31 a.m. Dept.: 54 Div.: Room:
Address of court (if different from the address above):
Notice of Intent to Appear by Telephone, by (name): Nicholas D. Fine, Esq.
INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided.
1. Party or parties (answer one):
a. This statement is submitted by party (name): Defendant L.A. CARE HEALTH PLAN
b. This statement is submitted jointly by parties (names):
2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only)
a. The complaint was filed on (date):
b. The cross-complaint, if any, was filed on (date):
3. Service (to be answered by plaintiffs and cross-complainants only)
a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.
b. The following parties named in the complaint or cross-complaint
(1) have not been served (specify names and explain why not):
(2) have been served but have not appeared and have not been dismissed (specify names):
(3) have had a default entered against them (specify names):
c. The following additional parties may be added (specify names, nature of involvement in case, and date by which
they may be served):
4. Description of case
a. Type of case in complaint cross-complaint (Describe, including causes of action):
Breach of Implied-in-Law Contract (Emergency Services, Post-Stabilization Services, Elective Services); Breach of
Implied-in-Fact Contract (Post-Stabilization Services, Elective Services); Quantum Meruit.
Page 1 of 5
Form Adopted for Mandatory Use Cal. Rules of Court,
Judicial Council of California CASE MANAGEMENT STATEMENT rules 3.720–3.730
CM-110 [Rev. September 1, 2021] www.courts.ca.gov
CM-110
PLAINTIFF/PETITIONER: LAKEWOOD
REGIONAL MEDICAL CENTER, et al. CASE NUMBER:
DEFENDANT/RESPONDENT: L.A. CARE HEALTH PLAN 23STCV28454
4. b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and
damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost
earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.)
Plaintiffs are two non-contracted hospitals who bring suit against L.A. Care, a public health plan, seeking additional
compensation for medical services Plaintiffs claim to have provided to L.A. Care’s members, pursuant to the
reimbursement provisions for non-contracted providers under the Knox-Keene Act. However, Plaintiffs have been
compensated in full in accordance with applicable law.
(If more space is needed, check this box and attach a page designated as Attachment 4b.)
5. Jury or nonjury trial
The party or parties request a jury triaI a nonjury trial. (If more than one party, provide the name of each party
requesting a jury trial):
6. Trial date
a. The trial has been set for (date):
b. No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if
not, explain):
c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):
Feb. 27-March 8, 2024 (trial USDC-LA); March 25-April 4, 2024 (trial USDC-SF); April 2-16, 2024 (trial Santa Cruz Sup); April
22-29, 2024 (trial Marin Sup); April 26-May 3, 2024 (trial Sonoma Sup); May 30-June 20, 2024 (trial Marin Sup); June 24-June
28, 2024 (trial LA Sup); July 8-17, 2024 (trial Alameda Sup); August 6-20, 2024 (trial USDC-Fresno); August 19-30, 2024 (trial
LA Sup); Sept. 23-Oct. 7, 2024 (trial LA Sup); Oct. 2-8, 2024 (trial USDC-SF); Oct. 15-29, 2024 (trial Alameda Sup); Oct. 21-31,
2024 (trial USDC-SF); Dec. 2-13, 2024 (trial USDC-SF); Feb. 3-11, 2025 (trial USDC-Sac); March 3-7, 2025 (trial USDC-SF);
April 1-15, 2025 (trial LA Sup); June 18-June 30, 2025 (trial USDC-Oak).
7. Estimated length of trial
The party or parties estimate that the trial will take (check one):
a. days (specify number): 2-3
b. hours (short causes) (specify):
8. Trial representation (to be answered for each party)
The party or parties will be represented at trial by the attorney or party listed in the caption by the following:
a. Attorney:
b. Firm:
c. Address:
d. Telephone number: f. Fax number:
e. E-mail address: g. Party represented:
Additional representation is described in Attachment 8.
9. Preference
This case is entitled to preference (specify code section):
10. Alternative dispute resolution (ADR)
a. ADR information package. Please note that different ADR processes are available in different courts and communities; read
the ADR information package provided by the court under rule 3.221 of the California Rules of Court for information about the
processes available through the court and community programs in this case.
(1) For parties represented by counsel: Counsel has has not provided the ADR information package
identified in rule 3.221 to the client and reviewed ADR options with the client.
(2) For self-represented parties: Party has has not reviewed the ADR information package identified in rule 3.221.
b. Referral to judicial arbitration or civil action mediation (if available).
(1) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action
mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the
statutory limit.
(2) Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of
Civil Procedure section 1141.11.
(3) This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action
mediation under Code of Civil Procedure section 1775 et seq. (specify exemption):
CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 2 of 5
CM-110
PLAINTIFF/PETITIONER: LAKEWOOD
REGIONAL MEDICAL CENTER, et al. CASE NUMBER:
DEFENDANT/RESPONDENT: L.A. CARE HEALTH PLAN 23STCV28454
10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or
have already participated in (check all that apply and provide the specified information):
The party or parties completing If the party or parties completing this form in the case have agreed to
this form are willing to participate in or have already completed an ADR process or processes,
participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR
processes (check all that apply): stipulation):
Mediation session not yet scheduled
Mediation session scheduled for (date):
(1) Mediation
Agreed to complete mediation by (date):
Mediation completed on (date):
Settlement conference not yet scheduled
(2) Settlement Settlement conference scheduled for (date):
conference Agreed to complete settlement conference by (date):
Settlement conference completed on (date):
Neutral evaluation not yet scheduled
Neutral evaluation scheduled for (date):
(3) Neutral evaluation
Agreed to complete neutral evaluation by (date):
Neutral evaluation completed on (date):
Judicial arbitration not yet scheduled
(4) Nonbinding judicial Judicial arbitration scheduled for (date):
arbitration
Agreed to complete judicial arbitration by (date):
Judicial arbitration completed on (date):
Private arbitration not yet scheduled
(5) Binding private Private arbitration scheduled for (date):
arbitration Agreed to complete private arbitration by (date):
Private arbitration completed on (date):
ADR session not yet scheduled
(6) Other (specify): ADR session scheduled for (date):
Agreed to complete ADR session by (date):
ADR completed on (date):
CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 3 of 5
CM-110
PLAINTIFF/PETITIONER: LAKEWOOD
REGIONAL MEDICAL CENTER, et al. CASE NUMBER:
DEFENDANT/RESPONDENT: L.A. CARE HEALTH PLAN 23STCV28454
11. Insurance
a. Insurance carrier, if any, for party filing this statement (name):
b. Reservation of rights: Yes No
c. Coverage issues will significantly affect resolution of this case (explain):
12. Jurisdiction
Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status.
Bankruptcy Other (specify):
Status:
13. Related cases, consolidation, and coordination
a. There are companion, underlying, or related cases.
(1) Name of case: University of Southern California, et al. v. Local Initiative Health Authority for Los Angeles County
(2) Name of court: Los Angeles County Superior Court
(3) Case number: 22STCV02072 (lead case)
(4) Status: Pending
Additional cases are described in Attachment 13a.
b. A motion to consolidate coordinate wiII be filed by (name party):
14. Bifurcation
The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of
action (specify moving party, type of motion, and reasons):
15. Other motions
The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues):
Motion for summary judgment or motion for summary adjudication.
16. Discovery
a. The party or parties have completed all discovery.
b. The following discovery will be completed by the date specified (describe all anticipated discovery):
Party Description Date
Defendant Written discovery Per Code
Defendant PMK Depositions of Plaintiffs Per Code
c. The following discovery issues, including issues regarding the discovery of electronically stored information, are
anticipated (specify):
CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 4 of 5
CM-110
PLAINTIFF/PETITIONER: LAKEWOOD
REGIONAL MEDICAL CENTER, et al. CASE NUMBER:
DEFENDANT/RESPONDENT: L.A. CARE HEALTH PLAN 23STCV28454
17. Economic litigation
a. This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code
of Civil Procedure sections 90-98 will apply to this case.
b. This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional
discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial
should not apply to this case):
18. Other issues
The party or parties request that the following additional matters be considered or determined at the case management
conference (specify):
19. Meet and confer
a. The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules
of Court (if not, explain):
b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following
(specify):
20. Total number of pages attached (if any): 3
I 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 case management conference, including the written authority of the party where required.
Date: January 22, 2024
Nicholas D. Fine
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
(TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY)
Additional signatures are attached.
CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 5 of 5
Attachment 13a
Defendant LA Care Health Plan’s Case Management Statement
(1) Name of case: University of Southern California, et al. v. Local Initiative Health
Authority for Los Angeles County dba LA Care Health Plan
(2) Name of court: Los Angeles County Superior Court
(3) Case number: 22STCV02659
(4) Status: Pending
(1) Name of case: Los Alamitos Medical Center, et al. v. Local Initiative Health Authority for
Los Angeles County dba LA Care Health Plan
(2) Name of court: USDC – Central District
(3) Case number: 22-cv-01602-JWH-ADS
(4) Status: Pending
(1) Name of case: University of Southern California, et al. v. Local Initiative Health
Authority for Los Angeles County dba LA Care Health Plan
(2) Name of court: Los Angeles County Superior Court
(3) Case number: 22STCV15865
(4) Status: Pending
(1) Name of case: University of Southern California, et al. v. Local Initiative Health
Authority for Los Angeles County dba LA Care Health Plan
(2) Name of court: Los Angeles County Superior Court
(3) Case number: 23STCV22700
(4) Status: Pending
(1) Name of case: San Joaquin Community Hospital, et al. v. Local Initiative Health
Authority for Los Angeles County dba LA Care Health Plan
(2) Name of court: Los Angeles County Superior Court
(3) Case number: 22STCV30779
(4) Status: Pending
(1) Name of case: University of Southern California, et al. v. Local Initiative Health
Authority for Los Angeles County dba LA Care Health Plan
(2) Name of court: Los Angeles County Superior Court
(3) Case number: 22STCV33996
(4) Status: Pending
(1) Name of case: University of Southern California, et al. v. Local Initiative Health
Authority for Los Angeles County dba LA Care Health Plan
(2) Name of court: Los Angeles County Superior Court
(3) Case number: 23STCV13310
(4) Status: Pending
(1) Name of case: Los Alamitos Medical Center, et al. v. Local Initiative Health Authority for
Los Angeles County dba LA Care Health Plan
(2) Name of court: USDC – Central District
(3) Case number: 23-cv-05076-JWH-ADS
(4) Status: Pending
(1) Name of case: Los Alamitos Medical Center, et al. v. Local Initiative Health Authority for
Los Angeles County dba LA Care Health Plan
(2) Name of court: Los Angeles County Superior Court
(3) Case number: 23STCV14984
(4) Status: Pending
(1) Name of case: San Joaquin Community Hospital, et al. v. Local Initiative Health
Authority for Los Angeles County dba LA Care Health Plan
(2) Name of court: Los Angeles County Superior Court
(3) Case number: 23STCV10175
(4) Status: Pending
(1) Name of case: University of Southern California, et al. v. Local Initiative Health
Authority for Los Angeles County dba LA Care Health Plan
(2) Name of court: Los Angeles County Superior Court
(3) Case number: 23STCV25633
(4) Status: Pending
(1) Name of case: University of Southern California, et al. v. Local Initiative Health
Authority for Los Angeles County dba LA Care Health Plan
(2) Name of court: Los Angeles County Superior Court
(3) Case number: 23STCV25875
(4) Status: Pending
(1) Name of case: Los Alamitos Medica Center, Inc., et al. v. Local Initiative Health
Authority for Los Angeles County dba LA Care Health Plan
(2) Name of court: Orange County Superior Court
(3) Case number: 30-2022-01251256-CU-BC-WJC
(4) Status: Pending
(1) Name of case: Lakewood Regional Medical Center, Inc., et al. v. Local Initiative Health
Authority for Los Angeles County dba LA Care Health Plan
(2) Name of court: Los Angeles County Superior Court
(3) Case number: 23STCV28454
(4) Status: Pending
(1) Name of case: Lakewood Regional Medical Center, Inc. v. Local Initiative Health
Authority for Los Angeles County dba LA Care Health Plan
(2) Name of court: Los Angeles County Superior Court
(3) Case number: 23STCV29235
(4) Status: Pending
1 PROOF OF SERVICE
2 I, Elena LaBella, am employed in the County of Alameda, State of California. I am over the age
of eighteen years and not a party to the within action. My business address is Orbach Huff & Henderson
3 LLP, 6200 Stoneridge Mall Road, Suite 225, Pleasanton, California 94588.
4
On January 22, 2024, I served the foregoing:
5
DEFENDANT L.A. CARE HEALTH PLAN’S CASE MANAGEMENT STATEMENT
6
on the interested parties in this action, by placing a true copy thereof enclosed in a sealed envelope
7 addressed as follows and I caused delivery to be made by the mode of service indicated below:
8
Kim Worobec, Esq. Attorney for Plaintiffs
9 Ryan G. Jacobson, Esq. LAKEWOOD REGIONAL MEDICAL
HELTON LAW GROUP, APC CENTER, INC. and LOS ALAMITOS
10 1590 Corporate Drive MEDICAL CENTER, INC.
Costa Mesa, CA 92626 Telephone: (562) 901-4499
11
ORBACH HUFF & HENDERSON LLP
Facsimile: (562) 901-4488
12 Email: kworobec@helton.law
rjacobson@helton.law
13
14 [ X ] (By E-Mail or Electronic Transmission) By e-mailing the document(s) to the person(s) at
the e-mail address(es) listed above, from e-mail address elabella@ohhlegal.com, per
15
agreement in accordance with CRC Rule 2.251 and Code of Civil Procedure § 1010.6. No
16 electronic message or other indication that the transmission was unsuccessful was received
within a reasonable time after the transmission.
17
I declare under penalty of perjury under the laws of the State of California that the foregoing is
18 true and correct. Executed on January 22, 2024, at Pleasanton, California.
19
20 Elena D. LaBella
21
22
23
24
25
26
27
28
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Defendant L.A. Care’s Proof of Service [23STCV28454]
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CM-110 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): FOR COURT USE ONLY Kevin E. Gilbert, Esq. (SBN: 209236)/Nicholas D. Fine, Esq. (SBN: 285017) ORBACH HUFF & HENDERSON LLP 6200 Stoneridge Mall Road, Suite 225 Pleasanton, CA 94588 (510) 999-7908 TELEPHONE NO.: FAX NO. (Optional): (510) 999-7918 kgilbert@ohhlegal.com/nfine@ohhlegal.com E-MAIL ADDRESS: ATTORNEY FOR (Name): Defendant Local Initiative Health Authority for Los Angeles, operating and doing business as L.A. CARE HEALTH PLAN SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES STREET ADDRESS: 111 North Hill Street MAILING ADDRESS: Los Angeles, CA 90012 CITY AND ZIP CODE: Stanley Mosk Courthouse BRANCH NAME: PLAINTIFF/PETITIONER: LAKEWOOD REGIONAL MEDICAL CENTER, INC., et al. DEFENDANT/RESPONDENT: L.A. CARE HEALTH PLAN CASE MANAGEMENT STATEMENT CASE NUMBER: (Check one): UNLIMITED CASE LIMITED CASE 23STCV28454 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) or less) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: February 2, 2024 Time: 8:31 a.m. Dept.: 54 Div.: Room: Address of court (if different from the address above): Notice of Intent to Appear by Telephone, by (name): Nicholas D. Fine, Esq. INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. This statement is submitted by party (name): Defendant L.A. CARE HEALTH PLAN b. This statement is submitted jointly by parties (names): 2. Complaint and cross-complaint (to be answered by plaintiffs and cross-complainants only) a. The complaint was filed on (date): b. The cross-complaint, if any, was filed on (date): 3. Service (to be answered by plaintiffs and cross-complainants only) a. All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed. b. The following parties named in the complaint or cross-complaint (1) have not been served (specify names and explain why not): (2) have been served but have not appeared and have not been dismissed (specify names): (3) have had a default entered against them (specify names): c. The following additional parties may be added (specify names, nature of involvement in case, and date by which they may be served): 4. Description of case a. Type of case in complaint cross-complaint (Describe, including causes of action): Breach of Implied-in-Law Contract (Emergency Services, Post-Stabilization Services, Elective Services); Breach of Implied-in-Fact Contract (Post-Stabilization Services, Elective Services); Quantum Meruit. Page 1 of 5 Form Adopted for Mandatory Use Cal. Rules of Court, Judicial Council of California CASE MANAGEMENT STATEMENT rules 3.720–3.730 CM-110 [Rev. September 1, 2021] www.courts.ca.gov CM-110 PLAINTIFF/PETITIONER: LAKEWOOD REGIONAL MEDICAL CENTER, et al. CASE NUMBER: DEFENDANT/RESPONDENT: L.A. CARE HEALTH PLAN 23STCV28454 4. b. Provide a brief statement of the case, including any damages. (If personal injury damages are sought, specify the injury and damages claimed, including medical expenses to date [indicate source and amount], estimated future medical expenses, lost earnings to date, and estimated future lost earnings. If equitable relief is sought, describe the nature of the relief.) Plaintiffs are two non-contracted hospitals who bring suit against L.A. Care, a public health plan, seeking additional compensation for medical services Plaintiffs claim to have provided to L.A. Care’s members, pursuant to the reimbursement provisions for non-contracted providers under the Knox-Keene Act. However, Plaintiffs have been compensated in full in accordance with applicable law. (If more space is needed, check this box and attach a page designated as Attachment 4b.) 5. Jury or nonjury trial The party or parties request a jury triaI a nonjury trial. (If more than one party, provide the name of each party requesting a jury trial): 6. Trial date a. The trial has been set for (date): b. No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (if not, explain): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability): Feb. 27-March 8, 2024 (trial USDC-LA); March 25-April 4, 2024 (trial USDC-SF); April 2-16, 2024 (trial Santa Cruz Sup); April 22-29, 2024 (trial Marin Sup); April 26-May 3, 2024 (trial Sonoma Sup); May 30-June 20, 2024 (trial Marin Sup); June 24-June 28, 2024 (trial LA Sup); July 8-17, 2024 (trial Alameda Sup); August 6-20, 2024 (trial USDC-Fresno); August 19-30, 2024 (trial LA Sup); Sept. 23-Oct. 7, 2024 (trial LA Sup); Oct. 2-8, 2024 (trial USDC-SF); Oct. 15-29, 2024 (trial Alameda Sup); Oct. 21-31, 2024 (trial USDC-SF); Dec. 2-13, 2024 (trial USDC-SF); Feb. 3-11, 2025 (trial USDC-Sac); March 3-7, 2025 (trial USDC-SF); April 1-15, 2025 (trial LA Sup); June 18-June 30, 2025 (trial USDC-Oak). 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. days (specify number): 2-3 b. hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial by the attorney or party listed in the caption by the following: a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented: Additional representation is described in Attachment 8. 9. Preference This case is entitled to preference (specify code section): 10. Alternative dispute resolution (ADR) a. ADR information package. Please note that different ADR processes are available in different courts and communities; read the ADR information package provided by the court under rule 3.221 of the California Rules of Court for information about the processes available through the court and community programs in this case. (1) For parties represented by counsel: Counsel has has not provided the ADR information package identified in rule 3.221 to the client and reviewed ADR options with the client. (2) For self-represented parties: Party has has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil action mediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed the statutory limit. (2) Plaintiff elects to refer this case to judicial arbitration and agrees to limit recovery to the amount specified in Code of Civil Procedure section 1141.11. (3) This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil action mediation under Code of Civil Procedure section 1775 et seq. (specify exemption): CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 2 of 5 CM-110 PLAINTIFF/PETITIONER: LAKEWOOD REGIONAL MEDICAL CENTER, et al. CASE NUMBER: DEFENDANT/RESPONDENT: L.A. CARE HEALTH PLAN 23STCV28454 10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, or have already participated in (check all that apply and provide the specified information): The party or parties completing If the party or parties completing this form in the case have agreed to this form are willing to participate in or have already completed an ADR process or processes, participate in the following ADR indicate the status of the processes (attach a copy of the parties' ADR processes (check all that apply): stipulation): Mediation session not yet scheduled Mediation session scheduled for (date): (1) Mediation Agreed to complete mediation by (date): Mediation completed on (date): Settlement conference not yet scheduled (2) Settlement Settlement conference scheduled for (date): conference Agreed to complete settlement conference by (date): Settlement conference completed on (date): Neutral evaluation not yet scheduled Neutral evaluation scheduled for (date): (3) Neutral evaluation Agreed to complete neutral evaluation by (date): Neutral evaluation completed on (date): Judicial arbitration not yet scheduled (4) Nonbinding judicial Judicial arbitration scheduled for (date): arbitration Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (date): Private arbitration not yet scheduled (5) Binding private Private arbitration scheduled for (date): arbitration Agreed to complete private arbitration by (date): Private arbitration completed on (date): ADR session not yet scheduled (6) Other (specify): ADR session scheduled for (date): Agreed to complete ADR session by (date): ADR completed on (date): CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 3 of 5 CM-110 PLAINTIFF/PETITIONER: LAKEWOOD REGIONAL MEDICAL CENTER, et al. CASE NUMBER: DEFENDANT/RESPONDENT: L.A. CARE HEALTH PLAN 23STCV28454 11. Insurance a. Insurance carrier, if any, for party filing this statement (name): b. Reservation of rights: Yes No c. Coverage issues will significantly affect resolution of this case (explain): 12. Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. Bankruptcy Other (specify): Status: 13. Related cases, consolidation, and coordination a. There are companion, underlying, or related cases. (1) Name of case: University of Southern California, et al. v. Local Initiative Health Authority for Los Angeles County (2) Name of court: Los Angeles County Superior Court (3) Case number: 22STCV02072 (lead case) (4) Status: Pending Additional cases are described in Attachment 13a. b. A motion to consolidate coordinate wiII be filed by (name party): 14. Bifurcation The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes of action (specify moving party, type of motion, and reasons): 15. Other motions The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): Motion for summary judgment or motion for summary adjudication. 16. Discovery a. The party or parties have completed all discovery. b. The following discovery will be completed by the date specified (describe all anticipated discovery): Party Description Date Defendant Written discovery Per Code Defendant PMK Depositions of Plaintiffs Per Code c. The following discovery issues, including issues regarding the discovery of electronically stored information, are anticipated (specify): CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 4 of 5 CM-110 PLAINTIFF/PETITIONER: LAKEWOOD REGIONAL MEDICAL CENTER, et al. CASE NUMBER: DEFENDANT/RESPONDENT: L.A. CARE HEALTH PLAN 23STCV28454 17. Economic litigation a. This is a limited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Code of Civil Procedure sections 90-98 will apply to this case. b. This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional discovery will be filed (if checked, explain specifically why economic litigation procedures relating to discovery or trial should not apply to this case): 18. Other issues The party or parties request that the following additional matters be considered or determined at the case management conference (specify): 19. Meet and confer a. The party or parties have met and conferred with all parties on all subjects required by rule 3.724 of the California Rules of Court (if not, explain): b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (if any): 3 I 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 case management conference, including the written authority of the party where required. Date: January 22, 2024 Nicholas D. Fine (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. CM-110 [Rev. September 1, 2021] CASE MANAGEMENT STATEMENT Page 5 of 5 Attachment 13a Defendant LA Care Health Plan’s Case Management Statement (1) Name of case: University of Southern California, et al. v. Local Initiative Health Authority for Los Angeles County dba LA Care Health Plan (2) Name of court: Los Angeles County Superior Court (3) Case number: 22STCV02659 (4) Status: Pending (1) Name of case: Los Alamitos Medical Center, et al. v. Local Initiative Health Authority for Los Angeles County dba LA Care Health Plan (2) Name of court: USDC – Central District (3) Case number: 22-cv-01602-JWH-ADS (4) Status: Pending (1) Name of case: University of Southern California, et al. v. Local Initiative Health Authority for Los Angeles County dba LA Care Health Plan (2) Name of court: Los Angeles County Superior Court (3) Case number: 22STCV15865 (4) Status: Pending (1) Name of case: University of Southern California, et al. v. Local Initiative Health Authority for Los Angeles County dba LA Care Health Plan (2) Name of court: Los Angeles County Superior Court (3) Case number: 23STCV22700 (4) Status: Pending (1) Name of case: San Joaquin Community Hospital, et al. v. Local Initiative Health Authority for Los Angeles County dba LA Care Health Plan (2) Name of court: Los Angeles County Superior Court (3) Case number: 22STCV30779 (4) Status: Pending (1) Name of case: University of Southern California, et al. v. Local Initiative Health Authority for Los Angeles County dba LA Care Health Plan (2) Name of court: Los Angeles County Superior Court (3) Case number: 22STCV33996 (4) Status: Pending (1) Name of case: University of Southern California, et al. v. Local Initiative Health Authority for Los Angeles County dba LA Care Health Plan (2) Name of court: Los Angeles County Superior Court (3) Case number: 23STCV13310 (4) Status: Pending (1) Name of case: Los Alamitos Medical Center, et al. v. Local Initiative Health Authority for Los Angeles County dba LA Care Health Plan (2) Name of court: USDC – Central District (3) Case number: 23-cv-05076-JWH-ADS (4) Status: Pending (1) Name of case: Los Alamitos Medical Center, et al. v. Local Initiative Health Authority for Los Angeles County dba LA Care Health Plan (2) Name of court: Los Angeles County Superior Court (3) Case number: 23STCV14984 (4) Status: Pending (1) Name of case: San Joaquin Community Hospital, et al. v. Local Initiative Health Authority for Los Angeles County dba LA Care Health Plan (2) Name of court: Los Angeles County Superior Court (3) Case number: 23STCV10175 (4) Status: Pending (1) Name of case: University of Southern California, et al. v. Local Initiative Health Authority for Los Angeles County dba LA Care Health Plan (2) Name of court: Los Angeles County Superior Court (3) Case number: 23STCV25633 (4) Status: Pending (1) Name of case: University of Southern California, et al. v. Local Initiative Health Authority for Los Angeles County dba LA Care Health Plan (2) Name of court: Los Angeles County Superior Court (3) Case number: 23STCV25875 (4) Status: Pending (1) Name of case: Los Alamitos Medica Center, Inc., et al. v. Local Initiative Health Authority for Los Angeles County dba LA Care Health Plan (2) Name of court: Orange County Superior Court (3) Case number: 30-2022-01251256-CU-BC-WJC (4) Status: Pending (1) Name of case: Lakewood Regional Medical Center, Inc., et al. v. Local Initiative Health Authority for Los Angeles County dba LA Care Health Plan (2) Name of court: Los Angeles County Superior Court (3) Case number: 23STCV28454 (4) Status: Pending (1) Name of case: Lakewood Regional Medical Center, Inc. v. Local Initiative Health Authority for Los Angeles County dba LA Care Health Plan (2) Name of court: Los Angeles County Superior Court (3) Case number: 23STCV29235 (4) Status: Pending 1 PROOF OF SERVICE 2 I, Elena LaBella, am employed in the County of Alameda, State of California. I am over the age of eighteen years and not a party to the within action. My business address is Orbach Huff & Henderson 3 LLP, 6200 Stoneridge Mall Road, Suite 225, Pleasanton, California 94588. 4 On January 22, 2024, I served the foregoing: 5 DEFENDANT L.A. CARE HEALTH PLAN’S CASE MANAGEMENT STATEMENT 6 on the interested parties in this action, by placing a true copy thereof enclosed in a sealed envelope 7 addressed as follows and I caused delivery to be made by the mode of service indicated below: 8 Kim Worobec, Esq. Attorney for Plaintiffs 9 Ryan G. Jacobson, Esq. LAKEWOOD REGIONAL MEDICAL HELTON LAW GROUP, APC CENTER, INC. and LOS ALAMITOS 10 1590 Corporate Drive MEDICAL CENTER, INC. Costa Mesa, CA 92626 Telephone: (562) 901-4499 11 ORBACH HUFF & HENDERSON LLP Facsimile: (562) 901-4488 12 Email: kworobec@helton.law rjacobson@helton.law 13 14 [ X ] (By E-Mail or Electronic Transmission) By e-mailing the document(s) to the person(s) at the e-mail address(es) listed above, from e-mail address elabella@ohhlegal.com, per 15 agreement in accordance with CRC Rule 2.251 and Code of Civil Procedure § 1010.6. No 16 electronic message or other indication that the transmission was unsuccessful was received within a reasonable time after the transmission. 17 I declare under penalty of perjury under the laws of the State of California that the foregoing is 18 true and correct. Executed on January 22, 2024, at Pleasanton, California. 19 20 Elena D. LaBella 21 22 23 24 25 26 27 28 -1- Defendant L.A. Care’s Proof of Service [23STCV28454]