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Case 1:21-cv-01397-RBW Document 1 Filed 05/21/21 Page 1 of 58
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`UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF COLUMBIA
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`MERCY GENERAL HOSPITAL,
`4001 J St
`Sacramento, CA
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`REGIONAL MEDICAL CENTER OF SAN
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`JOSE AKA ALEXIAN BROTHERS OF SAN
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`JOSE, INC. FKA ALEXIAN BROTHERS
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`HOSPITAL,
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`225 N Jackson Avenue
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`San Jose, CA
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`AHMC ANAHEIM REGIONAL MEDICAL
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`CENTER AKA ANAHEIM MEMORIAL
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`MEDICAL CENTER,
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`1111 W La Palma Avenue
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`Anaheim, CA
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`BAKERSFIELD MEMORIAL HOSPITAL,
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`420 34th St
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`Bakersfield, CA
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`CALIFORNIA HOSPITAL MEDICAL
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`CENTER LA AKA CALIFORNIA HOSPITAL )
`MEDICAL CENTER,
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`1401 South Grand Avenue
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`Los Angeles, CA
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`CALIFORNIA PACIFIC MEDICAL CENTER- )
`VAN NESS CAMPUS AKA CALIFORNIA
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`PACIFIC MEDICAL CENTER,
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`1101 Van Ness Avenue
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`San Francisco, CA
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`COMMUNITY HOSPITAL OF SAN
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`BERNADINO,
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`1805 Medical Center Drive
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`San Bernardino, CA
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`DANIEL FREEMAN MARINA HOSPITAL,
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`4650 LINCOLN BLVD.
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`MARINA EL REY, CA 90292
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`DANIEL FREEMAN MEMORIAL
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`Case No. 21-1397
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`4811-3131-4663.6
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`1
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`Case 1:21-cv-01397-RBW Document 1 Filed 05/21/21 Page 2 of 58
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`HOSPITAL,
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`333 N. PRAIRIE AVE.
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`INGLEWOOD, CA 90301
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`CALIFORNIA PACIFIC MEDICAL CTR-
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`DAVIES CAMPUS HOSP AKA DAVIES
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`MEDICAL CENTER,
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`601 Duboce Ave
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`San Francisco, CA
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`DOMINICAN HOSPITAL AKA DOMINICAN )
`SANTA CRUZ HOSPITAL,
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`1555 Soquel Drive
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`Santa Cruz, CA
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`EDEN MEDICAL CENTER,
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`20103 Lake Chabot Road
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`Castro Valley, CA
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`EMANATE HEALTH FOOTHILL
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`PRESBYTERIAN HOSPITAL AKA
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`FOOTHILL PRESBYTERIAN HOSPITAL,
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`250 S Grand Ave
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`Glendora, CA
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`GLENDALE ADVENTIST MEDICAL
`)
`CENTER AKA GLENDALE ADVENTIST
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`HOSPITAL,
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`1509 E Wilson Terrace
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`Glendale, CA
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`GLENDALE MEM HOSPITAL & HLTH
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`CENTER AKA GLENDALE MEMORIAL
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`HOSPITAL,
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`1420 S Central Ave
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`Glendale, CA
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`GOLETA VALLEY COTTAGE HOSPITAL,
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`351 S Patterson Ave
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`Santa Barbara, CA
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`HUNTINGTON MEMORIAL HOSPITAL,
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`100 W California Blvd
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`Pasadena, CA
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`EMANATE HEALTH INTER-COMMUNITY
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`4811-3131-4663.6
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`Case 1:21-cv-01397-RBW Document 1 Filed 05/21/21 Page 3 of 58
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`HOSPITAL AKA INTERCOMMUNITY
`MEDICAL CENTER,
`210 W San Bernardino Road
`Covina, CA
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`LAPALMA INTERCOMMUNITY
`HOSPITAL,
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`7901 Walker Street
`La Palma, CA
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`ADVENTIST HEALTH LODI MEMORIAL
`AKA LODI MEMORIAL HOSPITAL,
`975 S Fairmont Avenue
`Lodi, CA
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`LOMA LINDA UNIVERSITY MEDICAL
`CENTER,
`11234 Anderson St
`Loma Linda, CA
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`LONG BEACH COMMUNITY HOSPITAL,
`1720 Termin Ave.
`Long Beach, CA 90804
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`LONG BEACH MEMORIAL MEDICAL
`CENTER,
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`2801 Atlantic Ave
`Long Beach, CA
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`MARIAN REGIONAL MEDICAL CENTER
`AKA MARIAN HOSPITAL,
`1400 E Church St
`Santa Maria, CA
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`MARK TWAIN HOSPITAL,
`768 Mountain Ranch Road
`San Andreas, CA 95249
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`MARTIN LUTHER HOSPITAL,
`1830 W Romneya Drive
`Anaheim, CA 92801
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`MERCY AMERICAN RIVER HOSPITAL,
`4747 Engle Road
`Carmichael, CA 95608
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`4811-3131-4663.6
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`Case 1:21-cv-01397-RBW Document 1 Filed 05/21/21 Page 4 of 58
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`MERCY HOSPITAL AKA MERCY
`BAKERSFIELD HOSPITAL,
`2215 Truxtun Avenue
`Bakersfield, CA
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`MERCY HOSPITAL OF FOLSOM,
`1650 Creekside Drive
`Folsom, CA
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`MERCY MEDICAL CENTER AKA MERCY
`MEDICAL CENTER, MERCED
`COMMUNITY CENTER,
`333 Mercy Avenue
`Merced, CA
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`MERCY MEDICAL CENTER, MERCED
`DOMINICAN,
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`333 Mercy Avenue
`Merced, CA 95340
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`MERCY MEDICAL CENTER REDDING,
`2175 Rosaline Ave, Clairmont Hgts
`Redding, CA
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`METHODIST HOSPITAL OF
`SACRAMENTO,
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`7500 Hospital Drive
`Sacramento, CA
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`MERCY MT. SHASTA HOSPITAL,
`914 Pine Street
`Mt. Shasta, CA 96067
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`MERCY SAN JUAN MEDICAL CENTER
`AKA MERCY SAN JUAN HOSPITAL,
`6501 Coyle Ave
`Carmichael, CA
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`MILLS-PENINSULA MEDICAL CENTER
`AKA MILLS-PENINSULA HOSPITAL,
`1501 Trousdale Drive
`Burlingame, CA
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`NORTHRIDGE HOSPITAL MEDICAL
`CENTER AKA NORTHRIDGE HOSPITAL,
`ROSCOE,
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`4811-3131-4663.6
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`Case 1:21-cv-01397-RBW Document 1 Filed 05/21/21 Page 5 of 58
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`18300 Roscoe Blvd
`Northridge, CA
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`NORTHRIDGE HOSPITAL, SHERMAN
`WAY,
`14500 Sherman Circle Drive
`Van Nuys, CA 91405
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`MEMORIALCARE ORANGE COAST
`MEDICAL CENTER AKA ORANGE COAST
`MEMORIAL MEDICAL CENTER,
`9920 Talbert Avenue
`Fountain Valley, CA
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`PARADISE VALLEY HOSPITAL,
`2400 East 4th St
`National City, CA
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`POMONA VALLEY HOSPITAL MEDICAL
`CENTER,
`1798 N Garey Ave
`Pomona, CA
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`PIH HEALTH HOSPITAL-WHITTIER AKA
`PRESBYTERIAN INTERCOMMUNITY
`HOSPITAL,
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`12401 Washington Blvd
`Whittier, CA
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`QUEEN OF THE VALLEY HOSPITAL,
`1115 S. Sunset Ave.
`West Covina, CA 91790
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`REDLANDS COMMUNITY HOSPITAL,
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`350 Terracina Blvd
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`Redlands, CA
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`ROBERT F. KENNEDY MEDICAL CENTER, )
`4477 W. 118th St.
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`Hawthorne, CA 90250
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`MEMORIALCARE SADDLEBACK
`MEDICAL CENTER AKA SADDLEBACK
`MEMORIAL MEDICAL CENTER,
`24451 Health Center Drive
`Laguna Hills, CA
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`4811-3131-4663.6
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`5
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`Case 1:21-cv-01397-RBW Document 1 Filed 05/21/21 Page 6 of 58
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`SAN GABRIEL VALLEY MEDICAL
`CENTER AKA SAN GABRIEL VALLEY
`HOSPITAL,
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`438 W Las Tunas Drive
`San Gabriel, CA
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`SANTA BARBARA COTTAGE HOSPITAL,
`400 West Pueblo
`Santa Barbara, CA
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`SANTA MARTA HOSPITAL,
`319 N. Humphreys Ave.
`Los Angeles, CA 90022
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`SEQUOIA HOSPITAL,
`170 Alameda De Las Pulgas
`Redwood City, CA
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`SIERRA NEVADA MEMORIAL HOSPITAL,
`155 Glasson Way
`Grass Valley, CA
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`ST. BERNADINE MEDICAL CENTER,
`2101 N Waterman Ave
`San Bernardino, CA
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`ST. DOMINIC’S HOSPITAL,
`1777 W. Yosemite Ave.
`Manteca, CA 95337
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`ST. ELIZABETH COMMUNITY HOSPITAL,
`2550 Sister Mary Columba Drive
`Red Bluff, CA
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`ST. FRANCIS HOSPITAL, SANTA
`BARBARA,
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`601 E. Micheltorena Street
`Santa Barbara, CA 93103
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`SAINT FRANCIS MEDICAL CENTER AKA
`ST. FRANCIS MEDICAL CENTER,
`LYNNWOOD,
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`3630 East Imperial Highway
`Lynwood, CA
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`4811-3131-4663.6
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`Case 1:21-cv-01397-RBW Document 1 Filed 05/21/21 Page 7 of 58
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`ST. FRANCIS MEMORIAL HOSPITAL,
`900 Hyde St
`San Francisco, CA
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`ADVENTIST HEALTH ST HELENA AKA
`ST. HELENA HOSPITAL,
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`10 Woodland Road
`Saint Helena, CA
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`ST. JOHN’S PLEASANT VALLEY
`HOSPITAL,
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`2309 Antonio Ave
`Camarillo, CA
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`ST. JOHN’S REGIONAL MEDICAL
`CENTER,
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`1600 N Rose Ave
`Oxnard, CA
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`ST. JOSEPH’S BEHAVIORAL HEALTH,
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`2510 N. California St.
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`Stockton, CA 95204
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`ST JOSEPH'S MEDICAL CENTER OF
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`STOCKTON AKA ST. JOSEPH’S HOSPITAL, )
`STOCKTON,
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`1800 N California St
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`Stockton, CA
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`CALIFORNIA PACIFIC MEDICAL CENTER
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`- MISSION BERNAL AKA ST. LUKE’S
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`HOSPITAL,
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`3555 Cesar Chavez Street
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`San Francisco, CA
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`ST. MARY MEDICAL CENTER, LONG
`BEACH,
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`1050 Linden Ave
`Long Beach, CA
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`ST MARY'S MEDICAL CENTER AKA ST.
`MARY’S HOSPITAL MEDICAL CENTER,
`450 Stanyan St
`San Francisco, CA
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`ST. ROSE HOSPITAL,
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`4811-3131-4663.6
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`Case 1:21-cv-01397-RBW Document 1 Filed 05/21/21 Page 8 of 58
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`27200 Calaroga Ave
`Hayward, CA
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`ST. VINCENT MEDICAL CENTER,
`2131 W 3rd St
`Los Angeles, CA
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`STANFORD HEALTH CARE FKA
`STANFORD HOSPITALS AND CLINICS,
`300 Pasteur Drive
`Stanford, CA
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`SUTTER COAST HOSPITAL,
`800 E Washington Blvd
`Crescent City, CA
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`SUTTER MEDICAL CENTER,
`SACRAMENTO AKA SUTTER
`COMMUNITY HOSPITAL (SMC),
`2825 Capitol Avenue
`Sacramento, CA
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`SUTTER MEMORIAL HOSPITAL,
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`5151 F St.
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`Sacramento, CA 95819
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`SUTTER SANTA ROSA MEDICAL CENTER, )
`30 Mark West Springs Road
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`Santa Rosa, CA
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`SUTTER SOLANO MEDICAL CENTER,
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`300 Hospital Dr
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`Vallejo, CA
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`STANFORD HEALTH CARE –
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`VALLEYCARE AKA VALLEY MEMORIAL
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`HOSPITAL,
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`5555 West Las Positas Boulevard
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`Pleasanton, CA
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`SUTTER LAKESIDE HOSPITAL,
`5176 Hill Road E
`Lakeport, CA 95453
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`VALLEYCARE MEDICAL CENTER, and
`5555 West Las Positas Blvd.
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`4811-3131-4663.6
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`Case 1:21-cv-01397-RBW Document 1 Filed 05/21/21 Page 9 of 58
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`WOODLAND MEMORIAL HOSPITAL,
`1325 Cottonwood Street
`Woodland, CA
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`Pleasanton, CA 94588
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`Plaintiffs,
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`XAVIER BECERRA, in his official capacity as
`Secretary of the United States Department of
`Health and Human Services,
`
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`v.
`
`Defendant.
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`
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`COMPLAINT FOR JUDICIAL REVIEW OF FINAL ADVERSE
`AGENCY DECISIONS ON MEDICARE REIMBURSEMENT
`
`Plaintiffs (collectively, the “Hospitals”) by and through their undersigned attorneys, bring
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`this action against Defendant Xavier Becerra in his official capacity as Secretary of Health and
`
`Human Services (the “Defendant”), and state as follows:
`
`JURISDICTION AND VENUE
`
`1.
`
`This is a civil action arising under Title XVIII of the Social Security Act, as
`
`amended (42 U.S.C. §§ 1395 et seq.) (hereinafter referred to as the “Medicare Act” or the
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`“Act”), to obtain judicial review of a final adverse agency decision of the Secretary of the United
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`States Department of Health and Human Services.
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`This Court has jurisdiction under 42 U.S.C. § 1395oo(f).
`
`Venue lies in this judicial district under 42 U.S.C. § 1395oo(f) and 28 U.S.C. §
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`2.
`
`3.
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`1391.
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`4811-3131-4663.6
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`Case 1:21-cv-01397-RBW Document 1 Filed 05/21/21 Page 10 of 58
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`PARTIES
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`4.
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`Plaintiff Regional Medical Center of San Jose a/k/a Alexian Brothers of San Jose,
`
`Inc., f/k/a Alexian Brothers Hospital (Medicare provider number 05-0125), is located in
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`California and during the period at issue in this case furnished inpatient and outpatient hospital
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`services to, inter alia, patients entitled to benefits under both the Medicare programs and
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`Medicaid.
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`5.
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`Plaintiff AHMC Anaheim Regional Medical Center a/k/a Anaheim Memorial
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`Medical Center (Medicare provider number 05-0226), is located in California and during the
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`period at issue in this case furnished inpatient and outpatient hospital services to, inter alia,
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`patients entitled to benefits under both the Medicare programs and Medicaid.
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`6.
`
`Plaintiff Bakersfield Memorial Hospital (Medicare provider number 05-0036), is
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`located in California and during the period at issue in this case furnished inpatient and outpatient
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`hospital services to, inter alia, patients entitled to benefits under both the Medicare programs and
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`Medicaid.
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`7.
`
`Plaintiff California Hospital Medical Center LA a/k/a California Hospital Medical
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`Center (Medicare provider number 05-0149), is located in California and during the period at
`
`issue in this case furnished inpatient and outpatient hospital services to, inter alia, patients
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`entitled to benefits under both the Medicare programs and Medicaid.
`
`8.
`
`Plaintiff California Pacific Medical Center- Van Ness Campus a/k/a California
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`Pacific Medical Center (Medicare provider number 05-0047), is located in California and during
`
`the period at issue in this case furnished inpatient and outpatient hospital services to, inter alia,
`
`patients entitled to benefits under both the Medicare programs and Medicaid.
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`9.
`
`Plaintiff Community Hospital of San Bernadino (Medicare provider number 05-
`
`0089), is located in California and during the period at issue in this case furnished inpatient and
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`4811-3131-4663.6
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`Case 1:21-cv-01397-RBW Document 1 Filed 05/21/21 Page 11 of 58
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`outpatient hospital services to, inter alia, patients entitled to benefits under both the Medicare
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`programs and Medicaid.
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`10.
`
`Plaintiff Daniel Freeman Marina Hospital (Medicare provider number 05-0559),
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`is located in California and during the period at issue in this case furnished inpatient and
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`outpatient hospital services to, inter alia, patients entitled to benefits under both the Medicare
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`programs and Medicaid.
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`11.
`
`Plaintiff Daniel Freeman Memorial Hospital (Medicare provider number 05-
`
`0267), is located in California and during the period at issue in this case furnished inpatient and
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`outpatient hospital services to, inter alia, patients entitled to benefits under both the Medicare
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`programs and Medicaid.
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`12.
`
`Plaintiff California Pacific Medical Ctr-Davies Campus Hosp a/k/a Davies
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`Medical Center (Medicare provider number 05-0008), is located in California and during the
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`period at issue in this case furnished inpatient and outpatient hospital services to, inter alia,
`
`patients entitled to benefits under both the Medicare programs and Medicaid.
`
`13.
`
`Plaintiff Dominican Hospital a/k/a Dominican Santa Cruz Hospital (Medicare
`
`provider number 05-0242), is located in California and during the period at issue in this case
`
`furnished inpatient and outpatient hospital services to, inter alia, patients entitled to benefits
`
`under both the Medicare programs and Medicaid.
`
`14.
`
`Plaintiff Eden Medical Center (Medicare provider number 05-0488), is located in
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`California and during the period at issue in this case furnished inpatient and outpatient hospital
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`services to, inter alia, patients entitled to benefits under both the Medicare programs and
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`Medicaid.
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`4811-3131-4663.6
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`Case 1:21-cv-01397-RBW Document 1 Filed 05/21/21 Page 12 of 58
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`15.
`
`Plaintiff Emanate Health Foothill Presbyterian Hospital a/k/a Foothill
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`Presbyterian Hospital (Medicare provider number 05-0597), is located in California and during
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`the period at issue in this case furnished inpatient and outpatient hospital services to, inter alia,
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`patients entitled to benefits under both the Medicare programs and Medicaid.
`
`16.
`
`Plaintiff Glendale Adventist Medical Center a/k/a Glendale Adventist Hospital
`
`(Medicare provider number 05-0239), is located in California and during the period at issue in
`
`this case furnished inpatient and outpatient hospital services to, inter alia, patients entitled to
`
`benefits under both the Medicare programs and Medicaid.
`
`17.
`
`Plaintiff Glendale Mem Hospital & Hlth Center a/k/a Glendale Memorial Hospital
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`(Medicare provider number 05-0058), is located in California and during the period at issue in
`
`this case furnished inpatient and outpatient hospital services to, inter alia, patients entitled to
`
`benefits under both the Medicare programs and Medicaid.
`
`18.
`
`Plaintiff Goleta Valley Cottage Hospital (Medicare provider number 05-0357), is
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`located in California and during the period at issue in this case furnished inpatient and outpatient
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`hospital services to, inter alia, patients entitled to benefits under both the Medicare programs and
`
`Medicaid.
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`19.
`
`Plaintiff Huntington Memorial Hospital (Medicare provider number 05-0438), is
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`located in California and during the period at issue in this case furnished inpatient and outpatient
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`hospital services to, inter alia, patients entitled to benefits under both the Medicare programs and
`
`Medicaid.
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`20.
`
`Plaintiff Emanate Health Inter-Community Hospital a/k/a Intercommunity
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`Medical Center (Medicare provider number 05-0382), is located in California and during the
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`4811-3131-4663.6
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`12
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`Case 1:21-cv-01397-RBW Document 1 Filed 05/21/21 Page 13 of 58
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`period at issue in this case furnished inpatient and outpatient hospital services to, inter alia,
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`patients entitled to benefits under both the Medicare programs and Medicaid.
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`21.
`
`Plaintiff LaPalma Intercommunity Hospital (Medicare provider number 05-0580),
`
`is located in California and during the period at issue in this case furnished inpatient and
`
`outpatient hospital services to, inter alia, patients entitled to benefits under both the Medicare
`
`programs and Medicaid.
`
`22.
`
`Plaintiff Adventist Health Lodi Memorial a/k/a Lodi Memorial Hospital
`
`(Medicare provider number 05-0336), is located in California and during the period at issue in
`
`this case furnished inpatient and outpatient hospital services to, inter alia, patients entitled to
`
`benefits under both the Medicare programs and Medicaid.
`
`23.
`
`Plaintiff Loma Linda University Medical Center (Medicare provider number 05-
`
`0327), is located in California and during the period at issue in this case furnished inpatient and
`
`outpatient hospital services to, inter alia, patients entitled to benefits under both the Medicare
`
`programs and Medicaid.
`
`24.
`
`Plaintiff Long Beach Community Hospital (Medicare provider number 05-0170),
`
`is located in California and during the period at issue in this case furnished inpatient and
`
`outpatient hospital services to, inter alia, patients entitled to benefits under both the Medicare
`
`programs and Medicaid.
`
`25.
`
`Plaintiff Long Beach Memorial Medical Center (Medicare provider number 05-
`
`0485), is located in California and during the period at issue in this case furnished inpatient and
`
`outpatient hospital services to, inter alia, patients entitled to benefits under both the Medicare
`
`programs and Medicaid.
`
`4811-3131-4663.6
`
`13
`
`

`

`Case 1:21-cv-01397-RBW Document 1 Filed 05/21/21 Page 14 of 58
`
`
`
`26.
`
`Plaintiff Marian Regional Medical Center a/k/a Marian Hospital (Medicare
`
`provider number 05-0107), is located in California and during the period at issue in this case
`
`furnished inpatient and outpatient hospital services to, inter alia, patients entitled to benefits
`
`under both the Medicare programs and Medicaid.
`
`27.
`
`Plaintiff Mark Twain Hospital (Medicare provider number 05-0366), is located in
`
`California and during the period at issue in this case furnished inpatient and outpatient hospital
`
`services to, inter alia, patients entitled to benefits under both the Medicare programs and
`
`Medicaid.
`
`28.
`
`Plaintiff Martin Luther Hospital (Medicare provider number 05-0282), is located
`
`in California and during the period at issue in this case furnished inpatient and outpatient hospital
`
`services to, inter alia, patients entitled to benefits under both the Medicare programs and
`
`Medicaid.
`
`29.
`
`Plaintiff Mercy American River Hospital (Medicare provider number 05-0421), is
`
`located in California and during the period at issue in this case furnished inpatient and outpatient
`
`hospital services to, inter alia, patients entitled to benefits under both the Medicare programs and
`
`Medicaid.
`
`30.
`
`Plaintiff Mercy Hospital a/k/a Mercy Bakersfield Hospital (Medicare provider
`
`number 05-0295), is located in California and during the period at issue in this case furnished
`
`inpatient and outpatient hospital services to, inter alia, patients entitled to benefits under both the
`
`Medicare programs and Medicaid.
`
`31.
`
`Plaintiff Mercy General Hospital (Medicare provider number 05-0017), is located
`
`in California and during the period at issue in this case furnished inpatient and outpatient hospital
`
`4811-3131-4663.6
`
`14
`
`

`

`Case 1:21-cv-01397-RBW Document 1 Filed 05/21/21 Page 15 of 58
`
`
`
`services to, inter alia, patients entitled to benefits under both the Medicare programs and
`
`Medicaid.
`
`32.
`
`Plaintiff Mercy Hospital of Folsom (Medicare provider number 05-0414), is
`
`located in California and during the period at issue in this case furnished inpatient and outpatient
`
`hospital services to, inter alia, patients entitled to benefits under both the Medicare programs and
`
`Medicaid.
`
`33.
`
`Plaintiff Mercy Medical Center a/k/a Mercy Medical Center, Merced Community
`
`Center (Medicare provider number 05-0444), is located in California and during the period at
`
`issue in this case furnished inpatient and outpatient hospital services to, inter alia, patients
`
`entitled to benefits under both the Medicare programs and Medicaid.
`
`34.
`
`Plaintiff Mercy Medical Center, Merced Dominican (Medicare provider number
`
`05-0117), is located in California and during the period at issue in this case furnished inpatient
`
`and outpatient hospital services to, inter alia, patients entitled to benefits under both the
`
`Medicare programs and Medicaid.
`
`35.
`
`Plaintiff Mercy Medical Center Redding (Medicare provider number 05-0280), is
`
`located in California and during the period at issue in this case furnished inpatient and outpatient
`
`hospital services to, inter alia, patients entitled to benefits under both the Medicare programs and
`
`Medicaid.
`
`36.
`
`Plaintiff Methodist Hospital of Sacramento (Medicare provider number 05-0590),
`
`is located in California and during the period at issue in this case furnished inpatient and
`
`outpatient hospital services to, inter alia, patients entitled to benefits under both the Medicare
`
`programs and Medicaid.
`
`4811-3131-4663.6
`
`15
`
`

`

`Case 1:21-cv-01397-RBW Document 1 Filed 05/21/21 Page 16 of 58
`
`
`
`37.
`
`Plaintiff Mercy Mt. Shasta Hospital (Medicare provider number 05-0419), is
`
`located in California and during the period at issue in this case furnished inpatient and outpatient
`
`hospital services to, inter alia, patients entitled to benefits under both the Medicare programs and
`
`Medicaid.
`
`38.
`
`Plaintiff Mercy San Juan Medical Center a/k/a Mercy San Juan Hospital
`
`(Medicare provider number 05-0516), is located in California and during the period at issue in
`
`this case furnished inpatient and outpatient hospital services to, inter alia, patients entitled to
`
`benefits under both the Medicare programs and Medicaid.
`
`39.
`
`Plaintiff Mills-Peninsula Medical Center a/k/a Mills-Peninsula Hospital
`
`(Medicare provider number 05-0007), is located in California and during the period at issue in
`
`this case furnished inpatient and outpatient hospital services to, inter alia, patients entitled to
`
`benefits under both the Medicare programs and Medicaid.
`
`40.
`
`Plaintiff Northridge Hospital Medical Center a/k/a Northridge Hospital, Roscoe
`
`(Medicare provider number 05-0116), is located in California and during the period at issue in
`
`this case furnished inpatient and outpatient hospital services to, inter alia, patients entitled to
`
`benefits under both the Medicare programs and Medicaid.
`
`41.
`
`Plaintiff Northridge Hospital, Sherman Way (Medicare provider number 05-
`
`0299), is located in California and during the period at issue in this case furnished inpatient and
`
`outpatient hospital services to, inter alia, patients entitled to benefits under both the Medicare
`
`programs and Medicaid.
`
`42.
`
`Plaintiff MemorialCare Orange Coast Medical Center a/k/a Orange Coast
`
`Memorial Medical Center (Medicare provider number 05-0678), is located in California and
`
`4811-3131-4663.6
`
`16
`
`

`

`Case 1:21-cv-01397-RBW Document 1 Filed 05/21/21 Page 17 of 58
`
`
`
`during the period at issue in this case furnished inpatient and outpatient hospital services to, inter
`
`alia, patients entitled to benefits under both the Medicare programs and Medicaid.
`
`43.
`
`Plaintiff Paradise Valley Hospital (Medicare provider number 05-0024), is located
`
`in California and during the period at issue in this case furnished inpatient and outpatient hospital
`
`services to, inter alia, patients entitled to benefits under both the Medicare programs and
`
`Medicaid.
`
`44.
`
`Plaintiff Pomona Valley Hospital Medical Center (Medicare provider number 05-
`
`0231), is located in California and during the period at issue in this case furnished inpatient and
`
`outpatient hospital services to, inter alia, patients entitled to benefits under both the Medicare
`
`programs and Medicaid.
`
`45.
`
`Plaintiff PIH Health Hospital-Whittier a/k/a Presbyterian Intercommunity
`
`Hospital (Medicare provider number 05-0169), is located in California and during the period at
`
`issue in this case furnished inpatient and outpatient hospital services to, inter alia, patients
`
`entitled to benefits under both the Medicare programs and Medicaid.
`
`46.
`
`Queen of the Valley Hospital (Medicare provider number 05-0369), is located in
`
`California and during the period at issue in this case furnished inpatient and outpatient hospital
`
`services to, inter alia, patients entitled to benefits under both the Medicare programs and
`
`Medicaid.
`
`47.
`
`Plaintiff Redlands Community Hospital (Medicare provider number 05-0272), is
`
`located in California and during the period at issue in this case furnished inpatient and outpatient
`
`hospital services to, inter alia, patients entitled to benefits under both the Medicare programs and
`
`Medicaid.
`
`4811-3131-4663.6
`
`17
`
`

`

`Case 1:21-cv-01397-RBW Document 1 Filed 05/21/21 Page 18 of 58
`
`
`
`48.
`
`Plaintiff Robert F. Kennedy Medical Center (Medicare provider number 05-
`
`0420), is located in California and during the period at issue in this case furnished inpatient and
`
`outpatient hospital services to, inter alia, patients entitled to benefits under both the Medicare
`
`programs and Medicaid.
`
`49.
`
`Plaintiff MemorialCare Saddleback Medical Center a/k/a Saddleback Memorial
`
`Medical Center (Medicare provider number 05-0603), is located in California and during the
`
`period at issue in this case furnished inpatient and outpatient hospital services to, inter alia,
`
`patients entitled to benefits under both the Medicare programs and Medicaid.
`
`50.
`
`Plaintiff San Gabriel Valley Medical Center a/k/a San Gabriel Valley Hospital
`
`(Medicare provider number 05-0132), is located in California and during the period at issue in
`
`this case furnished inpatient and outpatient hospital services to, inter alia, patients entitled to
`
`benefits under both the Medicare programs and Medicaid.
`
`51.
`
`Plaintiff Santa Barbara Cottage Hospital (Medicare provider number 05-0396), is
`
`located in California and during the period at issue in this case furnished inpatient and outpatient
`
`hospital services to, inter alia, patients entitled to benefits under both the Medicare programs and
`
`Medicaid.
`
`52.
`
`Plaintiff Santa Marta Hospital (Medicare provider number 05-0577), is located in
`
`California and during the period at issue in this case furnished inpatient and outpatient hospital
`
`services to, inter alia, patients entitled to benefits under both the Medicare programs and
`
`Medicaid.
`
`53.
`
`Plaintiff Sequoia Hospital (Medicare provider number 05-0197), is located in
`
`California and during the period at issue in this case furnished inpatient and outpatient hospital
`
`4811-3131-4663.6
`
`18
`
`

`

`Case 1:21-cv-01397-RBW Document 1 Filed 05/21/21 Page 19 of 58
`
`
`
`services to, inter alia, patients entitled to benefits under both the Medicare programs and
`
`Medicaid.
`
`54.
`
`Plaintiff Sierra Nevada Memorial Hospital (Medicare provider number 05-0150),
`
`is located in California and during the period at issue in this case furnished inpatient and
`
`outpatient hospital services to, inter alia, patients entitled to benefits under both the Medicare
`
`programs and Medicaid.
`
`55.
`
`Plaintiff St. Bernadine Medical Center (Medicare provider number 05-0129), is
`
`located in California and during the period at issue in this case furnished inpatient and outpatient
`
`hospital services to, inter alia, patients entitled to benefits under both the Medicare programs and
`
`Medicaid.
`
`56.
`
`Plaintiff St. Dominic’s Hospital (Medicare provider number 05-0695), is located
`
`in California and during the period at issue in this case furnished inpatient and outpatient hospital
`
`services to, inter alia, patients entitled to benefits under both the Medicare programs and
`
`Medicaid.
`
`57.
`
`Plaintiff St. Elizabeth Community Hospital (Medicare provider number 05-0042),
`
`is located in California and during the period at issue in this case furnished inpatient and
`
`outpatient hospital services to, inter alia, patients entitled to benefits under both the Medicare
`
`programs and Medicaid.
`
`58.
`
`Plaintiff St. Francis Hospital, Santa Barbara (Medicare provider number 05-0061,
`
`is located in California and during the period at issue in this case furnished inpatient and
`
`outpatient hospital services to, inter alia, patients entitled to benefits under both the Medicare
`
`programs and Medicaid.
`
`4811-3131-4663.6
`
`19
`
`

`

`Case 1:21-cv-01397-RBW Document 1 Filed 05/21/21 Page 20 of 58
`
`
`
`59.
`
`Plaintiff Saint Francis Medical Center a/k/a St. Francis Medical Center,
`
`Lynnwood (Medicare provider number 05-0104), is located in California and during the period at
`
`issue in this case furnished inpatient and outpatient hospital services to, inter alia, patients
`
`entitled to benefits under both the Medicare programs and Medicaid.
`
`60.
`
`Plaintiff St. Francis Memorial Hospital (Medicare provider number 05-0152), is
`
`located in California and during the period at issue in this case furnished inpatient and outpatient
`
`hospital services to, inter alia, patients entitled to benefits under both the Medicare programs and
`
`Medicaid.
`
`61.
`
`Plaintiff Adventist Health St Helena a/k/a St. Helena Hospital (Medicare provider
`
`number 05-0013), is located in California and during the period at issue in this case furnished
`
`inpatient and outpatient hospital services to, inter alia, patients entitled to benefits under both the
`
`Medicare programs and Medicaid.
`
`62.
`
`Plaintiff St. John’s Pleasant Valley Hospital (Medicare provider number 05-
`
`0616), is located in California and during the period at issue in this case furnished inpatient and
`
`outpatient hospital services to, inter alia, patients entitled to benefits under both the Medicare
`
`programs and Medicaid.
`
`63.
`
`Plaintiff St. John’s Regional Medical Center (Medicare provider number 05-
`
`0082), is located in California and during the period at issue in this case furnished inpatient and
`
`outpatient hospital services to, inter alia, patients entitled to benefits under both the Medicare
`
`programs and Medicaid.
`
`64.
`
`Plaintiff St. Joseph’s Behavioral Health (Medicare provider number 05-4123), is
`
`located in California and during the period at issue in this case furnished inpatient and outpatient
`
`4811-3131-4663.6
`
`20
`
`

`

`Case 1:21-cv-01397-RBW Document 1 Filed 05/21/21 Page 21 of 58
`
`
`
`hospital services to, inter alia, patients entitled to benefits under both the Medicare programs and
`
`Medicaid.
`
`65.
`
`Plaintiff St Joseph’s Medical Center of Stockton a/k/a St. Joseph’s Hospital,
`
`Stockton (Medicare provider number 05-0084), is located in California and during the period at
`
`issue in this case furnished inpatient and outpatient hospital services to, inter alia, patients
`
`entitled to benefits under both the Medicare programs and Medicaid.
`
`66.
`
`Plaintiff California Pacific Medical Center - Mission Bernal a/k/a St. Luke’s
`
`Hospital (Medicare provider number 05-0055), is located in California and during the period at
`
`issue in this case furnished inpatient and outpatient hospital services to, inter alia, patients
`
`entitled to benefits under both the Medicare programs and Medicaid.
`
`67.
`
`Plaintiff St. Mary Medical Center, Long Beach (Medicare provider number 05-
`
`0191), is located in California and during the period at issue in this case furnished inpatient and
`
`outpatient hospital services to, inter alia, patients entitled to benefits under both the Medicare
`
`programs and Medicaid.
`
`68.
`
`Plaintiff St Mary’s Medical Center a/k/a St. Mary’s Hospital Medical Center
`
`(Medicare provider number 05-0457), is located in California and during the period at issue in
`
`this case furnished inpatient and outpatient hospital services to, inter alia, patients entitled to
`
`benefits under both the Medicare programs and Medicaid.
`
`69.
`
`Plaintiff St. Rose Hospital (Medicare provider number 05-0002), is located in
`
`California and during the period at issue in this case furnished inpatient and outpatient hospital
`
`services to, inter alia, patients entitled to benefits under both the Medicare programs and
`
`Medicaid.
`
`481

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