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“uMpwanason rc,
SUPERIOR COURT
1 | ELIZABETH STAGGS WILSON, Bar No. 183160 2017 DEC 13 AMO: 45
SHANNON R. BOYCE, Bar No. 325041 ,
Erie LET
esi treet, 63rd Floor f . an a
Los Angeles, CA 90071 ht,
Telephone: 213.443.4300 QEPUTY
Facsimile; 213.443.4299:
JOSE MACIAS, JR., Bar No. 265033
LITTLER MENDELSON, P.C.
50 W. San Fernando, 7th Floor
San Jose, CA 95113,2303
Telephone: 408.998.4150
Facsimile: 408,288.5686
Dow A WA BW WD
Attomeys for Defendants
DOCTORS HOSPITAL OF MANTECA, INC.;
10 | AUXILIARY OF DOCTORS HOSPITAL OF
MANTECA; TENET HEALTHCARE
11 || CORPORATION; TENET HEALTH
INTEGRATED SERVICES, INC.
SUPERIOR COURT OF CALIFORNIA
14 COUNTY OF SAN JOAQUIN, STOCKTON BRANCH
15 | REGINALD LYLE, on behalf of himself Case No. STK-CV-UOE-2016-6523
and others similarly situated,
16 : CLASS ACTION
Plaintiff,
7 ASSIGNED FOR ALL PURPOSES TO JUDGE
vy. ELIZABETH HUMPHREYS, DEPT. 22
18 Tt doctors HOSPITAL OF MANTECA, DECLARATION OF SHANNON R. BOYCE
19 | INC. AUXILIARY OF DOCTORS IN SUPPORT OF DEFENDANTS’
HOSPITAL OF MANTECA; DRS HOSP OPPOSITION TO PLAINTIFF'S EX PARTE
20 || OF MANTECA INC; SP OF MANTECA APPLICATION TO APPOINT A NEW
INC; TENET HEALTHCARE DISCOVERY REFEREE OR, IN THE.
21 || CORPORATION; TENET HEALTH ALTERNATIVE, TO SET A HEARING FOR
INTEGRATED SERVICES, INC.; TENET | PLAINTIFF'S MOTIONS TO COMPEL
9, | HEALTH; and DOES I to 100, Inclusive, DEFENDANT'S FURTHER RESPONSESTO
SPECIAL INTERROGATORIES, SET ONE
23 Defendants. AND REQUESTS FOR PRODUCITON OF
{ DOCUMENTS, SET ONE AND 'TO
oa CONTINUE TRIAL AND TRIAL-RELATED
DEADLINE
3 Date: December 14, 2017
26 1 Time: 8:30 a.m.
: Dept: 10C.
27 Complaint Filed: July 5, 2016
Trial Date: February 26, 2016
Case No, STK-CV-UOE-2016-6523
Sates DECLARATION OF SHANNON R, BOYCE IN SUPPORT OF DEFENDANTS’ OPPOSITION TO PLAINTIFF'S
vtec EX PARTE APPLICATION
maecl
oOo oc TD A PF YH De
Ree ~
PBSerARtaartauset= s
22
ummupoasaire,
‘aa Moonined
NUON
I, Shannon R. Boyce, declare as follows:
L [ am an attorney licensed to practice law before the courts of the State of
California. I am a Shareholder at the law finn of Littler Mendelson, A Professional Corporation,
which has been retaincd by Defendants DOCTORS HOSPITAL OF MANTECA, INC.,
AUXILIARY OF DOCTORS. HOSPITAL OF MANTECA, DRS HOSP OF MANTECA INC, SP
OF MANTECA INC, TENET HEALTHCARE CORPORATION, TENET HEALTH
INTEGRATED SERVICES, INC., and TENET HEALTH (collectively “Defendants” in the above-
captioned matter. I have personal knowledge of the facts set forth herein and, if called as a witness,
could testify competently thereto.
2, I made this declaration in support of Defendants’ Opposition to Plaintiff's Ex |
Parte Application to Appoint a New Discovery Referee Or, in the Alternative, to Set a Hearing for
Plaintiff's Motion to Compe! Defendant's Further Responses to Special Interrogatories, Set One and
Requests for Production of Documents, Set One and to Continue Trial and Trial-related Deadlines.
3. At the Parties’ April 3, 2017, Trial Setting Conference, this Court set a trial
date of February 26, 2018.
4. Approximately two months after filing the present putative class action,
Plaintiff Reginald Lyle filed a second action against all of the same Defendants in this exact same
court on September 19, 2016, entitled Lyle v. Doctors Hospital of Manteca, Inc. et al., San Joaquin
County Superior Court, Case No. STK-CV-UWT-2016-9383, Plaintiff Lyle is being represented by
the same attorneys. As in his present putative class action, Plaintiff has only served a single set of
written discovery and has failed to take or even request any dates for a single deposition.
5. Defendants propounded written discovery on June 27, 2087, Plaintiff.
fequested multiple extensions to respond to this discovery, which Defendants granted out of
professional courtesy.
6, After being provided with additional time to respond, Plaintiff served only
objections to Defendants’ discovery on August 22, 2017. When Defendants met and conferred with
2. Case No. STK-C¥-UQE-2016-6523
DECLARATION OF SHANNON R. BOYCE IN SUPPORT OF DEFENDANTS’ OPPOSITION TO PLAINTIFF'S
EX PARTE APPLICATIONCe NY HA HW FB WY PP A
URED soNPs
Ca tiea Soret
‘Sosfbo
os Amel, CA S007
2a eKD
Plaintiff, he then provided incomplete supplemental responses on September 29, 2017, without
verification, which are the subject of ongoing meet and confer efforts.
4. Defendants initially noticed Plaintiff's deposition for August 31, 2017, but we
were forced to continue the deposition date due to Plaintiff's requests for extension on written
discovery and subsequent incomplete responses provided, After attempting for months to secure an
altemative deposition date for Plaintiff, Defendants were forced to unilaterally notice the deposition
for December 19, 2017,
I declare under penalty of perjury under the laws of the State of Califomia that the
foregoing is true and correct.
Executed this 13th day of December, yin Los Angeles, California.
SHANNON R, BOYCE
Finmvvide:151730115,1 052845.1344
3. Case No, STK-CV-UOE-2016-6523
DECLARATION OF SHANNON R, BOYCE IN SUPPORT OF DEFENDANTS’ OPPOSITION TO PLAINTIFF'S
EX PARTE APPLICATION
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“uMpwanason rc, SUPERIOR COURT 1 | ELIZABETH STAGGS WILSON, Bar No. 183160 2017 DEC 13 AMO: 45 SHANNON R. BOYCE, Bar No. 325041 , Erie LET esi treet, 63rd Floor f . an a Los Angeles, CA 90071 ht, Telephone: 213.443.4300 QEPUTY Facsimile; 213.443.4299: JOSE MACIAS, JR., Bar No. 265033 LITTLER MENDELSON, P.C. 50 W. San Fernando, 7th Floor San Jose, CA 95113,2303 Telephone: 408.998.4150 Facsimile: 408,288.5686 Dow A WA BW WD Attomeys for Defendants DOCTORS HOSPITAL OF MANTECA, INC.; 10 | AUXILIARY OF DOCTORS HOSPITAL OF MANTECA; TENET HEALTHCARE 11 || CORPORATION; TENET HEALTH INTEGRATED SERVICES, INC. SUPERIOR COURT OF CALIFORNIA 14 COUNTY OF SAN JOAQUIN, STOCKTON BRANCH 15 | REGINALD LYLE, on behalf of himself Case No. STK-CV-UOE-2016-6523 and others similarly situated, 16 : CLASS ACTION Plaintiff, 7 ASSIGNED FOR ALL PURPOSES TO JUDGE vy. ELIZABETH HUMPHREYS, DEPT. 22 18 Tt doctors HOSPITAL OF MANTECA, DECLARATION OF SHANNON R. BOYCE 19 | INC. AUXILIARY OF DOCTORS IN SUPPORT OF DEFENDANTS’ HOSPITAL OF MANTECA; DRS HOSP OPPOSITION TO PLAINTIFF'S EX PARTE 20 || OF MANTECA INC; SP OF MANTECA APPLICATION TO APPOINT A NEW INC; TENET HEALTHCARE DISCOVERY REFEREE OR, IN THE. 21 || CORPORATION; TENET HEALTH ALTERNATIVE, TO SET A HEARING FOR INTEGRATED SERVICES, INC.; TENET | PLAINTIFF'S MOTIONS TO COMPEL 9, | HEALTH; and DOES I to 100, Inclusive, DEFENDANT'S FURTHER RESPONSESTO SPECIAL INTERROGATORIES, SET ONE 23 Defendants. AND REQUESTS FOR PRODUCITON OF { DOCUMENTS, SET ONE AND 'TO oa CONTINUE TRIAL AND TRIAL-RELATED DEADLINE 3 Date: December 14, 2017 26 1 Time: 8:30 a.m. : Dept: 10C. 27 Complaint Filed: July 5, 2016 Trial Date: February 26, 2016 Case No, STK-CV-UOE-2016-6523 Sates DECLARATION OF SHANNON R, BOYCE IN SUPPORT OF DEFENDANTS’ OPPOSITION TO PLAINTIFF'S vtec EX PARTE APPLICATION maecl oOo oc TD A PF YH De Ree ~ PBSerARtaartauset= s 22 ummupoasaire, ‘aa Moonined NUON I, Shannon R. Boyce, declare as follows: L [ am an attorney licensed to practice law before the courts of the State of California. I am a Shareholder at the law finn of Littler Mendelson, A Professional Corporation, which has been retaincd by Defendants DOCTORS HOSPITAL OF MANTECA, INC., AUXILIARY OF DOCTORS. HOSPITAL OF MANTECA, DRS HOSP OF MANTECA INC, SP OF MANTECA INC, TENET HEALTHCARE CORPORATION, TENET HEALTH INTEGRATED SERVICES, INC., and TENET HEALTH (collectively “Defendants” in the above- captioned matter. I have personal knowledge of the facts set forth herein and, if called as a witness, could testify competently thereto. 2, I made this declaration in support of Defendants’ Opposition to Plaintiff's Ex | Parte Application to Appoint a New Discovery Referee Or, in the Alternative, to Set a Hearing for Plaintiff's Motion to Compe! Defendant's Further Responses to Special Interrogatories, Set One and Requests for Production of Documents, Set One and to Continue Trial and Trial-related Deadlines. 3. At the Parties’ April 3, 2017, Trial Setting Conference, this Court set a trial date of February 26, 2018. 4. Approximately two months after filing the present putative class action, Plaintiff Reginald Lyle filed a second action against all of the same Defendants in this exact same court on September 19, 2016, entitled Lyle v. Doctors Hospital of Manteca, Inc. et al., San Joaquin County Superior Court, Case No. STK-CV-UWT-2016-9383, Plaintiff Lyle is being represented by the same attorneys. As in his present putative class action, Plaintiff has only served a single set of written discovery and has failed to take or even request any dates for a single deposition. 5. Defendants propounded written discovery on June 27, 2087, Plaintiff. fequested multiple extensions to respond to this discovery, which Defendants granted out of professional courtesy. 6, After being provided with additional time to respond, Plaintiff served only objections to Defendants’ discovery on August 22, 2017. When Defendants met and conferred with 2. Case No. STK-C¥-UQE-2016-6523 DECLARATION OF SHANNON R. BOYCE IN SUPPORT OF DEFENDANTS’ OPPOSITION TO PLAINTIFF'S EX PARTE APPLICATIONCe NY HA HW FB WY PP A URED soNPs Ca tiea Soret ‘Sosfbo os Amel, CA S007 2a eKD Plaintiff, he then provided incomplete supplemental responses on September 29, 2017, without verification, which are the subject of ongoing meet and confer efforts. 4. Defendants initially noticed Plaintiff's deposition for August 31, 2017, but we were forced to continue the deposition date due to Plaintiff's requests for extension on written discovery and subsequent incomplete responses provided, After attempting for months to secure an altemative deposition date for Plaintiff, Defendants were forced to unilaterally notice the deposition for December 19, 2017, I declare under penalty of perjury under the laws of the State of Califomia that the foregoing is true and correct. Executed this 13th day of December, yin Los Angeles, California. SHANNON R, BOYCE Finmvvide:151730115,1 052845.1344 3. Case No, STK-CV-UOE-2016-6523 DECLARATION OF SHANNON R, BOYCE IN SUPPORT OF DEFENDANTS’ OPPOSITION TO PLAINTIFF'S EX PARTE APPLICATION