LUIS MARQUEZ, ET AL. VS AME MEDICAL GROUP, INC., ET AL.

1. Decedent Luis Marquez was a resident of Los Angeles County, California.

2. Luis Marquez suffered a wrongful death on November 14, 2021 . He brings his surviving claims by and through his successor in interest, Margarita De La Rocha.

3. Plaintiff Margarita De La Rocha is Luis's mother. She is acting both individually and as the successor in interest to Luis Marquez under Code of Civil Procedure section 377.32. An affidavit, as required by that section, will be filed with the Court. Margarita De La Rocha is a resident of Los Angeles County, California.

4. At all times mentioned herein, Defendant Prime Healthcare Services - St. Francis, LLC, (also referred to as "St. Francis") and Does 2-15 are believed to be the owner, licensee, manager of St. Francis Medical Center and in the business of providing healthcare services subject to the requirements of State and Federal Law. At all times mentioned, Defendant Prime Healthcare Services - St. Francis, LLC's principal operating location is at 3630 E Imperial Hwy, Lynwood, Ca. , and is qualified to do business in California, and subject to the jurisdiction of the Superior Court of California. At all times relevant to this action Prime Healthcare was doing business as St. Francis Medical Center in Los Angeles County, California.

5. At all times mentioned herein, Defendant AME Medical Group, Inc. and Does 16- 30 are believed to be the owner, licensee, manager of Urgent Care - AME Medical Group in the business of providing healthcare services subject to the requirements of State and Federal Law. At all times mentioned, Defendant Prime Healthcare's principal operating location is at Paramount Blvd., Downey, Ca. , and is qualified to do business in California, and subject to the jurisdiction of the Superior Court of California. At all times relevant to this action Prime Healthcare was doing business as Urgent Care - AME Medical Group in Los Angeles County, California.

6. At all times mentioned herein, Defendant Doe 1 is a security company, entity unknown, responsible for hiring, employing, training, supervising security guards. Defendant Doe

1 entered into a contract or other arrangement with Defendant Prime Healthcare Services - St. Francis, LLC, and/or its designee, to provide security services and security guards at St. Francis Medical Center.

7. The true names and capacities of the defendants named herein as DOES 1 through 100, inclusive, whether individual, corporate, associate, or otherwise, are unknown to plaintiffs, who therefore sues such defendants by fictitious names pursuant to Code of Civil Procedure section 474. Plaintiffs are informed and believe that said DOE defendants are California residents, and Plaintiffs will amend this Complaint to show such true names and capacities when they have been determined.

8. Each of the Defendants designated herein as a DOE is responsible, in some manner, for the events and happenings herein referred to, thereby legally causing the injuries and damages to Plaintiff as hereinafter alleged.

9. In this complaint, plaintiffs refer to AME Medical Group and Prime Healthcare Services - St. Francis, LLC, and DOES 1 through 100, inclusive, as "Defendants." Whenever plaintiffs refer to the "Defendants," they are referring AME Medical Group, Prime Healthcare Services - St. Francis, LLC, and DOES 1 through 100, inclusive, as if they had identified each of them individually.

VENUE

10. These events took place Urgent Care - AME Medical Group and St. Francis Medical Center located in Los Angeles County at Paramount Blvd., Downey, CA. . . Venue is therefore proper in Los Angeles County.

Plaintiffs are informed and believe and thereon alleges the following:

11. On November 13, 2021 , Luis Marquez, 37 years old, presented to Urgent Care AME Medical Group. He complained of anxiety and depression that had been getting