Party Notice: NPH MEDICAL SERVICES, INC V. ROCKPORT ADMINISTRATIVE

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                                1   VINAY KOHLI (State Bar No. 268430)
                           vkohli@kslaw.com
                       2   KING & SPALDING LLP
                           633 West Fifth Street, Suite 1600                                                 2/4/2021
                       3   Los Angeles, CA 90071
                           Telephone:        +1 213 443 4355
                       4   Facsimile:        +1 213 443 4310

                       5   Attorneys for Defendants
                           Rockport Administrative Services, LLC;
                       6   Windsor Redding Care Center, LLC;
                           and Defendants/Cross-Complainants
                       7   Chico Heights Rehabilitation & Wellness Centre, LP;
                           Chico Healthcare & Wellness Center, LP;
                       8   Eureka Rehabilitation & Wellness Center, LP;
                           Fortuna Rehabilitation & Wellness Center, LP;
                       9   Granada Rehabilitation & Wellness Center, LP

                     10                         SUPERIOR COURT OF THE STATE OF CALIFORNIA
                     11                  COUNTY OF BUTTE, NORTH BUTTE COUNTY COURTHOUSE
                     12

                     13    NPH MEDICAL SERVICES, INC.,                                 Case No. 19CV03695

                     14                               Plaintiff,                       Assigned for All Purposes to:
                                                                                       Hon. Tamara L. Mosbarger – Department 1
                     15             v.
                                                                                       DEFENDANTS’ AND CROSS-
                     16    ROCKPORT ADMINISTRATIVE SERVICES,                           COMPLAINANTS’ NOTICE OF
                           LLC; CHICO HEIGHTS REHABILITATION                           APPLICATION AND APPLICATION TO
                     17    & WELLNESS CENTRE, LLC; CHICO                               PERMIT LEE NUTINI TO APPEAR AS
                           HEALTHCARE & WELLNESS CENTRE,                               THEIR COUNSEL PRO HAC VICE
                     18    LLC; EUREKA REHABILITATION &
                           WELLNESS CENTER, LLC; FORTUNA                               Date:         March 10, 2021
                     19    REHABILITATION & WELLNESS CENTER,                           Time:         9:00 a.m.
                           LLC; WINDSOR REDDING CARE CENTER,                           Dept:         1
                     20    LLC; and GRANADA REHABILITATION &                           Judge:        Hon. Tamara L. Mosbarger
                           WELLNESS CENTER, LLC; and DOES 1-20,
                     21                                                                Complaint filed:         December 17, 2019
                                                      Defendants.                      Filed Answer:            January 17, 2020
                     22
                           AND RELATED CROSS ACTION
                     23

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                                 DEFENDANTS’ AND CROSS-COMPLAINANTS NOTICE OF AND APPLICATION TO PERMIT LEE NUTINI
                                                             TO APPEAR AS THEIR COUNSEL PRO HAC VICE
                           38050567.v1
                       1            TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD:

                       2            PLEASE TAKE NOTICE that, pursuant to California Rule of Court 9.40, the

                       3   undersigned attorneys for Defendants ROCKPORT ADMINISTRATIVE SERVICES, LLC and

                       4   WINDSOR REDDING CARE CENTER, LLC; and Defendants and Cross-Complainants

                       5   CHICO HEIGHTS REHABILITATION & WELLNESS CENTRE, LP (incorrectly sued as an

                       6   “LLC”); CHICO HEALTHCARE & WELLNESS CENTRE, LP (incorrectly sued as an “LLC”);

                       7   EUREKA REHABILITATION & WELLNESS CENTER, LP (incorrectly sued as an “LLC”);

                       8   FORTUNA REHABILITATION & WELLNESS CENTER, LP (incorrectly sued as an “LLC”);

                       9   GRANADA REHABILITATION & WELLNESS CENTER, LP (incorrectly sued as an “LLC”),

                     10    will appear before the Honorable Tamara L. Mosbarger of the above-named Court at 1775

                     11    Concord Avenue, Chico, CA 95928, on March 10, 2020, at 9:00 a.m. or as soon thereafter as

                     12    counsel may be heard, to apply for an Order permitting attorney Lee Nutini to appear as counsel

                     13    pro hac vice for these Defendants and Cross-Complainants.

                     14             This application will be based upon this notice as well as the verified application of Lee

                     15    Nutini submitted contemporaneously therewith.              This motion will be based upon all records and

                     16    files in possession of the Court and upon any oral argument or further evidence as the Court may

                     17    receive at the hearing on this application.

                     18

                     19    DATED:      February 4, 2021.                            KING & SPALDING LLP
                     20

                     21                                                             By:   __________________________________
                                                                                          Vinay Kohli
                     22                                                                   Attorneys for Defendants
                                                                                          Rockport Administrative Services, LLC;
                     23                                                                   Chico Heights Rehabilitation & Wellness
                                                                                          Centre, LP; Chico Healthcare & Wellness
                     24
                                                                                          Centre, LP; Eureka Rehabilitation &
                     25                                                                   Wellness Center, LP; Fortuna Rehabilitation
                                                                                          & Wellness Center, LP; Granada
                     26                                                                   Rehabilitation & Wellness Center, LP;
                                                                                          Windsor Redding Care Center, LLC
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                     28                                                               1
                                         DEFENDANT’S NOTICE OF APPLICATION AND APPLICATION TO PERMIT LEE NUTINI
                                                             TO APPEAR AS THEIR COUNSEL PRO HAC VICE
                           38050567.v1
                       1                                               PROOF OF SERVICE

                       2
                           I am a citizen of the United States and resident of the State of California.             I am employed in the
                       3   county of Los Angeles, State of California, in the office of a member of the bar of this Court, at
                           whose direction this service was made.          I am over the age of eighteen years and not a party to the
                       4   within action.
                       5   On February 4, 2021, I served the following documents in the manner described below:
                       6         DEFENDANTS’ AND CROSS-COMPLAINANTS’ NOTICE OF APPLICATION
                                     AND APPLICATION TO PERMIT LEE NUTINI TO APPEAR AS THEIR
                       7                                           COUNSEL PRO HAC VICE
                       8
                           On the following party(ies) in this action:
                       9
                            Les Hait, Esq.
                     10     LES HAIT LAW CORPORATION
                            762 East Avenue
                     11     Chico, CA     95926
                     12     Tel:     (530) 895-3352
                            Fax:     (530) 895-0401
                     13     Email:    leshaitlaw@gmail.com

                     14     Jeffrey J. Swanson, Esq.
                            SWANSON LAW OFFICE
                     15
                            2515 Park Marina Drive, Suite 102
                     16     Redding, CA      96001
                            Tel:     (530) 225-8773
                     17     Fax:     (530) 232-27722
                            Email:    jeff@jswansonlaw.com
                     18

                     19
                               ☒       BY ELECTRONIC SERVICE:                 By electronically mailing a true and correct copy
                     20                through King & Spalding LLP’s electronic mail system to the email addresses set
                                       forth above.
                     21

                     22             I declare under penalty of perjury under the laws of the State of California that the
                     23    foregoing is true and correct.

                     24             Executed on February 4, 2021, at Los Angeles, California.

                     25

                     26
                                                                                  Patricia Newler
                     27

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                                 DEFENDANTS’ AND CROSS-COMPLAINANTS NOTICE OF AND APPLICATION TO PERMIT LEE NUTINI
                                                             TO APPEAR AS THEIR COUNSEL PRO HAC VICE
                           38050567.v1