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Complaint Information

FILED BY FAX

WEISS MARTIN SALINAS & HEARST

A PROFESSIONAL CORPORATION . DEC 2§ 2015

7108 No(r:th Fresno Street, Suite 250 Fresno, California 93720 RIOR COURT

(559) 438-2080 FRESNO SUPH

(559) 438-8363 Facsimile By SERUTY

Attorneys for Defendants COALINGA REGIONAL MEDICAL CENTER and COALINGA REGIONAL MEDICAL CENTER dba RALPH NEATE EXTENDED CARE CENTER

SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF FRESNO

LINDA J. ANDERSON LLOYD ANDERSON,

Case No. 14CECG02461 KCK

DECLARATION OF CHRISTOPHER M.

URONE AND REQUEST FOR JUDICIAL NOTICE IN SUPPORT O F DEFENDANTS COALINGA REGIONAL MEDICAL CENTER AND COALINGA REGIONAL

MEDICAL CENTER d/b/a RALPH NEATE

EXTENDED CARE CENTER’S MOTION TO STRIKE PORTIONS OF PLAINTIFFS’

SECOND AMENDED COMPLAINT .

14CECG02461

Plaintiffs, v |

I WESTERN HEALTH RESOURCES d/b/a ADVENTIST HOME HEALTH CARE;

COALINGA REGIONAL MEDICAL

CENTER; COALINGA REGIONAL MEDICAL CENTER d/b/a RALPH NEATE EXTENDED CARE CENTER; BEVERLY HEALTHCARE-CALIFORNIA, INC. d/b/a GOLDEN LIVING CENTER-HY-LOND;

COMMUNITY HOSPITALS OF CENTRAL

F Declaratlon Flled

DATE: February 23, 2016 TIME: 3:30 p.m. DEPT: 403

REGIONAL MEDICAL; CENTER;

COMMUNITY HOSPITALS OF CENTRAL

CALIFORNIA d/b/a CLOVIS COMMUNITY MEDICAL CENTER; HONGSHIK HAN, M.D.; KENNETH SMITH M.D.; O’KEY IJOMANTA SAMS M.D.; PAUL GRIFFIN M.D. and DOES 1 through 150, inclusive, Action filed: August 21, 2014 | Trial date: None

VVVVVVUVVVVV\JV\/WVVUVVVVV

Defendarilts.

| I, Christopher M. Urone, hereby declare as follows:.

1. I am an afiorney duly authorized to practice before the Courts of the State of California and I am a partner in the law firm of Weiss Martin Salinas & Hearst, attorneys for Defendants COALINGA REGIONAL MEDICAL CENTER (“Coalinga Regional”) and

1. I am an afiorney duly authorized to practice before the Courts of the State of California and I am a partner in the law firm of Weiss Martin Salinas & Hearst, attorneys for Defendants COALINGA REGIONAL MEDICAL CENTER (“Coalinga Regional”) andAdenc s e mu s neaete 200NNuhal .t s e LRI I . - L2 . . e . : : . cimesem . .

Adenc s e mu s neaete 200NNuhal .t s e LRI I . - L2 . . e . : : . cimesem . .

COALINGA REGIONA_L MEDICAL CENTER d/b/a RALPH NEATE EXTENDED CARE CENTER (“Ralph Neat<:3”) (cdllectively referred to herein as “Moving Defendants™). I declare that I have personal knozwledge of the following facts and that I make this Declaration based upon my personal knowlledge. Further, I declare that if called as a witness, I could and would competently testify theré:to. ' 2. Attached!ihereto as Exhibit “1,” and fully incorporated herein by this reference, is | a true and correct copy (!’.f this Court’s Order, dated November 5, 2015. It is respectfully requested that this Courl;: take judicial notice of this Order, as it was previously filed with this Court in the course and fs".cope of the pending litigation, and is still on file. Evidence Code §§

I 450, 451, 452 and 453.

3. Attached hereto as Exhibit “2,” and fully incorporated herein by this reference, is a true and correct copy of Plaintiffs’ Second Amended Complaint. Tt is reépectfully requested that the Court take judic’.ial notice of the Second Amended Complaint, as it was previously filed with this Court in the cogurse and scope of the pending litigation, and is still on file. Evidence Code §§ 450, 451, 452 a}:rld 453,

4, Attached heretc; as E);hibit “3,” and fully incorporated herein by this reference, is a true and correct copy of the Declaration of Sandra Earls, which was filed with Moving Defendants previous Def’l:nurrer and Motion to Strike. It is respectfully requested that this Court take judicial notice of tfic Declaration, as it was previously filed with this Court in the course and scope of the pending litigation, and is still on file. Evidence Code §§ 450, 451, 452 and 453.

I declare under the penalty of perjury under the laws of the State of California that the

. . st foregoing is true and coirect. This Declaration is executed on this 2{ day of December 2015,

in Fresno, California. m

CHRISTOPHER M. URONE

DECLARATION OF CHRISTOPHER M. URONE AND REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF MOTION |-