On March 20, 2019 a
Party Statement
was filed
involving a dispute between
Perez, Esperanza,
and
Brown, Tawna,
Bruun, Tawna,
Does 1 Through 50,
Kaiser Foundation Health Plan Inc A California Corporation,
Kaiser Foundation Hospitals A California Corporation,
Southern California Permanente Medical Group Inc., A Caifornia Corporation,
for Wrongful Termination Unlimited
in the District Court of San Bernardino County.
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v '
\u
Michele Ballard Miller (SBN 104198)
mbmiller@cozen. com
Ethan W. Chemin (SBN) 273906
echernin@cozen.c0m
COZEN O'CONNOR F | L E D
CALIFORNIA
. . . 5%POEURBIJCT35
401 Wllshlre Boulevard, Sulte 850 8932; g; RNARDINO
SAN BERNARowo DISTRICT
Santa Monica, California 9040J~
O(OWNOUIACQN-i
::::$;?1::=3%9£93247%%° seflflflH? Nov 022m
Attorneys for Defendants
KAISER B“ 0°58"
§35§E§AF83§ ?;‘Eygnigiwficsj R- L° Deputy
SOUTHERN CALIFORNIA PERMANENTE
MEDICAL GROUP, and TAWNA BRUUN
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN BERNARDINO
CONNOR
ESPERANZA PEREZ, Case No.2 ClVDSl920836
Boutsvum
MAM“!
.60
0' Plaintiff’
me
Sum
[Assigned to the Hon. Hon. Thomas S Garza,
Cozen
401
SANTA
VS.
Dept. 827]
KAISER FOUNDATION HOSPITALS, a DECLARATION 0F SARAH FAN 1N
KAISER
California Corporation; SUPPORT OF DEFENDANT KAISER
FOUNDATION HEALTH pLAN‘ INC” a FOUNDATION HOSPITALS’S NOTICE
SOUTHERN
California Corporation; and 0F PLAINTIFF’S NON'OPPOSITION TO
CALIFORNIA PERMANENTE MEDICAL ITS MOTION T0 COMPEL
GROUP, INC, a California Corporation; PRODUCTION 0F PLAINTIFF S ,
TAWNA BRUUN. an Individual; and DOES 1
MEDICAL RECORDS; REQUEST FOR
MONETARY SANCTIONS AGAINST
NNNNNNNNNA‘AAAAAAAA
through 50, Inclusive, ,
mVODU'I-hWN—‘OCDWVODU'I-th—l
PLAINTIFF AND HER COUNSEL IN
Defendants, THE SUM OF $3,739.60
QHHGIINW
Date: November 8, 2023
Time: 8:30 a.m.
Dept.: $27
Action Filed: March 2019 20,
Trial Date: September l, 2023 1
FAXED
1.EGAL\43735341\1 l
DECLARATION ISO NOTICE 0F PLAINTIFF’S NON-OPPOSITION TO MOTION TO COMPEL
PRODUCTION OF PLAINTIFF’S MEDICAL RECORDS; REQUEST FOR MONETARY SANCTIONS
CASE NO. ClVDSl920836
LEGAL\66675105\1
I. Sarah Fan. declare:
l. l am an attorney at law licensed t0 practice before all courts ofthe State ofCalifomia
and before this Court. I am a member ofthe law firm Cozen O'Connor. and am one ofthe attorneys
ofrecord for Defendant Kaiser Foundation Hospitals. Kaiser Foundation Health Plan, Inc.. Southern
California Permanente Medical Group, and Tawna Bruun (collectively “‘Defendants”). in the above-
O(Omflmmth-K captioned matter.
2. I have personal knowledge of the matters contained in this declaration. and ifcalled
to do so, can testify competently to the same. I make this declaration in support of Defendant Kaiser
Foundation Hospitals‘s ("KFH") Notice ofPlaintiffEsperanza Perez‘s (“Plaintiff“) Non-Opposition
to its Motion to Compel Production of Plaintiff‘s Medical Records ("Motion").
3. I am not aware that any opposition to KFH's Motion has been filed, nor has any such
_A_x_L_L
opposition been served on KFH.
(JONA
4. On October 26. 2023. in an attempt to infomally resolve the subject matter of this
00401
CONNOR
BOULEVARD
I50
CA Motion, my office met and conferred with Plaintiff‘s counsel. Twila White, by email. A true and
0‘
MW:
MI Mona
_L
A
correct copy 0f this email correspondence to Ms. White is attached here as Exhibit A. Ms. White
COZEN
SAN"
401
—¥ U1
never responded to this email.
—| O)
5. On October 27. 2023, I met and conferred with Ms. White by phone regarding the
—‘ \l
discovery issues in this case. I also reminded Ms. White that we had not received a response to
—¥
m KFH‘s proposal for production of Plaintiff‘s medical records. Ms. White agreed to review the
—K
<0
proposal over the weekend and respond, but she never did so. A true and correct copy ofthe email
NO correspondence that I sent to Ms. White memorializing our telephone conversation, dated October
N —¥
27, 2023, attached here as Exhibit B. Ms. White never indicated to me that any
is ofthe statements
NN in my email were incorrect 0r inaccurate.
N 00 6. On November l. 2023. having not heard from Ms. White. l reached out again by
NA email in an attempt t0 informally resolve the subject matter ofthe Motion. I reminded Ms. White
N O1 that she had not provided any response regarding KFH‘s proposal for production 0f Plaintiff‘s
N O) medical records. A true and correct copy of my email correspondence to Ms. White, dated
NV November l, 2023. is attached here as Exhibit C. I also left a voicemail message with Ms. White
Nm LEGAL\43735341\1 2
DECLARATION ISO NOTICE OF PLAINTIFF’S NON-OPPOSITION TO MOTION TO COMPEL
PRODUCTION OF PLAINTIFF’S MEDICAL RECORDS; REQUEST FOR MONETARY SANCTIONS
CASE NO. CIVDSI920836
1.EGAL\66675105\1
Document Filed Date
November 02, 2023
Case Filing Date
March 20, 2019
Category
Wrongful Termination Unlimited
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v ' \u Michele Ballard Miller (SBN 104198) mbmiller@cozen. com Ethan W. Chemin (SBN) 273906 echernin@cozen.c0m COZEN O'CONNOR F | L E D CALIFORNIA . . . 5%POEURBIJCT35 401 Wllshlre Boulevard, Sulte 850 8932; g; RNARDINO SAN BERNARowo DISTRICT Santa Monica, California 9040J~ O(OWNOUIACQN-i ::::$;?1::=3%9£93247%%° seflflflH? Nov 022m Attorneys for Defendants KAISER B“ 0°58" §35§E§AF83§ ?;‘Eygnigiwficsj R- L° Deputy SOUTHERN CALIFORNIA PERMANENTE MEDICAL GROUP, and TAWNA BRUUN SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN BERNARDINO CONNOR ESPERANZA PEREZ, Case No.2 ClVDSl920836 Boutsvum MAM“! .60 0' Plaintiff’ me Sum [Assigned to the Hon. Hon. Thomas S Garza, Cozen 401 SANTA VS. Dept. 827] KAISER FOUNDATION HOSPITALS, a DECLARATION 0F SARAH FAN 1N KAISER California Corporation; SUPPORT OF DEFENDANT KAISER FOUNDATION HEALTH pLAN‘ INC” a FOUNDATION HOSPITALS’S NOTICE SOUTHERN California Corporation; and 0F PLAINTIFF’S NON'OPPOSITION TO CALIFORNIA PERMANENTE MEDICAL ITS MOTION T0 COMPEL GROUP, INC, a California Corporation; PRODUCTION 0F PLAINTIFF S , TAWNA BRUUN. an Individual; and DOES 1 MEDICAL RECORDS; REQUEST FOR MONETARY SANCTIONS AGAINST NNNNNNNNNA‘AAAAAAAA through 50, Inclusive, , mVODU'I-hWN—‘OCDWVODU'I-th—l PLAINTIFF AND HER COUNSEL IN Defendants, THE SUM OF $3,739.60 QHHGIINW Date: November 8, 2023 Time: 8:30 a.m. Dept.: $27 Action Filed: March 2019 20, Trial Date: September l, 2023 1 FAXED 1.EGAL\43735341\1 l DECLARATION ISO NOTICE 0F PLAINTIFF’S NON-OPPOSITION TO MOTION TO COMPEL PRODUCTION OF PLAINTIFF’S MEDICAL RECORDS; REQUEST FOR MONETARY SANCTIONS CASE NO. ClVDSl920836 LEGAL\66675105\1 I. Sarah Fan. declare: l. l am an attorney at law licensed t0 practice before all courts ofthe State ofCalifomia and before this Court. I am a member ofthe law firm Cozen O'Connor. and am one ofthe attorneys ofrecord for Defendant Kaiser Foundation Hospitals. Kaiser Foundation Health Plan, Inc.. Southern California Permanente Medical Group, and Tawna Bruun (collectively “‘Defendants”). in the above- O(Omflmmth-K captioned matter. 2. I have personal knowledge of the matters contained in this declaration. and ifcalled to do so, can testify competently to the same. I make this declaration in support of Defendant Kaiser Foundation Hospitals‘s ("KFH") Notice ofPlaintiffEsperanza Perez‘s (“Plaintiff“) Non-Opposition to its Motion to Compel Production of Plaintiff‘s Medical Records ("Motion"). 3. I am not aware that any opposition to KFH's Motion has been filed, nor has any such _A_x_L_L opposition been served on KFH. (JONA 4. On October 26. 2023. in an attempt to infomally resolve the subject matter of this 00401 CONNOR BOULEVARD I50 CA Motion, my office met and conferred with Plaintiff‘s counsel. Twila White, by email. A true and 0‘ MW: MI Mona _L A correct copy 0f this email correspondence to Ms. White is attached here as Exhibit A. Ms. White COZEN SAN" 401 —¥ U1 never responded to this email. —| O) 5. On October 27. 2023, I met and conferred with Ms. White by phone regarding the —‘ \l discovery issues in this case. I also reminded Ms. White that we had not received a response to —¥ m KFH‘s proposal for production of Plaintiff‘s medical records. Ms. White agreed to review the —K <0 proposal over the weekend and respond, but she never did so. A true and correct copy ofthe email NO correspondence that I sent to Ms. White memorializing our telephone conversation, dated October N —¥ 27, 2023, attached here as Exhibit B. Ms. White never indicated to me that any is ofthe statements NN in my email were incorrect 0r inaccurate. N 00 6. On November l. 2023. having not heard from Ms. White. l reached out again by NA email in an attempt t0 informally resolve the subject matter ofthe Motion. I reminded Ms. White N O1 that she had not provided any response regarding KFH‘s proposal for production 0f Plaintiff‘s N O) medical records. A true and correct copy of my email correspondence to Ms. White, dated NV November l, 2023. is attached here as Exhibit C. I also left a voicemail message with Ms. White Nm LEGAL\43735341\1 2 DECLARATION ISO NOTICE OF PLAINTIFF’S NON-OPPOSITION TO MOTION TO COMPEL PRODUCTION OF PLAINTIFF’S MEDICAL RECORDS; REQUEST FOR MONETARY SANCTIONS CASE NO. CIVDSI920836 1.EGAL\66675105\1