Case 2:22-cv-06171 Document 1 Filed 08/30/22 Page 1 of 22 Page ID #:1
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`STEPHEN T. HOLZER, SBN 074561
`LEWITT, HACKMAN, SHAPIRO, MARSHALL & HARLAN
`16633 Ventura Boulevard, 11th Floor
`Encino, California 91436-1865
`Telephone: (818) 990-2120
`Telecopier: (818) 981-4764
`sholzer@lewitthackman.com
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`Attorneys for Plaintiff ROCKSY, LLC
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`Plaintiff,
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`Lewitt, Hackman, Shapiro, Marshall & Harlan
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`A Law Corporation
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`UNITED STATES DISTRICT COURT
`FOR THE CENTRAL DISTRICT OF CALIFORNIA
`CASE NO:
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`ROCKSY, LLC, a California limited
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`liability company,
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`COMPLAINT
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`1.
`FOR LIABILITY UNDER
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`CERCLA (42 U.S.C. A. §§
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`vs.
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`9601 et seq.);
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`SPACELABS HEALTHCARE,
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`FOR RECOVERY UNDER
`INC., a Delaware corporation,
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`HSAA (California Health &
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`Safety Code § 25300 et seq.);
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`Defendant.
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`FOR PRIVATE NUISANCE
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`(California Civil Code § 3479);
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`FOR PUBLIC NUISANCE
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`(California Civil Code § 3480);
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`FOR NEGLIGENCE AND
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`NUISANCE PER SE
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`(California Health & Safety
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`Code Section 25189.5, et seq.);
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`FOR UNJUST
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`ENRICHMENT (Common
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`Law); and
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`FOR DECLARATORY
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`RELIEF (28 U.S.C.A. § § 2201,
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`2202
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`DEMAND FOR JURY TRIAL
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`Case 2:22-cv-06171 Document 1 Filed 08/30/22 Page 2 of 22 Page ID #:2
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`Plaintiff, Rocksy, LLC (“Rocksy”), by and through its undersigned attorneys,
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`alleges as its complaint against Defendants Spacelabs Healthcare, Inc. (“Spacelabs
`Healthcare”) as follows:
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`INTRODUCTION
`This action arises under the Comprehensive Environmental Response,
`1.
`Compensation, and Liability Act (“CERCLA”), 42 U.S.C.A. §§ 9601 et seq., as
`amended, the Hazardous Substance Account Act; California Health & Safety Code
`§§ 25300 et seq.; California statutory law; and common law.
`2.
`This is a civil action commenced for recovery of response costs from
`the named Defendant incurred or to be incurred by Plaintiff in responding to the
`releases or threat of releases of hazardous substances on, into and/or from the
`property and/or groundwater located at and/or under 15519-15541 Lanark Street,
`City of Los Angeles, County of Los Angeles, State of California (the “Site”). This
`is also a civil action for damages to Plaintiff from such contamination.
`3.
`All of Plaintiff’s claims for relief contained in this complaint arise out
`of the same transaction and occurrence as the claim asserted under CERCLA.
`4.
`Plaintiff further seeks a declaration of Defendant’s liability for damages
`and for contribution and/or indemnity to and for all unreimbursed present and future
`response costs to be incurred by Plaintiff in connection with the Site and
`groundwater contamination.
`JURISDICTION AND VENUE
`This Court has subject matter jurisdiction over this case pursuant to
`5.
`CERCLA, 42 U.S.C.A. §§ 9601 et seq., 42 U.S.C.A §1332 and principles of pendant
`jurisdiction. Regarding diversity jurisdiction, more than $75,000 is at issue.
`6.
`Venue is proper in this district pursuant to § 113b of CERCLA, and 28
`U.S.C.A. § 1391(b) and (c), because the releases or threatened releases of hazardous
`substances that give rise to plaintiff’s claims have occurred in this district.
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`Case 2:22-cv-06171 Document 1 Filed 08/30/22 Page 3 of 22 Page ID #:3
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`NOTICE
`Plaintiff has provided a copy of this complaint to the Attorney General
`7.
`of the United States and to the Administrator of the Environmental Protection
`Agency and to the Director of the California Department of Toxics Substances
`Control.
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`PARTIES
`Plaintiff, is now, and at all times relevant to this action was, a Limited
`8.
`Liability Corporation duly organized and existing under the laws of the State of
`California, engaged in the business of theatrical drapery manufacturing and show
`business studio services, with its principal place of business located at the Site.
`9.
`Defendant Spacelabs Healthcare is a Delaware corporation with its
`principal place of business in Snoqualmie, Washington. Plaintiff is informed and
`believes and on the basis of such information and belief alleges Spacelabs Healthcare
`is
`the successor-in-interest
`to Spacelabs,
`Inc., a California corporation
`(“Spacelabs”), whether considered from the standpoint of traditional successor
`liability or from the standpoint of expanded CERCLA continuity of enterprise
`successor liability. In regard to successor liability, see Exhibit 1 hereto (highlight
`added), containing representations and admissions that Spacelabs Healthcare has
`retained essentially the same name as Spacelabs; is producing the same product
`(medical telemetry) as Spacelabs; and is explicitly holding itself out as the
`continuation of the previous Spacelabs enterprise. During the 1950’s to at least the
`mid-1960’s Spacelabs operated on at least that portion of the Site corresponding to
`the street address of 15519-15521 Lanark Street, Los Angeles, California (the
`“15519-15521 portion”). Spacelabs was in the business of providing, among other
`things, real time medical monitoring in connection with NASA’s space program and
`later was in the business of providing medical technology to civilian healthcare
`facilities. Space Healthcare is, among other things, in the same line of business.
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`10. Plaintiff is informed and believes and on the basis of such information
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`Case 2:22-cv-06171 Document 1 Filed 08/30/22 Page 4 of 22 Page ID #:4
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`and belief alleges that Spacelabs, as Spacelabs Healthcare’s predecessor-in-interest,
`in the course of its operations at the 15519-15521 portion of the Site ,used,
`processed, produced, stored, treated, and/or generated PCE, TCE and the chemicals
`listed in the following paragraphs
`11. Plaintiff is informed and believes and on the basis of such information
`and belief alleges that Spacelabs caused or contributed to the spilling, leaking,
`disposal and release into the environment of the hazardous substances, as set forth
`in the following paragraphs, during said company’s operations from 1958 through
`at least 1965 at the 15519-15521 portion of the Site (see Exhibit 2 hereto, evidencing
`such operations) thereby creating a condition of hazardous substance contamination
`at and on at least the 15519-15521 portion of the Site, and also off of that portion of
`the Site, for which Spacelabs Healthcare, as Spacelabs’ successor-in-interest, is now
`responsible.
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`FIRST CLAIM FOR RELIEF
`COST RECOVERY UNDER CERCLA § 107(A)
`12. Plaintiff repeats and realleges each and every allegation contained in
`paragraphs 1 through 11, as though fully set forth here.
`13. Plaintiff is informed and believes and on the basis of such information
`and belief alleges that Spacelab’s Healthcare’s predecessor-in-interest, Spacelabs,
`transported or arranged for the transport of hazardous substances that Spacelabs
`owned or possessed to at least the 15519-15521 portion of the Site; stored, treated,
`and disposed of hazardous substances on at least that portion of the Site; and
`otherwise operated on at least that portion of the Site during the time that hazardous
`substances were disposed of there. Spacelabs Healthcare, as Spacelabs’ successor-
`in-interest, is now thereby jointly and severally liable under §107(a) of CERCLA,
`42 U.S.C.A. § 9607(a), in particular 42 U.S.C.S. § 9607(a)(4)(B) (United States v.
`Atlantic Research Corp., (2007) 551 U.S. 128).
`14. Plaintiff is informed and believes and on the basis of such information
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`Case 2:22-cv-06171 Document 1 Filed 08/30/22 Page 5 of 22 Page ID #:5
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`and belief alleges that the Site, including the 15519-15521 portion thereof, is a
`facility, as that term is defined in CERCLA, 42 U.S.C.A. § 9601(9).
`15. A release or threatened release of a hazardous substance, as those terms
`are defined in CERCLA, at 42 U.S.C.A. § 9601(22), (14), has occurred at the Site,
`including the 15519-15521 portion thereof.
`16. Plaintiff did not cause or contribute to the environmental contamination
`at the Site and denies that Plaintiff is liable for costs incurred as the result of the
`alleged disposal, release or threatened release of hazardous substances at the Site.
`However, in the interest of an expeditious cleanup and acting in good faith, plaintiff
`undertook actions including, but not limited to, the response actions listed below in
`an effort to remove and remediate the environmental contamination at the Site.
`Plaintiff has incurred costs in excess of $75,000, according to proof, in the course of
`taking these actions. These actions and the costs incurred in taking them are
`consistent with the National Contingency Plan.
`17.
`In or about May-June 2003, Smith-Emery Geoservices performed a
`Phase II Environmental Site Assessment at the Site. The report from such
`investigation concluded that the soil vapor at the 15519-15521 portion of the Site
`was contaminated with tetrachloroethylene (PCE) in concentrations as high as
`15,400 ug/m and trichloroethylene (TCE) in concentrations as high as 96,000 ug/m.
`18. This assessment also concluded that the alleyway to the east of the
`15519-15521 portion of the Site was contaminated with concentrations in soil vapor
`of as high as 94,200 ug/m.
`19.
`In or about November, 2003, Smith-Emery Geoservices performed a
`Site Investigation at the Site and reported that soil at the 15519-15521 portion of the
`Site was contaminated with TCE in concentrations as high as 650 ug/kg and also
`was contaminated with PCE.
`20.
`In or about December, 2012, Partner Engineering and Science, Inc.
`performed a Phase II Subsurface Investigation at the Site and reported, regarding the
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`Case 2:22-cv-06171 Document 1 Filed 08/30/22 Page 6 of 22 Page ID #:6
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`15519-15521 portion of the Site, that PCE and TCE were detected in soil samples in
`concentrations exceeding the residential and industrial land use California Human
`Health Screening Levels, or CHHSL’s.
`21.
`In or about January, 2016, BA Environmental prepared an Investigation
`Activities Report. BA Environmental reported, regarding the 15519-15521 portion
`of the Site, that TCE was detected in soil vapor samples in concentrations as high as
`96,000 ug/m and that PCE was detected in concentrations as high as 15,400 ug/m.
`22. Via correspondence dated September 12, 2013, the California
`Department of Toxics Substances Control (DTSC) issued a Review of Preliminary
`Endangerment Assessment and, based on a review of the above reports, concluded
`regarding the Site that
`various hazardous substances were present in the soil
`at concentrations exceeding their Total Threshold
`Limit Concentrations (TTLC) and Soluble Threshold
`Limit Concentrations (STLC), i.e. at hazardous waste
`concentrations. Various hazardous
`constituents
`included: (1) volatile organic compounds (VOCs) such
`as perchloroethylene (PCE), trichloroethylene (TCE),
`1, 1, 1 - trichloroethane (TCA); and, (2) heavy metals
`such as chromium (Cr), lead (Pb), and copper (Cu).
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`23. Since, as noted, TCE contamination associated with the 15519-15521
`portion of the Site was found beyond the boundaries of that portion, Plaintiff is
`informed and believes and on the basis of such information and belief alleges that
`releases of contamination from that portion of the Site spread to other portions of the
`Site and also to offsite.
`24. Plaintiff is informed and believes and on the basis of such information
`and belief alleges that portions of the Site other than the 15519-15521 portion have
`also been contaminated by entities other than Spacelabs Healthcare’s predecessor-
`in-interest. However, in light of the fact that the contamination at the Site dates back
`as long as 60-70 years, Plaintiff has to date been unable to identify the pertinent
`Responsible Parties. Plaintiff will through discovery endeavor to identify such
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`Case 2:22-cv-06171 Document 1 Filed 08/30/22 Page 7 of 22 Page ID #:7
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`Responsible Parties and will seek leave of Court to amend this Complaint once such
`identities have been discovered.
`25.
`In 2013, Plaintiff entered into a Voluntary Cleanup Agreement with the
`DTSC and ever since has been proceeding to respond to Site contamination.
`Plaintiff has performed soil vapor extraction in an effort, among other things, to
`protect the neighborhood, including nearby apartment building occupants, from
`injury due to the spread of contaminated soil vapor. To date, Plaintiff’s efforts have
`removed over 2,200 pounds of vapors from the Site.
`26. Plaintiff did not cause or contribute to the environmental contamination
`at the Site and denies that Plaintiff is liable for costs incurred, or to be incurred, as
`the result of the alleged release or threatened release of hazardous substances at, on
`and/or under the Site.
`27. Defendant Spacelabs Healthcare , and each of them, are strictly liable
`to Plaintiff is for the costs referred to above and for interest on those costs pursuant
`to 42 U.S.C.A. § 9607(a).
`SECOND CLAIM FOR RELIEF
`COST RECOVERY UNDER CALIFORNIA HSAA §§25300 ET SEQ.
`28. Plaintiff repeats and realleges each and every allegation contained in
`paragraphs 1 through 27 as though fully set forth here.
`29. Plaintiff has incurred costs for taking the response actions described
`above regarding disposals and releases of hazardous substances caused by Spacelabs
`Healthcare’s predecessor-in-interest and for which Spacelabs Healthcare is liable.
`Plaintiff is incurring and will continue to incur costs for further response actions.
`Plaintiff is entitled to recovery of these expenditures from Defendant.
`30. The materials at issue are “hazardous substances” under the
`provisions of Health & Safety Code Section 25636(e).
`31. The hazardous substances released into the environment constituted a
`release within the meaning of Health & Safety Code Section 25320. The release of
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`said substances into the environment poses a threat to public health or to the
`environment.
`32. Spacelabs Healthcare is a person described in Health & Safety Code
`Section 25319 and is a responsible party as described in Health & Safety Code
`Section 25323.5.
`33. Spacelabs Healthcare is liable to Plaintiff for all costs of response,
`removal, and remedial action incurred by Plaintiff.
`THIRD CLAIM FOR RELIEF
`PRIVATE NUISANCE (California Civil Code §3479)
`34. Plaintiff incorporates by reference herein paragraphs 1 through 33 as
`though set forth in full.
`35. The existence of hazardous substances and contamination and other
`waste materials in the soil, the ground and/or the groundwater at, on and/or under
`the Site has resulted in a condition which is injurious to the health and offensive to
`the senses, and which is an obstruction to the free use of the Site and is an
`interference with Plaintiff’s comfortable use and enjoyment of the Site.
`36. As a result of the actions, inactions and omissions of Spacelabs, for
`which its successor-in-interest, Defendant Spacelabs Healthcare, is liable, a
`continuing nuisance exists and continues to exist resulting in damage to the Site
`and/or to groundwater on a daily basis, with each release and/or threatened release
`of hazardous substances and each migration of the same, from the surface into the
`soil and into the ground and/or groundwater, giving rise to a new cause of action.
`37. The condition of pollution and nuisance is specifically injurious to
`Plaintiff in light of Plaintiff’s ownership interest in the Site.
`38. As a result of a result of the actions, inactions and omissions of
`Spacelabs, for which its successor-in-interest, Defendant Spacelabs Healthcare, is
`liable, Defendant Spacelabs Healthcare, Plaintiff has suffered and will continue to
`suffer general, compensatory and consequential damages in excess of $75,000,
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`inclusive of but not limited to any and all amounts incurred and/or to be incurred for
`the investigation, assessment, monitoring, treatment, removal and/or remediation of
`hazardous substances, contamination and wastes at, on and/or under the Site, the
`diminution in value of the Site, and the loss of use and/or loss of rent from the use
`of some or all portions of the Site, all in amounts not yet fully ascertained, but which
`will be more specifically shown in accordance with proof at the time of trial.
`39. Plaintiff seeks to have Defendant Spacelabs Healthcare abate and stop
`the nuisance, but Defendant has so far failed and refused to do the same and the
`nuisance continues to exist.
`40. The failure timely to mitigate, through assessment, investigation,
`monitoring, treatment, removal and remediation, the hazardous substances, waste
`and contamination at, on and/or under the Site will further increase the damages and
`injuries Plaintiff has and will continue to suffer and incur.
`41. Plaintiff prays that a mandatory and/or prohibitory injunction be issued,
`requiring Defendants to enjoin and abate said nuisance and/or to perform any and all
`actions necessary to assess, investigate, remove, remediate, monitor, treat, or
`cleanup the hazardous substances, wastes and contamination from the Site or to pay
`for Plaintiff to accomplish these things.
`FOURTH CLAIM FOR RELIEF
`PUBLIC NUISANCE (California Civil Code §3480)
`42. Plaintiff incorporates by reference herein paragraphs 1 through 41 as
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`though set forth in full.
`43. The nuisance created by the existence of hazardous substances,
`contamination and wastes in the soil, ground and/or groundwater at the Site is a
`public nuisance which affects at the same time the entire community or
`neighborhood and/or a considerable number of persons and which has created and
`continues to create a significant threat to the health and safety of the public and/or
`the environment.
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`44. The nuisance is specifically injurious to Plaintiff, resulting in damages
`and injuries of a different type and effect from the damages and injuries which have
`resulted to the entire community or neighborhood, or to a considerable number of
`persons. The nuisance is continuing, with continuing injuries and damages to
`Plaintiff and the public on a daily basis.
`45. As a result of a result of the actions, inactions and omissions of
`Spacelabs, for which its successor-in-interest, Defendant Spacelabs Healthcare, is
`liable, Plaintiff has suffered and will continue to suffer general, compensatory and
`consequential damages in excess of $75,000, inclusive of but not limited to any and
`all amounts incurred and to be incurred for the investigation, assessment,
`monitoring, treatment, removal and/or remediation of hazardous substances,
`contamination and wastes at the Site, and/or the loss of use and/or loss of rent from
`the use of some or all portions of the Site, and other amounts yet to be determined,
`all of which have not yet been fully ascertained but which will be more specifically
`shown in accordance with proof at the time of trial.
`46. Plaintiff seeks to have Defendant Spacelabs Healthcare abate and stop
`the nuisance, but it has so far failed and refused to do the same and the nuisance
`continues to exist. The failure timely to mitigate, through assessment, investigation,
`monitoring, treatment, removal and remediation, the hazardous substances, waste
`and contamination at the Site, will further increase the damages and injuries Plaintiff
`has and will continue to suffer and incur.
`47.
`In the event that this situation is deemed to be a continuing nuisance,
`Plaintiff requests that a mandatory and/or prohibitory injunction be issued requiring
`Defendants to enjoin and abate the alleged nuisance and to perform any and all
`assessment, monitoring, investigation, removal, remediation, treatment, cleanup or
`otherwise to accomplish the same.
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`FIFTH CLAIM FOR RELIEF
`NEGLIGENCE AND NEGLIGENCE PER SE
`48. Plaintiff incorporates by reference herein paragraphs 1 through 47as
`though set forth in full.
`49. The hazardous substances, wastes and contamination in the soil, the
`ground and/or groundwater at, on and under the Site were released in whole or in
`part as a result of the negligence and careless actions, inactions, and omissions and
`the reckless conduct of Spacelabs Healthcare’s predecessor-in-interest, which
`generated an allowed the disposal of hazardous substances, wastes and other
`contaminants at, on and under the Site.
`50. Defendant Spacelabs Healthcare’s actions and/or inactions in failing to
`respond to the contamination at issue is a violation of applicable environmental laws
`including, but not limited to, CERCLA, the Hazardous Substance Account Act,
`California Health & Safety Code Section 25189.5, et seq. and regulations. These
`actions and inactions of Defendant Spacelabs Healthcare’s predecessors-in-interest
`are and were negligent per se as such actions violate express statutory provisions
`concerning such conduct and activity. Defendant is liable for these violations.
`51. As a result of a result of the actions, inactions and omissions of
`Spacelabs, for which its successor-in-interest, Defendant Spacelabs Healthcare, is
`now liable, Plaintiff has suffered and will continue to suffer general, compensatory
`and consequential damages in excess of $75,000, including but not limited to
`amounts incurred or to be incurred by Plaintiff for the assessment, monitoring,
`investigation, removal and/or remediation of hazardous substances, wastes and
`contamination in the soil, ground and/or groundwater at, on and under the Site, and
`the loss of use and/or loss of rent from use of some or all portions of the Site, and
`other amounts yet to be determined, all of which have not yet been fully ascertained
`but which will be more specifically shown in accordance with proof at the time of
`trial.
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`Case 2:22-cv-06171 Document 1 Filed 08/30/22 Page 12 of 22 Page ID #:12
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`SIXTH CLAIM FOR RELIEF
`UNJUST ENRICHMENT (Common Law)
`52. Plaintiff incorporates by reference herein paragraphs 1 through 51 as
`though set forth in full.
`53. Defendant Spacelabs Healthcare has failed to perform its duty to
`remove from the Site and to remedy the nuisance there existing. This failure to take
`action has forced plaintiff to enter into contracts to accomplish the removal and
`remedy the dangerous situation.
`54. Plaintiff has expended in excess of $ 75,000 and will incur additional
`expenditure es for contract or other services to remedy the danger presented by
`Spacelabs Healthcare’s predecessor-in-interest’s hazardous materials and has
`thereby conferred a benefit on Spacelabs Healthcare which would be unjust and
`inequitable for this Defendant to retain.
`55. Defendant Spacelabs Healthcare is liable for the costs of removal and
`remedial and preventative actions at the Site.
`56. Plaintiff is entitled to restitution from Defendant Spacelabs Healthcare
`for all costs of removal and remedial and preventive actions at the Site.
`SEVENTH CLAIM FOR RELIEF
`DECLARATORY RELIEF
`57. Plaintiff incorporates by reference herein paragraphs 1 through 56 as
`though set forth in full.
`58. An actual controversy exists between the Plaintiff and the Defendant
`Spacelabs Healthcare, because Plaintiff contends and Defendant denies, that if
`Plaintiffs’ allegations with respect to damages and injury are true, then Defendants
`has responsibility for such costs and damages that have been or will be incurred, for
`activities performed and/or to be performed in the repair, investigation, assessment,
`monitoring, treatment, removal, remediation and cleanup of any hazardous
`substances, wastes or contamination at, on and/or under the Site, for the and the loss
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`Case 2:22-cv-06171 Document 1 Filed 08/30/22 Page 13 of 22 Page ID #:13
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`of use of such property, and for such other damages in amounts that Plaintiff will
`continue to incur.
`59. Plaintiff requests that a judicial determination and declaration be issued
`setting forth the parties’ rights and obligations as necessary and appropriate in order
`to avoid a multiplicity of actions and in order for the parties to ascertain their rights
`and duties with respect to the Plaintiff’s claims herein, and each of them.
`WHEREFORE, Plaintiff requests judgment against Defendants for:
`
`1.
`All response costs and other costs incurred by Plaintiff in
`connection with the Site according to proof, and interest on those costs from
`the date they were incurred;
`2.
`A judicial declaration that Defendant is liable under CERCLA §
`107(a) for all response costs and is liable to Plaintiff in contribution and/or
`indemnity under and Health & Safety Code §§ 25300 et seq.,
`3.
`A judicial determination that Defendant is liable to Plaintiff
`under California statutory law and under common law for all damages and all
`past, present, and future response costs and other costs that may be incurred
`by Plaintiff in connection with the Site;
`4.
`Plaintiff’s costs of litigation including, without limitation,
`reasonable attorney’s and expert witness’ fees; and
`5.
`Such other and further relief as the court deems just and proper.
`
`DATED: August 30, 2022
`LEWITT, HACKMAN, SHAPIRO,
`
` MARSHALL & HARLAN
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`By: /s/Stephen Holzer
`STEPHEN T. HOLZER
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`Attorneys for Plaintiff
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`Case 2:22-cv-06171 Document 1 Filed 08/30/22 Page 14 of 22 Page ID #:14
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`DEMAND FOR JURY TRIAL
`Plaintiff demands a trial by jury of all issues so triable pursuant to Rule 38 of
`the Federal Rules of Civil Procedure.
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`DATED: August 30, 2022
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`LEWITT, HACKMAN, SHAPIRO,
` MARSHALL & HARLAN
`By: /s/ Stephen Holzer
`STEPHEN T. HOLZER
`
`
`Attorneys for Plaintiff
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`Case 2:22-cv-06171 Document 1 Filed 08/30/22 Page 15 of 22 Page ID #:15
`Case 2:22-cv-06171 Document1 Filed 08/30/22 Page 15of22 Page ID#:15
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`EXHIBIT 1
`EXHIBIT 1
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`8/29/22, 8:51 AM
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`Our Heritage | Spacelabs Healthcare
`Case 2:22-cv-06171 Document 1 Filed 08/30/22 Page 16 of 22 Page ID #:16
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`https://spacelabshealthcare.com/sbout-us/our-heritage/
`
`
`
`June 1965: Ed White becomes the first American to walk
`Remote vital signs monitoring by Spacelabs
`
`Pioneering spirit with a history of innovation
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`https://spacelabshealthcare.com/about-us/our-heritage/
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`Our Heritage
`Since 1958, Spacelabs has continually rede
`ned the boundaries of what’s possible in
`healthcare technology.
` From monitoring Ed White’s historic Gemini IV spacewalk and Neil
`Armstrong’s rst step on the moon, to watching over millions of patients around the world
`

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`8/29/22, 8:51 AM
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`Our Heritage | Spacelabs Healthcare
`Case 2:22-cv-06171 Document 1 Filed 08/30/22 Page 17 of 22 Page ID #:17
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`today, Spacelabs’ pioneering innovations in real-time telemetry enable health monitoring and
`diagnostics for people and patients across the care continuum.
`Spacelabs Healthcare, a subsidiary of OSI Systems
`, Inc., began in 1958 as co-
`founders Ben L.
`Ettelson and James A. Reeves
`began working with the U.
`S. Air Force and NASA. Spacelabs
`went on to become a prime contractor to NASA for the historic Gemini and Apollo missions.
`The Gemini Program required real
`-time, remote physiological monitoring of orbiting astronauts
`from Earth. Spacelabs’ innovation in medical telemetry helped make history as part of the
`Gemini IV ight as astronaut Edward H. White II became the rst American to walk in space in
`June 1965.
`In 1966, Spacelabs introduced its ground-breaking medical technology to civilian healthcare
`facilities. By 1968, Spacelabs had expanded its line of products to oer a range of bedside and
`multi-patient central station monitors.
`NASA’s Apollo Program was dedicated to fullling President John F. Kennedy’s challenge to
`land a man on the moon by the end of the decade. In July 1969, Neil Armstrong stepped onto
`the moon wearing Spacelabs telemetry. NASA honored Spacelabs with a certicate of
`appreciation for outstanding contributions to the Apollo Program. By the early 1970s,
`Spacelabs was installing its “Apollo 70 Cardiac Care Monitoring System” at hospitals
`throughout the United States, with astronauts including Alan Shepard and Edgar Mitchell
`attending in person to participate in the dedication celebrations on several occasions.
`Today, health monitoring is much more than the collection and display of vital signs. Eective
`health management requires diagnostic delity data acquisition from multiple sources,
`sophisticated analysis through intelligent algorithms, and translation of this data into clinically
`actionable information. Vital signs can now be collected wherever the patient is — from
`hospital to clinic to home. Healthcare professionals expect immediate access to this
`information where and when they need it. Spacelabs is working to connect the entire care
`continuum with insightful information that empowers clinicians to make better informed
`decisions and deliver value-based care.
`

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`8/29/22, 8:51 AM
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`Our Heritage | Spacelabs Healthcare
`Case 2:22-cv-06171 Document 1 Filed 08/30/22 Page 18 of 22 Page ID #:18
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`Spacelabs co-founder Jim Reeves receives NASA’s Certicate of Appreciation fr