Preview
17CV309032
Santa Clara — Civil
A. Floresca
r1 CIV-110
‘ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Slate Bar number, and adcress)Lawrance A. Bohm (SBN:
208716) and Victoria L, Gutierrez (SBN: 282715) BOHM LAW GROUP, INC, yy Su StS eeneeT CA,
4600 Northgate Boulevard, Suite 210, Sacramento, CA 95834 County of Santa Clara,
TELEPHONE NO: 916,927,5574 FAXNO. (Oplonay, 916.927.2046 on 12/27/2019 1:17 PM
E-MAIL ADDRESS (Optionai):
Reviewed By: A. Floresca
ATTORNEY FOR (Neme): Plaintiff, Andrei Belorousou
Case #17CV309032
SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA
REET ADpRess; 191 North First Street Envelope: 3817153
MAILING ADoRess: SAME
cry anpzecove: San Jose, 95113
BRANCH Name: Downtown Superior Court /s/ A. Floresca
PLAINTIFF/PETITIONER: ANDREI BELOROUSOU
DEFENDANT/RESPONDENT: KAISER FOUNDATION HOSPITALS, et al.
REQUEST FOR DISMISSAL case Nuaer: 17CV309032
A conformed copy will not be returned by the clerk unless a method of return is provided with the document.
This form may not be used for dismissal of a derivative action or a class actionor of any party or cause of action ina
class action. (Cal. Rules of Court, rules 3.760 and 3.770.) s
1. TO THE CLERK: Please dismiss this action as follows:
a. (1) 7] With prejudice (2) [--] Without prejudice
. (1) [_] Complaint (2) [Petition
(3) [__] Cross-complaint filed by (name): on (date):
(4) [_] Cross-complaint filed by (name): ‘on (date):
(5) Entire action of all parties and all causes of action
(6) [] Other (specify):*
2. (Complete in all cases except family law cases.)
The court L_]did [¥_] did not waive court fees and costs for a party in this cas ‘This information may be obtained from
the clerk. If court fees and costs were waived, the declaration on the back of I$ form be completed).
Date: December 27, 2019
Nictoria L., Gutierrez > U
a
(TYPE OR PRINT NAME OF attorney [___] PARTY WITHOUT ATTORNEY) (SIGNATURE)
“it dismissal r juosted Is of ified parties only of specified causes of action Attorney or party without attorney for:
oF of of ecified cross-c aints onl 80 stato and Identity the parties, Plaintiff/Petitioner [1 DefendanvRespondent
‘causes of action, or cross-complaints to bo "di ismisser
[) cross-Complainant
3. TO THE CLERK: Consent to the above dismissal Is hereby given.**
>
Date:
(TYPE OR PRINT NAME OF [___] ATTORNEY [___] PARTY WITHOUT ATTORNEY) (SIGNATURE)
"If a cross-complaint-or Response (Family Law) seeking affirmative Attorney or party without attorney for:
relief— is on file, the atto for cross-compininant (respondent) must
matt consent if required by Code of Civil Procedure section 581 [1 PlaintitfiPetitioner [J Defendant/Respondent
[1 Cross-Complainant
(To be completed by clerk) 12/27/2019 1:17 PM
4. Dismissal entered as requested on (date):
5 [__] Dismissal entered on (date): as to only (name):
6. (_] Dismissal not entered as requested for the following reasons (specify):
12/27/2019 1:17 PM
7. @ eS) Attorney or party without attorney notified on (date):
b, [] Attorney or party without attorney not notified. Filing party failed to provide
a copy to be conformed [_] means to return conformed copy
/s/ A. Floresca
Clerk of Court
Clerk, by. , Deputy
Date 2/27/2019 1:17 PM
Paget of2
Form Adoplod for Mandatory Use odo of Civil Procedura, GB1 ol 50q,
‘Judielal Counct of Callomia REQUEST FOR DISMISSAL Gov. Code, § 68637(6); Cal. Rules of Cou i Tula 3.1390
‘CIV-110 [Rev. Jan, 1, 2013}, winw.courts.ca.gov
CIV-110
PLAINTIFF/PETITIONER: ANDREI BELOROUSOU CASE NUMBER:
DEFENDANT/RESPONDENT: KAISER FOUNDATION HOSPITALS, et al. 1 eee
e
COURT'S RECOVERY OF WAIVED COURT FEES AND COSTS
if a party whose court fees and costs were Initially walved has recovered or will recover $10,000 or
more in value by way of settlement, compromise, arbitration award, mediation settlement, or other
means, the court has a statutory lien on that recovery. The court may refuse to dismiss the case until
the Iten Is satisfied. (Gov. Cade, § 68637.)
Declaration Concerning Waived Court Fees
1 The court waived court fees and costs in thls action for (name):
2. The person named in item t Is (check one below):
a. [_] not recovering anything of value by this action.
b. [_] recovering less than $10,000 In value by this action.
c. [[_] recovering $10,000 or more in value by this action. (if tem 2c is checked, item 3 must be completed.)
3. (] All court fees and court costs that were walved in this action have been pald to the court (check one): [__] Yes [_] No
| declare under penalty of perjury under the laws of the State of California that the information above is true and correct.
Date: es <<
(TYPE OR PRINT NAME OF [] ATTORNEY [—] PARTY MAKING DECLARATION) (SIGNATURE)
C1V.510 (Rev. Januery 1, 2015] REQUEST FOR DISMISSAL Page 2012
PROOF OF SERVICE
I am a resident of the State of California, over the age of eighteen years, and not a party to the
within action. My business address is 560 Mission Street, 31st Floor, San Francisco, California 94105
On December 27, 2019, I served the within document(s):
e REQUEST FOR DISMISSAL
by placing the document(s) listed above in a sealed envelope with postage thereon fully prepaid,
x] in the United States mail at San Francisco, California, addressed as set forth below.
by placing the document(s) listed above, together with a signed copy of this declaration, in a
O sealed Federal Express envelope with postage paid on account and deposited with Federal
Express at San Francisco, California, addressed as set forth below.
by electronic service - transmitting the document(s) listed above, electronically, via Nationwide
Legal to the parties set forth below
10 Kyle A. Pruner, Esq. Christian J. Rowley, Esq.
11 Victoria L. Gutierrez, Esq. Andrea Bednarova, Esq.
BOHM LAW GROUP, INC. SEYFARTH SHAW LLP
12 4600 Northgate Boulevard, Suite 210 560 Mission Street, 31st Floor
Sacramento, California 95834 San Francisco, California 94105
13 Telephone: 916.927.5574 Telephone: (415) 397-2823
Facsimile: 916.927.2046 Facsimile: (415) 397-8549
14
Attorneys for Plaintiff
15 Attorneys for Defendant
KAISER FOUNDATION HOSPITALS
16 I am readily familiar with the firm's practice of collection and processing correspondence for
mailing. Under that practice it would be deposited with the U.S. Postal Service on that same day with
17 postage thereon fully prepaid in the ordinary course of business. | am aware that on motion of the party
served, service is presumed invalid if postal cancellation date or postage meter date is more than one day,
18 after date of deposit for mailing in affidavit.
19 I declare under penalty of perjury under the laws of the State of California that the above is true
and correct.
20
Executed on December 27, 2019, at San Francisco, California.
21
22 4 r
CU LAVA Hl. 2?
23
Chpisyince Jacobs
24
25
26
27
28
PROOF OF SERVICE / CASE NO. 17CV309032
60910853v.1
Preview
17CV309032 Santa Clara — Civil A. Floresca r1 CIV-110 ‘ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Slate Bar number, and adcress)Lawrance A. Bohm (SBN: 208716) and Victoria L, Gutierrez (SBN: 282715) BOHM LAW GROUP, INC, yy Su StS eeneeT CA, 4600 Northgate Boulevard, Suite 210, Sacramento, CA 95834 County of Santa Clara, TELEPHONE NO: 916,927,5574 FAXNO. (Oplonay, 916.927.2046 on 12/27/2019 1:17 PM E-MAIL ADDRESS (Optionai): Reviewed By: A. Floresca ATTORNEY FOR (Neme): Plaintiff, Andrei Belorousou Case #17CV309032 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA REET ADpRess; 191 North First Street Envelope: 3817153 MAILING ADoRess: SAME cry anpzecove: San Jose, 95113 BRANCH Name: Downtown Superior Court /s/ A. Floresca PLAINTIFF/PETITIONER: ANDREI BELOROUSOU DEFENDANT/RESPONDENT: KAISER FOUNDATION HOSPITALS, et al. REQUEST FOR DISMISSAL case Nuaer: 17CV309032 A conformed copy will not be returned by the clerk unless a method of return is provided with the document. This form may not be used for dismissal of a derivative action or a class actionor of any party or cause of action ina class action. (Cal. Rules of Court, rules 3.760 and 3.770.) s 1. TO THE CLERK: Please dismiss this action as follows: a. (1) 7] With prejudice (2) [--] Without prejudice . (1) [_] Complaint (2) [Petition (3) [__] Cross-complaint filed by (name): on (date): (4) [_] Cross-complaint filed by (name): ‘on (date): (5) Entire action of all parties and all causes of action (6) [] Other (specify):* 2. (Complete in all cases except family law cases.) The court L_]did [¥_] did not waive court fees and costs for a party in this cas ‘This information may be obtained from the clerk. If court fees and costs were waived, the declaration on the back of I$ form be completed). Date: December 27, 2019 Nictoria L., Gutierrez > U a (TYPE OR PRINT NAME OF attorney [___] PARTY WITHOUT ATTORNEY) (SIGNATURE) “it dismissal r juosted Is of ified parties only of specified causes of action Attorney or party without attorney for: oF of of ecified cross-c aints onl 80 stato and Identity the parties, Plaintiff/Petitioner [1 DefendanvRespondent ‘causes of action, or cross-complaints to bo "di ismisser [) cross-Complainant 3. TO THE CLERK: Consent to the above dismissal Is hereby given.** > Date: (TYPE OR PRINT NAME OF [___] ATTORNEY [___] PARTY WITHOUT ATTORNEY) (SIGNATURE) "If a cross-complaint-or Response (Family Law) seeking affirmative Attorney or party without attorney for: relief— is on file, the atto for cross-compininant (respondent) must matt consent if required by Code of Civil Procedure section 581 [1 PlaintitfiPetitioner [J Defendant/Respondent [1 Cross-Complainant (To be completed by clerk) 12/27/2019 1:17 PM 4. Dismissal entered as requested on (date): 5 [__] Dismissal entered on (date): as to only (name): 6. (_] Dismissal not entered as requested for the following reasons (specify): 12/27/2019 1:17 PM 7. @ eS) Attorney or party without attorney notified on (date): b, [] Attorney or party without attorney not notified. Filing party failed to provide a copy to be conformed [_] means to return conformed copy /s/ A. Floresca Clerk of Court Clerk, by. , Deputy Date 2/27/2019 1:17 PM Paget of2 Form Adoplod for Mandatory Use odo of Civil Procedura, GB1 ol 50q, ‘Judielal Counct of Callomia REQUEST FOR DISMISSAL Gov. Code, § 68637(6); Cal. Rules of Cou i Tula 3.1390 ‘CIV-110 [Rev. Jan, 1, 2013}, winw.courts.ca.gov CIV-110 PLAINTIFF/PETITIONER: ANDREI BELOROUSOU CASE NUMBER: DEFENDANT/RESPONDENT: KAISER FOUNDATION HOSPITALS, et al. 1 eee e COURT'S RECOVERY OF WAIVED COURT FEES AND COSTS if a party whose court fees and costs were Initially walved has recovered or will recover $10,000 or more in value by way of settlement, compromise, arbitration award, mediation settlement, or other means, the court has a statutory lien on that recovery. The court may refuse to dismiss the case until the Iten Is satisfied. (Gov. Cade, § 68637.) Declaration Concerning Waived Court Fees 1 The court waived court fees and costs in thls action for (name): 2. The person named in item t Is (check one below): a. [_] not recovering anything of value by this action. b. [_] recovering less than $10,000 In value by this action. c. [[_] recovering $10,000 or more in value by this action. (if tem 2c is checked, item 3 must be completed.) 3. (] All court fees and court costs that were walved in this action have been pald to the court (check one): [__] Yes [_] No | declare under penalty of perjury under the laws of the State of California that the information above is true and correct. Date: es << (TYPE OR PRINT NAME OF [] ATTORNEY [—] PARTY MAKING DECLARATION) (SIGNATURE) C1V.510 (Rev. Januery 1, 2015] REQUEST FOR DISMISSAL Page 2012 PROOF OF SERVICE I am a resident of the State of California, over the age of eighteen years, and not a party to the within action. My business address is 560 Mission Street, 31st Floor, San Francisco, California 94105 On December 27, 2019, I served the within document(s): e REQUEST FOR DISMISSAL by placing the document(s) listed above in a sealed envelope with postage thereon fully prepaid, x] in the United States mail at San Francisco, California, addressed as set forth below. by placing the document(s) listed above, together with a signed copy of this declaration, in a O sealed Federal Express envelope with postage paid on account and deposited with Federal Express at San Francisco, California, addressed as set forth below. by electronic service - transmitting the document(s) listed above, electronically, via Nationwide Legal to the parties set forth below 10 Kyle A. Pruner, Esq. Christian J. Rowley, Esq. 11 Victoria L. Gutierrez, Esq. Andrea Bednarova, Esq. BOHM LAW GROUP, INC. SEYFARTH SHAW LLP 12 4600 Northgate Boulevard, Suite 210 560 Mission Street, 31st Floor Sacramento, California 95834 San Francisco, California 94105 13 Telephone: 916.927.5574 Telephone: (415) 397-2823 Facsimile: 916.927.2046 Facsimile: (415) 397-8549 14 Attorneys for Plaintiff 15 Attorneys for Defendant KAISER FOUNDATION HOSPITALS 16 I am readily familiar with the firm's practice of collection and processing correspondence for mailing. Under that practice it would be deposited with the U.S. Postal Service on that same day with 17 postage thereon fully prepaid in the ordinary course of business. | am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day, 18 after date of deposit for mailing in affidavit. 19 I declare under penalty of perjury under the laws of the State of California that the above is true and correct. 20 Executed on December 27, 2019, at San Francisco, California. 21 22 4 r CU LAVA Hl. 2? 23 Chpisyince Jacobs 24 25 26 27 28 PROOF OF SERVICE / CASE NO. 17CV309032 60910853v.1