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MARYLON M. BOYD SBN #139642 FILED BY FAX
LAW OFFICES OF MARYLON M. BOYD ALAMEDA COUNTY
UNO
2201 Broadway Street, Suite 815
Oakland, California 94612 April 26, 2011
Telephone: (510) 663-8772 OF
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F acsimile: (310) 663-8781 THE SUPERIO R COURT
lawofficeofmarylonboyd@yahoo.com By Catherine Green, Depuy
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CASE NUMBER:
Attorney for Plaintiff
ROBIN BONGON RG10495979
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ALAMEDA COUNTY SUPERIOR COURT
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UNLIMITED JURISDICTION
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) Case No.: RG10495979
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ROBIN BONGON ; Reservation Nos.: R-1162620
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Plaintiff, )
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} PLAINTIFF’S REQUEST FOR
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JUDICIAL NOTICE IN SUPPORT OF
SE UND, ON
HOSPITAL INC RAISER } MOTION TO COMPEL DEFENDANT
FOUNDATION HEALTH PLAN, INC; ) KAISER FOUNDATION HOSPITAL,
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KER PERMANENTE, INC.; RON ) INC.’S FURTHER DISCOVERY
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and D ARRAY THROUGH 10 ) RESPONSES ; AND FOR SANCTIONS
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Defendants Date: May 3, 2011
Time: 3:00 p.m.
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Dept: 512
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Judge: John M. True, II
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Complaint filed: January 27, 2010
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Plaintiff Robin Bongon, pursuant to California Evidence Code Section 452(d),
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hereby requests the Court take judicial notice of the following document, a true and correct
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copy of which is attached hereto as follows:
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Exhibit 1. The Declaration of Cheryl Bower filed February 4, 2011 in support of
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Requestfor Judicial
NoticeInsupport
of MotionTo CompelFurther
Responses
Bongon v,Kaiser
Alameda Sup.Ct.
#:RG10495979
Defendant’s Motion to Compel Plaintiff's Discovery.
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Plaintiff further requests that the Court take judicial notice of the matters on file in
this Court’s records that are the proper subject for judicial notice. Evid.. Code §§ 450, 451
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& 452. Leyva v. Superior Court (1985) 164 Cal. App. 3d 462 and Day v. Sharp (1975) 50
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Cal _App.3d 904, 914.
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10 Dated: April 25, 2011 LAW OFFICES OF ManirLoN M. BOYD
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/ Marylon . Boyd Att for
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28 Pli’s
RequestforJudicial
NoticeInsupport
of MotionTo CompelFurther
Responses
Bongon v.Kaiser
Alameda Sup.Ct#:RG10495979
EXHIBIT 1
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ME 23525"
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Michele Ballard Miller (GBN 104198)
mbm Gonrikeriawaroup-com
Mary L. Guilfoyle(SBN 143308)
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mig@milleriawgroup.cam
Gregory F. Fortescue (SBN 249133)
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millerlawgroup.com
MILLER LAW GROUP
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A Professional Corporation
111 Sutter Street, Suite 700
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San Francisco, CA 94104
Tel. (415) 464-4300
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Fax (415) 464-4336
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Attorneys for Defendants KAISER
FOUNDATION HOSPITALS, KAISER
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FOUNDATION HEALTH PLAN, INC., and
RON NAVARRA
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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IN AND FOR THE COUNTY OF ALAMEDA
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ROBIN BONGON, Case No.: RG10495979
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ASSIGNED FOR ALL PURPOSES TO
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Plaintiff, JUDGE John M. True, Hi
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DEPARTMENT 512
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DECLARATION OF CHERYL BOWER IN
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KAISER FOUNDATION HOSPITALS, INC.; SUPPORT OF DEFENDANT KAISER
KAISER FOUNDATION HEALTH PLAN, INC.; FOUNDATION HOSPITALS’ REPLY
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KAISER PERMANENTE, INC.; RON MEMORANDUM OF POINTS AND
NAVARRA, and DOES 1-10, inclusive, AUTHORITIES IN SUPPORT OF MOTION
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TO COMPEL PLAINTIFF’S DISCOVERY
RESPONSES AND DEPOSITION
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Defendants.
Date: February 14, 2011
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Time: 3:00 P.M.
Dep't: 512
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Reservation No.: R1123138
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DECLARATION OF CHERYL BOWER INSuPPORT OF OEF. KAISER’S REPLY MEMORANDUM OF POINTS AND
AUTHORITIES INSUPPORT OF MOTION TO COMPEL
Case No. RG10495979
1,CHERYL BOWER, declare:
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; 1. |work for the Miller Law Group as @ secretary to Gregory F. Fortescue,
counsel of record for Defendants KAISER FOUNDATION HOSPITALS ("Defendant Kaiser’),
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KAISER FOUNDATION HEALTH PLAN, INC, and RON NAVARRA (collectively,
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“Defendants”). |make this declaration based on personal knowledge. Ifcalled as a witness, |
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could and would testify competently to the following.
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2. On December 23, 2010, our office was personally served with Plaintiff
Robin Bongon’s Request for Production of Documents (Set One), Requests for Admissions
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(Set One), Form Interrogatories — General (Set One), Form Interrogatories — Employment
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Law (Set One), and Deposition Notices for Anne Dench, Carlos Avila, Patty Gunderson and
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Dan McNulty. Attached as Exhibit 1 to this Declaration is a true and correct copy of the Proof
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of Service which accompanied the written discovery and deposition notices.
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3. On January 24, 2011, | served Defendant Kaiser's Responses to
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Plaintiffs Request for Production of Documents (Set One), Requests for Admissions (Set
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One), Form Interrogatories — General (Set One), Form Interrogatories — Employment Law
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(Set One) by overnight express delivery with verifications. Attached as Exhibit 2 to this
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Declaration are true and correct copies of the Proofs of Service which accompanied the
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foregoing discovery responses.
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] BY OVERNIGHT DELIVERY: By placing the document(s) fisted above in a sealed
envelope(s) and consigning it/them to an express mail or overnight courier for
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guaranteed delivery on the next business day following the date of consignment to
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the address(es) set forth above. A copy of the consignment slip isattached to the
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lastpage ofthis proof of service. :
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{] |declare under penalty of perjury under the laws of the State of California that the
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foregoing istrue and correct. ‘ .
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Executed on January 24, 2011 atSan Francisco, California,
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Cheryl Bower/ .
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PROOF OF SERVICE
Case No.RG10495975
PROOF OF SERVICE
|, Cheryl Bower, declare that |am employed at Miller Law Group, A Professional
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Corporation, whose address is 111 Sutter Street, Suite 700, San Francisco, CA 94104: |am
over the age of eighteen (18) years and am not a party to this action. On the below date, by
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the method noted below, | served thefollowing document(s):
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DEFENDANT KAISER FOUNDATION HOSPITALS' RESPONSE TO PLAINTIFF'S FORM
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INTERROGATORIES - GENERAL (SET ONE}
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on the interested parties in this action by placing a true and correct copy thereof, enclosed
ina sealed envelope addressed as follows:
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Marylon M. Boyd, Esq. Attorney forPlaintiff. Robin Bongon
LAW OFFICES OF MARYLON M. BOYD
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2201 Broadway Street,Suite 815
Oakland, CA 94612
Tel: (510) 663-8772
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Fax: (510) 663-8781
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Email, lawofficeofmarylonboyd@yahao.com
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IX} BY OVERNIGHT DELIVERY: By placing the document(s) listed above in a sealed
envelope(s) and consigning itthem to an express mail or overnight courier for
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guaranteed delivery on the next business day following the date of consignment to
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the address(es) set forth above. A copy ofthe consignment slipis attached to the
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lastpage ofthis proof of service.
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[J] | declare under penalty of perjury under the laws of the State of Californiathat the
foregoing istrue and correct.
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Executed on January 24, 2011 atSan Francisco, California.
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PROOF OF SERVICE
Cage No.RG10495979
PROOF OF SERVICE
i,Cheryl Bower, declare that 1 am employed at Miller Law Group, A Professional
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Corparatian, whose address is 111 Sutter Street,-Suite 700, San Francisco, CA 94104; |am
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over the age of eighteen (18) years and am not a party fo this action. On the below date, by
the method noted betow, | served the following document(s):
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DEFENDANT KAISER FOUNDATION HOSPITALS’ RESPONSE TO PLAINTIFF'S
REQUEST FOR ADMISSION (SET ONE)
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on the interested parties in this action by placing a true and correct capy thereof, enclased
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Marylon M. Boyd, Esq. Attorney forPlaintiff:Robin Bongan
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LAW OFFICES OF MARYLON-M. BOYD
2201 Broadway Street, Suite 815
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Oakland, CA 94612
Tel: (510) 663-8772
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Fax: (510) 663-8781
Email: tawofficeofmaryionboyd@yahoo.com
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envelope(s) and consigning it/them to an express mail or overnight courier for
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guaranteed delivery on the next business day following the date of consignment to
the address(es) set forth above. A copy of the consignment slipis attached to the
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lastpage ofthis proof of service, .
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foregoing istrue and correct.
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Executed on January 24, 2011 atSan Francisco, California.
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Case No,RG10496g79
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EXHIBIT 4
Michele Ballard Miller (SBN 104498)
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Gregory F. Fortescue (SBN 249133)
gfi@millerlawgroup.com
MILLER LAW GROUP
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A Professional Corporation
111 Sutter Street, Suite 700
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San Francisco, CA 94104
Tel. (415) 464-4300
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Fax (415) 464-4336
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Attorneys for Defendants KAISER
FOUNDATION HOSPITALS, INC.,
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KAISER FOUNDATION HEALTH PLAN, INC.,
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SUPERIOR COURT OF CALIFORNIA
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IN AND FOR THE COUNTY OF ALAMEDA
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KAISER FOUNDATION HOSPITAL, INC.; Complaint filed: January 27, 2010
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PROOF OF SERVICE
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{,Chery! Bower, deciare that |am employed at Miller Law Group, A Professional
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Corporation, whose address is 111 Sutter Street, Suite 700, San Francisco, CA 94104; |am
over the age of aighteen (18) years and am not a party to this action. On the below date,by
the method noted below, |served the following document(s):
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VERIFICATION TO DEFENDANT KAISER FOUNDATION HOSPITALS’ RESPONSE TO
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PLAINTIFF ROBIN BONGON’'S FORM INTERROGATORIES — EMPLOYMENT LAW
{SET ONE); VERIFICATION TO DEFENDANT KAISER FOUNDATION HOSPITALS’
RESPONSE TO PLAINTIFF ROBIN BONGON’S FORM INTERROGATORIES —
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GENERAL (SET ONE); VERIFICATION TO DEFENDANT KAISER FOUNDATION
HOSPITALS’ RESPONSE TO PLAINTIFF ROBIN BONGON’S REQUEST FOR
PRODUCTION OF DOCUMENTS (SET ONE); AND VERIFICATION TO DEFENDANT
KAISER FOUNDATION HOSPITALS’ RESPONSE TO PLAINTIFF ROBIN
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BONGON’S REQUESTS FOR ADMISSIONS (SET ONE}
on the interested parties in this action by placing a true and correct copy thereof, enclosed
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in a sealed envelope addressed as fallows:
Marylon M. Bayd, Esq. Attomey for Plaintiff: Robin Bongon
LAW OFFICES OF MARYLON M. BOYD
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2201 Broadway Street, Suite 815
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Oakland, CA 94612
Tel: (610) 663-8772
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Fax: (510) 663-8781
CORPORATION
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BRAROELO, CALEORN
Email: tawofficeofmarylonboyd@yahco.com
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MOFRSEIGSAL
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MILLer
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envelope(s) and consigning it/them to an express mail or overnight courier for .
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guaranteed delivery on the next business day following the date of consignment to
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the address(es) set forth above. A copy of the consignment slip ts attached to the
last page of this proof of service.
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(J | declare under penalty of perjury under the laws of the State of California that the
foregoing istrue and correct.
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Executed on February 2, 2011 at San Francisco, California.
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PROOF OF SERVICE
Case No. RG10485979
VERIFICATION
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|,Christine Robisch, declare:
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! serve as Senior Vice President/Area Manager San Francisco Service Area
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for Defendant Kaiser Foundation Hospitals, and am authorized to make this verification on
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itsbehalf.
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The attached DEFENDANT KAISER FOUNDATION HOSPITALS’
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RESPONSE TO PLAINTIFF ROBIN BONGON’S FORM INTERROGATORIES ~
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EMPLOYMENT LAW, SET ONE is the product of information gathered by others, and on
that basis | am informed and believe, and on the basis of such information and belief
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declare, that the facts stated therein are true.
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{declare under the penalty of perjury that the foregoing istrue and correct and
that this Verification is executed on February 2, 2011, inSan Francisco, California.
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. Christine Robisch
Senior Vice President/Area Manager
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VERIFICATION OF DEF.S RESPONSE TO PLTF’S FORM INTERROGATORIES _ EMPLOYMENT LAW (SET ONE) _
Alameda County Superior Court,Case No.:RG10495979
VERIFICATION
|,Christine Rabisch, declare:
| serve as Senior Vice President/Area Manager San Francisco Service Area
for Defendant Kaiser Foundation Hospitals, and am authorized to make this verification on
itsbehalf,
The attached DEFENDANT KAISER FOUNDATION HOSPITALS’
RESPONSE TO PLAINTIFF ROBIN BONGON'S FORM INTERROGATORIES
GENERAL, SET ONE is the product ofinformation gathered by others, and on that basis |
am informed and believe, and on the basis of such information and belief declare, that the
facts stated therein are true.
|declare under the penalty of perjury that the foregoing istrue and correct and
that this Verification is executed on February 2,2011, inSan Francisco, California.
(WM Qube
Christine Robisch
Senior Vice President/Area Manager
San Francisco Service Area
4840-7363-6616,
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VERIFICATION OF OEF.'S RESPONSE TO PLTF'S FORM INTERROGATORIES - GENERAL (SET ONE)
Alameda County SuperiorCourt, Case No.:RG10498979
VERIFICATION
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|,Ghristine Robisch, declare:
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for Defendant Kaiser Foundation Hospitals, and am authorized to make this verification on
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The attached DEFENDANT KAISER FOUNDATION HOSPITALS’
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RESPONSE TO PLAINTIFF ROBIN BONGON’S REQUEST FOR PRODUCTION OF
DOCUMENTS, SET ONE is the product of information gathered by others, and on that basis .
Lam informed and believe, and on the basis ofsuch information and belief declare, that the
facts stated therein are true.
ideclare under the penalty of perjury that the foregoing istrue and correct and
that this Verification is executed on February 2, 2011, in San Francisca, California.
My Christine Robisch
Senior Vice Prasident/Area Manager
San Francisco Service Area
4B52-1474-9448,
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VERIFICATION OF DEF,’S RESPONSE TO PLTF'S REQUEST FOR PRODUCTION OF DOCS {SET ONE)
: Alameda County Superier Court,Case No.:RG10495979
VERIFICATION
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I,Christine Robisch, declare:
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| serve as Senior Vice PresidenArea Manager San Francisco Service Area
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for Defendant Kaiser Foundation Hospitals, and am authorized to make this verification on
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The attached DEFENDANT KAISER FOUNDATION HOSPITALS'
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RESPONSE TO PLAINTIFF ROBIN BONGON’S REQUESTS FOR ADMISSION, SET ONE
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is the product of information gathered by others, and on that basis | am informed and
believe, and on the basis of such information and belief declare, that the facts stated therein
are true,
|declare under the penalty of perjury that the foregoing istrue and correct and
that this Verification is executed on January February 2, 2011, inSan Francisco, California.
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Christine Robisch
Senior Vice President/Area Manager
San Francisco Service Area
4850-1329-1784,
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VERIFICATION OF DEF.'S RESPONSE TO PLTE’S REQUEST FOR ADMISSION {SET ONE)
Alameda County Superior Court,Case No.: RG10495979
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MARYLON M. BOYD SBN #139642 FILED BY FAX LAW OFFICES OF MARYLON M. BOYD ALAMEDA COUNTY UNO 2201 Broadway Street, Suite 815 Oakland, California 94612 April 26, 2011 Telephone: (510) 663-8772 OF OS F acsimile: (310) 663-8781 THE SUPERIO R COURT lawofficeofmarylonboyd@yahoo.com By Catherine Green, Depuy Be CASE NUMBER: Attorney for Plaintiff ROBIN BONGON RG10495979 A BH ALAMEDA COUNTY SUPERIOR COURT NS UNLIMITED JURISDICTION CO oO ) Case No.: RG10495979 UO ROBIN BONGON ; Reservation Nos.: R-1162620 UL Plaintiff, ) a v. ) Rea se } PLAINTIFF’S REQUEST FOR S&H JUDICIAL NOTICE IN SUPPORT OF SE UND, ON HOSPITAL INC RAISER } MOTION TO COMPEL DEFENDANT FOUNDATION HEALTH PLAN, INC; ) KAISER FOUNDATION HOSPITAL, HD KER PERMANENTE, INC.; RON ) INC.’S FURTHER DISCOVERY DH and D ARRAY THROUGH 10 ) RESPONSES ; AND FOR SANCTIONS KN Defendants Date: May 3, 2011 Time: 3:00 p.m. we Dept: 512 Oo Judge: John M. True, II So Complaint filed: January 27, 2010 SH MORRO NM Plaintiff Robin Bongon, pursuant to California Evidence Code Section 452(d), WwW hereby requests the Court take judicial notice of the following document, a true and correct & NR Lh copy of which is attached hereto as follows: Ow NM Exhibit 1. The Declaration of Cheryl Bower filed February 4, 2011 in support of SN NON oOo Pit's Requestfor Judicial NoticeInsupport of MotionTo CompelFurther Responses Bongon v,Kaiser Alameda Sup.Ct. #:RG10495979 Defendant’s Motion to Compel Plaintiff's Discovery. WoW Plaintiff further requests that the Court take judicial notice of the matters on file in this Court’s records that are the proper subject for judicial notice. Evid.. Code §§ 450, 451 th BH & 452. Leyva v. Superior Court (1985) 164 Cal. App. 3d 462 and Day v. Sharp (1975) 50 “MS Cal _App.3d 904, 914. co Oo sh 10 Dated: April 25, 2011 LAW OFFICES OF ManirLoN M. BOYD WW 12 13 / Marylon . Boyd Att for 14 PlaintifiiMobin Bohgon a 15 16 17 18 19 20 a1 22 23 24 25 26 27 28 Pli’s RequestforJudicial NoticeInsupport of MotionTo CompelFurther Responses Bongon v.Kaiser Alameda Sup.Ct#:RG10495979 EXHIBIT 1 PAXE pe e | "9 ME 23525" Il Michele Ballard Miller (GBN 104198) mbm Gonrikeriawaroup-com Mary L. Guilfoyle(SBN 143308) NO mig@milleriawgroup.cam Gregory F. Fortescue (SBN 249133) w millerlawgroup.com MILLER LAW GROUP & A Professional Corporation 111 Sutter Street, Suite 700 oo San Francisco, CA 94104 Tel. (415) 464-4300 OF Fax (415) 464-4336 NN Attorneys for Defendants KAISER FOUNDATION HOSPITALS, KAISER oe FOUNDATION HEALTH PLAN, INC., and RON NAVARRA oO oe SUPERIOR COURT OF THE STATE OF CALIFORNIA ew 3 IN AND FOR THE COUNTY OF ALAMEDA ew ww eo ROBIN BONGON, Case No.: RG10495979 ow ASSIGNED FOR ALL PURPOSES TO GR Plaintiff, JUDGE John M. True, Hi ee DEPARTMENT 512 oe ND DECLARATION OF CHERYL BOWER IN 2 KAISER FOUNDATION HOSPITALS, INC.; SUPPORT OF DEFENDANT KAISER KAISER FOUNDATION HEALTH PLAN, INC.; FOUNDATION HOSPITALS’ REPLY Ge 2 KAISER PERMANENTE, INC.; RON MEMORANDUM OF POINTS AND NAVARRA, and DOES 1-10, inclusive, AUTHORITIES IN SUPPORT OF MOTION 6 oe TO COMPEL PLAINTIFF’S DISCOVERY RESPONSES AND DEPOSITION 5S N Defendants. Date: February 14, 2011 NM A Time: 3:00 P.M. Dep't: 512 NS MN Reservation No.: R1123138 O&O Ff ON Gf wm wm 8 MN on DECLARATION OF CHERYL BOWER INSuPPORT OF OEF. KAISER’S REPLY MEMORANDUM OF POINTS AND AUTHORITIES INSUPPORT OF MOTION TO COMPEL Case No. RG10495979 1,CHERYL BOWER, declare: = YN ; 1. |work for the Miller Law Group as @ secretary to Gregory F. Fortescue, counsel of record for Defendants KAISER FOUNDATION HOSPITALS ("Defendant Kaiser’), FF KAISER FOUNDATION HEALTH PLAN, INC, and RON NAVARRA (collectively, om “Defendants”). |make this declaration based on personal knowledge. Ifcalled as a witness, | ODO could and would testify competently to the following. SN oF 2. On December 23, 2010, our office was personally served with Plaintiff Robin Bongon’s Request for Production of Documents (Set One), Requests for Admissions 3 (Set One), Form Interrogatories — General (Set One), Form Interrogatories — Employment | oy Law (Set One), and Deposition Notices for Anne Dench, Carlos Avila, Patty Gunderson and Hw Dan McNulty. Attached as Exhibit 1 to this Declaration is a true and correct copy of the Proof DH of Service which accompanied the written discovery and deposition notices. F&F HF 3. On January 24, 2011, | served Defendant Kaiser's Responses to DB Plaintiffs Request for Production of Documents (Set One), Requests for Admissions (Set SN One), Form Interrogatories — General (Set One), Form Interrogatories — Employment Law oe a (Set One) by overnight express delivery with verifications. Attached as Exhibit 2 to this a YD Declaration are true and correct copies of the Proofs of Service which accompanied the 2 > foregoing discovery responses. |= © ] BY OVERNIGHT DELIVERY: By placing the document(s) fisted above in a sealed envelope(s) and consigning it/them to an express mail or overnight courier for f& guaranteed delivery on the next business day following the date of consignment to aa the address(es) set forth above. A copy of the consignment slip isattached to the om lastpage ofthis proof of service. : @ {] |declare under penalty of perjury under the laws of the State of California that the “~ foregoing istrue and correct. ‘ . 18 Executed on January 24, 2011 atSan Francisco, California, 19 20 WEIN Cheryl Bower/ . 21 22 23 24 25 26 ait 28 PROOF OF SERVICE Case No.RG10495975 PROOF OF SERVICE |, Cheryl Bower, declare that |am employed at Miller Law Group, A Professional NM Corporation, whose address is 111 Sutter Street, Suite 700, San Francisco, CA 94104: |am over the age of eighteen (18) years and am not a party to this action. On the below date, by & the method noted below, | served thefollowing document(s): ® DEFENDANT KAISER FOUNDATION HOSPITALS' RESPONSE TO PLAINTIFF'S FORM om INTERROGATORIES - GENERAL (SET ONE} OD on the interested parties in this action by placing a true and correct copy thereof, enclosed ina sealed envelope addressed as follows: oN Marylon M. Boyd, Esq. Attorney forPlaintiff. Robin Bongon LAW OFFICES OF MARYLON M. BOYD Oo 2201 Broadway Street,Suite 815 Oakland, CA 94612 Tel: (510) 663-8772 GS eek Fax: (510) 663-8781 = Email, lawofficeofmarylonboyd@yahao.com YB a eae wD IX} BY OVERNIGHT DELIVERY: By placing the document(s) listed above in a sealed envelope(s) and consigning itthem to an express mail or overnight courier for B® guaranteed delivery on the next business day following the date of consignment to om the address(es) set forth above. A copy ofthe consignment slipis attached to the a lastpage ofthis proof of service. DBD [J] | declare under penalty of perjury under the laws of the State of Californiathat the foregoing istrue and correct. oN a Executed on January 24, 2011 atSan Francisco, California. hekR WX Ob CO OR Chery! Bolvet |= OO Nw VU OOD F&F oO ORS RO @S OBS pp BM PROOF OF SERVICE Cage No.RG10495979 PROOF OF SERVICE i,Cheryl Bower, declare that 1 am employed at Miller Law Group, A Professional NM Corparatian, whose address is 111 Sutter Street,-Suite 700, San Francisco, CA 94104; |am we over the age of eighteen (18) years and am not a party fo this action. On the below date, by the method noted betow, | served the following document(s): fF DEFENDANT KAISER FOUNDATION HOSPITALS’ RESPONSE TO PLAINTIFF'S REQUEST FOR ADMISSION (SET ONE) on DM on the interested parties in this action by placing a true and correct capy thereof, enclased ina sealed envelope addressed as follows: ON Marylon M. Boyd, Esq. Attorney forPlaintiff:Robin Bongan we LAW OFFICES OF MARYLON-M. BOYD 2201 Broadway Street, Suite 815 oo Oakland, CA 94612 Tel: (510) 663-8772 = Fax: (510) 663-8781 Email: tawofficeofmaryionboyd@yahoo.com NR tw {J = BY OVERNIGHT DELIVERY: By placing the document(s) listed above in a sealed envelope(s) and consigning it/them to an express mail or overnight courier for BR guaranteed delivery on the next business day following the date of consignment to the address(es) set forth above. A copy of the consignment slipis attached to the om lastpage ofthis proof of service, . OD Ss —) | declare under penalty of perjury under the faws of the State of California that the SM foregoing istrue and correct. wo Executed on January 24, 2011 atSan Francisco, California. Bene g OWL Ye OD Cheryl Bowet J te NB Be F&F mo N ao |e PROOF OF SERVICE Case No,RG10496g79 EXHIBIT 3 Norco Qvernite { 9:00PM Drop-Off, Delivery throughout California,Arizona, Nevada & ... Page Jof | Merce Herc Heres Norco Hiteo Gwernne = Amgah ==MesengarCourier Math Shipman Numbah TATA OOORTAS TE A MARTON Bavn Bled Yo Accoum Humbert 18630 Compuny! Readenca: LAWGFFICES OF MareyLON M, BOYTD Shige's Riling Refertice: KARERGONGON 220) BROADWAY Caationion Adigrtca, EE BRC Sw mis Ghippir Mame: CHERYL BOWER thy: GARLAND 2 anand Special never Dolvery Service ria Gay Gupte OiangaSonn: GARLAND 1724792019 8:50:25 PM Reaigitnt Gignac: THA Dinlvery Sean: GARLAND 172000077 17:40:00AM Demvery Time: 11340;00Ake Bate: 7252077 Track Another Shipment @ https://www.overniteexpress.com/tracking/tracking.asp 2/2/2011 EXHIBIT 4 Michele Ballard Miller (SBN 104498) mbm@milterlawgroup.com Nm Gregory F. Fortescue (SBN 249133) gfi@millerlawgroup.com MILLER LAW GROUP w& A Professional Corporation 111 Sutter Street, Suite 700 fF San Francisco, CA 94104 Tel. (415) 464-4300 mw Fax (415) 464-4336 @ Attorneys for Defendants KAISER FOUNDATION HOSPITALS, INC., N KAISER FOUNDATION HEALTH PLAN, INC., And RON NAVARRA oo 8 SUPERIOR COURT OF CALIFORNIA = UU IN AND FOR THE COUNTY OF ALAMEDA NM £ a g NIN. YW = o 3Z LTRS 6 8F ROBIN BONGON, Case No.: RG10495979 FF = SOA = OS ud =Pe mW Plaintiff, PROOF OF SERVICE = Oo v. ON ee KAISER FOUNDATION HOSPITAL, INC.; Complaint filed: January 27, 2010 KAISER FOUNDATION HEALTH PLAN, INC.; KAISER PERMANENTE, INC.; RON | Oo NAVARRA; and DOES 1 THROUGH 10, OC NM Defendants. |= NOM NHN GB ON om F ON om BR 2 BOM oN PROOF OF SERVICE Case No.: RG10495979 PROOF OF SERVICE =y {,Chery! Bower, deciare that |am employed at Miller Law Group, A Professional wR Corporation, whose address is 111 Sutter Street, Suite 700, San Francisco, CA 94104; |am over the age of aighteen (18) years and am not a party to this action. On the below date,by the method noted below, |served the following document(s): BF VERIFICATION TO DEFENDANT KAISER FOUNDATION HOSPITALS’ RESPONSE TO om PLAINTIFF ROBIN BONGON’'S FORM INTERROGATORIES — EMPLOYMENT LAW {SET ONE); VERIFICATION TO DEFENDANT KAISER FOUNDATION HOSPITALS’ RESPONSE TO PLAINTIFF ROBIN BONGON’S FORM INTERROGATORIES — NO GENERAL (SET ONE); VERIFICATION TO DEFENDANT KAISER FOUNDATION HOSPITALS’ RESPONSE TO PLAINTIFF ROBIN BONGON’S REQUEST FOR PRODUCTION OF DOCUMENTS (SET ONE); AND VERIFICATION TO DEFENDANT KAISER FOUNDATION HOSPITALS’ RESPONSE TO PLAINTIFF ROBIN 8.2 BONGON’S REQUESTS FOR ADMISSIONS (SET ONE} on the interested parties in this action by placing a true and correct copy thereof, enclosed a in a sealed envelope addressed as fallows: Marylon M. Bayd, Esq. Attomey for Plaintiff: Robin Bongon LAW OFFICES OF MARYLON M. BOYD HN 2201 Broadway Street, Suite 815 BO Oakland, CA 94612 Tel: (610) 663-8772 fF Fax: (510) 663-8781 CORPORATION A GRour BRAROELO, CALEORN Email: tawofficeofmarylonboyd@yahco.com oO Law MOFRSEIGSAL SO MILLer —&] BY OVERNIGHT DELIVERY: By placing the document(s) listed above in a sealed envelope(s) and consigning it/them to an express mail or overnight courier for . WN San guaranteed delivery on the next business day following the date of consignment to A the address(es) set forth above. A copy of the consignment slip ts attached to the last page of this proof of service. oO Oo (J | declare under penalty of perjury under the laws of the State of California that the foregoing istrue and correct. += Executed on February 2, 2011 at San Francisco, California. UN & Cheryl Boyer SO mm F [en “JN nh oo PROOF OF SERVICE Case No. RG10485979 VERIFICATION oh NW |,Christine Robisch, declare: WwW fF ! serve as Senior Vice President/Area Manager San Francisco Service Area oO for Defendant Kaiser Foundation Hospitals, and am authorized to make this verification on DG itsbehalf. oN The attached DEFENDANT KAISER FOUNDATION HOSPITALS’ no RESPONSE TO PLAINTIFF ROBIN BONGON’S FORM INTERROGATORIES ~ BD EMPLOYMENT LAW, SET ONE is the product of information gathered by others, and on that basis | am informed and believe, and on the basis of such information and belief DS declare, that the facts stated therein are true. DG le ok ee {declare under the penalty of perjury that the foregoing istrue and correct and that this Verification is executed on February 2, 2011, inSan Francisco, California. oe NB oe AIM Ades A oe . Christine Robisch Senior Vice President/Area Manager NM S'S San Francisco Service Area ON ON ON 4829-1659-8536, v.1 ON £ WN & dg NM MoM aw VERIFICATION OF DEF.S RESPONSE TO PLTF’S FORM INTERROGATORIES _ EMPLOYMENT LAW (SET ONE) _ Alameda County Superior Court,Case No.:RG10495979 VERIFICATION |,Christine Rabisch, declare: | serve as Senior Vice President/Area Manager San Francisco Service Area for Defendant Kaiser Foundation Hospitals, and am authorized to make this verification on itsbehalf, The attached DEFENDANT KAISER FOUNDATION HOSPITALS’ RESPONSE TO PLAINTIFF ROBIN BONGON'S FORM INTERROGATORIES GENERAL, SET ONE is the product ofinformation gathered by others, and on that basis | am informed and believe, and on the basis of such information and belief declare, that the facts stated therein are true. |declare under the penalty of perjury that the foregoing istrue and correct and that this Verification is executed on February 2,2011, inSan Francisco, California. (WM Qube Christine Robisch Senior Vice President/Area Manager San Francisco Service Area 4840-7363-6616, v, 4 , VERIFICATION OF OEF.'S RESPONSE TO PLTF'S FORM INTERROGATORIES - GENERAL (SET ONE) Alameda County SuperiorCourt, Case No.:RG10498979 VERIFICATION + ON |,Ghristine Robisch, declare: we fF | serve as Senior Vice PresidenVArea Manager San Francisco Service Area om for Defendant Kaiser Foundation Hospitals, and am authorized to make this verification on DB itsbehalf. oN eo The attached DEFENDANT KAISER FOUNDATION HOSPITALS’ op RESPONSE TO PLAINTIFF ROBIN BONGON’S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE is the product of information gathered by others, and on that basis . Lam informed and believe, and on the basis ofsuch information and belief declare, that the facts stated therein are true. ideclare under the penalty of perjury that the foregoing istrue and correct and that this Verification is executed on February 2, 2011, in San Francisca, California. My Christine Robisch Senior Vice Prasident/Area Manager San Francisco Service Area 4B52-1474-9448, y.7 a 1 . VERIFICATION OF DEF,’S RESPONSE TO PLTF'S REQUEST FOR PRODUCTION OF DOCS {SET ONE) : Alameda County Superier Court,Case No.:RG10495979 VERIFICATION ~ON I,Christine Robisch, declare: & & | serve as Senior Vice PresidenArea Manager San Francisco Service Area HF for Defendant Kaiser Foundation Hospitals, and am authorized to make this verification on DOD itsbehalf. NSN ao The attached DEFENDANT KAISER FOUNDATION HOSPITALS' fP RESPONSE TO PLAINTIFF ROBIN BONGON’S REQUESTS FOR ADMISSION, SET ONE o is the product of information gathered by others, and on that basis | am informed and believe, and on the basis of such information and belief declare, that the facts stated therein are true, |declare under the penalty of perjury that the foregoing istrue and correct and that this Verification is executed on January February 2, 2011, inSan Francisco, California. f Christine Robisch Senior Vice President/Area Manager San Francisco Service Area 4850-1329-1784, ¥.1 1 VERIFICATION OF DEF.'S RESPONSE TO PLTE’S REQUEST FOR ADMISSION {SET ONE) Alameda County Superior Court,Case No.: RG10495979