throbber
Tamarah Harber-Pickens
`Clerk ofthe Superior Court
`
`Zachary Rosen
`Returned via E-File
`
`SUPERIOR COURT
`Telephone 661-868-5393
`1415 Truxtun Avenue
`Bakersfield CA 93301
`
`Case Name:
`
`Document:
`
`5/4/20
`BCV—20-100051
`ARNISON ET AL VS ADVENTIST HEALTH
`ET AL
`STIPULATION AND ORDER
`
`Returned
`
`EDD
`
`The attached papers are being returned for the following reason(s): D Check #
`D This pleading does not appear to be for Superior Court, Kern County.
`The attached document is an improper ex-parte communication and has not been considered by the Court.
`required or a Request to Waive Court Fees must be submitted.
`Fee of $
`Application for Waiver 0f Fees missing attachment(s):
`D Last three (3) paystubs, if employed.
`D Certified Copy of Statement ofAccount for previous six (6) months certified by Dept. of Corrections
`D Trust Account Withdrawal Order form (CDC form 193) completed by the Dept. of Corrections
`
`indicating $3.00 fee to Dept. of Corrections has been paid or insufficient funds in the account to cover.
`Does not conform to Rule 2. 100-2.1 19, California Rules of Court, as to form and format.
`Superior Court case number is wrong, incomplete, or missing.
`Consolidated matter: A11 consolidated case numbers must be listed in the heading with the lead case listed
`first.
`Consolidated matter:
`Title is incorrect or missing parties.
`Summons does not conform to complaint/cross-complaint/petition.
`Not an original. Copies are not acceptable.
`Copies must be provided if endorsed copies are requested. Submit one original plus
`Does not conform to Kem County Local Rule/Code:
`Must use Mandatory Judicial Council form.
`is not eligible for filing. Reason:
`Item(s) #
`incomplete.
`Missing required forms/attachment:
`Original Will must be presented at the time of filing petition.
`Signature missing:
`Date and place of execution not completed.
`Document(s) must be verified.
`Show date, time, and location of hearing pursuant to California Rules of Court.
`The date you have noticed this matter is a Court holiday/weekend.
`Acknowledgement of Receipt/Citation must be attached to the completed proof of service.
`Attach Proof of Service on opposing party.
`Correct Proof of Service:
`Not appraised by the Probate Referee.
`Order/Judgment does not conform to the Court minutes.
`Order page does not contain enough information regarding case; need at least three lines oftext with
`identifying information for order and case (short title case and case number).
`Dismissal cannot be entered for the following reasons:
`ED
`Other: Please correct the name of the defaulted party, it must match the default exactly also the answer
`can be attached as an exhibit but must be submitted separately for filing. Any questions please call the clerk’s
`office at 661-868-7204
`Tamarah Harber-Pickens
`CLERK OF THE SUPERIOR COURT
`By: Egtkoa Dggaoto-
`
`EDD
`
`DDDDDDDDDDDDDDDDDDDDDD
`
`copy(ies).
`
`ANY CORRESPONDENCE REQUIRING AN ANSWER FROM THE COURT MUST BE
`ACCOMPANIED BY A SELF-ADDRESSED STAMPED ENVELOPE LARGE ENOUGH TO RETURN DOCUMENTS
`
`Rcv. 12/20l7
`
`, Deputy Clerk
`
`

`

`Envelope Details
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`Print this page
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`Case # BCV—20-100051 - ARNISON ET AL VS ADVENTIST
`HEALTH ET AL (Lampe, David R.)
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`Total Provider Tax Fees
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`Kem-Bakersfield-Civil
`4/2/2020 11:48 AM
`BCV-20-100051
`ARNISON ET AL VS ADVENTIST HEALTH ET AL
`Lampe, David R.
`Zachary Rosen
`Boyce, Schaeffer, Mainieri, LLP
`Shonti Conner
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`EFile
`Stipulation and Order
`
`Stipulation and Proposed Order to Set Aside
`Default
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`https://ca1ifornia.tylerhost.net/EnvelopeDetails.aspx?envelopeguid=a7eb63c7-d8ac-4dc9-98...
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`5/5/2020
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`

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`Envelope Details
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`Comments.
`Status
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`Please correct the name of the defaulted party; it must match the default
`exactly also the answer can be attached as an exhibit but must be submitted
`separat_ely for filing. Any questions please call the clerk’s office at 661 -868-
`7204
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`5/4/2020
`14 -
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`[685551]
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`Assbéieiéeiié!?,é.rtié§.
`_Party/Busi_ness Name
`ACCELRATED URGENT CARE
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`5/5/2020
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`

`\OOOVQUI-PWNH
`
`NNNNNNMNNw—nr—I—ap—I—r—Ir—tr—‘p—I
`
`OOQQKII$WNHOKDOOVONUI-PWNHO
`
`James C. Schaeffer, Esq. (SBN 120172)
`Zachary S. Rosen, Esq. (SBN 273483)
`SCHAEFFER COTA ROSEN LLP
`500 Esplanade Drive, Suite 950
`Oxnard, CA 93036
`Phone: (805) 988-9200
`(805) 988-9292
`Fax:
`Attorneyé for Defendants
`Emerald Emergency dba
`Accelerated Urgent Care
`
`SUPERIOR COURT OF THE STATE OF CALIFORNIA
`COUNTY OF KERN
`
`MARIA ARNISON, NAOMI ARNISON, a
`minor by her guardian ad litem SHELLY
`ALLDREDGE, '
`
`Plaintiffs,
`
`v.
`ADVENTIST HEALTH, ADVENTIST
`HEALTH PHYSICIANS NETWORK,
`ADVENTIST HEALTH BAKERSFIELD,
`ENRIQUE Q. DELEON P.A.,
`ACCELERATED URGENT CARE,
`BRENDON HELSTON, F.N.P., MARIE
`RAMOS, F.N.P., IKECHUKWU, ARENE,
`M.D., LORRAINE ASH, D.O.,
`NAVINCHANDRA MANIBI-{AI AMEN,
`M.D., ATHER MEHBOOB, M.D.,
`APINUNT KHEMTHONG, M.D.,
`DOES 1 through 100,
`Defendants.
`
`Case No.: BCV-20-100051
`Hon. : David R. Lampe
`Dept. : 11
`
`STIPULATION AND [PROPOSED]
`ORDER TO SET ASIDE DEFAULT
`
`Not yet assigned
`Trial Date:
`Action Filed: January 8. 2020
`
`Plaintiffs, MARIA ARNISON, NAOMI ARNISON, a minor by her guardian ad litem
`SHELLY ALLDREDGE, by and through their counsel of record, and Defendant, Emerald
`Emergency dba Accelerated Urgent Care, by and through their counsel of record, Schaeffer Cota
`Rosen, LLP, hereby agree and stipulate as follows:
`
`STIPULATION AND [PROPOSED] ORDER TO SET ASIDE DEFAULT
`
`l
`
`

`

`\DOONQUl-wav-I
`
`NNNNNNNNN—Iu—aflwy—n—p—ny—Ip—Ir—I
`
`OONQm-PWN—‘OOWQQM#WNHO
`
`The Request for Entry of Default as to Defendant Emerald Emergency dba
`l.
`Accelerated Urgent Care, dated March 11, 2020, and the default obtained by the plaintiffs
`therefrom is set aside; and
`The Answer attached hereto as Exhibit A shall be deemed filed and served as of
`2.
`the date this Stipulation is executed and entered by the Court.
`
`Dated:
`
`April 1
`
`, 2020
`
`SCHAEFFER COTA ROSEN LLP
`
`By:
`
`J
`r
`
`1
`
`'
`
`C. Schae‘ffer
`nary S. Rosen
`Attorneys for Defendants
`Emerald Emergency dba
`Accelerated Urgent Care
`
`Dated:
`
`, 2020
`
`MCCUNE WRIGHT AREVALO LLP
`
`By:
`
`Steven J. Weinberg
`
`Attorneys for Plaintiffs
`Maria Arnison, Naomi Arnison,
`a minor by her guardian ad litem
`Shelly Alldredge
`
`2
`STIPULATION AND [PROPOSED] ORDER TO SET ASIDE DEFAULT
`
`

`

`5—-
`
`\DOOVONLII-th
`
`The Request for Entry of Default as to Defendant Emerald Emergency dba
`1.
`Accelerated Urgent Care, dated March 11, 2020, and the default obtained by the plaintiffs
`therefrom is set aside; and
`The Answer attached hereto as Exhibit A shall be deemed filed and served as of
`2.
`the date this Stipulation is executed and entered by the Court
`
`Dated:
`
`, 2020
`
`SCHAEFFER COTA ROSEN LLP
`
`By:
`
`James C. Schaeffer
`Zachary S. Rosen
`
`Attorneys for Defendants
`Emerald Emergency dba
`Accelerated Urgent Care
`
`NNHHH—In—p—‘p—nr—u—‘r—
`
`Dated: '7 [I
`
`, 2020
`
`MCCUNE WRIGHT AREVALO LLP
`
`Attorneys for
`laintiffs
`Maria Amison, Naomi Amison,
`a minor by her guardian ad litem
`Shelly Alldredge
`
`2
`STDULATION AND [PROPOSED] ORDER TO SET ASIDE DEFAULT
`
`

`

`[PROPOSED] ORDER
`
`IT IS HEREBY ORDERED that:
`The Request for Entry of Default as to Defendant Emerald Emergency dba
`1.
`Accelerated Urgent Care, dated March 11, 2020, and the default obtained by the plaintiffs
`therefrom is set aside; and
`The Answer attached hereto as Exhibit A is deemed filed and served as of the date
`
`2.
`
`below.
`
`Dated:
`
`JUDGE OF THE SUPERIOR COURT
`
`H
`
`\OOOVQUl-bww
`
`NNNNNNNNNHHH—a—A—ap—A—Ih—A—t
`
`OOVQM§WNHOWWVQMAWNHO
`
`3
`STIPULATION AND [PROPOSED] ORDER TO SET ASIDE DEFAULT
`
`

`

`EXHIBIT A
`
`

`

`\OOONGUIAWNv—I
`
`NNNNNNNNNu—nwp—Ip—dy—Iu—nu—np—tu—Iu—n
`
`OOVQm-PWNHOKOOOVQMAWNP‘O
`
`James C. Schaeffer, Esq. (SBN 120172)
`Zachary S. Rosen, Esq. (SBN 273483)
`SCHAEFFER COTA ROSEN LLP
`500 Esplanade Drive, Suite 950
`Oxnard, CA 93036
`Phone: (805) 988-9200
`(805) 988-9292
`Fax:
`Attorneys for Defendants
`Emerald Emergency dba
`Accelerated Urgent Care
`
`SUPERIOR COURT OF THE STATE OF CALIFORNIA
`COUNTY OF KERN
`
`MARIA ARNISON, NAOMI ARNISON, a
`minor by her guardian ad litem SHELLY
`ALLDREDGE,
`
`Plaintiffs,
`
`V.
`ADVENTIST HEALTH, ADVENTIST
`HEALTH PHYSICIANS NETWORK,
`ADVENTIST HEALTH BAKERSFIELD,
`ENRIQUE Q. DELEON P.A.,
`ACCELERATED URGENT CARE,
`BRENDON HELSTON, F.N.P., MARIE
`RAMOS, F.N.P., IKECHUKWU, ARENE,
`M.D., LORRAINE ASH, D.O.,
`NAVINCHANDRA MANIBHAI AMEN,
`M.D., ATHER MEHBOOB, M.D.,
`APINUNT KHEMTHONG, M.D.,
`DOES 1 through 100,
`Defendants.
`
`‘vavvvvvvvvvvvvvvvvvvvv
`
`Case No.2 BCV-20—100051
`Hon.: David R. Lampe
`Dept: 11
`DEFENDANT EMERALD EMERGENCY
`DBA ACCELERATED URGENT CARE’S
`ANSWER TO PLAINTIFF’S COMPLAINT
`
`Not yet assigned
`Trial Date:
`Action Filed: January 8, 2020
`
`TO THE HONORABLE COURT, AND TO ALL PARTIES AND THEIR
`RESPECTIVE ATTORNEYS OF RECORD:
`COMES NOW defendant EMERALD EMERGENCY dba ACCELERATED URGENT
`CARE answering the unverified Complaint (“Complaint”) for Wrongful Death as a Result of
`Medical Negligence on file herein hereby denies and alleges as follows:
`
`_
`
`DEFENDANT EMERALD EMERGENCY DBA ACCELERATED URGENT CARE’S ANSWER TO
`PLAINTIFF’S COMPLAINT
`
`1
`
`

`

`\OOOVONUI-hwwr—a
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`NNNNNNNNNb—I—Ip—A—np—nflwfiu—np—a
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`
`Pursuant to the provisions of Code 0f Civil Procedure, § 431.30(d), this answering
`defendant denies generally and specifically each, every and all of the allegations of plaintiffs’
`unverified Complaint, and each and every purported cause of action therein, and the whole
`thereof; this answering defendant further denies that the plaintiffs and plaintiffs’ decedent were
`injured or damaged in any sum or sums, or at all, by reason of any negligent act or omission t0
`act, or by reason 0f any other conduct 0n the part of this answering defendant or any 0f his agents
`and employees.
`
`FIRST AFFIRMATIVE DEFENSE
`That the Complaint does not state facts sufficient to constitute a cause of action against
`this answering defendant.
`
`SECOND AFFIRMATIVE DEFENSE
`That the plaintiffs and/or plaintiffs’ decedent was negligent, and said negligence was a
`proximate cause of the injuries and damages alleged, if any, and any recovery in this action
`should be reduced proportionate to plaintiffs and/or plaintiffs’ decedent’s own negligence.
`THIRD AFFIRMATIVE DEFENSE
`In the event this answering defendant is found to be negligent, which supposition is
`denied and merely stated for the purpose of this affirmative defense, this defendant may elect to
`introduce evidence of any amounts paid or payable, if any, as a benefit to plaintiffs pursuant to
`Civil Code § 3333.1.
`
`FOURTH AFFIRMATIVE DEFENSE
`Without admitting any of the allegations of the Complaint, this answering defendant
`conditionally and provisionally alleges that any award of damages, if any, for non-economic
`losses cannot exceed the amount specified in Civil Code § 3333.2.
`FIFTH AFFIRMATIVE DEFENSE
`Without admitting any of the allegations of the Complaint, this anSWering defendant
`conditionally and provisionally alleges that if there is any award for future damages in excess of
`the amount specified in Code of Civil Procedure § 667.7, then in that event defendant has the
`right to elect payment in whole 0r in part as specified in Code ofCivil Procedure § 667.7.
`
`2
`DEFENDANT EMERALD EMERGENCY DBA ACCELERATED URGENT CARE’S ANSWER TO
`PLAINTIFF’S COMPLAINT
`
`

`

`SIXTH AFFIRMATIVE DEFENSE
`That the plaintiffs herein are barred from recovery from this answering defendant by
`operation of the statute of limitations as set forth in Code ofCivil Procedure, including, but not
`
`limited to, § 340.5.
`
`SEVENTH AFFIRMATIVE DEFENSE
`That plaintiffs’ actions herein are barred by the provisions of Civil Code, § 1714.8 in that
`the injuries and damages complained of by plaintiff, if any, were solely as the result ofthe natural
`course of a disease or condition and/or expected result of reasonable treatment rendered for the
`disease or condition by the defendant herein.
`EIGHTH AFFIRMATIVE DEFENSE
`Without admitting any of the allegations of the Complaint, in the event this answering
`defendant is found to be liable, any liability ofthis answering defendant for the amount of non-
`economic damages shall be allocated to this answering defendant in direct proportion to this
`defendant’s percentage of fault, if any, according to the Fair Responsibility Act of 1986, Civil
`Code § 1431.1 et. seq.
`
`NINTH AFFIRMATIVE DEFENSE
`Without admitting any of the allegations of the Complaint, this answering defendant
`conditionally and provisionally alleges that if plaintiffs and/or plaintiffs’ decedent sustained any
`injuries or damages, such injuries were caused by, or contributed to by, the acts or omissions of
`other persons or entities and that such acts or omissions constitute an intervening and superseding
`cause of said injuries or damages, thus barring plaintiffs from any recovery against this answering
`
`defendant.
`
`TENTH AFFIRMATIVE DEFENSE
`The allegations of the Complaint are barred by the Emergency Care/Good Samaritan
`statutes, including but not limited to California Health and Safety Code § 1317 and California
`Business and Professions Code §§ 2395, 2396, et seq.
`
`3
`DEFENDANT EMERALD EMERGENCY DBA ACCELERATED URGENT CARE’S ANSWER TO
`PLAINTIFF’S COMPLAINT
`
`\OOOQQUI$DJN
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`

`

`\OOOflmUl-AUJN—a
`
`NNNNNNNNNr—tu—p—nr—‘r—Ip—nh—IH—tw
`
`OOQONM-PWNHOOOOQONM-hWN—‘O
`
`ELEVENTH AFFIRMATIVE DEFENSE
`That plaintiffs prays forjudgment for an amount including prejudgment interest which is
`violative of California case and statutory and case law.
`TWELFTH AFFIRMATIVE DEFENSE
`The plaintiffs and/or plaintiffs’ decedent had knowledge of, appreciated and voluntarily
`assumed the risk of probable and likely injury by reason of such plaintiffs’ and/or plaintiffs
`defendant’s conduct at the time and place mentioned in the Complaint.
`THIRTEENTH AFFIRMATIVE DEFENSE
`Defendant, as to all causes 0f action, acted, at all times mentioned in the Complaint, with
`express or implied consent of plaintiffs and/or plaintiffs’ decedent.
`FOURTEENTH AFFIRMATIVE DEFENSE
`Plaintiffs’ causes of action, and each 0f them, are barred by the doctrine 0f laches.
`FIFTEENTH AFFIRMATIVE DEFENSE
`Plaintiffs’ causes of action, and each of them, are unintelligible and uncertain.
`SIXTEENTH AFFIRMATIVE DEFENSE
`Defendant alleges, as to all causes of action, that by reason of the acts and omissions of
`the plaintiff and/or plaintiff s decedent, plaintiff has waived any entitlement to any recovery, for
`any breach of duty or for any other cause.
`SEVENTEENTH AFFIRMATIVE DEFENSE
`Defendant alleges, as to all causes of action, that by reason of the acts and omissions of
`the plaintiff and/or plaintiffs’ decedent, plaintiffs are estopped from entitlement to any recovery,
`if any exists.
`
`EIGHTEENTH AFFIRMATIVE DEFENSE
`Defendant alleges, as to all causes of action, that by reason of the acts and omissions of
`the plaintiffs and/or plaintiffs’ decedent, plaintiffs have released and discharged defendant from
`any liability.
`
`NINETEENTH AFFIRMATIVE DEFENSE
`Defendant alleges, as to all causes of action, that plaintiffs are barred from any recovery,
`
`4
`DEFENDANT EMERALD EMERGENCY DBA ACCELERATED URGENT CARE’S ANSWER TO
`PLAINTIFF’S COMPLAINT
`
`

`

`if any, by the doctrine of unclean hands.
`TWENTIETH AFFIRMATIVE DEFENSE
`Defendant alleges, as to all causes of action, that it did not breach any duty to plaintiffs
`and/or plaintiffs’ decedent.
`TWENTY-FIRST AFFIRMATIVE DEFENSE
`In the event this answering defendant should be found liable to plaintiffs, this defendant
`is entitled to an offset and/or reduction, and plaintiffs are barred from recovering any and all
`amounts paid for plaintiffs and/or plaintiffs’ decedent’s alleged injuries by way of settlement or
`judgment of any claim, incident or lawsuit which may have contributed to the injuries averred.
`TWENTY-SECOND AFFIRMATIVE DEFENSE
`Pursuant to Code 0f Civil Procedure § 875, in the event that a money judgment is
`rendered jointly against this defendant and one or more co-defendants, a right of contribution
`shall be administered in accordance with the principles of equity.
`
`WHEREFORE, this defendant prays that the plaintiffs take nothing by this action, for
`costs of suit incurred herein and for such other and further relief as the Court deems just and
`
`proper.
`
`Dated:
`
`April 1
`
`, 2020
`
`SCHAEFFER COTA ROSEN LLP
`
`\OOOVQLIIADJNH
`
`NNNNNNNNN—du—du—IHr—ap—v—Iy—Ip—nr—t
`
`OOVOM-AWN—‘OWOOVONMAUJNHO
`
`)
`
`a
`
`By:
`
`v
`s C. Schaeffer
`chary S. Rosen
`Attorneys for Defendants
`Emerald Emergency dba
`Accelerated Urgent Care
`
`5
`DEFENDANT EMERALD EMERGENCY DBA ACCELERATED URGENT CARE’S ANSWER TO
`PLAINTIFF’S COMPLAINT
`
`

`

`PROOF OF SERVICE
`Maria Arm'son. v. Adventist Health, et al.
`Kern County Superior Court
`Case No. BCV-20-1 00051
`STATE OF CALIFORNIA, COUNTY OF VENTURA
`I am employed in the County of Ventura, State 0f California. I am over the age of 1 8 years and
`am not a party to this action. My business address is 500 Esplanade Drive, Suite 950, Oxnard, California
`93036. On April 2, 2020, I served the following document(s) described as STIPULATION AND
`[PROPOSED] ORDER TO SET ASIDE DEFAULT on the list of interested parties attached:
`SEE ATTACHED SERVICE LIST
`By United States Mail (C.C.P. § § 1013a, et seq.):
`I enclosed said document(s) in a sealed
`l placed the envelope for collection and mailing,
`envelope or package to each addressee.
`I am readily familiar with the firm’s practice for
`following our ordinary business practices.
`collecting and processing correspondence for mailing. On the same day that correspondence is
`placed for collection and mailing, it is deposited in the ordinary course of business with the
`United States Postal Service, with postage fully prepaid.
`
`I enclosed said
`document(s) in a sealed envelope or package provided by an overnight delivery carrier to each
`I placed the envelope or package, delivery fees paid for, for collection and
`addressee.
`overnight delivery at a regularly utilized drop box maintained by the overnight delivery carrier.
`
`D By Overnight Delivery/Express Mail (C.C.P. § § 1013(c)(d), ct scq.):
`D By Fax Transmission (C.C.P. § 1012.4, ct seq.):
`
`I transmitted by telecopy/facsimile the
`foregoing document. The document was transmitted to each addressee’s fax number at the
`dates and times shown 0n the attached transmission receipts, to the recipients as shown on the
`attached list. The fax machine utilized, 805-988-9292, complied with California Rules of
`Court, Rule 2.301(3), and reported the transmission(s) complete without error. Record(s) of
`the transmission was generated by the fax machine and is (are) attached.
`
`D By Messenger Service: I enclosed said document(s) in a sealed envelope or package to each
`
`addressee. I provided them to a professional messenger service (First Legal Support Services)
`for personal service on the same day. An original proof of service by messenger will be filed
`pursuant t0 California Rules ofCourt, Rule 3.1300(0).
`
`By Electronic Mail: Via e-mail to the addresses shown on the attached service list.
`By Personal Service: By personally delivering copies to the person served. I delivered such
`envelope by hand to the offices ofthe addressee pursuant to C.C.P. § 101 1.
`
`I declare under the penalty of perjury under the laws of the State of California and of the
`United States that the foregoing is true and correct.
`
`Executed on April 2, 2020, at Oxnard, California.
`
`Shonti Conner
`
`PROOF OF SERVICE
`
`l
`
`\OOOVO\kh-PUJNt—‘
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`SERVICE LIST
`Maria Amison v. Adventist Health, et a1.
`Kern County Superior Court
`Case No.: BCV-20-100051
`
`Attorneys for Defendant
`Angela S. Haskins, Esq.
`HAIGHT BROWN & BONESTEEL LLP
`555 South Flower Street
`Forty-Fifth Floor
`Los Angeles, CA 9007
`Phone: (213) 542-8006
`Fax: (213) 542-8100
`Email: ahaskins@hbblaw.com
`
`Attorneys for Defendant
`Dennis R. Thelen, Esq.
`LEBEAU THELEN LLP
`PO BOX 12092
`Bakersfield, CA 93389-2092
`5001 East Commercenter Drive
`Suite 300
`Bakersfield, CA 93389—2092
`Phone: (661) 325-8962
`Fax: (661) 325-1127
`Email:~ dthelen@lebeauthelen.com
`
`Attorneys for Plaintiff
`Steven J. Weinberg, Esq.
`MCCUNE WRIGHT AREVALO LLP
`73255 El Paseo
`Suite 10
`Palm Desert, CA 92260
`Phone: (760) 346-0227
`Fax: (760) 346-8573
`Email: SJW@Mccunewright.com
`
`Attorneys for Defendant
`Craig S. Dummit, Esq.
`DUMMIT BUCHHOLZ & TRAPP
`11755 Wilshire Boulevard
`15th Floor
`Los Angeles, CA 90025
`Phone: (310) 479-0944
`Fax: (310) 312-3836
`Email: craig.dummit@dbt.law
`
`Attornevs for Defendant
`William White, Esq.
`WPHTE CANEPA LLP
`7690 Noah Palm Avenue
`Suite 105
`Fresno, CA 9371 l
`Phone: (559) 439-0800
`Fax: (559) 439-0802
`Email: wwhite@whitecanepa.com
`
`

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