On March 04, 2015 a
Letter,Correspondence
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.
Preview
THERESA J. BARTA (State Bar No. 150995)
BARTA LAW
4041 MacArthur B1vd.,
Newport Beach,
Suite 280
California 92660
ILE _
Tel. (949) 833-3383 JAN 2 0 2018
Fax (949) 209-2530
Email: theresa@barta-1aw.com Clerk of Court
C
Superfior I Santa Clara
ty o!
'
BY DEPUTY
Attorney for Plaintiff,
Diana P. Blum, M.D.
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SANTA CLARA
l0 DIANA P. BLUM, M.D., Case No. 115-CV-277582
ll
STIPULATION OF FACT
Plaintiff, RE: PATIENT NOTIFICATION
12 LETTERS
VS.
13 Trial Date: January 8, 2018
SUTTER HEALTH, a California corporation'
Time: 8:45 a.m.
a
l4 PALO ALTO FOUNDATION MEDICAL Dept;
VWWVVVVVWVWVVW
16
GROUP, a California corporation; PALO Judge: Hon. Drew C. Takaichi
15 ALTO MEDICAL FOUNDATION, a
California corporation; and DOES 1 through
16 20,
Defendants.
l7
18
l9
20
21
22
23
24
STIPULATED FACT
Exhibit 602 isa copy ofthe 1,132 letters that were sent on September l1,
2013 to patients that Dr. Blum saw or treated while she was employed at the
Physician Group. The names, addresses, and medical record numbers ofthe
patients have been redacted for privacy reasons. There were no other versions of
this letter thatwere sent to patients.
Exhibit 83 is a list0fthe patients who were sent the letter (Exhibit 602).
The patients’ lastnames have been redacted for privacy reasons.
10
ll Exhibit 83 and Exhibit 602 are admitted into evidence.
12
M
Dated: January 22, 2018
13
(ledbwfla—
14
Theresa J. Band
Attorney for Plaintiff, Dr. Diana Blum
15
16
Dated: January 22, 201 8
17
GORDON REES SCULLY
MANSUKHANI, LLP
l8
Marcie Fitzsimmons
Attorney for Defendant, Palo Alto Foundation
l9
Medical Group, Inc.
20 Dated: January 22, 2018
21
22 LITTLER MENDELSON, P.C.
Lindbergh Porter
23
Attorney for Defendants Sutter Health and
Palo Alto Medical Foundation
24
Document Filed Date
January 25, 2018
Case Filing Date
March 04, 2015
Category
Wrongful Termination Unlimited(36)
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THERESA J. BARTA (State Bar No. 150995) BARTA LAW 4041 MacArthur B1vd., Newport Beach, Suite 280 California 92660 ILE _ Tel. (949) 833-3383 JAN 2 0 2018 Fax (949) 209-2530 Email: theresa@barta-1aw.com Clerk of Court C Superfior I Santa Clara ty o! ' BY DEPUTY Attorney for Plaintiff, Diana P. Blum, M.D. SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CLARA l0 DIANA P. BLUM, M.D., Case No. 115-CV-277582 ll STIPULATION OF FACT Plaintiff, RE: PATIENT NOTIFICATION 12 LETTERS VS. 13 Trial Date: January 8, 2018 SUTTER HEALTH, a California corporation' Time: 8:45 a.m. a l4 PALO ALTO FOUNDATION MEDICAL Dept; VWWVVVVVWVWVVW 16 GROUP, a California corporation; PALO Judge: Hon. Drew C. Takaichi 15 ALTO MEDICAL FOUNDATION, a California corporation; and DOES 1 through 16 20, Defendants. l7 18 l9 20 21 22 23 24 STIPULATED FACT Exhibit 602 isa copy ofthe 1,132 letters that were sent on September l1, 2013 to patients that Dr. Blum saw or treated while she was employed at the Physician Group. The names, addresses, and medical record numbers ofthe patients have been redacted for privacy reasons. There were no other versions of this letter thatwere sent to patients. Exhibit 83 is a list0fthe patients who were sent the letter (Exhibit 602). The patients’ lastnames have been redacted for privacy reasons. 10 ll Exhibit 83 and Exhibit 602 are admitted into evidence. 12 M Dated: January 22, 2018 13 (ledbwfla— 14 Theresa J. Band Attorney for Plaintiff, Dr. Diana Blum 15 16 Dated: January 22, 201 8 17 GORDON REES SCULLY MANSUKHANI, LLP l8 Marcie Fitzsimmons Attorney for Defendant, Palo Alto Foundation l9 Medical Group, Inc. 20 Dated: January 22, 2018 21 22 LITTLER MENDELSON, P.C. Lindbergh Porter 23 Attorney for Defendants Sutter Health and Palo Alto Medical Foundation 24