St. Clair vs. HealthNet

TOPV FOR COUTUSE ONt
cM-010
(Nan, S16lo 8dt nunbet, and addrss):

OR PARY WHOUT TTO RNEV
c orby #26 8633 ONFORMED COPY
s M. nfti7iFrrli-
EVERRIA L LP
SH E RNOFF BI DART ECH uperior Court of California
600 S. ln dia n HII Bolevard CotJr'tv c'f t-os Anoeles
o
Claremont, Ca lifornia 1 7 1 FAX NO,: 909-44 7-2043
TELEPHON NO.: I 09-62 1-4935 HY 12Nlr.
et al.
ATTORNEY FOR (Nane): Plal ntiff Me lissa st. Cla
CALIFORNIA' COUNTY OF LOS ANG ft, atlcrr xaculive 0f corlttar
SUPEIOR COURT OF
STREET AOORESS: 111 N. HillStree 8y Jud! Lnla,'9Bl$f
t"
MAILING AOORSS:
Los Angeles 90012
cTY ANO ZIP coo:
Central
sFTANCH NAME:
et al.
CAS NAME: St. Clalr, et al.,
v. Health Net of California' lnc,,
CASE NUMSER:
ComPlex Case Deslgnation
c IVIL CA S COVER SH EET n
a Unll mited Llmlted n counter Joinder
JUOGE:
Amo u nt (Amount) Filed with first aPoearance bY defendant

DPT:
de mand ed demanded ls (Cal. Rules'of Court, rule 1811)
or
nstructons on
ttems 1-5 below must o
case tYPe that best thls case:

one box below for Provlslonallv Complex clvll Lltlgatlo.
Auto Tort ii;:'Rrl;; r couit, rules 18oo'1812)
Breach of contract/warrantY (06)
n Auto (22)
Colloctions (09)
n AntltrusVTrade regulation (03)
n Uninsured motorst (46)
lnsurance coverage (1 B) n Construction defect (10)
other Pl/PDMD (Porsonal lnJury/Property Other conlract (37)
Mass tort (40)
amageM/rongful oeath) Tort n Securities tltlgation (28)
Real ProPerty
n Asbestos (04)
n n nvironmental/Toxlc tort (30)
Product liabllity (24) Eminentdomaln/lnvetse
condemnallon (14)
lnsuranco covorage claims arising from tho
case
tr Medical malPractlce (45) bove listed provlslonally complex
Wrongful ovlction (33) types (41)
X other PI/PD1!D (23)
Other real Property (26) Enforoement of Judgment
Non-Pl/PDMD (Othar) Tort
n
(07) Unlawful Detalner E Enforcement ofjudgment (20)
n
BusinesstorUunfalrbuslnesspractlce
civilrlghts (08) n Commerclal (31) Mlscellaneous Clvll ComPtalnt
Defamatlon (13) n Resldentll (32)
n Rtco (27)
Fraud (1 6) u Drugs (38)
n other complalnt (not specfied above)
(42)
Judiclal Revlew Mlscellaneous Clvll Ptlton
lntellectual ProPertY (1 9)
Professional negllgence (25) tr Asset forfeiture (05)
tr Partnershlp and corporate governanco
(21)
Other non'Pl/PDND tort (35) n Petillon re: arbitration award (1 1)

E Other petition (not specilled above)
(43)
Employmont n wrt of mandate (02)
n Wrongful tennination (36) tr Other fudicial revlew (39)
n Other emp loyrnent (1 5)
rts
3.
4
5.
Da
TRAVIS
NOT lcE
small claims cases or cases filed
paper filed in the action or proceedlng (except
P lal ntlff mu st file this covef sheet with the first
Code)' (Cal. Rules of Court, rule 201 .) I
Failure to file maY result
robate Code, FamilY Code or wji.r" and lnstitutions
under the P
ln sanctlons local court rulo.
to anv cover shoet required by copy of this cover sheet on a
Fil e th s cove heet ln addition i.q. Rulos of Court, you must serve
this case is .com plox u nde rule oit of tlro California
proceeding. 1ol2
other parties to the action or will for de9 1800-1
case thi Cal.
Unless rh ls N ot' lnc. Stsndsrds ol Admlnlsvofion, S 19
Form (o CIVIL CASE COVER SHEET www,wlinlo,ca 'gov
JudlciEl of
cM.010 (Rov Jrru8ry l, 20081
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"ororing lrnpi. staiistics about the ty[es and numbers of cases filed
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the cases that belong under each case type in iiem i ,r" first paper filed in a civil case may
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do not need to submit a cover sheet with
"r"n and 227 of the California Rules of Court'
subject a party, ts counsel, or both to sanctions unei rules 201'8(c)
To Parties in ComPlex Cases
sheef to designate whether the case is complex' lf a plaintiff
ln complex cases only, parties must also use lhe civir case cover
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believes the case is complex under rule l
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"r joinder in the plaintiff s designation, a
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made no designaton, a designaton that the case is complex'
counter-designation that i "r" is not complex, oi, r r" plaintiff has
CASE TYPES AND EXAMPLES
Gontract Provisionally Complex Civil Litigation
Auto Tort
Breach of ContractMarrantY (06) (Cal. Rules of Court Rules 1800'1812)
Auto (22)-Personal njury/Property
I
DamageAlVrongful Death Breach of Rental/Lease AntitrusVTrade Regulation (03)

Contract (not unlawful detainer Construction Defect (1 0)
Uninsured Motorist (46) (if the or wrongful eviction) Claims lnvolving Mass Tort (40)
case involves an uninsured
ContractllNarrantY Breach-Seller Securities Litigation (28)
motorist claim subiect to Plaintiff (not fraud or negligence) Environmental/Toxic Tort (30)
arbitration, check this item
Negligent Breach of Contract/ lnsurance Coverage Claims
instead of Auto) (arising from ProvisionallY
WarrantY .
Other Breach of ContractMarranty comPtex case tYPe listed above)

Other Pl/PDM/D (Personal lnjurY/ Collections (e.9., moneY owed, oPen (41)
Property DamageMrongful Death) book accounts) (09)
Tort Collection Case-Seller Plaintiff Enforcement of Judgment
Asbestos (04) Other Promissory Note/Collections Enforcement of Judgment (20)
Asbestos ProPertY Damage Case
Asbestos Personal lnjury/ Abstract of Judgment (Out of
lnsurance Coverage (not provisionally CountY)
Wrongful Death comPlex) (18) Confession of Judgment (non-
Product Liability (nof asbesfos or Auto Subrogation domestic relations
o, s nv i roi n m e n t a I) (24) Other Coverage
Medical MalPractice (45) Sister State Judgment
Other Contract (37) Administrative AgencY Award
Medical MalPractice- Contractual Fraud (not unPaid taxes)
PhYsicians & Surgeons Other Contract DisPute
Other Professional Health Care Pettion/Certification of Entry of
Real PropertY Judgment on UnPaid Taxes
MalPractice Eminent Domain/l nverse
Other Pl/PDND (23) Other Enforcement of Judgment
Condemnation (14) Case
Premises LiabilitY (e.g., sliP Wrongful Eviction (33)
and fall) OtheiReal Properiy (.9., quiet title) (26) Miscellaneous Civil ComPlaint
lntentional BodilY lnjury/PDIVD Writ of Possession of Real Property Rrco (27)
(e.g., assault, vandalism) Mortgage Foreclosure Other omPlainl (not sPecified
lntentional lnfl iction of Quiet Title above) (42)
Emotional Distress Other Real Property (not eminent Declaratory Relief OnlY
Negligent lnfliction of domain, landlord/tenant' or lnjunctive Relief OnlY (non-
Emotional Distress foreclosure) harassment)
Other Pl/PDVD Mechanics Lien
Non-Pl/PDM/D (Other) Tort Unlawful Detainer Other Commercial ComPlaint
Business TorUUnfair Business Commercial(31) Case (nonlorUnon-comPlex)
Practice (07) Residential (32) Other Civil ComPlaint
Civil Rights (e.9., discrimination, Druos (38) if the case involves illegal ( n o n -to rl/n on - c o m P I e x )
"
false arrest) (not civl ruas.' ne cX thi s ite m ; oth e ruvi se,
harassrnenf (08)
Miscellaneous Civil Petition
reprt as Commercial or
PartnershiP and CorPorate
Defamation (e.9., slander, libel) Residential)
Governance (21)
(1 3)
Judicial Review Other Petition (not specified above)
Fraud (16) (43)
lntellectual ProPertY (1 9) Asset Forfeiture (05)
Professional Negligence (25) Petition Re: Arbitration Award (11) Civil Harassment
Writ of Mandate (02) Workplace Violence
Legal MalPractice
Writ-Administrative Mandamus Elder/DePendent Adult
Oter Professional MalPractice
(not medical or legal Writ-Mandamus on Limited Court Abuse
Case Matter Election Contest
Other Non-Pl/PDND Tort (35) Petition for Name Change
Writ-Other Limited Court Case
Employment Review Petition for Relief from Late
Wrongful Termination (36) Other Judicial Review (39) Claim
Other EmPloYment (15) Review of Health Officer Order Other Civil Petition
Notice of APPeal-Labor
Commissioner APPeals
Page 2 ol 2
CM-01 0 [Rev. January 1, 20061 CIVIL CASE COVER SHEET Amerlcan Logal Not, lnc'
www.USCourtForms.com
OPY s uM-100
SUMMONS
I
p ff t^',i{ii ilt[*'
"
(ctTACtoN JUDICTAL) CONFORMED COPY

ORIGNAL FILED
Superlor Court of California
NOTICE TO DFENDANT: Countv of l..o a nnnlns
LA, rpA, a
corporation; HEALTH.ARE
nl,f,tr+ryf3fi33*,o,rf9,,
1 throush 1o
" l'lAY 1 ? ?011
tti"nland DOES
[i Carlsr, Exencttvo flcer/ler}

.B, By:Judll"org,0sPulv
{.lf
as n- rn{u rt t t
CASE NUMBER:
nam6 address court
(Et nombre Y direccin de la corte es):
Los Angeles SuPerior Court
(Nmoro del Caso):
6 6 0 I&s
11'l N. Hill Street
Los Angeles, California 90012
of plaintiffs attorney' or olaintiff without an attorney, is:

The name, address, and telephone number det abogado del "';;:;;;;;i;,"; d''t
i^"rinp que no ttene abosado' es):
ta direccin i;;;'1;''* de teroio
EI nombre,
fl;Ni:'.Tv, t.*zeeosgLLP e0e-6214e35
rinr ainnr EcHEvERRIA rudiLat
ffio o"*ffi;ff1gli;"''
...
tr ;{i Clerk, bY
, DeputY
(Adjunto)
(Secretaro)
3, non ot (sPecifY):
ccP 416.10 (corporation) n CCP 416.60 (minor)
under:
ccP 416,20 (defunct corPoration) tr CCP 6.70 (conseruatee)
41
CCP 416.40 (association or partners hp) n CCP 416.90 (authorized Person)
othor (sPecifi,);
4. E bY Personal delivery on (dale):
codo of civl
nrcan L08lNol lnc,
Form AdoPlod lor Mandlory U80
SUMMONS wFormsWodtow.com
Judlclal Courrcil of Cslilornis
SUM-100 [Rev- JulY 1, 20091
SUM.2OO
CASE NUMBER:
SHORT TITLE:
St. Clair, et al. v. Health Net of California, Inc',
et al
INSTRUCTIONS FOR USE

summons if space does not permit the listing of all parties on the summons'
) trris form may be used as an attachment to any
in the plaintiff or defendant box on the summons: "Additional
Parties
lf this attachment is used, insert the following siatement
Attachment form is attached."
Lstadditionalparties(checkonlyonebox.lJseaseparatepageforeachtypeofparty'):
ptaintiff l--l Defenclant |.-_l cross complainant l-l cross-Defendant
and as successor-in-interest to LAURIE ST' CLAIR
Page 2ot2
Form Adopted for Mandalory Uso ADDITIONAL PARTIES ATTACHMENT

Judcal Councl of Calforni
suM-2oo(A) [Rsv. January 1, 2007] Attechment to Summons
opv
#38856
1MILLIAM M. SHERNOFF
L
'in,vrs M. coRBY#268633
5
iffi#inH:
2 Sef"fUgt, BRUCHEY #2'1 199
sFF BIDART EcHEVERRIA
LLP ti|y 1Q ZOn
3
o s. Indian Hill Boulevard or'
4 iut.*ont, California 9 l7 I t
sn
'r rhiirirri
u u s u, x
Telephone: 9 09 -621 493 5
t
!{o
5 axigog+7-2043
6
AttomeYs for Plaintiffs
7
I
9
SUPEzuOR COURT FOR THE
STATE OF CALIFORNIA
L0 ANGELES
FoR rHE corJNry oF Los
'o d 11 BC 6 0S40
iT.
individuall{P*t Case No.:
12 MELISSA ST. CLAIR,
k s ,u.*ttor-in-interest to decedent LAURIE COMPLAINT AND DEMAND F'OR
13 sf. cmrn; ALYSIA sr. cLAIR,
'ff
t I
l.!>
t.J

L4
tuiaourry and as successor-in-interest to
JURY TRIAL
Erd
$

r.nt LiuzuP sr. cLAIR; andand as I. Wrongful' Death Due to the Breach
of the
zT- i 15 rtierrnnw DOMA, individual-ly- Duty f Goo Faith and Faith Dealing
ry I ,*ttttot-in'interest to LAUNE ST'
t
TY
p
76 CLAIR,
J' 2. Violation of Civil Code Section3428
5 L7
Plaintif,
dH
lgbsl
3, 'Wrongful Death due to Negligence
Ed 18
n@d
Et44 v
Es.d
T9 4, Negligent Infliction of Emotional
INC.' A Distress
20 HEALTH NET OF CALIFORNIA,
tot*ution; FIEALTI'ICARE LA' IPA' a
10'
21 ittutioniand DQES 1 through
22 Defendants.
23
24
25
26
27
28
I
AND DEMAND FOR JURY TRIAL
1 INTRODUCTION
2 1'Lauriest.Clairwasalovingmotherofthreeandformercustomerservlce
J
representative who had her rife cut short at the age
of 53 from river cirrhosis because Defendants
Heath Care LA, IPA ("HCLA"), delayed in
4 Health Net of Califomia, Inc. ("Health Net") and
care, including failing to timely provide Laurie
5
approving and ananging for medically necessaly
liver transplant'
6
with access to a specialist that could perform a necessary
Laurie's liver condition

7 2. Laurie was first diagnosed with liver cirrhosis in 2013.
I was being monitored by Dr. Mordo Suchov, a
gastroenterology specialist' By June 30'2015
had worsened, so Dr' Suchov

9
Laurie,s liver condition had rapidly declined and her symptoms
evaluation with a liver transplant
10
submitted a request for authori zationfor a liver transplant
l-& request and Laurie was approved for
t"
11.
specialist. on July 8,2015,HCLA approved Dr. suchov's
12 an office consultation with USC Medical Group. But
when Laurie attempted to make an
k: -j
m i
-ty 13
appointment, there was no doctor within USC that accepted
her insurance-in other words the
LLhJ i
LL> 14 authorization prvided by HCLA was invalid'
NbJ
zri
ilTJ

P
15 3. Since Laurie's liver condition and resulting symptoms
had become so severe-
u
t>
p
U
1.6
and due to the problems with her invalid authorization-she
decided to go to california Hospital
L
n1 17 Medical center. on July l7,2}Is,Laurie was seen at california
Hospital by Dr' Fredrick weiss'
El=l that Laurie was'oa definite candidate
3 IT
1B
another gastroenterology specialist. Dr. Weiss concurred
HJ
19
- for transplantation."
Net and HCLA
20 4. Unfortunately, despite the severity of Laurie's condition, Health
and belief, Laurie alleges
21,
failed to timely provide access to a liver specialist. upon information
specialist within its network, so Health
22
that Health Net and HCLA did not have a liver transplant
23
Net and/or HCLA needed to contract with an out-of-network
liver transplant specialist in order to
and HCLA horribly delayed
24 provide Laurie with the care she desperately needed. But Health Net
and perform the necessary liver
25 in providing access to a liver specialist who could treat Laurie
26 transplant.
made numerous phone
27 5. Between July and November 2}!s,Laurie and her family
28 calls to both Health Net and HCLA, pleading with them
to find Laurie a liver specialist or any
COMPLAINT AND DEMAND FOR JURY TzuAL

She was repeatedly told that Health Net
1
doctor who courd perform the necessary river transprant.
Agreement ("LoA") with a specialist
2
androrHclA were attempting too.work out,,a retter of
was declining rapidly, and without a new
J
who could treat her. Meanwhile, Laurie's condition
and HCLA callously put their own
4 liver, it was unlikely that she would survive. Health Net
needed. No person should have to wait for
5
interests ahead of the life-saving medical care Laurie
more than four months'korking out"
6
life-saving medical treatment while their health plan takes
7
a LOA with a doctor.
to medically
8 6. Ultimately, Health Net and HCLA's failure to provide access
death. On November 10, 2015' surrounded
9
necessary care, tragically caused Laurie's premature
gave out and she died' According to her
10
by her friends and family members, Laurie's heart
r0 working properly' but her liver was no
v,
l-

1T
doctors, Laurie's heaft, lungs, and other vital organs were
fluids were seeping into Laurie's
3 E
12 longer functioning. Without a functioning liver, poisonous
-y
m =
13
i heart and lungs.
LLhJ ?
and Matthew
t!> 1,4
7. Laurie,s three children, plaintiffs Melissa St. Clair, Alysia St. Clair,
NbJ
zri
rft.J

E
15
Doma bring this wrongful death action to recover damages
resulting from the premature death of
LJbJ Health Net and HCLA from
their mother. Plaintiffs also seek punitive damages to prevent
P 1,6
TY
l
nl 17 putting any of their other Californians' lives at risk for their own
profit'
El=l 18 THE PARTIES
fl
I-
5-
- t9 g. plaintiff Melissa St. Clair, is and at all relevant times was, a resident of the city of
the daughter of decedent Laurie St'
20 Torrance, county of Los Angeles, state of california. she is
interest to the Estate of Laurie St'
21.
Clair. She is acting both individually and as the successor in
22 procedure Section 377.32. An affdavit as required by that
Clair, pursuant to Code of Civil
23
section has been filed with this action'
24 g. plaintiff Alysia St. Clair, is and at all relevant times was, a resident of the county
Laurie st. clair. she is acting
25 of Los Angeles, state of california. she is the daughter of decedent
26
both individually and as the successor in interest to the Estate
of Laurie St. Clair, pursuant to
by that section has been filed
27 Code of civil procedure Section 377.32. An affidavit as required
28
with this action.
COMPLAINT AND DEMAND FOR JURY TRIAL

1,
10. plaintiff Matthew Doma, is and at all relevant times was' a resident of the city of
He is the son of decedent Laurie st. clair. I{e
2
carsono county of Los Angeles, state of califomia.
to the Estate of Laurie st. clair,
J
is acting both individualry and as the successor in interest
4 civil procedure section 377.32. An affidavit as required by that section has
pursuant to code of
5
been filed with this action.
is and at all relevant
6 1 1. Defendant Health Net of California, Inc. ('oHealth Net")
under the laws of california and is
7
times was a corporation duly organized andexisting
in california, with its principle
8
authorized to transact and is transacting the business of insurance
9 place of business in the county of Los Angeles'
times was a
10 lZ. Defendant Health Care LA, IPA ("HCLA") is and at all relevant
r0 u. with its principle place of
v,
l-v corporation duly organ ized andexisting under the laws of california,

12 business in the county of Los Angeles'
k i
or other, of
13 13. The true names or capacities, whether individual, corporate, associate,
'
lr-tJ

?
lJ-> 1.4
Does 1 through 100, inclusive, are unknown to plaintiffs,
who therefore sue defendants by such
TbJ
zT-'" 15
fictitious names. plaintiffs are informed and believe and thereon allege
that each of the
r/ E
tl p
1.6
defendants sued herein as Does is legally responsible in some manner for
the events and
rt
nf T7
happenings referred to herein and will ask leave of this court to amend the complaint to insert
II
H
5
r- 1B
their true names and capacities when they become known.
I-
Hd
19 F'ACTUAL BACKGROUND
20 A. Laurie was insured under a Health Net and HCLA health plan.
plan
21,
14, In 2015, Laurie received her health insurance through a Health Net HMO
22 (The Plan member ID is 95769077D).
on its behalf
23 15. Health Net contracted with HCLA to authorize health care services
24 for Laurie.
25 B. Laurie needed access to a specialist to arrange for a life-saving liver transplant'
was
26 16. In 2013, Laurie was diagnosed with liver cirrhosis. Laurie's liver condition
27 Dr' Suchov recommended
being monitored by Dr. Mordo Suchov, a gastroenterology specialist.
a point where she was a candidate
that they monitor her condition and if her health declined to
28

1
for a liver transplant, then he would refer her to a liver specialist.
2 17. In 2015, Laurie's symptoms began to worsen. Laurie was experiencing pain in her
On June 30'2015' Laurie went to see
J
abdominal area, fatigue, hemorrhoids, and difficulty eating'
Dr. suchov determined that Laurie
4 Dr. suchov about her worsening health. At that point in time,
2015, Dr. suchov submitted a request
was a candidate for a liver transprant. on or about June 30,
a liver specialist'
6
for authorization to HCLA for a liver transplant consultation with
approval letter from
7 1g. On or about July 8, z1ls,Laurie received an authorization
I HCLA. This letter appeared to provide Laurie with an authorization
to be seen by a USC Care
The letter lists Dr' Suchov

9
Medical Group liver specialist for a consultation for a liver transplant.
10
as the requesting physician and provided what appeared to be a valid authotizationnumber'
l-&
v."
1"1,
20r s07 0 17 2t033200460.

told that they
k E
12 lg. But when Laurie attempted to make an appointment at USC she was
a
-ry
m not treat her. In other words,
[ 13
did not accept her Health Net/HCLA health plan and that they could
t-LJ ?
L> 1.4
the authori zationthat HCLA had provided to Laurie was invalid.
TLJ
zTi

and to
15 20. Laurie called HCLA to try to figure out why the authorizationwas invalid
u 8
uu p
16
try to get in to see a specialist that could treat her. But she was not given a straight
answer'
I!
mf did not
17 21. Upon information and beliet Laurie alleges that Health Net and I-ICLA
I-
H and HCLA needed to contract
have a liver transplant specialist within its network, so Health Net
18
5
IE
with the care she
--rl 19 with an out-of-network liver transplant specialist in order to provide Laurie
20 needed. Since that contract was not yet in place, Laurie was left
with no access to the
desperately
21.
medically necessary care she needed.
22 22. Since Laurie's liver condition and resulting symptoms had become so
severe-
23
and due to the problems with her invalid authorization-she decided
to go to california Hospital
by Dr. Fredrick weiss,

24
Medical center. on July 17,2015,Laurie was seen at california Hospital
ooa
concurted that Laurie was
25 another gastroenterology specialist. After further testing, Dr. V/eiss
26
defi nite candidate for transplantation."
27 C. Health Net and HCLA callously delayed in providing access to a liver specialist'
get access to
28 23. Over the next three months, Laurie repeatedly called HCLA to try to

about the status of her
1,
aliver specialist. But she was either not given a straight answer
attempting to work out an LOA with a
2
authorization request or was told that HCLA was still
August 4'2015'
J
specialist that could treather. Laurie made calls on July 20, 2015,July 21, 2015'
4 August 21,20t5-yet she was never
August ll,2015,August 12,2015,August 13,2015, and
5
able to get the care she needed.
Net-as her health plan-to see why it
6 24. On August 2g,2015,Laurie called Health
7 was taking so rong simpry to get access to a speciarist
that could treat her. She asked for Health
I Net's assistance to resolve the problem. Meanwhile, she continued

to wait'
Melissa, and
9 25. By early October 2015,Laurie had become so sick that her daughter,
very weak' She could no
10
the rest of her family began to take care of her. Laurie had become
t-&
rv"
11,
longer lift her legs, go outside, or drive a car. Laurie would occasionally
have a good day, but
of her days were filled with

k i 12 for the most part, her condition was deteriorating rapidly and most
1
-ry
m 13
i agonizing pain and fatigue.
l!> i
LLLJ
resolve the
1"4
26. Due to Laurie's condition, Melissa also had to take over trying to
EIJ
zT:

as possible' Melissa called
15 insurance issues to try to get Laurie in to see a liver specialist as soon
ryt-l P
t
-r9
p
1.6
HCLA almost every day. Melissa also made repeated calls to Health Net,
including four calls on
!t
nj 17
october 6,20ls,and four more calls on october 7,2015. She told them
that her mother urgently
IT
H her mom would die. During these
fr r-
18
needed a liver transplant and that without a liver transplant,
II
Hd
a liver transplant. But the
19 phone calls, Melissa would cry and beg the representative to authorize
Laurie's case and that that
20 representatives would simply tell Meliss athatthey were working on
21.
the authori zationfor a liver transplant was still being processed.
On Octobe r 12,2015,Melissa again tried calling Health Net to see why

it was
22 27 .
she needed. She
23 taking so long-now more than four months-to get her mom the treatment
for help but Health Net was
24 was on the phone with Health Net for a total of 84 minutes pleading
that day but again was not
25
unhelpful. Melissa tried making two more calls to Health Net later
26 able to get anY answers.
that
27 2g. Laterthat day Melissa then called HCLA and spoke to a representative
to go to USC for a
28
identified herself as Shirley. According to Shirley, in order for Laurie

o'worked
out."
1.
consultation, HCLA and usc needed to sign a
LoA-which was still yet to be
that she would get back to Melissa in 1-
2
shirley said that they were still working on her case and
a
J
3 business daYs.
4 29,MelissamadetwomorecalltoHealthNetonoctober1l3,20t5.Thistimeshe
5
was on the phone with Health Net for 55 minutes.
Again, Health Net was not able to give
6
Melissa the answers she needed'
7 30. on octobe r 14,2}Il,Melissa called HCLA and spoke to Louis' According to
cap hospital'" Louis gave no

8
Louis, Laurie could no longer go to USC because it was "a
four months to receive a valid
9
explanation of what that meant. After waiting more than
Laurie would need to be redirected to
10
authorization to receive treatment at usc, Louis stated that
FP 11.
another hospital. Melissa called HCLA four different times that day'
v." 3
and spoke to
k :j 12 31. The next day, on october |5,2015,Melissa againcalled HCLA
m i
-ty Laurie were USC or UCLA'
1,3
Angie. According to Angie, the only two facilities that could treat
LLLd:
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she said that HCLA was still trying to determine which facility
would treat her-now four
nul;
LL 15
u
months after the original request was made'
ryJ r
t
Ty
p
16 32. On October 16,2}ll,Melissa called HCLA seven different times.
On one call she
43
Jf 17
spoke to Angie for 38 minutes. This time Angie informed
her that HCLA was in the process of
H
fl
-
-I 18
arranging for Laurie to be treated at UCLA for her liver transplant.
According to Angie, the
II
HJ
19
authorization was in Process.
20 33. On Octobe r l9,2l1,Melissa called back HCLA again seven different times. She
21.
again spoke to Angie who confirmed that HCLA was still
working on obtaining an authorization
process. Later that day, in
22 for Laurie to be treated at UCLA and that the authori zationwas in
to set up a member ID
23
anticipation of obtaining a valid authorization, Melissa called UCLA
24 number for her mom.
the Medi-Cal Ombudsman
25 34. On Octobe r 22,20l5,both Laurie and Melissa called
26
to file complaints against Health Net and HCLA'
27 35. on Octobe r 29,2015,Laurie called HCLA five different times' But again, there
care but had no access to a

28 was still no authorization for care. She was desperate for medical

1
doctor that could treat her.
2 36.OnOctobet30,2015,Laurie'sconditionbecamesoseriousthatshewentto
for the worse'
3 providence Little company of Mary Hospital. Laurie's health had taken a turn
her body, blood would start appearing on her
4 Even though there was no wound or opening in
her own blood. once fluid starled seeping
5 pants and clothes. Laurie was no longer abre to retain
put her on dialysis' But the dialysis caused
6
out of Laurie's body, the doctors attempted to
point, the doctor's told the family that
7
Laurie,s blood pressure to drop to an unsafe level. At this
8
there was nothing more they could do for Laurie.
Fluid that the liver would normally process was
9
spreading to the rest of Laurie's body. This fluid was
like a poison that was wreaking havoc on
10
Laurie's lungs, heart, and other vital organs'
r0 Without a
l-e 1"1,
37. On November 10, 2015,Laurieos heart gave out and she died'
rv"
and other vital organs' Eventually'
k g 12 functioning liver, poisonous fluid was seeping into her lungs
attack'
13
this poisonous fluid reached Laurie's heart and caused a heart
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than four months
1.4
3g. Laurie should not have died. Health Net and HCLA took more
ObJ
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15
to authorize and provide access to a liver specialist. Health
Net and HCLA callously ignored
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16
Laurie and Melissa's repeated pleas to provide her access to this
life-saving care'
.l- 3
tJ] J 17 FIRST CAUSE OF ACTION
rI Fair Dealing
H L8 wrongful Death Due to the Breach of the Implied Duty of Good Faith and
3
II
(Against Health Net of California, Inc)
Hd
19
- 39. plaintiffs refer to each and every paragraph of the complaint and incorporate those
20
paragraphs as though set forlh in full in this cause of action.
21. owed to Laurie in
40. Health Net has breached its duty of good faith and fair dealing
22
the following resPects:
23 to medically
a) Unreasonably failing to ensure that its plan members have access
24
necessary medical treatment;
25 with have
b) Unreasonably failing to ensure that the medical groups it contract
26
adequate specialist available in its networks;
27 it contacts with have
c) Unreasonably failing to ensure that the medical groups
28 specialist care not
procedures in place to timely provide access to out-of-network
I
1 available within the medical group;
2 d)UnreasonablyfailingtoensurethatLauriehadaccesstomedicalnecessary
J sPecialist care;
4 Unreasonably delaying contracting with a specialist
who could treat Laurie and or
e)
5 who could perform Laurie's liver transpiant;
and Melissa's complaints
6
Unreasonably failing to adequately respond to Laurie
7 about HCLA and the delay in providing access to
life-saving treatment;
I g) Unreasonably avoiding authorization of medically

necessary services for its own
9 financial gain by ignoring the seriousness of Laurie's condition;

to obtain' in a
10 h) Unreasonably engaging in a pattern and practice of failing
r0 with out of network medical
l-E
g^ 11" reasonable amount of time, letters of agreement

12
3 i groups;
physician groups
13 i) Unreasonably failing to select and retain competent provider
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provider physician
LL> -' 1,4 and to have procedures in place to audit the quality of those
tul
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16 j) Unreasonably failing to ensure that HCLA had contractual agreements
in place

ulf 17 with necessarY Providers;
II
H Health Net's
3
18 41. Health Net has furthermore committed institutional bad faith.
I.
the conduct is part of a repeated
--l 19
institutional bad faith amounts to reprehensible conduct because
pattern of unfair practices
20 pattern of unfair practices and not an isolated occufence. The
2't
constitutes a conscious course of wrongful conduct that is
firmly grounded in the established
22 plaintiffs are informed and believe and thereon allege that
company policies of Health Net.
other than Laurie and that
23 Health Net has engaged in similar wrongful conduct as to individuals
similar harm to others'
24 Health Net substantially increased its profits as a result of causing
25 42. plaintiffs are informed and believe and thereon allege that Health Net has
26 of good faith and fair dealing owed to Laurie by other acts and omissions
of
breached its duty
27 unaware but which will be shown according o proof at the time
of
which plaintiffs are presently
28 trial

and bad faith conduct
1 43. As a proximate result of the aforementioned unreasonable
love, companionship, comfolt, care,
2
of Health Net, plaintiffs have been deprived of Laurie's
a
J
assistance, protection, affection, moral support,
training, and guidance to their damage in the
4 amount to be determined according to proof at the

time of trial, plus interest and other
proof, and in amounts to be determined at the

5 foreseeable and incidentar damages according to
6
time of trial.
as herein alleged, and
7 44. As a further proximate result of the conduct of Health Net,
I of the death of Laurie, plaintiffs have suffered economic
damage, including the loss of financial
9
support, gifts and benefits, and the reasonable value of
Laurie's household services' Plaintiffs
buriar expenses in the amount to be show'

10
have also incurred damages for Laurie's funerar and
r0
l-(r 1,1,
at the time of trial.
v""
Net to cause injury
k i 12 45. Health Net,s conduct described herein was intended by Health
carried out with a willful and
13
to Laurie. Alternatively Health Net engaged in despicable conduct
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to cruel and unjust hardship in
14
conscious disregard of Laurie's rights or subjected Laurie
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misrepresentation, deceit, or
LL e 15
conscious disregard of Laurie's rights or was an intentional
il
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1,6
concealment of a material fact known to Health Net with the intention
of depriving Laurie of
I}
nj 17 property or legal rights. Health Net's conduct therefore constitutes malice,
oppression, or fraucl
H punitive damages in an amount
fr--
II
L8
under California Civil Code 3294,entitling plaintif to
HJ
- 19
appropriate to punish and set an example of Health Net'
officers or
20 46. Health Net,s conduct described herein was undertaken by its corporate
were responsible for claims
21"
rnanaging agents, identified herein as DOES 1 through 100, who
decisions' This conduct was
22 supervision and operations, underwriting, communications, and/or
of and ratified, authorized,
23
undertaken on behalf of Health Net, which had advance knowledge
24 and approved the conduct.
25 SECOND CAUSE OF ACTION
26
Violation of Civil Code Section 3428
(Against Health Net and Health Care LA' IPA)
27
47. plaintiffs refer to each and every paragraph of the complaint and incorporate those
28
paragraphs as though set forth in full in this cause of action.
10

1
4S.CivilCodesection342Sprovidesinrelevantpart:
2
a duty of ordinary care to
[A] health care service plan of managed care entity shall have
health care service to its subscribers and
3 arrange for the provision of medicall"y necessary
enrollees, wher the health rur. ,.rui"e is a benefit provide under the plan, and shall be
4 to exercise that ordinary care
liable for any and all harm legally caused by its failure
5 when both of the following aPPIY:
delay, or
6 (1) The failure to exercise ordinary care resulted in the denial,
furnished to, a
modification of the health care seivice recommended for, or
7
subscriber or enrollee'
8
(2) The subscriber or enrollee suffered substantial harm.
9 loss of life, loss or
49. Subsection (b) of the statute defines "substantial harm" as
L0
disfigurement, severe and chronic
significant impairment of limb or bodily function, significant
r0
1't"
g"
3 physical pain, or signifcant financial loss'"
12
k 3 50. Health Net and HCLA failed to exercise ordinary care to arrange
for the provision
13
and HCLA failed to arrange for
'
l!hl

?
of medically necessary health care services to Laurie. Health Net
LL> $ 14
plan that could timely provide her with
tl! d a specialist provider available under Laurie's health
zL; 15
a liver specialist and liver transplant'
N/CJ E necessary services for her condition, including a referral to
u
TY
p
16
whether the providers were
-L3 Health Net and HCLA also failed to promptly authorize treatment,
$i 17
within or outside of plaintiff s network, after both Health Net and HCLA were repeatedly
H
E r-
-I 18
II
HI
advised of Laurie's condition.
19 treatment of for
51 . As alleged herein, Health Net and HCLA's delay in authorizing
20
Laurie caused substantial harm, including her early death.
21.
exhaust because
52. There was no independent medical review" process for Laurie to
22
there was no such process that applied to defendants' delay
in authorizing the necessary services'
23
Defendants never denied that Laurie was entitled to a referral.
Additionally, Laurie and Melissa
24
made numerous complaints to Health Net and HCLA. At no time
did either Health Net or I-ICLA
25
suggest that any independent review process was available
to address the delay that Laurie
26
and Laurie used it, the
experienced. Finally, even if an independent review process existed,
27
substantial harm'
process would not have been completed by the time Laurie suffered
28 physical
53. As a proximate result of defendants' conduct, Laurie suffered injury,
t1
't of limb or bodily function' significant
pain and suffering, mental stress, significant impairment
loss of life'
2
disfigurement, severe and chronic physical pain' and
fraudulently and oppressively
J 54. Defendants, conduct was also done maliciously,
4 civil code sectio n3294. Defendants' conduct was also authorized,
within the meaning of
of Health Net and HCLA'
5
ratified and performed by officers and managing agents
6 THIRD CAUSE OF ACTION
7
Wrongful Death Due to Professional Negligence
(Against Health Care LA' IPA)
8
9
paragraphsasthoughsetforthinfullinthiscauseofaction.
10 HCLA' as a
56. Under Laurie's Health Net Plan, Health Net contacted with
r0
r"
u,
l-u
participating physician group, to administer the utilization review
of her health care and
12 to administer her health care and
k i treatment on behalf of Health Net. HCLA was contracted
13
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?
treatment under the terms and conditions of the policy with
Health Net'
i 14
. Health Net entered into a contract with HCLA, whereby HCLA
would administer
ntd; 57
ZL " 15
health care and treatment for Health Net plan members including,
but not limited to Laurie, for
CJ E
fit
Ty
p
1,6
.! profit and in return for financial reimbursement'
n5 17 Net'
5g. Laurie is a beneficiary of said contract between HCLA and Health
El=l 18
In its capacity as Laurie's health care and treatment administrator, HCLA
owed
fr 59.
---
Hd
19 the plan with Health Net'
Laurie a duty of care to ensure that she received the benefits due under
20
In its capacity as Laurie's health care and treatment administrator, HCLA
owed
60.
21.
Laurie a duty of care to ensure that its actions did not injure Laurie'
22 Laurie
6I. In its capacity as Laurie's health and treatment administrator, HCLA owed
23 treatment and care as
a duty of care to ensure that Laurie received all medically necessary
24
allowed under the Health Net Plan.
25 was medically
62. As set forth above, all the medical care at issue in this complaint
26
necessary and proper under Laurie's plan'
27 treatment for
63. Health Care LA unreasonably delay medically necessary care and
28 that could treat her liver
Laurie, including failing to provide timely access to a specialist
12

1.
condition.
Laurie, HCLA
2 64. In unreasonably delaying and failing to provide treatment for
a the
J
breached the duties it owed Laurie. HCLA directly, proximately, and knowingly breaclied
4
duties of care it owed to Laurie.
had been physically
5 65. As a direct and proximate result of HCLA's conduct, Laurie
to be determined according to
and financially injured and has suffered damages in an amount
6
7 proof at the time of trial.

B F'OURTH CAUSE OF' ACTION
9
Negligent Infliction of Emotional Distress
(Against Health Net and Healthcare LA)
10
l-p 1,1.
full in this cause of action.
, paragraphs as though set forth in
12
k E 67. Melissa, Alysia, and Mathew have suffered serious emotional and
physical
13
'H
lJ-IJ

9
distress as a result of perceiving the death of their mother, Laurie.
tt> 1"4
6g. Health Net and Healthcare LA negligently caused Laurie's death by blocking
tru
zTi
rLu
d
E
15
access to medically necessary care, including a liver transplant. Laurie's inability to timely
UbJ P 16 in her health and
TY
-- a receive medically necessary care and a new liver resulted in a rapid decline
[nl 17
II
premature death.
H 18
fl 69. At all times, Melissa, Alysia, and Mathew were aware that Health Net and
HI
-I 19
- HCLA's failure to authorize medically necessary care and a liver transplant was significantly
20 pain and suffering' As
impacting Laurie's wellbeing and that Laurie was experiencing extreme
21"
realized that their mother
Health Net and HCLA,s delay continued, Melissa, Alysia, and Mathew
22
would not be able to survive.
23 Health
70. Melissa, Alysia, and Mathew suffered serious emotional distress due to
24 health. Melissa,
Net and HCLA,s conduct and from having to watch their mother's deteriorating
25 having to watch
Alysia, and Mathew cared deeply for their mother and suffered deeply from
26 be forced to watch a
their mother,s health rapidly deteriorate and needlessly die. No one should
27 group refuse to authorize
parent die because an insurance company and its contracted physician
28 fought for their mother's life'
and provide essential medical care. Melissa, Alysia, and Mathew
l3
't
horror, nervousness, grief' anxiety' worry'
Throughout this ordeal, they suffered anguish, fright,
2
shock, humiliation, and shame.
in causing Melissa,
J 7I. Health Net and HCLA's conduct was a substantial factor
Alysia, and Mathew were forced to
4 Alysia, and Mathew's serious emotional distress. Melissa,
5
undergo the indignity and frustration of Health Net and
HCLA's failure to provide a liver
health. They will always be
6
transplant while watching the deterioration of their mother's
7 haunted by the thought that their mother could have lived
longer if she had received a liver
8 have feelings of disdain and contempt for Health Net and

I-ICLA'
transplant and they will always
9 PRAYER FOR REI,IEF
10 plaintif respectfully request that this court enter judgment against Health Net' The final
l-p 11 judgment should set forth the following as appropriate for each cause of action:
*
General and special damages including, plaintiffs' loss of love,

companionship,
k i 12 1.
1
0 [
-ry 1,3
comfort, care, assistance, protection, affection, moral suppotl, training'
guidance in an amount to
LLkl
L> ?
1.4
be determined according to proof at the time of trial for Health
Net's breach of the implied
EIJ
zri
ry
d
P
15
covenant of good faith and fair dealing'
u
Tg
p
16 Z. Economic damages, including plaintiffs' loss of financial support,
gifts and
.-
l 17
benefits, time from work, reasonable value of household services,
and funeral and burial
rI
H
5
L8
expenses in an amount to be shown at the time of trial for Health Net's breach of the implied
II
19
--- ovenant of good faith and fair dealing.
pain and
20 3. Laurie,s pre-death general damages, including damages for the extreme
function, significant
21.
suffering, mental stress, significant impairment of limb or bodily
22 disfigurement, severe and chronic physical pain, and premature loss
of life that Laurie sufferecl
23
due to Health Net's violations of civil code section3428.
suffered due
24 4. Damages for the reasonable attorney fees and costs incured herein,
25
to Health Net's violations of Civil Code section3428'
distress suffered
26 5. General damages for plaintif' mental, emotional, and physical
27 as a result of Health Net's negligent infliction of emotional distress, in an amount to be
28 determined at the time of trial.
T4
COMPLAINT AND DEMAND FOR JUR Y TRIAL

.L
For punitive damages and exemplary damages in an amount

to be determined at
6.
2
the time of trial.
J
7. Any other and fufther relief as the court may deem just and proper'
4 plaintif respectfully request that this court enter judgment against HCLA' The final
5 judgment should set forth the following as appropriate for each cause of action:
companionship,
6
1. General and special damages including, plaintiffs' loss of love,
training, guidance in an amount to
7
comfort, care, assistance, protection, affection, moral support,
8
be determined according to proof at the time of trial for HCLA's negligence'
gifts and
9 2. Economic damages, including plaintiffs' loss of financial support,
and funeral and burial
10 benefits, time from work, reasonable value of household services,
l-p
v."
11.
expenses in an amount to be shown at the time of trial for HCLA's negligence'

pain and
k i 12 3. Laurie,s pre-death general damages, including damages for the extreme
1
m i
-ty 13
suf'fering, mental stress, significant impairment of limb or bodily function,
significant
lrIJ ? that Laurie suff.ered
lJ.> 1.4
disfigurement, severe and chronic physical pain, and premature loss of life
ntd;
LL n 15 HCLA's violations of Civil Code section3428'
due to
u cJ E
hJllJ p
U
1"6
4. Damages for the reasonable attorney fees and costs incurred herein, suffered
due
t>
J.-
m1 17
to HCLA's violations of Civil Code section3428'
II
H suffered
rf
r-
II
18 5. General damages for plaintiffs' mental, emotional, and physical distress
HI
determined at
1,9
as a result of HCLA's negligent infliction of emotional distress, in an amount to be
20 the time of trial.
at
21.
6. For punitive damages and exemplary damages in an amount to be determined
22 the time of trial for HCLA violations of Civil Code section3428.
23 7, Any other and further relief as the Court may deem just and proper.
24
Dated: May 11,2017
25
26
By:
\i u
WILLIAM M. OFF
TRAVIS M. Y
27
SAMUEL BRUCHEY
28 Attorneys for Plaintiffs
15
COMPLAINT AND DEMAND FOR JUR Y TRIAL

1. JURY DEMAND
by a jury
2 Plaintiffs demand a jury trial on all causes of action that can be heard
J
FF BID LLP
4 Dated: May 11,2017
5
By:
6 WILLIAM M. OFF
TRAVIS M. CORBY
7 SAMUEL BRUCHEY
Attorneys for Plaintiffs
8
10
ro
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s"
12
i
"tk 13
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1 17
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5
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20
21
22
23
24
25
26
27
28
16

OFY
CAS NUMBER
Cal ifo rnla, lnc. et al.

cl air et al. v H eatth N et ol
SHORT TITLE:
Bt.
ADDENDUM AND
clvl L CASE COVER SHEET
STATEMENT o F LOCATON
COURT HOUSE LocATtON)
FOR ASS IGN MFNT TO
(cERTlFl CATE OF GROUNDS
geles s uperlor Court.
cag e filings ln ttr e Los An
civil
to Local Ru le 2.0 'ln a new
This form ls requlred pursuant
hearing expeoted for this case:
of hearing and fill in the estimated length of
Item l, Check the types
JURY TRTAL? ttt ct'Ass AcrloN? nvesLlMlTEocAsE?flvesTIMEESTIMATEDFoRTRALT0nHoURs/.qlDAY:S.
and courthouselocation(4steps-lfyouchecked"LinnltedCase'',skiptoltemlll,Pg'4):
ttom ll, lndcate the correct district
sheet heading for your
civil c1':.9ou"'sheet form' find the main civil case cover
step 1: After first completing the you selected'
A' the civil Case Cover Sheet case type
case in the left margino.',*,'.nJ, to the right in corumn
describes the naturo of this case'
in corumn B berow which best
step 2: check 4 superior court type of acron
you have
applies to the type of action
C, circle the reason for the oourt location choice that
SteP 3: ln Column Rule 2'0'
;h.JkJ to the court location, see Local
ot uny exception
g Cou rtho us Locatlon (see Col um
n c below)
A ppllcable Reason 6 for choosln
garaged vehlcle.
dlslrict, 6. Locatlon
1.
7. Locatlon wholl}/
2.
8. Locatlon
3,
9. Locatlon
10- LocaUon
4,
5.
on page 4 in ltem lll: complete ltem

lV' sign the declaration
step 4: Fill in the information requested
c
B Applicable Ressons'
A Type of Actlon See SteP 3 Above
cvlt Casg Covr Sheet (Check only one)
Category No.
Death 1.,2.,4.
Pesonal lnlury/ProParty Oamage/Wrongful
Auto (22) A7 100 Motor Vehlcle
O# 1,,2.,4.
-o Da mageNrongful Death Unl ngured Motorlst
<l- Uninsured Motorlst (46)
A71 10 Personal lnlury/ProPertY
2.
tr 46070 Asbestos Property Damage
2.
Asbe8tos (04) Death
tr A7 221 Asbe6tos' Personal lnjuryM/rongful
s
.o asbestos of toxldenvlronmental)
1,,2.,3., 4,. B'
CLF tr A7260 Product UabilltY (not
QE Product Llablllty (24)
(L(o 1.,4.
& Surgeons
-o
.f a A7210 Medlcal Malpractce 'Physldans
i,,4,
Medlcal MalPractlce (45) A A7240 Other Professlonal Health
Care Malpractlce
-= Et
EE (e'9" sllp and fall) 1,,
3= tr 47250 Premlses Llablllty
b
f Other trAT2S0lntontlonalBodilylnlury/PropertyDamge/WrongfulDeath(e.9..
1., 4.
fOE Personal lnlury ssault, vandallsm' etc') 1., 3:
,t(I' ProPerty Damage
Wrongful Death g A7270 lntentlonal lnlctlon of Emotlonal
Dlstresg
(23)
gt A7220 othr Prsonal lnlury/Property DamagsMrongful
Death @
Local Rute 2.0

RSH ADD U
LACIV {Os (Rev.03/11) Page I of4
AND STATEMENT O F LOCATION
LASC Approved 03'04
CASE NUMBER
sHoRT TrrLE:
st. clair, et al. v. Health Net of california' lnc" et
al
G
B
A Type ofAction
Applicable Reasons -
civil Case Cover Sheet (Check onlY one) See SteP 3 Above
Category No.
4n
Business Tort (07) trA6029otherCommercial/BusinessTort(notfraud/breachofcontract)
tr 46005 CivilRights/Discrimination
L,2.,3.
'-
(l)
9
civil Rights (08)
s Defamation (13) tr A6010 Defamation (slander/lbel)
1., 2,, 3.
3
55
1 ,, 2.,3
CD
Fraud (16) tr A6013 Fraud (no contract)
9
5
(/! E 46017 Legal MalPractice
1 ,,2,, 3.
LO -
8H' Professional Negligence (25)
tr A6050 Other Professional Malpractice (not medical or legal)
1.,2,,3,
cts
O(o
zo ,1,
Other (35) E A6025 Other Non-Personal lnjury/Property Damage tort
.,2., 3
{) Wrongful Terminaton (36) tr 46037 Wrongful Termnaton
1
E 1., 2.,3.
t A6024 Other Employment Complaint Case
aoE Other EmPloYment (15)
tr 46109 Labor Commissioner Appeals
10.
uJ
or wrongful
tr 46004 Breach of Rental/Lease Contract (not unlawful detainer 2.,5.
eviction)
2.,5.
Breach of Contracv Warranty EI A6OOB ContractMarranty Breach -seller Plaintiff (no fraud/negligence)
(06) 1,,2,, 5.
(not insurance) E A6019 Negligent Breach of ContractMarranty (no fraud)
1.,2,,5.
E A6028 Other Breach of ContractMananty (not fraud or negligence)
o 2., 5., 6
G'
L
El 46002 Collections Case-seller Plaintiff
co Collections (09) 2.,5.
tr A6012 Other Promissory Note/Collections Case
c)
1., 2., 5,, B.
lnsurance Coverage (1 B) El 46015 lnsurance Coverage (not complex)
1., 2., 3,, 5.

tr A6009 Contractual Fraud
1., 2., 3., 5.
Other Contract (37) n 46031 Tortous lnterference
L,2,,3., B.
trA6o2TothercontractDispute(notbreach/insurance/fraud/negligence)
nent Dom nverse fl 47300 Eminent Domain/condemnation Number of

parcels..- 2.
Condemnation (14)
2.,6.
C,
o-
Wrongful Eviction (33) tr 46023 Wrongful Eviction Case
o
2.,6.
o-
(
tr 46018 Mortgage Foreclosure
2.,6.

()
Other Real Property (26) tr 46032 Quiet Title
2.,6.
trA6060otherRealProperty(noteminentdomain,landlord/tenant,foreclosure)
mercial 2.,6.
trA602lUnlawfulDetaner-commercial(notdrugsorwrongfuleviction)
(31)
c,
. 2.,6
or wrongful eviction)
G'
(,
Unlawful Detaner-Residental El A6020 unlavuful Detainer-Residential (not drugs
o (32)
2,,6.
=
E Unlawful Detainer' D A602OFUnlawful Detainer-Post-Foreclosure
ls Post.Foreclosure (34)

2.,6.
= Unlawful Detaner-Drugs (38) tr 46022 Unlawful Detainer-Drugs
Local Rule 2.0

LACIV 109 (Rev.03/11) CIVIL CASE COVER SHEET ADDENDUM
Page 2 of 4
LASC Approved 03-04
AND STATEMENT OF LOCATION
CAS NUMBER
sHoRrrrrl':
st. clair, et al. v. Health Net of california' lnc" et
al
B c
A Type of Action
Applicable Reasons -
Civil Case Cover Sheet See SteP 3 Above
(Check onlY one)
Category No'
2..6.
Asset Forfeiture (05) 46108 Asset Forfeiture Case
2.,5
Petition re Arbitration (1 1) tr 461 15 Petition to Compel/ConfirmA'/acate Arbitration
=
.E
2,,8.
o, EI A6151 Wrt - Administrative Mandamus
3 Writ of Mandate (02) tr 46152 Wrt - Mandamus on Limited Court Case Matter
2.
.9
!:t 2.
-, n A6153 Writ - Other Limited Court Case Review
2,,8.
Other Judiclal Review (39) tr 46150 Other Wrt /Judicial Review
., 2., 8.
c, AntitrusvTrade Regulation (03) t A6003 AntitrusuTrade Regulation
1
o
,, 2,,3
ftt
cn Construction Defect (10) E 46007 Construction Defect
1
=
gx Claims lnvolving Mass Tort n 46006 Claims lnvolving Mass Tort
2 B.
o- (40)
E
o 1 .,2., B.
(J Securities Litigation (28) E 46035 Securities Litigation Case
-
1., 2., 3., B.
c Toxic Tort tr 46036 Toxic ToruEnvironmental
.o Environmental (30)
.9
o 1., 2., 5., B.
L
d
lnsurance Coverage Claims
from ComPlex Case (41)
n A6014 lnsurance Coverage/Subrogation (complex case only)
2.,9,
tr 46141 Sister State Judgment
2.,6.
,c
D 46160 AbstractofJudgment
(uo 2.,9.
E
c, E) Enforcement
tr 46107 Confession of Judgment (non-domestic relations)
2,,8.
9E
.; of Judgment (20) tr 46140 Administrative Agency Award (not unpaid taxes)
2,,
uJo n 461 14 Petiton/Certfcate for Entry of Judgment on Unpaid Tax B.
2., 8., 9.
t 46112 OtherEnforcementof JudgmentCase
1., 2., B.
Rrco (27) El A6033 Racketeering (RICO) Case
tt
2
o
(u= EI 46030 Declaratory Relief OnlY
1., 2., B.
b 2., B.
tr 46040 lnjunctive Relief Only (not domestic/harassment)
3o
=o
tt=
Other ComPlaints
(Not Specified Above) (42) E 46011 Other Commercial Complant Case (non-torvnon-complex)
1.,2.,8.
1.,2,, B.
= EI A6000 Other Civil Complaint (non{orunon-complex)
2,, B.
Governance (21)
tr A6113 Partnership and Corporate Governance Case
2., 3., L
n 46121 Civil Harassment
at, 2., 3., L
oo
=c
tD
tr A6123 Workplace Harassment
{., 5 2.,3.,9.
$D E A6124 Elder/Dependent Adult Abuse Case
o- Other Petitions 2.
(Not Specified Above) E 46190 Election Contest
.a . (43) 2.,7
=c) tr A6110 Pettion for Change of Name
.
2., 3., 4., B.

tr A6170 Petton for Relief from Late Claim Law
,o
tr 46100 Other Civil Pettion
Local Rule 2.0

LACIV 1 09 (Rev. 03/1 1) CIVL CASE COVER SHEE T ADDENDUM
Page 3 of 4
LASC ApProved 03-04
AND STATEMENT OF LOCATION
CASE NUMBER
sHoRrrrrl:
st. clair, et al. v. Health Net of california' lnc" et al'
performance' or other
accident, party's residence or place of business,
Item lll. statement of Location: Enter the address of the you selected'
page 1, as the proper reason forfiling in the court location
circumstance indicated in ltem ll., step 3 on
ADORESS:
REASON: Check the appropriate boxes for the numbers

shown 18150 Prairie Avenue, #103
selected for
under Column C for the typ of action that you have
this case.
J1.2. n3.84. n5. n6' n7' n8. trg' 10'

STATE: ZIP CODE:
CITY:
CA s0504
Torrance
that the foregoing is true

Item lv. Declaration of Assignmen I declare under penalty of perjury under the laws of the state of california
properly filed for assignment o 1" Los Angeles superior courthouse in the
and correct and that the above-entifled matter is
Central District of the Superior court of California, County of Los
Angeles [Code Civ. Proc', $ 392 et seq'' and Local
Rule 2.0, subds. (b), (c) and (d)1.
\,. t\
Dated: May 11,2017 PART/-..
(stcNATURE OF ATTORNEY/FIL|NG ',
TO BE FILED IN ORDER TO PROPERLY

PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY
COMMENCE YOUR NEW COURT CASE:
1. Original Complaint or Petition.

by the clerk'
2. lf filing a complaint, a completed summons form for issuance
3. CivilCase Cover Sheet, JudicialCouncilform CM'010'

Civil Case Cover Sheet Addendum and Statement of Location
form, LACIV 109, LASC Approved 03-04 (Rev
4.
03/1 1 ).
5'Paymentinfullofthefilingfee,unlessfeeshavebeenwaived,
form clV-O10, if the plaintiff or petitioner is a
6. A signed order appointing the Guardian ad Litem, Judicial council
to issue a summons'
minor under r aTais f ge will be required by Court in order
of the cover sheet and this addendum
7. Additional copies of documents to be conformed y trg clerk, copies
must be ,"*"-rn wir' tne iumr;;ai ;;mptaini, or other initiating pleading in the case'
Local Rule 2.0

LACIV 109 (Rev. 03/11) CIVIL CASE C OVER SH EET ADDENDUM
Page 4 ol 4
LASC Approved 03-04 AND STATEMENT OF LOCATION
[?it:i crIoN)B
NOTTCE i'igi,",",'-i,Blf
1*ll,H$'"'3SJfJ'iRft 00I 0Be$
Case Number
sirle of this form'

belorv. Thcro is more
informatio n on the reverse
purposes to the judge i
Your case is assigncd for all
DEPT 48 506
s34 Hon. Elizabeth Allen Vy'hitc
1
Hon. Debre K. \ileintraub 49 509
636 Hon. Deirdre Hill
L2
Hon. Bnrbara A. Meiers 50 508
300 Hon. Teres A, Beudct
t4
Hon. TerrY A. Grecn 5t 511
307 Hon. iVlichael J. RaPhel
15
Hon. Richrd Fruin 52 510
306 Hon. Susnn BrYanteason
16
Hon. Rita Miller 5J 513
I'Ion. HorYard L' Hlm
t7 309
Hon. Richard E. Rco 54 512
311 Hon. Ernest tVI. Hiroshige
L9
Hon. StePhanie Borvick 5! 515
310 Hon. Mlcolm H. lVfackeY
20
Hon. Datila Corral LYons 50 514
314 Hon. Michael Johnson
24
Hon. Robert L. Hess 58 516
318 Hon. John P. DoYle
28
Hon. Yvette lVf. Plnzuelos 6l 132
400 IIon. GregorY Keosian
SchePer 30
llon. arbara 62 600
Hon. Michael L' Stern
3l 407
Hon. Snmanth Jessner 68 6r7
406 Hon. lVlnrk IVIooncY
iel S. MurPhY 621
69
408 Hon. Wllllam F, FaheY
Linficld 34
n. Michael P. 129
1l
410 Hon. IVlonica Bnchner
Hon. GregorY Alarcon n1 131
413 Hon. Ruth Ann Kwnn
31
Hon. lVInrc Marmro 733
73
4t2 Hon. Rfnel Ongkelro
38
Hon. lVf aureen DuffY'Lewis 735
14
4ls Hon. JosePh R. Kalin
39
I'Ion. Elizabcth Feffer 730
78
4t4 Hon. Gail Rudermnn Feuer
40
IIon. Dnvid Sotelo
42 4t6
Hon. HollY E. Kendig 324 ccw
529 Hon. Steven J. Kleifield
45
Hon. Ivlel Red Recsna ionnllY ComPlex
46 500 Non-clnss Action Cses
Hon. Frederick C' Shaller ccw
Assignment is Pcnding 308
47 507
Hon. RandolPh Hammock
Page I of2
. NOTICE OF CASE ASSGNMENT -
"
LACIV CCH 190 (Rev'12/16) Hr-lrvrrrEo clvlL cAsE
LASC APProved 05'06
''
INSTRUCTIONS FOR HANDLING UNLIMITED CIVIL CASES
The foltowing critical provisions of the Chapter Three Rules, as applicable in the Central
District, are summarized for your assistance'
APPLICTION
The chapter Three Rules were effective January l, 1994. They apply to all general civil cases.
PRTOBITY OVER-.OIITER RULES

inconsistent.
The Chapter Thee Rules shall have priority over all other Local Rules to the extent the others are
CIALLENGE TO SSIGNED JUDGE

for all purposes to a
A challenge under Code of civil procedure section 170.6 must be made within 15 days after notice of assignment
judge, or iia party has notyet appeared, within l5 days ofthe first appearance.
TIME STAND,RDS
Cases assigned to the Individual Calendaring Court will be subject to processing under the following time standards:
be served within 60 days of filing and proof of service shall be filed within 90 days of
filing'
COMpLAINTS: All complaints shall
their answer
Without leave of court first being obtained, no cross-complaint may be filed by any parry after
is
cRoss-coMpLAINTS:
of filing
filed. Cross-complaints shall be served within 30 days of theiling date and a proof of service filed within 60 days the date.
Status Conference will be scheduled by the assigned Independent Calendar Judge no later
than 270 days after the filingof the complaint'
A
Counsel must be fully prepared to discuss the follwing issues: alternative disput resolution, bifurcation, settlement, trial date, and expert
witnesses.
FrNAL STATUS CONFERENCE

frled and served all motions
The Court will require the parties at a status conference not more than l0 days before the trial to have timely
jury instructions, and special jury
in limine, bifrrcation motins, statements of major evidentiary issues, dispositive motons, requested
instructions and special jury vrdicts. These mattirs may be heard and resolved at this conference. At least 5 days before this conference,
to the court a brief statement of the case to be read to
counsel must also t uu. *Jttung" tittt of exhibits and witnesses and have submitted
the jury panel as required by Capter Eight of the Los Angeles Superior Court Rules.
SANCTIOI-{S
made by the Court, and
The court will impose appropriate sanctions for the failure or refusal to comply with chapter Three Rules, orders
.rtubtirhud by the Court or by the Chapter Three-Rules. Such sanctions may be on a party or if appropriate on
time standards or deadlins
counsel for the partY.
provisions is therefore not a

This is not a complete delineation of the Chapter Three Rules, and adherence only to the above
guarantee againsi th; imposition of sanctions under Trial Court Delay Reduction. Careful reading and compliance with the
actual Chapter Rules is absolutely imperative.
LACV CCH 190 (Rev.'l?16) - NOTICE OF CASE ASSIGNMENT - Page 2 of2
LASC Approved 05-06 UNLIMITED CIVIL CASE

VOLUNTARY EFF ICIENT LITIGATION STI PU LATIONS
The Early organizational Meeting stipulation, Discovery

Resolution Stipulation, and Motions in Limine Stipulation are
Superlor Gourt of Callfornla voluntary stipulations entered into by the parties. The parties
County of Los Angetes
may enter into one, two, or all three of the stipulations;
however, they may not alter the stipulations as wrtten,
because the Court wants to ensure uniformity of application.
Los Angsles County
Bar Assoclatlon These stipulations are meant to encourage cooperation
Lltlgatlon Sectlon
Los Angs County

between the parties and to assist in resolving issues in a
manner that promotes economc case resolution and judicial
Bar Assocatlon Labor and
Employmont Law Sectlon
efficiency.
wffi
Consumer Attorneys
Assoclatlon of Los Angeles
The following organzatons endorse the goal of
promotng efficiency in litigation and ask that counsel
consider using fhese stipulations as a voluntary way to
promote communcatons and procedures among counsel
and with the cout to fairly resolve issues in their cases.
lLos Angeles Gounty Bar Association Litigation sectionl

Southorn Callfornla
Dofonse Counsel
I Los Angeles Gounty Bar Association
Labor and EmPloYment Law Sectionl
"*'*ita*
Asgoclaton of
Buslness Trlal Lawyerc lGonsumer Attorneys Association of Los Angelesl
lsouthern California Defense Counsell
lAssociation of Business Trial Lawyerst

Callfornla Employmont
Lawyors Assoclatlon lGalifornia Employment Lawyers Association I
LACIV 230 (NEW)

LASC Approved 4-1 1
For Optlonal Uso
SAIESARNUMSR R.rw.d lG oll'r F|. shmP
COURT OF COUNTY OF LOS ANGE
-es-r{uER:
STIPULATION - DISCOVERY RESOLUTION

This spulation is intended to provide a fast and informal resolution of discovery issues
ttrrouglr llmlted papenrorf an'd informat conference with the Court to aid in the
resolutlon of the issues. "n
The parties agree that
1. prior to the discovery cut-off in this action, no discovery motion shall be filed or heard unless
pursuant
the moving party fiisi makes a wrltten request for an lnformal Discovery Conference
to the terms of this stlPulation,
parties
Z, Atthe lnformal Discovery Conference the Court will consider the dispute presented by
preclude
and determine whether it can be resolved informally. Nothing set forth herein will a
prty fror makinj record at the conclusion of an lnformal Discovery Conference, either
orally or in writing.
3. Following a reasonable and good faith attempt at an informal resolution of each issue to be
presente, a party may requst an tnformal Discovery Conference pursuant to the following
procedures:
a. The party requesting the lnformal Discovery conference will:
i. File a Request for lnformal Discovery Conference with the clerk's offlce on the
approved iorm (copy attached) and deliver a courtesy, conformed copy to the
assigned department;
i. lnclude a brief summary of the dispute and speciff the relief requested; and
ii. Serve the opposing party pursuant to any authorized or agreed.method of service
that ensJre ittat t-h op-psing pfty receives the Request for lnformal Discovery
conference no later than the next court day following the filing.
b. Any Answer to a Request for lnformal Discovery conference must:
i. Also be filed on the approved form (copy attached);
ii. lnclude a brief summary of why the requested relief should be denied;
LACIV 036 (new)
lSC Approved 04/11
For Oponal Use
STIPULATION - DISCOVERY RESOLUTION Page 1 of 3
CAg NUMEER:
stoRl ne
. Be filed within two (2) court days of receipt of the Request; and
iv. Be served on the opposing party pursuant to any authorized or agreed upon
method of service thi ensurs that the opposing party receives the Answer no
later than the next court day following the filing'
c. No other pleadings, including but not limited to exhibits, declarations, or attachments, will
be accepted.
d. lf the Court has not granted or denied the Request for lnformal Discovery Conference
within ten (10)days flowing the filing the Request, then it shall be.deemed to have
of
been denied.' lf tre Court acts on th Request, the parties will be notified whether the
Request for lnformal Discovery Conference has been gra{e.d or denied.and, if
granted,
whlch must be within twenty (20)
the ate and time of the lnformal Discovery Conference,
days of the filing of the Request for lnformal Discovery Conference.
e. lf the conference is not held within twenty (20) days of the filing of the Request for
tnformal Discovery Conference, unless extended by agreement of the partles and the
Court, then the Rquest for the lnformal Discovery Conference shall be deemed to have
been denied at that time.
4, lf (a) the Court has denied a conference or (b) one of the time deadlines above has expired
without the Court having acted or (c) the lnformal Dscovery Conference is concluded without
resolving the dispute, thn a party inay file a discovery motion to address unresolved issues.
5. The parties hereby further agree that the time for making a motion to _compel or other
discoiery motion is tolled from tne date of filing of the Request fo1 lnformal Discovery
Conferece until (a) the request is denied or'deemed denied or (b) twenty (20) days after the
filing of the Requsi for tnformal Discovery Conference, whichever is earlier, unless extended
by Order of the Court.
It is the understanding and intent of the parties that this stipulation shall, for each discovery
Jrput" to which it applies, constitute a writing mernorialzing a "specitic later date to which
the propounding lor manOing or requesting]-party and the responding party have agreed in
riti'ng,; within tr meanng oiCode vl Proceure sections 2030.300(c), 2031.320(c)' and
2033.290(c).
6. Nothing herein will preclude any party from applying ex pafte for appropriate relief, including
an ordr shortening time for a motion to be heard conceming discovery.
7. Any party may terminate this stipulation by giving twenty-one (21) days notice of intent to
terminate the stiPulation.
B. References to "days" mean calendar days, unless otherwise noted. lf the date for performing
any act pursuant t tns stlpulation fails n a Saturday, Sunday or Court holday, then the time
foiperforming that act shall be extended to the next Court day.
lClV036 (new)
LASC Approved 04/11
For Optlonal Use
STIPULATION - DISCOVERY RESOLUTION
Page 2 of 3
CAAENUMSN:
SSoRTn1le
The following Parties stiPulate:
Date:
(ATTORNts,Y PLAINTIFF)
OR PRINI
Date:
(ATT9riNtsY DEFENIIANT)
cl-YPE 9R NAME)
Date:
(Al oF{NY oEF,NUAN l)
(f Ytts uK NAME)
Date:
(Al roKNtsY DEFENDAN I )
(TYPts (JK NAME)
Date:
(ATTORNEY FOK
(l YPts (JK NAME)
Date:
(ATTORNEY FgR
OR PRINT
Date:
NAME) (ATTORNEY FOT

ITYPE QR
LACIV 036 (new)

LASC Approved 04/1
For Optlonal Use
I STIPULATION - DISCOVERY RESOLUTION
Page 3 of 3
R.r.w!d ld qff! slmp
PRY ITHOUI AITORNY: 9fA1 8R iUU8R
NA, ANO AD0888 OF ATIoRNEY OR
TELEPHONE NO.: FAX NO. (Optlonl):

E.MAIL ADORESS
s OF NTY
STIPULATION - EARLY ORGANIZATIONAL MEETING
parties at an early stage ln

Thls sflpulation ls intended to encourage cooperatlon among the
th; ltgkon and to assist the parties ln efflclent case resolutlon.
The partlee agree that:
1. The parties commit to conduct an initial conference (in-person or v4. teleconference or via
vOo'onterence) *ttrn 15 days from the date this stipuiation is signed, fo drscuss
and conslder
whethertherc can be agreement on the following:
a. Are motions to challenge the pleadings necessary? lf the issue can be resolved by
amendment as oi right,-or if th Couriwould allow leave to amend, could an amended
lf so, the parties
complaint rurG moit r ail of the lssues a demurrer might otherwise raise? jssues
g* workthiough pleadng lssues so that a demurrer need only raise they cannot
or
ie-solve. ls the issutnt tne dfendant seeks to raise amenable to resolution on demurrer,
of
would ror" tn.i type of motion be preferable? Could a voluntary targeted exchange
documents or informtion by any party cure an uncertainty in the pleadings?
ncore' of the litlgation. (For example, in an
b. lnitial mutual exchanges of documents at the
employment cse, th employment records, pe_rsonnel file and documents relating to the
ucore." ln a personal injury case' an incident or
codut in que$in coutd'be-considered
police repori, medical records, and repair or maintenance records could be consldered
ucore.');
c. Exchange of names and contact information of witnesses;

judgment, or to
d. Any insurance agreement that may be available to s.atisfy part or all of a
indmnfy or reimburse for payments made to satlsfy a judgment;
e. Exchange of any other information that might be helpful to facilitate understanding, handling,
or resoltion of the case in a manner that preserves obJections or privileges by agreement;
f. Controlling issues of law that, if resolved early, will promote efficiency and economy in other
pna.6 of-the case. Also, when and how such issues can be presented to the Court;
g.
- Whether or when the case should be scheduled with a settlement officer, what dlscovery or
court ruling on legalissues is reasonably required to make settlement discusslons meanlngful,
and whether thelarfles wish to use a sltting judge or a private mediator or other
options as
LACIV 229 (Rsv 02|/15)

l.SG Approved 04/l l STIPULATION - EARLY ORGANIZATIONAL MEETING
Page 1 of 2
For Optional Use
c!NUM8m:
sHoRf fle
the
OscusseO in the'Alternative Dispute Resolution (ADR) lnformation Package" served with
comPlaint;
privileged or protected from disclosure' on
h. Computation of damages, including documents, not
which such comPutation is based;
(see information at
i. Whether the case is suitabte for the Expedited Jury Trial procedures
rm ation"),
wwyv, I a co u rt.o ra u nd er " civif' and then u nder " G e ne ral I nf o
will be extended
2. The time for a defending- party to respond to a complalnt or cross-complaint
'
to (INSERT DATE)
for the cmplaint, and
Code $ 68616(b)'
complani, wtri.'ii.orprised of the 30 days to respond under Government
gO d;t; by Code of Cirt Procedure section 1054(a),,good cause havlng
and the "rritt"O
benefTts provide_d by
. been rouno oyiJcill srdrurng Judge due to the case management
ns Stpulatoh. copy tin" Geeral rder can be found at W14'9lg under'Civil"
click on "Gengra| tnfinatton", then ctick on 'Voluntary Effclent Ltigation Slu/afions".
g. The parties will prepare a Jolnt report tifled "Joint Status Repgrt Pursuant to lnitial
'rty
Conference
an orgztonal fueetini stlputatton, and^if desired, a proposed order summarzing
rsufts oi tner mt and confer no ovsng the Court of any way !t may assist
the parties'
to
efficlent conduct or resolution of the case. The parties shall attach the Joint Status Report
the Case Unagement Conference statemeni, and flle the documents when the CMC
statement is due.
4. References to
udays" mean calendar days, unless otherwise noted. lf the date for performing
time
any act purrranit tns stipulation falls n a Saturday, Sunday or Court hollday, then the
foiperfdrming that act shalt be extended to the next Court day
Date:
(TYPE OR PRINT NAM E) (ATTORNEY FOR

Date:
(TYPE OR NAME) (ATTORNEY FOR

Date:
(wPE OR PRINT NAME) (ATTORNEY FOR

Date:
(TYPE OR PRINT NAME) (ATTORNEY FOR DEFEN
Date:
(TYPE OR NAME)
Date:
(TYPE OR PRINT NAMts) (ATTORNEY F9R

Date:
(TYPE OR PRINTNAME) -1ffiFEv FoR-)
STIPULATION - EARLY ORGANIZATIONAL MEETING Page 2 of 2

LASC Approved 04t11
gfAT AR NIJMEER R6dcd lqCldkl Flh SlmP
NE AO AODRSS OF ATTORNE'Y OR PAT.Y wlITIOUf ATIORNF:
TELEPHONE NO, FAX NO. (Oponal):

E.MAIL AODRESS
SUPE RIOR COURT OF CA L I FORN COUNTY LOS ANG
INFORMAL DISCOVERY CONFERENCE

to the Resol ution of the
1. This document relates to:

tr Request for lnformal Discovery Conference
- Answer to Request for lnformal Discovery Conference
2. Deadline for Court to decide on Request: (lnsert date l0 calondar days followlng ffllng of
the Request). t
3. Deadline for Court to hold lnformal Discovery Conference: (lnsert date 20 clndar
days followlng lillng of lhe Requsst).
4. For a Request for lnformal Discovery Conference, fly descrlbe the nature of the
discovery disPute, including the facts and legal arguments at lssue. For an Answer to
Req uest for lnformal Discovery Conference, dgfly describe why the Court should denY
the requested , lncludlng the facts and ments at issue.
LACIV 094 (new) INFORMAL DISCOVERY CONFERENCE

LASC Approved (X/11
For Optlonal Use
(pursuant to the Discovery Resolution Stipulation of the parties)
sTAt R tulBR RilN.d ltr cldkl F!. ShP
SUPERIOR RT OF IA COUNTY OF ELES
-
CASENUMR:
STIPUT.ATION AND ORDER - MOTIONS IN LIMINE
Thls stipulation is intended to provide fast and informal resolutlon of evidentiary

issues tirrough dillgent efforts to define and discuss such lssues and limit papenrvork.
The parties agree that:
1. At least _ days before the final status conference, each party will provide all other
parties wttr a list containing a.one paragraph explanation of each proposed motion in
iimne. Each one paragraph explanation must identit the substance of a single proposed
motion in limine and the grounds for the proposed motion.
2. The partes thereafter will meet and confer, either in person or via teleconference or
videoconference, concerning all proposed motions ln limine. ln that meet and confer, the
parties will determine:
a. Whether the parties can stipulate to any of the proposed motions. lf the parties so
stipulate, they may file a stipulation and proposed order with the Court.
b. \Mether any of the proposed motions can be briefed and submitted by means of a
short joint statement of issues. For each motion which can be addressed by a short
joint statement of issues, a short joint statement of lssues must be filed with the Court
10 days prior to the final status conference. Each side's portion of the short joint
statenent of issues may not exceed three pages. The parties will meet and confer to
agree on a date and manner for exchanging the parties' respective. portions of the-
sort joint statement of issues and the process for filing the short joint statement of
issues.
3. All proposed motions in limine that are not either the subject of a stipulation or briefed via
a sirort joint statement of issues will be briefed and. filed in accordance with the California
Rules of Court and the Los Angeles Superior Court Rules.
LACIV 075 (n6w)

LASC Approved 04/l
For Optlonal Use
I STIPULATION AND ORDER - MOTIONS IN LIMINE
Page 1 of 2
CAS NUMBT:
sH0Rlrle
Date:
EY FOR P FF)
(wPEOR PRINT NAME)
Date:
E) FOR
OR PRINT
Date:
(ATTORNEY DEFENDANT)
(wPEOR NAME)
Date:
(ATTORNEY DEFENDANT)
Date:
(wPEoR NT NAME)
Date:
(TYPE OR P R]NT NAME) (ATTORNEY FOR

Date:
(TYPE OR NAME) (ATTORNEY FOR
THE COURT SO ORDERS.
Date
JUDICIAL OFFICER
I-ACIV 076 (new)

LASC Approved 04/1 I STIPULATION AND ORDER - MOTONS IN LIMINE Pag2 ol2
Superior Court of California
CountY of Los Angeles
ALTERNATIVE DISPUTE RESOLUTION (ADR)

INFORMATION PACKET
The person who files a civil lawsut (plaintff) must include the ADR information
packet with the complaint when serving the defendant. cross-complainants must
serve the ADR lnformation Packet on any new parties named to the
action
together with the cross-complalnt.
There are a number of ways to resolve civil disputes without having to sue
someone. These alternatives to a lawsuit are known as alternative dispute
resolution (ADR).
partes decide disputes
ln ADR, trained, impartial persons decide disputes or help
the
themselves. These persons are called neutrals. For example, in mediations,
disputing parties or by
neutral is the mediator. Neutrals normally are chosen by the
the court. Neurals can help resolve disputes without having to go to court'
TAADR 005 (Rev. Oglt7l

LASC Adopred 10-03
Cal. Rules of Court, rule 3.221
Advantages of ADR
Often faster than going to tral
o Often less expensiie, iaving the litigants court costs,
attorney's fees and expert fees'
. have more control over the outcome'
May permt 3,nor. p.r,i.ipaiion, allowing parties to
resolutrion of the dispute'
Allows for flexibiliiy in choice of ADR processes and
with the neutral to resolve the dispute and
Fosters cooperation by ailowing partils to work together
mutuallY agree to remedY.
o ADR can be faster and save money, it can reduce
There are fewer, if any, court appearances. Because
stress.
DisadvantagesofADR-ADRmaynotbesutableforeverydispute.
by a judge or
lf ADR is binding, the parties normally give up most court protections, includingbyaandecision
appellate court'
jury under formal rules of evidence an procedure, and review for legal error
r ADR may not be effective if it takes place before the parties have sufficient information to resolve the
dispute.
The neutral may charge a fee for his or her services'
o have to face the usual and traditional
lf the dispute is not resolved through ADR, the parties may then
costs of trial, such as attorney's fees and expert fees'
The Most Common TYPes of ADR
a Mediatlon
a mutually acceptable resolution

ln medation, a neutral (the mediator) assists the parties in reaching
parties, rather than the mediator'
of their dispute, unlike lawsuits or some other types of ADR, the
decide how the dispute is to be resolved'
. Mediation is particularly effectlve when the parties have a continuing

relationship, like
neighbors or business popte. Mediation is also very effective
where personal feelings are
gives the parties a chance
getting in the way of a resolution. This is because mediation normally
io their feelings and find out how the other sees things.
"rpr.r,
cooperate or compromise or
Medaton may not be effective when one party is unwilling to
power over the other. Therefore, it may
when one of tfie parties has a significant advantage in
not be a good choice if the parties have a history of abuse or vctimization'
LAADR 005 (Rev. /r7l

LASC Adopted 10-03
Cal. Rules of Court, rule 3.221
Psge 2 of4
Arbitration
and evidence from each

ln arbitration, a neutral person called an "arbitrator" hears arguments
is typically less formal than a
side and then decides the outcome of the dispute. Arbitration
or "non-
trial, and the rules of evidence may be relaxed. Arbitration may be either "binding"
bindng.,, Binding arbitration means the parties waive their right
to a trial and agree to accept
the arbltrator,s declsion as final. Non-binding arbitraton means that the parties are free to
request a tral f they reject the arbitrator's decision'
decide the outcome of

Arbitration is best for cases where the parties want another person to
of a trial' lt may
ther dspute for them but would like to avoid the formality, time, and expense
a decsion-maker who has
also be appropriate for complex matters where the parties want
training or experience in the subject matter of the dispute'
t Mandatory Settlement Conference (MSC)
option'
settlement Gonferences are approprate ln any case where settlement is an
the Court and are often held near the date
Mandatory Settlement Conferences are ordered by
judge who devotes his or her
a case is set for tral. The parties and their attorneys meet with a
in the case but
time exclusively to preside over the MSC.'The judge does not make a decision
assists the parties in evaluating the strengths and weaknesses of the case
and in negotiating a
settlement.
The Los Angeles Superior Court Mandatory Settlement Conference (MSC)

program is free of
charge and staffed by experienced sitting civiljudges who devote their time exclusively to
pruriding over MSCs. The judges participating n the judicial MSC program and their locations
website
are identified in the tist oi settlement Officers found on the Los Angeles Superior Court
at http://www.lacourt.orsl. This program is available in generaljurisdiction cases with
'upffiindependentcalendar(lC)andcentralCivilWest(ccw)courtroom5.
ln addition, on an ad hoc basis, personal injury cases may be referred to the
program on the
Courthouse or the
eve of tral by the personal lnury master calendar courts in the Stanley Mosk
asbestos calendar court in CCW.
judge in the lc courtroom,

ln order to access the Los Angeles superior court Msc Program the
the parties to
the ccw courtroom or the personal injury master calendar courtroom must refer
the program. Further, all parties muit complete the information requested in the Settlement
Conference lntake Form and emailthe completed form to mscdeptlS@lacourt.org.
LAADR 005 (Rev. A3/L7l

LASC Adopted 10'03
Cal. Rules of Court, rule 3.22L
Page 3 of4
Additional lnformation
To locate a dispute resolution program or neutral in your community:
e Consumer lnformation
Contact the calfornia Department of Consumer Affairs (w!,yw.dq.ca.eov)
Center toll free at 800-952-5210, or;
r Contact the local bar association (http://www'lacba'ore/l or;
o Look in a telephone directory or search online for "mediators; or "arbitrators."
There may be a charge for services provided by private arbitrators and mediators'
A list of approved State Bar Approved Mandatory Fee Arbitration

programs is available at
below. or you may

To request information about, or assistance with, dispute resolution, call the number listed
call a Contract provider agency directly. A list of current Contract Provider agencies in Los Angeles County is
available at the link below.
u m
County of Los Angeles Dispute Resolution Program

3175 West 6th Street, Room 406
Los Angeles, CA 90020'1798
TEL: (213)738-262t
FAX: (213) 386'399s
LAADR 005 (Rev. A3/L7l

LASC Adopted 10-03
Cal, Rules of Court, rule 3.221
Page 4 of 4

St. Clair vs. HealthNet

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TOPV FOR COUTUSE ONt

(Nan, S16lo 8dt nunbet, and addrss):

Amo u nt (Amount) Filed with first aPoearance bY defendant

case tYPe that best thls case:

Other non'Pl/PDND tort (35) n Petillon re: arbitration award (1 1)

Employmont n wrt of mandate (02)

n Wrongful tennination (36) tr Other fudicial revlew (39)

n Other emp loyrnent (1 5)

DamageAlVrongful Death Breach of Rental/Lease AntitrusVTrade Regulation (03)

Other Breach of ContractMarranty comPtex case tYPe listed above)

(ctTACtoN JUDICTAL) CONFORMED COPY

[i Carlsr, Exencttvo flcer/ler}

of plaintiffs attorney' or olaintiff without an attorney, is:

CCP 416.40 (association or partners hp) n CCP 416.90 (authorized Person)

INSTRUCTIONS FOR USE

ptaintiff l--l Defenclant |.-_l cross complainant l-l cross-Defendant

and as successor-in-interest to LAURIE ST' CLAIR

Form Adopted for Mandalory Uso ADDITIONAL PARTIES ATTACHMENT

Laurie's liver condition

had worsened, so Dr' Suchov

COMPLAINT AND DEMAND FOR JURY TzuAL

COMPLAINT AND DEMAND FOR JURY TRIAL

COMPLAINT AND DEMAND FOR JURY TzuAL

The letter lists Dr' Suchov

by Dr. Fredrick weiss,

COMPLAINT AND DEMAND FOR JURY TRIAL

I Net's assistance to resolve the problem. Meanwhile, she continued

of her days were filled with

On Octobe r 12,2015,Melissa again tried calling Health Net to see why

COMPLAINT AND DEMAND FOR JURY TRIAL

cap hospital'" Louis gave no

care but had no access to a

COMPLAINT AND DEMAND FOR JURY TzuAL

I g) Unreasonably avoiding authorization of medically

9 financial gain by ignoring the seriousness of Laurie's condition;

COMPLAINT AND DEMAND FOR JURY TRIAL

4 amount to be determined according to proof at the

proof, and in amounts to be determined at the

buriar expenses in the amount to be show'

COMPLAINT AND DEMAND FOR JURY TRIAL

COMPLAINT AND DEMAND FOR JURY TRIAL

7 proof at the time of trial.

8 have feelings of disdain and contempt for Health Net and

General and special damages including, plaintiffs' loss of love,

COMPLAINT AND DEMAND FOR JUR Y TRIAL

For punitive damages and exemplary damages in an amount

COMPLAINT AND DEMAND FOR JUR Y TRIAL

COMPLAINT AND DEMAND FOR JURY TRIAL

Cal ifo rnla, lnc. et al.

JURY TRTAL? ttt ct'Ass AcrloN? nvesLlMlTEocAsE?flvesTIMEESTIMATEDFoRTRALT0nHoURs/.qlDAY:S.

on page 4 in ltem lll: complete ltem

Local Rute 2.0

1., 2., 3,, 5.

nent Dom nverse fl 47300 Eminent Domain/condemnation Number of

Local Rule 2.0

2., 3., 4., B.

Local Rule 2.0

REASON: Check the appropriate boxes for the numbers

J1.2. n3.84. n5. n6' n7' n8. trg' 10'