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BY FAX
Joseph Antonelli, Esq. (Bar No. 137039)
JAntonelli@antonellilaw.com
Janelle Carney, Esq. (Bar No. 201570)
JCarney@antonellilaw.com
LAW OFFICE OF JOSEPH ANTONELLI
14758 Pipeline Ave., Suite E, 2nd Floor
Chino Hills, CA 91709
Tel.: (909) 393-0223 / Fax: (909) 393-0471
Joseph Lavi, Esq. (SBN 209776)
Vincent C. Granberry, Esq. (SBN 276483)
LAVI & EBRAHIMIAN, LLP
8889 W. Olympic Blvd., Suite 200
Beverly Hills, California 90211
Telephone: (310) 432-0000
Facsimile: (310) 432-0001
David M. deRubertis (SBN 208709)
The deRubertis Law Firm, APC
4219 Coldwater Canyon Avenue
Studio City, California 91604
Telephone: (818) 761-2322
Facsimile: (818) 761-2323
e-mail: David@deRubertisLaw.com
Attorneys for PLAINTIFF REGINALD LYLE,
on behalf of himself and others similarly situated.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN JOAQUIN
REGINALD LYLE, on behalf of himself and
others similarly situated,
Plaintiff,
Vv.
DOCTORS HOSPITAL OF MANTECA, INC.;
AUXILLARY OF DOCTORS HOSPITAL OF
MANTECA; DRS HOSP OF MANTECA INC;
SP. OF MANTECA INC; TENET
HEALTHCARE CORPORATION; TENET
HEALTH INTEGRATED SERVICES, INC.;
TENET HEALTH; and DOES 1 to 100,
inclusive,
Defendants
eee
ORIGINAL |
Gy. FILED
ERIOR COURT
MIO MAR (8 PH fg
ROSA SUNQUEIRO, CLE
a
Case No.: STK-CV-UOE-2016-6523
Hon. Michael Mulvihill
Dept, 10C
CLASS ACTION
PROOF OF SERVICE RE: MOTION TO
COMPLY
Submitted to the Discovery Referee
Submission Date: April 11] 2019
Action Filed: July 5, 2016
Trial Date: June 10, 2019
PROOF OF SERVICE RE: MOTION TO COMPLY
a
RK
™NoO mR AH Bw ND
PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF SAN BERNARDINO
lam employed in the County of San Bernardino, State of California. I ant over the age off
eighteen (18) and not a party to the within action; my business address is 14758 Yipeline
Avenue, Suite E, Second Floor, Chino Hills, CA 91709-6025.
envelopes addressed as stated below:
ELIZABETH STAGGS WILSON
SHANNON R. BOYCE
LITTLER MENDELSON, P.C.
633 West Sth Street, 63rd Floor
Los Angeles, CA 90071
M
On March 15, 2019, I served the foregoing document described as:
1.
NOTICE OF PLAINTIFF’S MOTION TO COMPLY WITH DEFENDANT
DOCTORS HOSPITAL OF MANTECA’S RESPONSES TO PLAINTIFE’S
REQUESTS FOR PRODUCTION OF DOCUMENTS, SETS [WO (2)
THROUGH FIVE (5) AND/OR EVIDENTIARY SANCTION|FOR
FAILURE TO COMPLY;
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF
PLAINTIFF’S MOTION TO COMPLY WITH DEFENDANY DOCTOHS
HOSPITAL OF MANTECA’S RESPONSES TO PLAINTIFIPS
REQUESTS FOR PRODUCTION OF DOCUMENTS, SET'S |I'WO (2)
THROUGH FIVE (5) AND/OR EVIDENTIARY SANCTION|FOR |
FAILURE TO COMPLY); :
DECLARATION OF JANELLE CARNEY IN SUPPORT OF| PLAINTIFE’S
MOTION TO COMPLY WITH DEFENDANT DOCTORS HLOSPITAL OF
MANTECA’S RESPONSES TO PLAINTIFF’S REQUESTS fon
PRODUCTION OF DOCUMENTS, SETS TWO (2) THROUGH FIVE (5)
AND/OR EVIDENTIARY SANCTION FOR FAILURE TO COMPLY;
SEPARATE STATEMENT IN SUPPORT OF PLAINTIFF’S|MOTION TO
COMPLY WITH DEFENDANT DOCTORS HOSPITAL OF MANTECA’S
RESPONSES TO PLAINTIFF’S REQUESTS FOR PRODUCTION OF
DOCUMENTS, SETS TWO (2) THROUGH FIVE (5) AND/OR
EVIDENTIARY SANCTION FOR FAILURE TO COMPLY);
on INTERESTED PARTIES in this action by placing a copy thereof enclosed in scaled
1
PROOF OF SERVICE RE: MOTION TO COMPLYCo wo RIA A HW Rh wYw HN
MPN NN NN NY DY He ee Be Be Be Se ee eS
eI AA FY PB =F SF OD we IA DAH RY NH HK SD
JOHN A. ABBOTT
2453 Grand Canal Blvd. 2" Floor
Stockton, CA 95207
XX BY FEDERAL EXPRESS: I deposited in a box or other facility regularly
FEDERAL EXPRESS, an express service carrier, or delivered to a courier or dri
by said express service carrier to receive documents, together with an unsigned et
declaration, in an envelope designated by the said express service carrier, with dq
or provided for.
JOSE MACIAS, JR.
LITTLER MENDELSON, P.C.
50 W. San Fernando, 15th Floor
San Jose, CA 95113.2303
XX BY MAIL: Iam "readily familiar" with the firm's practice of collection at
maintained |by
er authorized
py of this *
‘liver fees paid
nd processing
correspondence for mailing. Under that practice it would be deposited with U.S. Postal service
on that same day with postage thereon fully prepaid at CHINO HILLS, California in the ordinary}
course of business. I am aware that on motion of the party served, service is pres}
ed invalid if
postal cancellation date or postage meter date is more than one day after date of deposit for
mailing in affidavit.
Joseph Lavi, Esq. (SBN 209776) Vincent C. David M. deRubertis (SBN 208709)
Granberry, Esq. (SBN 276483) The deRubertis Law Firm, APC 4219
LAVI & EBRAHIMIAN, LLP 8889 W. Coldwater Canyon Avenue Stutlio City,
Olympic Blvd., Suite 200 Beverly Hills, Califoria 91604 e-mail: |
California 90211 David@deRubertisLaw.com :
jlavi@lelawfirm.com
Vegranberry@lelawfirm.com
XX BY E-MAIL: I electronically served the above-mentioned documents to each of the
recipients at their respective e-mail addresses. My e-mail address is: Kligh@antoy
Executed on March 15, 2019 at Chino Hills, California.
I declare under penalty of perjury under the laws of the State of Californi
is true and correct.
Kimberly Ligh
2
ellilaw.com
that the above
PROOF OF SERVICE RE: MOTION TO COMPLY
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BY FAX Joseph Antonelli, Esq. (Bar No. 137039) JAntonelli@antonellilaw.com Janelle Carney, Esq. (Bar No. 201570) JCarney@antonellilaw.com LAW OFFICE OF JOSEPH ANTONELLI 14758 Pipeline Ave., Suite E, 2nd Floor Chino Hills, CA 91709 Tel.: (909) 393-0223 / Fax: (909) 393-0471 Joseph Lavi, Esq. (SBN 209776) Vincent C. Granberry, Esq. (SBN 276483) LAVI & EBRAHIMIAN, LLP 8889 W. Olympic Blvd., Suite 200 Beverly Hills, California 90211 Telephone: (310) 432-0000 Facsimile: (310) 432-0001 David M. deRubertis (SBN 208709) The deRubertis Law Firm, APC 4219 Coldwater Canyon Avenue Studio City, California 91604 Telephone: (818) 761-2322 Facsimile: (818) 761-2323 e-mail: David@deRubertisLaw.com Attorneys for PLAINTIFF REGINALD LYLE, on behalf of himself and others similarly situated. SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN JOAQUIN REGINALD LYLE, on behalf of himself and others similarly situated, Plaintiff, Vv. DOCTORS HOSPITAL OF MANTECA, INC.; AUXILLARY OF DOCTORS HOSPITAL OF MANTECA; DRS HOSP OF MANTECA INC; SP. OF MANTECA INC; TENET HEALTHCARE CORPORATION; TENET HEALTH INTEGRATED SERVICES, INC.; TENET HEALTH; and DOES 1 to 100, inclusive, Defendants eee ORIGINAL | Gy. FILED ERIOR COURT MIO MAR (8 PH fg ROSA SUNQUEIRO, CLE a Case No.: STK-CV-UOE-2016-6523 Hon. Michael Mulvihill Dept, 10C CLASS ACTION PROOF OF SERVICE RE: MOTION TO COMPLY Submitted to the Discovery Referee Submission Date: April 11] 2019 Action Filed: July 5, 2016 Trial Date: June 10, 2019 PROOF OF SERVICE RE: MOTION TO COMPLY a RK ™NoO mR AH Bw ND PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF SAN BERNARDINO lam employed in the County of San Bernardino, State of California. I ant over the age off eighteen (18) and not a party to the within action; my business address is 14758 Yipeline Avenue, Suite E, Second Floor, Chino Hills, CA 91709-6025. envelopes addressed as stated below: ELIZABETH STAGGS WILSON SHANNON R. BOYCE LITTLER MENDELSON, P.C. 633 West Sth Street, 63rd Floor Los Angeles, CA 90071 M On March 15, 2019, I served the foregoing document described as: 1. NOTICE OF PLAINTIFF’S MOTION TO COMPLY WITH DEFENDANT DOCTORS HOSPITAL OF MANTECA’S RESPONSES TO PLAINTIFE’S REQUESTS FOR PRODUCTION OF DOCUMENTS, SETS [WO (2) THROUGH FIVE (5) AND/OR EVIDENTIARY SANCTION|FOR FAILURE TO COMPLY; MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF PLAINTIFF’S MOTION TO COMPLY WITH DEFENDANY DOCTOHS HOSPITAL OF MANTECA’S RESPONSES TO PLAINTIFIPS REQUESTS FOR PRODUCTION OF DOCUMENTS, SET'S |I'WO (2) THROUGH FIVE (5) AND/OR EVIDENTIARY SANCTION|FOR | FAILURE TO COMPLY); : DECLARATION OF JANELLE CARNEY IN SUPPORT OF| PLAINTIFE’S MOTION TO COMPLY WITH DEFENDANT DOCTORS HLOSPITAL OF MANTECA’S RESPONSES TO PLAINTIFF’S REQUESTS fon PRODUCTION OF DOCUMENTS, SETS TWO (2) THROUGH FIVE (5) AND/OR EVIDENTIARY SANCTION FOR FAILURE TO COMPLY; SEPARATE STATEMENT IN SUPPORT OF PLAINTIFF’S|MOTION TO COMPLY WITH DEFENDANT DOCTORS HOSPITAL OF MANTECA’S RESPONSES TO PLAINTIFF’S REQUESTS FOR PRODUCTION OF DOCUMENTS, SETS TWO (2) THROUGH FIVE (5) AND/OR EVIDENTIARY SANCTION FOR FAILURE TO COMPLY); on INTERESTED PARTIES in this action by placing a copy thereof enclosed in scaled 1 PROOF OF SERVICE RE: MOTION TO COMPLYCo wo RIA A HW Rh wYw HN MPN NN NN NY DY He ee Be Be Be Se ee eS eI AA FY PB =F SF OD we IA DAH RY NH HK SD JOHN A. ABBOTT 2453 Grand Canal Blvd. 2" Floor Stockton, CA 95207 XX BY FEDERAL EXPRESS: I deposited in a box or other facility regularly FEDERAL EXPRESS, an express service carrier, or delivered to a courier or dri by said express service carrier to receive documents, together with an unsigned et declaration, in an envelope designated by the said express service carrier, with dq or provided for. JOSE MACIAS, JR. LITTLER MENDELSON, P.C. 50 W. San Fernando, 15th Floor San Jose, CA 95113.2303 XX BY MAIL: Iam "readily familiar" with the firm's practice of collection at maintained |by er authorized py of this * ‘liver fees paid nd processing correspondence for mailing. Under that practice it would be deposited with U.S. Postal service on that same day with postage thereon fully prepaid at CHINO HILLS, California in the ordinary} course of business. I am aware that on motion of the party served, service is pres} ed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. Joseph Lavi, Esq. (SBN 209776) Vincent C. David M. deRubertis (SBN 208709) Granberry, Esq. (SBN 276483) The deRubertis Law Firm, APC 4219 LAVI & EBRAHIMIAN, LLP 8889 W. Coldwater Canyon Avenue Stutlio City, Olympic Blvd., Suite 200 Beverly Hills, Califoria 91604 e-mail: | California 90211 David@deRubertisLaw.com : jlavi@lelawfirm.com Vegranberry@lelawfirm.com XX BY E-MAIL: I electronically served the above-mentioned documents to each of the recipients at their respective e-mail addresses. My e-mail address is: Kligh@antoy Executed on March 15, 2019 at Chino Hills, California. I declare under penalty of perjury under the laws of the State of Californi is true and correct. Kimberly Ligh 2 ellilaw.com that the above PROOF OF SERVICE RE: MOTION TO COMPLY