On March 04, 2015 a
Motion-Secondary
was filed
involving a dispute between
Diana P. Blum,
and
Palo Alto Foundation Medical Group, Inc.,
Palo Alto Medical Foundation,
Sutter Health,
for Wrongful Termination Unlimited(36)
in the District Court of Santa Clara County.
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Theresa J Barta, SBN 150995
BARTA LAW
4041 Macarthur Blvd., Ste. 280
Newport Beach, CA 92660
Telephone: (949) 833
Facsimile: (949) 209
Email: theresa@barta law.com
Charles M. Louderback, SBN 88788
Stacey L. Pratt, SBN 124892
LOUDERBACK LAW GROUP
44 Montgomery Street, Suite 2970
San Francisco, CA 94104
Telephone: (415) 615
Facsimile: (415) 795
Mail: clouderback@louderbackgroup.com
spratt@louderbackgroup.com
Attorneys for Plaintiff
DIANA P. BLUM, M.D.
IN AND FOR THE STATE OF CALIFORNIA
COUNTY OF SANTA CLARA UNLIMITED JURISDICTION
DIANA P. BLUM, M.D. Civil Case No.
Plaintiff,
REPLY DECLARATION OF
THERESA J. BARTA IN SUPPORT OF
PLAINTIFF’S MOTION TO STRIKE
SUTTER HEALTH, a California corporation; AND TAX DEFENDANTS SUTTER
PALO ALTO FOUNDATION MEDICAL HEALTH AND PALO ALTO
GROUP, INC., a California corporation; PALO MEDICAL FOUNDATION’S
MEMORANDUM OF COSTS
ALTO MEDICAL FOUNDATION
California corporation; and DOES 1 through 20, Date: April
Time: 1:30 p.m.
Defendants. Dept:
Judge: Hon. Drew C. Takaichi
Complaint filed: March 4, 2015
Trial Date: January 8, 2018
00022475 v2
REPLY DECLARATION OF THERESA J. BARTA IN SUPPORT OF PLAINTIFF’S MOTION TO STRIKE
AND TAX DEFENDANTS SUTTER HEALTH AND PALO ALTO MEDICAL FOUNDATION’S
MEMORANDUM OF COSTS Case No. 2015 277582
I, THERESA J. BARTA, declare:
I am an attorney duly licensed to practice before all the courts of the State of
California and am the sole member of Barta Law. Along with co counsel from the Louderback
Law Group, who has recently become associated as counsel, I represent Plaintiff Diana Blum,
M.D. in this action. I served as trial counsel in this action. The matters stated herein are of my
own personal knowledge and if called to testify to these matters, I could and would competently
testify thereto.
During the duration of the trial in this action, I stayed at the Residence Inn in San
Jose at a cost of $259 per night.
Attached hereto as Exhibit A is a true and correct copy of the notice of appeal filed
April 6, 2018 from the order of nonsuit and judgment entered in favor of defendants Sutter Health
and Palo Alto Medical Foundation.
Executed this day of April, 2018 in Newport Beach, California.
I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
Theresa J Barta
00022475 v2
REPLY DECLARATION OF THERESA J. BARTA IN SUPPORT OF PLAINTIFF’S MOTION TO STRIKE
AND TAX DEFENDANTS SUTTER HEALTH AND PALO ALTO MEDICAL FOUNDATION’S
MEMORANDUM OF COSTS Case No. 2015 277582
EXHIBIT A
Document Filed Date
April 16, 2018
Case Filing Date
March 04, 2015
Category
Wrongful Termination Unlimited(36)
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Theresa J Barta, SBN 150995 BARTA LAW 4041 Macarthur Blvd., Ste. 280 Newport Beach, CA 92660 Telephone: (949) 833 Facsimile: (949) 209 Email: theresa@barta law.com Charles M. Louderback, SBN 88788 Stacey L. Pratt, SBN 124892 LOUDERBACK LAW GROUP 44 Montgomery Street, Suite 2970 San Francisco, CA 94104 Telephone: (415) 615 Facsimile: (415) 795 Mail: clouderback@louderbackgroup.com spratt@louderbackgroup.com Attorneys for Plaintiff DIANA P. BLUM, M.D. IN AND FOR THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA UNLIMITED JURISDICTION DIANA P. BLUM, M.D. Civil Case No. Plaintiff, REPLY DECLARATION OF THERESA J. BARTA IN SUPPORT OF PLAINTIFF’S MOTION TO STRIKE SUTTER HEALTH, a California corporation; AND TAX DEFENDANTS SUTTER PALO ALTO FOUNDATION MEDICAL HEALTH AND PALO ALTO GROUP, INC., a California corporation; PALO MEDICAL FOUNDATION’S MEMORANDUM OF COSTS ALTO MEDICAL FOUNDATION California corporation; and DOES 1 through 20, Date: April Time: 1:30 p.m. Defendants. Dept: Judge: Hon. Drew C. Takaichi Complaint filed: March 4, 2015 Trial Date: January 8, 2018 00022475 v2 REPLY DECLARATION OF THERESA J. BARTA IN SUPPORT OF PLAINTIFF’S MOTION TO STRIKE AND TAX DEFENDANTS SUTTER HEALTH AND PALO ALTO MEDICAL FOUNDATION’S MEMORANDUM OF COSTS Case No. 2015 277582 I, THERESA J. BARTA, declare: I am an attorney duly licensed to practice before all the courts of the State of California and am the sole member of Barta Law. Along with co counsel from the Louderback Law Group, who has recently become associated as counsel, I represent Plaintiff Diana Blum, M.D. in this action. I served as trial counsel in this action. The matters stated herein are of my own personal knowledge and if called to testify to these matters, I could and would competently testify thereto. During the duration of the trial in this action, I stayed at the Residence Inn in San Jose at a cost of $259 per night. Attached hereto as Exhibit A is a true and correct copy of the notice of appeal filed April 6, 2018 from the order of nonsuit and judgment entered in favor of defendants Sutter Health and Palo Alto Medical Foundation. Executed this day of April, 2018 in Newport Beach, California. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Theresa J Barta 00022475 v2 REPLY DECLARATION OF THERESA J. BARTA IN SUPPORT OF PLAINTIFF’S MOTION TO STRIKE AND TAX DEFENDANTS SUTTER HEALTH AND PALO ALTO MEDICAL FOUNDATION’S MEMORANDUM OF COSTS Case No. 2015 277582 EXHIBIT A