Declaration In OppositionCal. Super. - 6th Dist.October 16, 20171 SHARON R. VINICK, ESQ., State Bar No. 129914 E-Mail: sharon@levyvinick.com 2 LESLIE F. LEVY, ESQ., State Bar No. 104634 E-Mail: leslie@levyvinick.com 3 LEVY VINICK BURRELL HY AMS LLP 180 Grand Avenue, Suite 1300 4 Oakland, CA 94612 Tel.: (510)318-7700 5 Fax: (510) 318-7701 6 SUPREETA SAMPATH, ESQ., State Bar No. 232190 E-Mail: supreeta@sampathlaw.com 7 THE SAMP A TH LAW FIRM 351 California Street, Suite 700 8 San Francisco, CA 94104 Tel.: (415) 231-5855 9 Fax: ( 415) 202-6467 1 O Attorneys for Plaintiff Dr. Payam Tabrizi 11 SUPERIOR COURT OF THE STATE OF CALIFORNIA 12 FOR THE COUNTY OF SANTA CLARA 13 UNLIMITED JURISDICTION 14 15 16 17 18 19 20 21 22 23 24 25 26 ) ) PAYAMTABRIZI,M.D., ) ) Plaintiff, ) ) V. ) ) COUNTY OF SANT A CLARA d/b/a SANT A) CLARA VALLEY MEDICAL CENTER, ) CURT COMSTOCK, M.D., JEFFREY ) ARNOLD, M.D., and DOES 1-10 inclusive. ) ) Defendants. ) ) ) ) ) ) ) ____________ ) I, Sharon R. Vinick, declare as follows: Case No. 17 CV 317480 DECLARATION OF SHARON R. VINICK IN SUPPORT OF PLAINTIFF'S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO DEFENDANT COUNTY OF SANT A CLARA'S MOTION FOR PROTECTIVE ORDER Memorandum of Points and Authorities filed concurrently herewith Date: August 28, 2018 Time: 9:00 a.m. Dept.: 19 Judge: Hon. Peter Kirwan Complaint Filed: Trial Date: October 16, 2017 TBD 1. I am an attorney licensed to practice law before the courts of the State of 27 California and am employed as a partner at Levy, Vinick, Burrell, Hyams LLP. I am one of the 28 attorneys ofrecord for Plaintiff Payam Tabrizi, M.D. I have personal knowledge of all the DECLARATION OF SHARON R. VINICK ISO PLAINTIFF'S MPA IN OPPOSITION TO DEFENDANT COUNTY OF SANTA CLARA'S MOTION FOR PROTECTIVE ORDER; CASE NO. 17 CV 317480 Electronically Filed by Superior Court of CA, County of Santa Clara, on 8/17/2018 3:22 PM Reviewed By: L. Nguyen Case #17CV317480 Envelope: 1849181 1 matters set forth below, except those stated on information and belief, which I believe to be true, 2 and, if called upon to testify, could and would testify competently to those facts. 3 2. On November 21, 2017, I submitted a request for production of documents 4 seeking, inter alia, communications between Santa Clara Valley Medical Center ("SCVMC") 5 personnel that discussed Dr. Tabrizi. Attached as Exhibit 1 to my declaration is a true and correct 6 copy of Plaintiffs request for production. 7 3. On February 1, 2018, SCVMC produced an unredacted copy of an email dated 8 August 24, 2016, from Pauline Sanders, the Clinical Risk Manager of SCVMC, with the subject 9 line "Shadowing in the OR," and bates stamped as SCC001998-1999 ("Sanders' Email"). 10 4. On May 15, 2018, I received a letter from Defense counsel saying that 11 SCC001998-1999 had been inadvertently produced, that the document was protected by 12 attorney-client privilege, and that I should destroy it immediately. Additionally, Defense counsel 13 provided a supplemental privilege log with a redacted version of Sanders' Email re-produced at 14 SCC006170-6172, which indicates that the subject line of Sanders' email is "Shadowing in the 15 OR." Attached as Exhibit 2 to my declaration is a true and correct copy of SCC006170-6172. 16 5. On May 22, 2018, Defense counsel wrote again asserting the privilege. They 17 identified recipients Winifred Botha, Theresa Fuentes, Melissa Kiniyalocts, and Jennifer 18 Sprinkles as attorneys with County Counsel, but did not offer any individualized explanation of 19 who the remaining 23 non-attorney recipients were or why there were needed. 20 6. On page 7 of their supplemental privilege log, there is an email bates numbered 21 SCC006170-6172 and dated August 25, 2016, the redacted response to the Sanders' Email. In 22 the column headed "Privilege Type," the log identifies the document as protected by the 23 "Attorney Client Privilege." The "To" column identifying recipients indicates that the email 24 chain began with the Sanders' Email, which was originally sent from Pauline Sanders to Paul 25 Lorenz, with carbon copies sent to John Siegel, Kimberly Shepherd, Gina Bommarito, Dawn 26 Adams, Irma Alcaraz, Jeffrey Arnold, Winifred Botha, Carolyn Brown, Frances Calderon, Terry 27 Edmonson, Theresa Fuentes, Laura Elaine Glenn, Ofelia Hawk, Felicia Houston, Yvonne 28 Karanas, Melissa Kiniyalocts, Paul Lorenz, Sofia Menzies, Melissa Murphy, Alice Naqvi 2 DECLARATION OF SHARON R. VINICK ISO PLAINTIFF'S MPA IN OPPOSITION TO DEFENDANT COUNTY OF SANTA CLARA'S MOTION FOR PROTECTIVE ORDER; CASE NO. 17 CV 317480 1 Mugler, Andrew Nevitt, Phuong Nguyen, Paul Russell, Pauline Sanders, David Schoendaler, 2 Jennifer Sprinkles, Thomas W entzien, and Cynthia Ziebell. The next email in this chain is a 3 reply sent from Theresa Fuentes, attorney for County Counsel, to Paul Lorenz, without any 4 recipients copied. Next, Paul Lorenz replied to Theresa Fuentes, Pauline Sanders, Carolyn 5 Brown, Alice Naqvi Mugler, Terry Edmonson, John Siegel, Benita McLarin, and Adriana 6 Herrera. Last, John Siegel replies to Jeffrey Arnold. Attached as Exhibit 3 to my Declaration is a 7 true and correct copy of County' s Supplemental Privilege Log dated May 15, 2018. 8 7. On June 8, 2018, I completed an in-person inspection of the disputed documents 9 in their entirety at the Santa Clara County Counsel's Office in San Jose, California. 10 8. In the Declaration of Pauline Sanders in Support of Defendant County of Santa 11 Clara' s Motion for Protective Order ("Sanders Dec."), Sanders identifies, for the first time, the 12 title of each of the recipients in the disputed email. My understanding of the professional title of 13 each email recipient comes from the information contained in the Sanders Dec. 14 9. According to the Sanders Dec., Sanders' Email was concerning an incident in 15 which a high school student scrubbed into surgery while under the supervision of Plaintiff 16 Dr. Payam Tabrizi. This occurred while the student was participating in the SCVMC 1 7 Observership Program. 18 10. Defense counsel, to date, has not provided us with the job duties for each of the 19 recipients of Sanders' Email , or an individualized explanation of why each recipient would be 20 relevant, so I conducted additional research online to try to ascertain the recipients ' respective 21 job duties at SCVMC. 22 11. Among the recipients was Terry Edmonson, Director of Acute Psychiatric 23 Services for Nursing. According to SCVMC's website (www.scvmc.org), the Psychiatry 24 department does not offer any surgical services. Attached as Exhibit 4 to my declaration is a true 25 and correct copy of SCVMC' s website page listing Psychiatry's "Full List of Services." 26 12. Irma Alcaraz, R.N., Quality Improvement Manager oflnpatient Nursing, and 27 Melissa Murphy, R.N., Director of Medical Surgical Nursing, were also sent Sanders' Email. 28 Although they both have a supervisory role in a nursing department, neither appears to have a 3 DECLARATION OF SHARON R. VINICK ISO PLAINTIFF'S MP A IN OPPOSITION TO DEFENDANT COUNTY OF SANTA CLARA' S MOTION FOR PROTECTIVE ORDER; CASE NO. 17 CV 317480 1 role that would involve them in the operating room. On information and belief, "Medical 2 Surgical Nursing" is a broad term used to refer to treatment of adult patients in a hospital setting 3 but does not include participating in the operating room directly. Further, on infonnation and 4 belief, there are separate positions at SCVMC called the "Nurse Manager, Operating Room 5 Services," and the "Director of Nursing, Critical Care, Surgical Services and Administrative 6 Services," who report to the Director of Peri operative (surgical) Services. Neither of the people 7 who occupied those positions related to the operating room were included in Sanders ' Email. 8 Attached as Exhibit 5 to my declaration is a true and correct copy of SCVMC' s "PACU and 9 ASU Policy Manual" with an organizational chart including the Nurse Manager, Operating 10 Room Services and Director of Nursing, Critical Care, Surgical Services, and Administrative 11 Services. 12 13. Also among the recipients were Ofelia Hawk, Director of Ambulatory Quality an 13 Standards; Sonia Menzies, Director of Ambulatory Care and Community Health Services; and 14 Paul Russell , Medical Director of Ambulatory Care and Community Health Services. All three 15 people are employed in SCVMC' s Ambulatory Care department. On information and belief, 16 "ambulatory," in a medical context, refers to out-patient services. SCVMC' s outpatient clinic 17 does not list any surgical services on its website. Rather, it lists urgent care, obstetrics and 18 gynecology, pediatrics, comprehensive perinatal services, laboratory, and pharmacy. Attached 19 as Exhibit 6 hereto is a true and correct copy of SCVMC's website page listing SCVMC' s 20 outpatient clinic services. 21 14. On information and belief, based on my review of non-privileged documents in 22 the case, the surgery discussed in Sanders ' Email was a hip replacement surgery. On information 23 and belief, a hip replacement is a major in-patient procedure that replaces one ' s hip joint with a 24 prosthetic implant. 25 15. Yet another recipient of the Sanders Email was David Schoendaler, Liability 26 Claims Adjuster III. On information and belief, an insurance claims adjustor investigates 27 insurance claims once a claim has already been made; they are not attorneys, and, accordingly, 28 they cannot provide legal advice. Attached as Exhibit 7 hereto is a true and correct copy of Davi 4 DECLARATION OF SHARON R. VINICK ISO PLAINTIFF' S MPA IN OPPOSITION TO DEFENDANT COUNTY OF SANTA CLARA 'S MOTION FOR PROTECTIVE ORDER; CASE NO. 17 CV 317480 1 Schoendaler's job title according to Transparent California. 2 16. In analyzing the role of each of the individuals who received Sanders' Email, I 3 also referred to non-privileged documents describing the SCVMC Observership Program. The 4 document produced by SCVMC bearing the bates stamp SCC001935 has a list of departments in 5 which observership opportunities were available. This document also lists the name of the 6 Program Director of each participating department. I compared the names of the Program 7 Directors identified on SCCOOI 935 with the recipients of the Sanders' Email and determined that 8 none of the Program Directors identified on SCCOOI 935 received Sanders' Email. Attached as 9 Exhibit 8 hereto is a true and correct copy ofSCC001935. 10 17. Santa Clara Valley Medical Center had 4,578 employees in 2012. Attached as 11 Exhibit 9 hereto is a true and correct copy of Becker's Hospital Review of Santa Clara Valley 12 Medical Center identifying SCVMC's number of employees. 13 I declare under penalty of perjury, under the laws of the State of California, that the 14 foregoing is true and correct and that this declaration was executed on August 17th, 2018 at 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Oakland, California. SHARON R. VINICK 5 DECLARATION OF SHARON R. VINICK ISO PLAINTIFF'S MPA IN OPPOSITION TO DEFENDANT COUNTY OF SANTA CLARA'S MOTION FOR PROTECTIVE ORDER; CASE NO. 17 CV 317480 Exhibit 1 xhibit SHARON R. VINICK, ESQ., State Bar No. 129914 E-Mail: sharon@lcvyvinick.com 2 LESLIE F. LEVY, ESQ., State Bar No. 104634 E-Mail: leslie@levyvinick.com 3 LEVY VINICK BURRELL HY AMS LLP 180 Grand A venue, Suite 1300 4 Oakland, CA 94612 Tel.: (510) 318-7700 5 Fax: (510) 318-7701 6 SUPREET A SAMPA TH, ESQ., State Bar No. 232190 E-Mail: supreeta@sampathlaw.com 7 THE SAMPATH LAW FIRM 351 California Street, Suite 700 8 San Francisco, CA 94104 Tel.: (415) 231-5855 9 Fax: (415) 202-6467 IO Attorneys for Plaintiff Dr. Payam Tabrizi 11 12 13 14 SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SANTA CLARA UNLIMITED JURISDICTION 15 PAYAMTABRIZI,M.D., 16 17 v. Plaintiff, 18 COUNTY OF SANTA CLARA, d/b/a SANTA CLARA VALLEY MEDICAL 19 CENTER, CURT COMSTOCK, M.D., JEFFREY ARNOLD, M.D., and DOES 1-10, 20 inclusive, Defendants. ) Case No. 17 CV 317480 ) ) PLAINTIFF DR. PAYAM TABRIZI'S ) REQUEST FOR PRODUCTION OF ) DOCUMENTS, SET ONE, TO ) DEFENDANT COUNTY OF SANTA ) CLARA ) ) Complaint Filed: October 16, 2017 ) Trial Date: TBD ) ) ) 21 22 ____________ ) 23 PROPOUNDING PARTY: PLAINTIFF DR. PAY AM TABRIZ! 24 RESPONDING PARTY: 25 SETNO.: DEFENDANT COUNTY OF SANTA CLARA ONE 26 27 TO DEFENDANT COUNTY OF SANTA CLARA: Pursuant to California Code of Civil Procedure§§ 2031.010 et seq., Plaintiff Dr. 28 PAY AM T ABRIZI ("Plaintiff') requests Defendant COUNTY OF SANT A CLARA I PLAINTIFF DR. PAY AM T ABRIZI'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE. TO DEFENDANT COUNTY OF SANTA CLARA; CASE NO. 17 CV 317480 1 ("Defendant") to produce and permit the inspection, copying and/or photocopying of the 2 documents or tangible things designated below. 3 Inspection shall be a personal inspection, including the copying of the below-mentioned 4 documents, by Plaintiff and Plaintiffs attorney of record at 10:00 a.m. thirty days from the date 5 this demand is served, at the offices of LEVY VINICK BURRELL HY AMS LLP, 180 6 Grand Avenue, Suite 1300, Oakland, CA 94612. ln the alternative, Defendant may mail said 7 documents to Plaintiff's attorney's office at the above address within the same time period. 8 DEFINITIONS 9 The following definitions apply throughout this request for production, unless the context 10 clearly indicates otherwise. 11 12 1. 2. "ARNOLD" refers to Defendant Dr. Jeffrey Arnold. "COMMUNICATION" means any document reflecting an exchange of thoughts, 13 opinions, or infonnation including handwriting, typewriting, e-mail, text messages, telephone 14 messages, voicemail, tape-recording, digital recording and every other means of recording upon 15 any tangible thing, including ESL 16 3. "COMPLAINT" refers to PLAINTIFF's most recently filed complaint in the 17 instant case. 18 19 4. 5. "COMSTOCK" refers to Defendant Dr. Curt Comstock. "CONCERN" or "CONCERNING" means to embody, pertain to, consist of, 20 constitute, contain, reflect, identify, state, deal with, comprise, discuss, or in any way be 21 pertinent to the referenced subject matter. 22 23 6. 7. "CRAWLEY'' refers to Vernon Crawley who works for the EOD. "DEFENDANT" or "SCVMC" means County of Santa Clara, dba Santa Clara 24 Valley Medical Center. 25 8. "DOCUMENT" or "DOCUMENTS" means any writing, as defined in California 26 Evidence Code section 250, or any other tangible or intangible thing in defendant's custody, 27 possession or control or known to defendant, whether printed, recorded, reproduced by any 28 process, or written or produced by hand, or created or maintained in electronic form, including 2 PLAINTIFF DR. PAY AM T ABRIZI'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, TO DEFENDANT COUNTY OF SANT A CLARA; CASE NO. 17 CV 317480 all metadata associated with any such electronic writings, including but not limited to charges, 2 complaints, claims, affidavits, declarations, statements, letters, reports, employee records, 3 agreements, communications, correspondence, memorandum, telephone records, publications, 4 manuals, diagrams, telegrams, summaries, records of personal conversations, e-mail, voice mail, 5 calendars, appointment books, logs, brochures, pamphlets, opinions or reports of consultants, 6 graphs of any DOCUMENTS, revisions or graphs of any DOCUMENTS, invoices, receipts, 7 computer data, tapes, cassettes, disks, magnetic cards, audio or video recordings, and original or 8 preliminary notes. The term DOCUMENT shall include the file folders in which the 9 DOCUMENT is maintained. In addition, the term DOCUMENT shall include copies of any 10 infonnation set forth on the surface of any box, file folder, or other container in which the 11 document is maintained, all labels and notes set forth or attached to the interior or exterior 12 thereof, and all other information describing or facilitating the organization of such 13 DOCUMENTS, including but not limited to indices. Any electronic or computer record or file 14 containing all or part of the information that forth in any DOCUMENT, and any DOCUMENTS 15 containing any comment, notation, addition, deletion, insertion or marketing of any kind, which 16 is not part of another document, is to be considered a separate DOCUMENT. 17 18 9. 10. "EOD" refers to the Equal Opportunity Division of Santa Clara County. "ESI" means any information or DOCUMENTS on operational systems including 19 accounting, financial, distribution, or manufacturing systems; e-mail; Instant Messages (IM); 20 html files; Web pages; text messages; cell phone data; Excel spreadsheets and underlying 21 formulae; metadata; data processing cards or tapes, computerized data, computer diskettes, or 22 infonnation otherwise contained on a computer's hard drive, disks or backup tape; computer 23 databases (i.e., Access); erased, fragmented, or damaged data; Blackberry data; and anything 24 stored on computer or other electronic means located on or in, but not limited to, cache memory; 25 optical disks; magnetic tapes/back-up tapes; PDAs, Blackberries and iPhones; cell phones; IM 26 tools; USB drives, or other media. 27 11. "EMT" refers to an individual who has trained, or is in training, as an Emergency 28 Medical Technician. 3 PLAINTIFF DR. PAY AMT ABRlZI'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, TO DEFENDANT COUNTY OF SANT A CLARA; CASE NO. 17 CV 317480 12. The term "IDENTIFY," when used in reference to a person, means provide the 2 individual's name, job title, address, and telephone number. 3 13. "JAIL CLINIC" refers to any clinic operated or staffed by SCVMC that is located 4 in a jail including but not limited to clinics located in the Elmwood Correctional Facility in 5 Milpitas, the Juvenile Detention Center in downtown San Jose, and the Main Jail in downtown 6 San Jose. 7 14. The term "METADATA" means the data found within DOCUMENTS. It 8 includes all electronically-stored information that describes or defines the DOCUMENT that is 9 not generally visible in the ordinary electronic display or printing of the document. Common l O examples include comments, markups and revisions, author name, owner name, names of those 11 who have edited the document, creation dates, edit dates, and other information, including but 12 not limited to records of past versions and drafts. 13 15. The term "NATIVE FORMA r' as it relates to the production of electronic data 14 means the file format in which the DOCUMENT is ordinarily read and written by its related 15 software application. For example, a Microsoft Word 2003 document has a NATIVE FORMAT 16 of .doc. 17 16. "NGUYEN" refers to Dr. Phoung Nguyen, who was the Medical Staff President 18 for SCVMC. 19 17. "PERSON" or "PERSONS" means any natural person, proprietorship, joint 20 venture, partnership, trust, business trust, syndicate, association, joint stock company, 21 corporation, limited liability company, or any other organization, whether incorporated or 22 unincorporated. 23 18. "PERSONNEL FILE" means any and all records maintained either in the normal 24 course of business or for any special purpose with respect to the application, course of 25 employment, and tennination of any employee of DEFENDANT and specifically includes 26 applications, disciplinary notice, perfonnance evaluations, employment histories or summaries, 27 records of residential addresses and telephone numbers, termination notices, job assignment or 28 classification records, personnel action notices, compensation and other similar records. For 4 PLAJNTIFF DR. PAY AM T ABRIZI ' S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, TO DEFENDANT COUNTY OF SANTA CLARA; CASE NO. 17 CV 317480 1 purposes of this request, the term "personnel record" ·need not include records of medical 2 benefits, condition, or claims; designations of, or changes in, beneficiary; garnishments; income 3 tax records; or insurance benefits, except as pertaining to the records of the Plaintiff (in which 4 case such records are to be included). Nothing in this request shall be construed to require or 5 authorize the Responding Party or its attorneys to obtain medical infonnation or documents from 6 Defendant's workers' compensation administrator or insurer (whether self-insured or not). 7 Plaintiff does not waive her right to privacy in any and all such information, nor does Plaintiff 8 consent to Defendant seeking or obtaining such information from any source documents 9 protected by the California Confidentiality of Medical Information Act. 10 11 19. 20. ,tPLAINTIFF" or "TABRIZ!" means Plaintiff Dr. Payam Tabrizi. "REGARDING," "REFER TO," "REFERS TO," "RELATE TO," "RELATES 12 TO," "RELATING," "RELATED TO," and "RELATING TO" mean and include the having of 13 any logical or factual connection, directly or indirectly, with a matter discussed, and shall mean 14 and include any one or more of the following: constituting, evidencing, referring to, discussing, 15 describing, concerning, mentioning, reflecting, depicting, summarizing, involving, regarding, 16 embodying, containing, consisting of, pertaining to in any way, arising out of, or being in 17 connection with that subject. 18 21. "YOU," "YOUR," or "THE COUNTY" refers to Defendant County of Santa 19 Clara and its divisions, departments, branches and facilities. 20 INSTRUCTIONS 21 The following instructions apply throughout this request for production, unless the 22 context clearly indicates otherwise: 23 1. This request requires that Defendant produce all documents responsive to any of 24 the following numbered requests which are in Defendant's possession or control or subject to 25 Defendant's possession or control, wherever they may be located. The documents which 26 Defendant must identify and produce include not only documents which Defendant's presently 27 possesses, but also documents which are in the possession or control of Defendant's attorneys, 28 accountants, bookkeepers, employees, representatives, or anyone else acting on Defendant's 5 PLAINTIFF DR. p A y AM T ABRTZrs REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE. TO DEFENDANT COUNTY OF SANT A CLARA; CASE NO. 17 CV 317480 behalf. 2 2. All documents that are responsive in whole or in part to any of the following 3 numbered requests shall be produced in full, without abridgment, abbreviation or expurgation of 4 any sort. If any such documents cannot be produced in full, produce the writing to the extent 5 possible and indicate in your written response what portion of the document is not produced and 6 why it could not be produced. 7 3. Whenever a Document demand is framed in the conjunctive, it shall also be taken 8 in the disjunctive. 9 4. Whenever a Document demand is framed in the singular, it shall also be taken in IO the plural. 11 5. The specificity of any one particular Document demand sha11 not be construed to 12 reduce the scope of any generalized Document demand. 13 14 6. 7. Documents attached to each other should not be separated. Produce, where possible, originals of the documents files requested, whether 15 signed or unsigned. Produce all prior drafts, as well as the final form, of all documents. Produce 16 each and every copy where such copy contains any commentary or notation that does not appear 17 on the original or final version. 18 8. Each request contained herein extends to all Documents in Defendant's 19 possession, custody, or control. 20 9. For all documents maintained in electronic form (ESI), this request requires that 21 the Responding Party produce the information, in their native format(s) (e.g. infonnation created 22 in Excel format, must be produced in Excel format (.xis) with underlying formulae and metadata 23 intact). If, in the regular c-0urse of business, the information is maintained in an un-readable 24 form or reviewing would require proprietary or legacy software, the ESI may be translated into 25 usable form and produced in a searchable Portable Document Format (PDF) with intact fields for 26 date, author, origin, creation, modification and other information obtainable from the original 27 electronic files. Any request for e-mail or other ESI communication does not include SPAM, 28 bulk mail, junk mail or other disruptive online messages, including advertising messages sent as 6 PLAINTIFF DR. PAY AM T ABRlZI'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, TO DEFENDANT COUNTY OF SANT A CLARA; CASE NO. 17 CV 317480 2 3 e-mail or other unsolicited or untargeted communication advertising goods or services. 12. 13. Please bates-stamp all Documents produced. Nothing in this request authorizes Defendant to obtain infonnation protected by 4 the California Confidentiality of Medical Information Act and/or information from the worker's 5 compensation medical files of the worker's compensation insurance carrier or third party 6 administrator for Defendant. 7 14. If any Document is withheld under a claim of privilege or other protection, please 8 produce a privilege log and provide all the following infonnation with respect to any such 9 Document, so as to aid the Court and the parties hereto in determining the validity of the claim o 10 privilege or other protection: 11 12 13 14 15 16 17 18 19 20 21 22 23 a. The identity of the person(s) who prepared the Document and who signed the Document, and over whose name it was sent or issued; b. C. The identity of the pcrson(s) to whom the Document was directed; The nature and substance of the Document, with sufficient particularity to enable the Court and the parties thereto to identify the document; d. The date of the Document; e. The identity of the person(s) who has (have) custody of, or control over, the Document and each copy thereof; f. furnished; g. h. 1. The identity of each person to whom a copy of the Document was The number of pages of the Document; The basis on which any privilege or other protection is claimed; Whether any non-privileged or non-protected matter is included in 24 the Document. 25 REQUESTS FOR PRODUCTION OF DOCUMENTS 26 REQUEST FOR PRODUCTJON NO. 1: 27 The complete contents of PLAINTIFF's personnel file, including but not limited to 28 personnel records used to detennine PLAINTIFF's qualifications for employment, disciplinary 7 PLAINTIFF DR. PAY AM T ABRIZJ'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, TO DEFENDANT COUNTY OF SANT A CLARA; CASE NO. 17 CV 317480 action and tennination. 2 REQUEST FOR PRODUCTION NO. 2: 3 The complete contents of any files, other than his personnel file, maintained in 4 PLAINTIFF's name by DEFENDANT. 5 REQUEST FOR PRODUCTION NO. 3: 6 All DOCUMENTS that CONCERN or RELATE to PLAINTIFF'sjob performance while 7 employed by DEFENDANT, including but not limited to perfonnance appraisals or evaluations 8 (whether written or oral, whether formal or informal), commendations, awards, bonuses, and/or 9 letters of thanks, recognition, disciplinary actions, or any other similar DOCUMENTS. IO REQUEST FOR PRODUCTION NO. 4: 11 All DOCUMENTS that DESCRIBE, CONCERN or RELATE to any complaint 12 regarding PLAINTIFF's job perfonnance while employed by DEFENDANT, including but not 13 limited to complaints made by other medical professionals employed by SCVMC and/or patients 14 ofSCVMC. 15 REQUEST FOR PRODUCTION NO. 5: 16 All DOCUMENTS that DESCRIBE, CONCERN or RELATE to any complaint 17 regarding PLAINTIFF's job perfonnance while employed by DEFENDANT, including but not 18 limited to complaints made by other medical professionals employed by SCVMC and/or patients 19 of SCVMC, excluding any documents that are covered by, or constitute, peer review 20 proceedings. 21 REQUEST FOR PRODUCTION NO. 6: 22 All DOCUMENTS that constitute, CONCERN, REFLECT, RELATE or REFER to any 23 disciplinary action, or performance improvement plan, given or issued to PLAINTIFF. 24 REQUEST FOR PRODUCTION NO. 7: 25 All DOCUMENTS that constitute, CONCERN, REFLECT, RELATE or REFER to any 26 concerns, problems or deficiencies with respect to PLAINTIFF's perfonnance. 27 REQUEST FOR PRODUCTION NO. 8: 28 All DOCUMENTS that mention, refer, or relate to criteria, standards, or other 8 PLAINTJFF DR. PAY AMT ABRlZI'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, TO DEFENDANT COUNTY OF SANT A CLARA; CASE NO. 17 CV 317480 1 performance metrics used to evaluate PLATNTJFF's performance. 2 REQUEST FOR PRODUCTION NO. 9: 3 All DOCUMENTS used, considered, reviewed, read or relied upon in deciding to 4 terminate PLAINTIFF's employment. 5 REQUEST FOR PRODUCTION NO. 10: 6 All DOCUMENTS that reflect or CONCERN the reasons why PLAINTIFF was 7 terminated. 8 REQUEST FOR PRODUCTION NO. 11: 9 For the period January 1, 2012 to the present, all DOCUMENTS that CONCERN or 10 RELATE to employee manuals, employee handbooks, policy manuals, personnel policies, 11 procedures, rules, guidelines, standards, directives, or similar DOCUMENTS, that were 12 applicable to PLAINTIFF' s employment. (If individual documents are produced from a 13 handbook, manual or similar compilation, please include a copy of the cover page or similar 14 document that indicates the source from which the individual document was taken, as well as a 15 copy of the Table of Contents.) 16 REQUEST FOR PRODUCTION NO. 12: l 7 For the period January 1, 2012 to the present, all DOCUMENTS that CONCERN or 18 RELATE to any Memorandum of Understanding that was applicab]e to PLAINTIFF's 19 employment. 20 REQUEST FOR PRODUCTION NO. 13: 21 For the period January 1, 2012 to the present, all DOCUMENTS that CONCERN or 22 RELATE to YOUR adoption or implementation of a "Just Culture" model or initiative, 23 including any policies, procedures, rules, guidelines, standards, directives, or similar 24 DOCUMENTS that RELATE to your adoption or implementation of a "Just Culture" model or 25 initiative. 26 REQUEST FOR PRODUCTION NO. 14: 27 For the period January 1, 2012 to the present, all DOCUMENTS that CONCERN or 28 RELATE to any policies, rules or regulations of SCVMC that CONCERN or RELATE to 9 PLAINTIFF DR. PAY AMT ABRIZI'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, TO DEFENDANT COUNTY OF SANT A CLARA; CASE NO. 17 CV 317480 1 discrimination, harassment or retaliation, including but not limited to policies that CONCERN 2 or RELATE to reporting and investigating allegations of discrimination, harassment or 3 retaliation. 4 REQUEST FOR PRODUCTION NO. 15: 5 For the period January 1, 2012 to the present, all DOCUMENTS that CONCERN or 6 RELATE to any training for employees of SCVMC that CONCERN or RELATE to 7 discrimination, harassment or retaliation. 8 REQUEST FOR PRODUCTION NO. 16: 9 For the period January I, 2010 to the present, all DOCUMENTS that CONCERN or 10 RELATE to any training given to COMSTOCK that CONCERN or RELATE to discrimination, 11 harassment or retaliation, including but not limited to the results of any tests that COMSTOCK 12 took in conjunction with such training. 13 REQUEST FOR PRODUCTION N0.17: 14 For the period January 1, 2012 to the present, all DOCUMENTS, including but not 15 limited to organizational charts or graphs, that CONCERN or RELATE to PLAINTlFF's 16 position(s) while employed by DEFENDANT, including but not limited to those showing or 17 explaining the chain of authority above and below PLAINTIFF. 18 REQUEST FOR PRODUCTION NO. 18: 19 For the period January l, 2000 to the present, all DOCUMENTS that describe, 20 CONCERN, REFER, or RELATE to any rules, regulations, or policies concerning or regarding 21 . any observership program operated for, or by, SCVMC, including any revisions, updates or 22 changes in such rules, regulations or policies. 23 REQUEST FOR PRODUCTION NO. 19: 24 For the period January 1, 2007 to the present, all DOCUMENTS that IDENTIFY any 25 person who applied for, and was accepted into, any observership program operated for, or by, 26 SCVMC. 27 REQUEST FOR PRODUCTION NO. 20: 28 For the period January 1, 2007 to the present, all DOCUMENTS that IDENTIFY any 10 PLAINTIFF DR. PAY AMT ABRIZI'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, TO DEFENDANT COUNTY OF SANT A CLARA; CASE NO. 17 CV 317480 1 person who participated as an observer in any observership program operated for, or by, 2 SCVMC. 3 REQUEST FOR PRODUCTION NO. 21: 4 For the period January 1, 2007 to the present, all DOCUMENTS that IDENTIFY any 5 person who observed any surgical procedures during their participation in any observership 6 program operated for, or by, SCVMC. 7 REQUEST FOR PRODUCTION NO. 22: 8 For the period January 1, 2007 to the present, all DOCUMENTS that IDENTIFY any 9 physician or employee of SCVMC who supervised any person who observed any surgical 10 procedures during their participation in any observership program operated for, or by, SCVMC. l 1 REQUEST FOR PRODUCTION NO. 23: 12 For the period January 1, 2007 to the present, all DOCUMENTS that CONCERN, 13 REFER, or RELATE to any investigation into any violation of any rules, regulations, or policies 14 that RELATE or REFER to any observership program operated for, or by, SCVMC. 15 REQUEST FOR PRODUCTION NO. 24: 16 For the period January 1, 2007 to the present, all DOCUMENTS that describe, 17 CONCERN, REFER, or RELATE to any rules, regulations, or policies concerning or regarding 18 any program operated for, or by, SCVMC, which permits or facilitates the training of EMTs by 19 anesthesiologists employed by YOU, including any revisions, updates or changes in such rules, 20 regulations or policies. 21 REQUEST FOR PRODUCTION NO. 25: 22 For the period January 1, 2007 to the present, all DOCUMENTS that IDENTIFY any 23 person who participated as an EMT in any program operated for, or by, SCVMC, which permits 24 or facilitates the training ofEMTs by anesthesiologists employed by YOU. 25 REQUEST FOR PRODUCTION NO. 26: 26 For the period January 1, 2007 to the present, all DOCUMENTS that IDENTIFY any 27 doctor employed by YOU who supervised any person who participated as an EMT in any 28 program operated for, or by, SCVMC, which permits or facilitates the training of EMTs by 11 PLAINTIFF DR. PAY AM T ABRJZl'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, TO DEFENDANT COUNTY OF SANT A CLARA; CASE NO. 17 CV 317480 1 anesthesiologists employed by YOU. 2 REQUEST FOR PRODUCTION NO. 27: 3 For the period January 1, 2007 to the present, all DOCUMENTS that CONCERN, 4 REFER, or RELATE to any investigation into any violation of any rules, regulations, or policies 5 that relate or refer to any program operated for, or by, SCVMC, which permits or facilitates the 6 training of EMTs by anesthesiologists employed by YOU. 7 REQUEST FOR PRODUCTION NO. 28: 8 For the period January 1, 2007 to the present, all DOCUMENTS that DESCRIBE, 9 CONCERN or RELATE to any complaint regarding COMSTOCK, including but not limited to 10 complaints made by other medical professionals employed by SCVMC and/or patients of 11 SCVMC. 12 REQUEST FOR PRODUCTION NO. 29: 13 For the period January 1, 2007 to the present, all DOCUMENTS that DESCRIBE, 14 CONCERN or RELATE to any complaint that COMSTOCK made inappropriate comments or 15 remarks, including but not limited to racist, sexist or culturally insensitive comments or remarks. 16 REQUEST FOR PRODUCTION NO. 30: 17 For the period January I, 2007 to the present, all DOCUMENTS that DESCRIBE, 18 CONCERN or RELATE to any complaint that COMSTOCK assaulted a patient, including but 19 not limited to Lynne Brune. (With the exception of Ms. Brune, Plaintiff has no objection to the 20 redaction of patient identifying information.) 21 REQUEST FOR PRODUCTION NO. 31: 22 For the period January 1, 2007 to the present, all DOCUMENTS that DESCRIBE, 23 CONCERN or RELATE to any complaint that COMSTOCK harassed a patient. (With the 24 exception of Ms. Brune, Plaintiff has no objection to the redaction of patient identifying 25 information.) 26 REQUEST FOR PRODUCTION NO. 32: 27 For the period January 1, 2007 to the present, a11 DOCUMENTS that DESCRIBE, 28 CONCERN or RELATE to any investigation conducted by, or on behalf of, DEFENDANT 12 PLAINTIFF DR. PAY AM T ABRIZI'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, TO DEFENDANT COUNTY OF SANTA CLARA; CASE NO. 17 CV 317480 regarding or concerning any complaint about COMSTOCK, including but not but not limited to 2 complaints that he made inappropriate comments or harassed patients. (With the exception of 3 Ms. Brune, Plaintiff has no objection to the redaction of patient identifying information.) 4 REQUEST FOR PRODUCTION NO. 33: 5 All DOCUMENTS that DESCRIBE, CONCERN or RELATE to any lawsuit filed 6 against SCVMC that relates to or concerns the conduct of COMSTOCK, including but not 7 limited to any lawsuit alleging harassment. 8 REQUEST FOR PRODUCTION NO. 34: 9 All DOCUMENTS that DESCRIBE, CONCERN or RELATE to any discipline imposed 10 by DEFENDANT on COMSTOCK on account of, or in response to, any complaint that he made 11 inappropriate comments or harassed patients or assaulted patients. 12 REQUEST FOR PRODUCTION NO. 35: 13 All DOCUMENTS that DESCRIBE, CONCERN or RELATE to any complaint that 14 COMSTOCK engaged or participated in inappropriate or improper billing practices. 15 REQUEST FOR PRODUCTION NO. 36: 16 All COMMUNICATIONS sent or received by COMSTOCK that DESCRIBE, 17 CONCERN or RELATE to any complaint that COMSTOCK engaged or participated in 18 inappropriate or improper billing practices. 19 REQUEST FOR PRODUCTION NO. 37: 20 All COMMUNICATIONS sent or received by ARNOLD that DESCRIBE, CONCERN 21 or RELATE to any complaint that COMSTOCK engaged or participated in inappropriate or 22 improper billing practices. 23 REQUEST FOR PRODUCTION NO. 38: 24 All COMMUNICATIONS sent or received by NGUYEN that DESCRIBE, CONCERN 25 or RELATE to any complaint that COMSTOCK engaged or participated in inappropriate or 26 improper billing practices. 27 REQUEST FOR PRODUCTION NO. 39: 28 All DOCUMENTS that DESCRIBE, CONCERN or RELATE to any investigation 13 PLAINTIFF DR. PAY AMT ABRIZI'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, TO DEFENDANT COUNTY OF SANT A CLARA; CASE NO. 17 CV 317480 1 conducted by, or on behalf of, DEFENDANT REGARDING or CONCERNING any complaint 2 that COMSTOCK engaged or participated in inappropriate or improper billing practices. 3 REQUEST FOR PRODUCTION NO. 40: 4 All DOCUMENTS that DESCRIBE, CONCERN or RELATE to any complaint made by 5 T ABRIZI regarding COMSTOCK, including but not limited to complaints that he made racist, 6 sexist or culturally insensitive remarks, or that he engaged in inappropriate or improper billing 7 practices. 8 REQUEST FOR PRODUCTION NO. 41: 9 All DOCUMENTS that DESCRIBE, CONCERN or RELATE to any investigation 10 conducted by, or on behalf of, DEFENDANT REGARDING or 'CONCERNING any complaint 11 made by T ABRIZI regarding COMSTOCK, including but not limited to complaints that he made 12 racist, sexist or culturally insensitive remarks, or that he engaged in inappropriate or improper 13 billing practices. 14 REQUEST FOR PRODUCTION NO. 42: 15 All DOCUMEN!S that DESCRIBE, CONCERN or RELATE to any complaint made by 16 TABRIZ! to the EOD. 17 REQUEST FOR PRODUCTION NO. 43: 18 All DOCUMENTS that DESCRIBE, CONCERN or RELATE to any investigation 19 conducted by, or on behalf of, DEFENDANT REGARDING or CONCERNING any complaint 20 made by T ABRIZI to the EOD. 21 REQUEST FOR PRODUCTION NO. 44: 22 All DOCUMENTS that DESCRIBE, CONCERN or RELATE to any discipline imposed 23 011 COMSTOCK on account of, or in response to, any complaint made by T ABRIZI 24 REGARDING COMSTOCK, including but not limited to complaints made by T ABRIZI to the 25 EOD. 26 REQUEST FOR PRODUCTION NO. 45: 27 All DOCUMENTS that DESCRIBE, CONCERN or RELATE to any complaint or claim 28 made by T ABRIZI that he was terminated in retaliation for complaining about harassment and/or 14 PLAINTIFF DR. PAY AM TABRIZI'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, TO DEFENDANT COUNTY OF SANT A CLARA; CASE NO. 17 CV 317480 1 retaliation. 2 REQUEST FOR PRODUCTION NO. 46: 3 All DOCUMENTS that DESCRIBE, CONCERN or RELATE to any investigation 4 conducted by, or on behalf of, DEFENDANT REGARDING or CONCERNING any complaint 5 or claim made by T ABRIZI that he was tenninated in retaliation for complaining about 6 harassment and/or retaliation. 7 REQUEST FOR PRODUCTION NO. 47: 8 The complete EOD file relating to each and every complaint filed by T ABRIZI with 9 EOD. 10 REQUEST .FOR PRODUCTION NO. 48: 11 All COMMUNICATIONS sent or received by COMSTOCK that DESCRIBE, 12 CONCERN, RELATE or REFER to any complaint made by TABRIZI to the EOD. 13 REQUEST FOR PRODUCTION NO. 49: 14 All COMMUNICATIONS sent or received by ARNOLD that DESCRIBE, CONCERN, 15 RELATE or REFER to any complaint made by T ABRIZI to the EOD. 16 REQUEST FOR PRODUCTION NO. 50: 17 All COMMUNICATIONS sent or received by NGUYEN that DESCRIBE, CONCERN, 18 RELATE or REFER to any complaint made by T ABRIZI to the EOD. 19 REQUEST FOR PRODUCTION NO. 51: 20 All COMMUNICATIONS sent or received by CRAWLEY that DESCRIBE, 21 CONCERN, RELATE or REFER to any complaint made by TABRIZI to the EOD. 22 REQUEST FOR PRODUCTION NO. 52: 23 For the period January 1, 2014 to the present, all COMMUNICATIONS between 24 COMSTOCK and ARNOLD REGARDING, RELATING TO, or CONCERNING TABRIZ!. 25 REQUEST FOR PRODUCTION NO. 53: 26 For the period January l, 2014 to the present, all COMMUNICATIONS between 27 COMSTOCK and NGUYEN REGARDING, RELATING TO, or CONCERNING T ABRIZI. 28 // 15 PLAJNTIFF DR. PAY AM T ABRIZI'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, TO DEFENDANT COUNTY OF SANT A CLARA; CASE NO. 17 CV 317480 1 REQUEST FOR PRODUCTION NO. 54: 2 For the period January 1, 2014 to the present, all COMMUNICATIONS between 3 ARNOLD and NGUYEN REGARDING, RELATING TO, or CONCERNING TABRIZI. 4 REQUEST FOR PRODUCTION NO. 55: 5 For the period January 1, 2014 to the present, all COMMUNICATIONS between 6 ARNOLD and Dr. Jeffrey Kryger REGARDING, RELATING TO, or CONCERNING 7 TABRIZ!. 8 REQUEST FOR PRODUCTION NO. 56: 9 For the period January 1, 2014 to the present, a11 COMMUNICATIONS between 10 ARNOLD and Dr. Jeffrey Smith REGARDING, RELATING TO, or CONCERNING TABRIZI. 11 REQUEST FOR PRODUCTION NO. 57: 12 For the period January 1, 2014 to the present, all COMMUNICATIONS between 13 COMSTOCK and Dr. Jeffrey Kryger REGARDING, RELATING TO, or CONCERNING 14 TABRIZ!. 15 REQUEST FOR PRODUCTION NO. 58: 16 For the period January 1, 2014 to the present, all COMMUNICATIONS between 17 COMSTOCK and Dr. Jeffrey Smith REGARDING, RELATING TO, or CONCERNING 18 TABRIZ!. 19 REQUEST FOR PRODUCTION NO. 59: 20 For the period January l, 2014 to the present, al1 COMMUNICATIONS between 21 COMSTOCK and Dr. William Maloney REGARDING, RELATING TO, or CONCERNING 22 TABRIZI. 23 REQUEST FOR PRODUCTION NO. 60: 24 All DOCUMENTS that REFLECT, DESCRIBE, CONCERN or RELATE to any 25 compensation paid to TABRIZ! for working in any JAIL CLINIC. 26 REQUEST FOR PRODUCTION NO. 61: 27 All DOCUMENTS that DESCRIBE, CONCERN or RELATE to any investigation 28 conducted by, or on behalf of, DEFENDANT REGARDING or CONCERNING TABRIZI 16 PLAINTIFF DR. PAY AMT ABRIZI 'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, TO DEFENDANT COUNTY OF SANT A CLARA; CASE NO. 17 CV 317480 receiving compensation for working in any JAIL CLINIC. 2 REQUEST FOR PRODUCTION NO. 62: 3 For the period January 1, 2010 to the present, all DOCUMENTS that DESCRIBE, 4 CONCERN or RELATE to rules or regulations CONCERNING payment to doctors who are 5 employed by SCVMC and who work in any JAIL CLINIC. 6 REQUEST FOR PRODUCTION NO. 63: 7 For the period January 1, 2010 to the present, all DOCUMENTS that DESCRIBE, 8 CONCERN or RELATE to any decision to pay, or cease paying, TABRIZI for working in any 9 JAIL CLINIC. 10 REQUEST FOR PRODUCTION NO. 64: 11 All COMMUNICATIONS sent or received by COMSTOCK that DESCRIBE, 12 CONCERN or RELATE to any decision to pay, or cease paying, TABRIZI for working in any 13 JAIL CLINIC. 14 REQUEST FOR PRODUCTION NO. 65: 15 All COMMUNICATIONS sent or received by ARNOLD that DESCRIBE, CONCERN 16 or RELATE to any decision to pay, or cease paying, TABRIZ! for working in any JAIL CLINIC. 17 REQUEST FOR PRODUCTION NO. 66: 18 All COMMUNICATIONS sent or received by T ABRIZI that DESCRIBE, CONCERN 19 or RELATE to any decision to pay, or cease paying, T ABRIZI for working in any JAIL CLINIC. 20 REQUEST FOR PRODUCTION NO. 67: 21 All DOCUMENTS that DESCRIBE, CONCERN or RELATE to any decision by 22 COMSTOCK to remove T ABRIZI from the role of setting, or creating, any call schedule for the 23 orthopedic department, including but not limited to any holiday call schedule. 24 REQUEST FOR PRODUCTION NO. 68: 25 All COMMUNICATIONS sent or received by COMSTOCK that DESCRIBE, 26 CONCERN or RELATE to any decision by COMSTOCK to remove TABRIZ! from the role of 27 setting, or creating, any call schedule for the orthopedic department, including but not limited to 28 the holiday caB schedule. 17 PLAINTIFF DR. PAY AM T ABRIZI'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, TO DEFENDANT COUNTY OF SANT A CLARA; CASE NO. 17 CV 317480 1 REQUEST FOR PRODUCTION NO. 69: 2 All DOCUMENTS that CONCERN or RELATE to PLAINTIFF's complaint to the 3 Equal Employment Opportunity Commission ("EEOC"), including but not limited to any 4 investigation thereof. 5 REQUEST FOR PRODUCTION NO. 70: 6 For the period January 1, 2012 to the present, all DOCUMENTS that CONCERN or 7 RELATE to any complaints made to the Department of Fair Employment and Housing 8 ("DFEH") constituting, describing, alleging or CONCERNING complaints of harassment, 9 discrimination or retaliation by DEFENDANT. 10 REQUEST FOR PRODUCTION NO. 71: 11 For the period January 1, 2012 to the present, all DOCUMENTS that CONCERN or 12 RELATE to any complaints made to the EEOC constituting, describing, alleging or 13 CONCERNING complaints of harassment, discrimination or retaliation by DEFENDANT. 14 REQUEST FOR PRODUCTION NO. 72: 15 For the period January 1, 2012 to the present, all DOCUMENTS that CONCERN or 16 RELATE to any lawsuits filed in any federal or state court in the United States of America 17 against DEFENDANT that contain or assert claims for harassment, discrimination or retaliation 18 by DEFENDANT. 19 REQUEST FOR PRODUCTION NO. 73: 20 For the period January 1, 2012 to the present, all DOCUMENTS that CONCERN or 21 RELATE to any complaints made to the DFEH constituting, describing, alleging or 22 CONCERNING complaints of harassment, discrimination or retaliation allegedly committed by, 23 or engaged in by, COMSTOCK. 24 REQUEST FOR PRODUCTION NO. 74: 25 For the period January 1, 2012 to the present, all DOCUMENTS that CONCERN or 26 RELATE to any complaints made to the EEOC constituting, describing, alleging or 27 CONCERNING complaints of harassment, discrimination or retaliation allegedly committed by, 28 or engaged in by COMSTOCK. 18 PLAINTIFF DR. PAY AMT ABRIZl'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, TO DEFENDANT COUNTY OF SANT A CLARA; CASE NO. 17 CV 317480 REQUEST FOR PRODUCTION NO. 75: 2 For the period January I, 2012 to the present, all DOCUMENTS that CONCERN or 3 RELATE to any lawsuits filed in any federal or state court in the United States of America 4 against DEFENDANT that contain or assert claims for harassment, discrimination or retaliation 5 allegedly committed by, or engaged in by COMSTOCK. 6 REQUEST FOR PRODUCTION NO. 76: 7 For the period January 1, 2012 to the present, aJI DOCUMENTS that CONCERN or 8 RELATE to any complaints made to the DFEH constituting, describing, alleging or 9 CONCERNING complaints of harassment, discrimination or retaliation allegedly committed by, 10 or engaged in by ARNOLD. 11 REQUEST FOR PRODUCTION NO. 77: 12 For the period January 1, 2012 to the present, al1 DOCUMENTS that CONCERN or 13 RELATE to any complaints made to the EEOC constituting, describing, alleging or 14 CONCERNING complaints of harassment, discrimination or retaliation allegedly committed by, 15 or engaged in by ARNOLD. 16 REQUEST FOR PRODUCTION NO. 78: 17 For the period January 1, 2012 to the present, all DOCUMENTS that CONCERN or 18 RELATE to any lawsuits filed in any federal or state court in the United States of America 19 against DEFENDANT that contain or assert claims for harassment, discrimination or retaliation 20 allegedly committed by, or engaged in by ARNOLD. 21 REQUEST FOR PRODUCTION NO. 79: 22 All DOCUMENTS pertaining to any investigation(s) into the allegations made by 23 PLAINTIFF in his COMPLAINT, including but not limited to written statements of witnesses, 24 notes of interviews with witnesses, tape recordings of any and all oral statements and/or 25 interviews of witnesses, transcriptions of any tape recordings of any and all oral statements 26 and/or interviews of witnesses, reports REGARDING the results of any and all investigations 27 and/or correspondence RELATING to the allegations contained in the COMPLAINT. 28 // 19 PLAINTIFF DR. PAY AM T ABRIZI'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, TO DEFENDANT COUNTY OF SANT A CLARA; CASE NO. 17 CV 317480 REQUEST FOR PRODUCTION NO. 80: 2 All DOCUMENTS that CONCERN or RELATE to any statements made by any 3 PERSON relating to any of the allegations contained in PLAINTIFF's COMPLAINT, including 4 but not limited to written statements, notes of interviews, tape recordings of any and all oral 5 statements and/or interviews, transcriptions of any tape recordings of any and all oral statements 6 and/or interviews, reports REGARDING the results of any and all interviews or investigations, 7 or correspondence RELATING to the allegations contained in the COMPLAINT. 8 REQUEST FOR PRODUCTION NO. 81: 9 For the period January 1, 2012 to the present, all DOCUMENTS that constitute, 10 CONCERN or RELATE to any policy, practice, rule, or guidelines regarding providing or 11 giving departing staff members, including doctors, copies of any academic documents and 12 presentations, including lectures and power point presentations, which are drafted or saved on 13 computers owned by SCVMC. 14 REQUEST FOR PRODUCTION NO. 82: 15 For the period January 1, 2012 to the present, all DOCUMENTS that constitute, 16 CONCERN or RELATE to SCVMC's policies and procedures relating to the retention and 17 storage of all DOCUMENTS on any computer owned by SCVMC, including all policies and 18 procedures relating to the backup or destruction of such DOCUMENTS. 19 REQUEST FOR PRODUCTION NO. 83: 20 All DOCUMENTS that constitute, CONCERN or RELATE to T ABRIZI"S lectures, 21 notes and presentations, including, but not limited to, lectures and power point presentations 22 located on the hard drive of the desktop computer T ABRIZI last used while employed. (Plaintiff 23 has no objection to the redaction of patient identifying information.) 24 REQUEST FOR PRODUCTION NO. 84: 25 Al1 textbooks, journals, technique/equipment guides, binders with study materials, and 26 other written materials that were located in the office that was used, or assigned to T ABRIZI at 27 the time of his termination. 28 // 20 PLAINTIFF DR. PAY AM T ABRIZI'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, TO DEFENDANT COUNTY OF SANT A CLARA; CASE NO. 17 CV 317480 1 REQUEST FOR PRODUCTION NO. 85: 2 All ofT ABRIZI's framed medical diplomas and certifications which were located in the 3 office at SCVMC used by T ABRIZI at the time of his termination. 4 REQUEST FOR PRODUCTION NO. 86: 5 All of T ABRIZI' s personal effects, including framed posters, framed pictures of friends 6 and family, photo albums, and stereo system, which were located in the office at SCVMC used 7 by T ABRIZI at the time of his termination. 8 REQUEST FOR PRODUCTION NO. 87: 9 All of the medical equipment owned by TABRIZ] and used by him during his 10 employment at SCVMC, which was not returned to him at the time of his termination, including 11 but not limited to two trays of medical equipment labeled "T ABRIZJ LARGE SET" and 12 "T ABRIZI SMALL SET," drills, drill sleeves, reduction clamps and tensioners, retractors, tissue 13 protectors, a set of protective lead glasses, and a thyroid lead shield with T ABRIZI' S nickname 14 "Breeze" written on it. 15 REQUEST FOR PRODUCTION NO. 88: 16 All DOCUMENTS identified or relied upon in Responding Party's response to 17 PLAINTIFF's Special Interrogatories, Set One. 18 REQUEST FOR PRODUCTION NO. 89: 19 All DOCUMENTS identified in Responding Party's response to PLAINTIFF's Form 20 Interrogatories - Employment Law, Set One. 21 REQUEST FOR PRODUCTION NO. 90: 22 All insurance policies through which DEFENDANT is, was, or might be insured in any 23 manner for any damage, claims or actions arising from the allegations in PLAINTIFF' s 24 COMPLAINT. 25 REQUEST FOR PRODUCTION NO. 91: 26 All DOCUMENTS, including but not limited to memoranda, handwritten notes, letters, 27 correspondence, policies, and policy numbers pertaining to insurance policies that may cover 28 DEFENDANT's and/or defense costs related to this action. 21 PLAINTIFF DR. PAY AMT ABRIZI'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, TO DEFENDANT COUNTY OF SANT A CLARA; CASE NO. 17 CV 317480 l REQUEST FOR PRODUCTION NO. 92: 2 All DOCUMENTS sufficient to describe the routine e-mail system maintenance for 3 employees of DEFENDANT from January 1, 2010 to present. 4 REQUEST FOR PRODUCTION NO. 93: 5 All DOCUMENTS identifying the methods and terms used to search for information 6 (hard-copy and ESI) responsive to PLAINTIFF' s Request for Production of Documents, Set 7 One. 8 REQUEST FOR PRODUCTION NO. 94: 9 All DOCUMENTS identifying the methods and terms used to search for information text 10 messages responsive to PLAINTIFF's Request for Production of Documents, Set One. 11 Dated: November 21, 2017 LEVY VINICK BURRELL HY AMS LLP 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 By~\K\J~ SHARON R. VINICK Attorneys for Plaintiff Dr. Pa yam Tabrizi 22 PLAINTIFF DR. PAY AM T ABRIZI'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, TO DEFENDANT COUNTY OF SANT A CLARA; CASE NO. 17 CV 317480 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF SANTA CLARA I am employed in the County of Alameda, State of California; I am over the age of 18 years and not a party to the within entitled action; my business address is 180 Grand A venue, Suite 1300, Oakland, California 94612. On November 21, 2017, I served the foregoing documents, described as • PLAINTIFF DR. PAY AM T ABRIZI'S REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, TO DEFENDANT COUNTY OF SANT A CLARA on the interested parties to said action by the following means: D D D D D (By Facsimile Transmission) By transmitting via facsimile the document(s) listed above to the fax number( s) set forth below. (By Mail) By placing the document(s) listed above in a sealed envelope with postage thereon fully prepaid, in the United States Mail at Oakland, California addressed as set forth below. (By Hand Delivery) By causing a true copy thereof, enclosed in a sealed envelope, to be delivered by hand to the addresses shown below. (By Overnight Delivery) By placing a true copy thereof, enclosed in a sealed envelope, with delivery charges prepaid, to be sent by Federal Express, addressed as shown below. (By Personal Service) By personally delivering a true copy thereof, enclosed in a sealed envelope, to the addressees shown below. (By E-Mail) By electronically transmitting a PDF of the document listed above, addressed as set forth below. I declare under penalty of perjury and under the laws of the State of California that the 17 above is true and correct and that that I am employed in the office of a member of the bar of this court at whose direction the service was made. 18 19 20 21 22 23 24 25 26 27 ?.R Executed on November 21, 2017, at Oakland, California. NAME AND ADDRESS/EMAIL OF EACH PERSON SERVED: James R. Williams Gregory J. Charles OFFICE OF WE COUNTY COUNSEL 70 West Hedding Street, East Wing, gth Floor San Jose, CA 95110-1770 1 Proof of Service Case No. 17 CV 317480 Exhibit 2 xhibit From: To: CC: BCC: Siegel, John(/O=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=6186634FD590428CB586E702DF70828E-SIEGEL, JOH) Arnold, Jeffrey Subject: Fwd: Shadowing in the OR 08/25/2016 11:15:52 AM -0700 (PST) Sent: From: "Lorenz, Paul E" Date: August 25, 2016 at 9:10:17 AM PDT To: "Fuentes, Theresa" , "Sanders, Pauline" , "Brown, Carolyn" , "Naqvi Mugler, Alice" , "Edmonson, Terry" , "Siegel, John" , "Mclarin, Benita" , "Herrera, Adriana" Subject: Re: Shadowing in the OR ttorney Client Privilege On Aug 25, 2016, at 8:41 AM, Fuentes, Theresa wrote: SCC006170 From: Sanders, Pauline Sent: Wednesday, August 24, 2016 8:15 PM To: Lorenz, Paul E Cc: Siegel, John; Shepard, Kimberly; Bommarito, Gina; Adams, Dawn B; Alcaraz, Irma; Arnold, Jeffrey; Botha, Winifred; Brown, Carolyn; Calderon, Frances; Edmonson, Terry; Fuentes, Theresa; Glenn, Laura Elaine; Hawk, Ofelia; Houston, Felicia; Karanas, Yvonne; Kiniyalocts, Melissa; Lorenz, Paul E; Menzies, Sonia; Murphy, Melissa; Naqvi Mugler, Alice; Nevitt, Andrew; Nguyen, Phuong H.; Russell, Paul; Sanders, Pauline; Schoendaler, David; Sprinkles, Jennifer; Wentzien, Thomas; Ziebell, Cynthia Subject: RE: Shadowing in the OR Confidential and Privile ed SCC006171 SCC006172 ‘ ttomey Client Priviiege COGB‘T Exhibit 3 xhibit 1 JAMES R. WILLIAMS, County Counsel (S.B. #271253) GREGORY J. CHARLES, Deputy County Counsel (S.B. #208583) 2 BRYAN K. ANDERSON, Deputy County Counsel (S.B. #170666) OFFICE OF THE COUNTY COUNSEL 3 70 West Hedding Street, East Wing, Ninth Floor San Jose, California 95110-1770 4 Telephone: (408) 299-5900 ~~(;,c(} M, Facsimile: ( 408) 292-7240 5 .. :~ MAY f D 201E ./ ~ ~~'17~7&'. \ ,_;;1~· 6 Attorneys for Defendants COUNTY OF SANTA CLARA AND CURT 7 COMSTOCK, M.D. 8 9 10 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA 11 PA YAM TABRIZ!, M.D., No. 17-CV-317480 12 13 V. Plaintiff, DEFENDANT COUNTY OF SANTA CLARA'S SUPPLEMENTAL PRIVILEGE LOG IN RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS 14 COUNTY OF SANTA CLARA, d/bla SANTA CLARA VALLEY MEDICAL CENTER, CURT 15 COMSTOCK, M.D., JEFFREY ARNOLD, M.D. and DOES 1-10, inclusive, Defendants. SET ONE 16 17 18 Defendant County of Santa Clara hereby provides this Supplemental Privilege Log for 19 documents contained within its Response to Plaintiff's Request for Production of Documents, 20 21 22 23 24 25 26 27 28 Set One. Ill Ill Ill Ill Ill Ill Ill Ill 1 County's Supplemental Privilege Log in Response to Request for Production of Documents Set One 17-CV-317480 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Begin Bates End From To Bates SCC001998 SCCOOI999 Sanders, Paul Lorenz; cc: Siegel, Pauline John; Shepherd, Kimberly; Bommarito, Gina; Adams, Dawn; Alcaraz, Irma; Arnold, Jeffrey; Botha,Winifred (CCO); Brown, Carolyn; Calderon, Frances; Edmonson, Terry; Fuentes, Theresa (CCO); Glenn, Laura Elaine; Hawk, Ofelia; Houston, Felicia; Karana, Yvonne; Kiniyalocts, Melissa (CCO); Lorenz, Paul; Menzies, Sofia; Murphy, Melissa; Naqvi Mugler, Alice~ Nevitt, Andrew; Nguyen, Phuong; Schoendaler, David; Sprinkles, Jennifer (CCO); Wentzien, Thomas; Ziebell, Cynthia SCC005376 SCC005378 Tabrizi, Comstock, Curt Payam SCC005473 SCC005474 Bonilla, Nguyen, Phuong H. Jovanah SCC005475 SCC005476 Bonilla, Anderson, Bryan (CCO) Jovanah SCC005477 SCC005478 Bonilla, Anderson, Bryan (CCO) Jovanah SCC005479 Bonilla, Fuentes, Theresa (CCO) Jovanah SCC005480 SCC005481 Nguyen, Bonilla, Jovanah Phuong H. 2 County's Supplemental Privilege Log in Response to Request for Production of Documents Set One Date File Type Privilege Type 8/24/2016 Email Attorney Client Privilege 9/12/2013 Email Evidence Code 1157 7/14/2017 Email Attorney Client Privilege; Work Product Privilege 7/13/2017 Email Attorney Client Privilege; Work Product Privilege 7/13/2017 Email Attorney Client Privilege; Work Product Privilege 7/13/2017 Email Attorney Client Privilege; Work Product Privilege 7/14/2017 Email Attorney Client Privilege; Work Product Privilege l 7-CV-317480 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Begin Bates End From To Bates SCC005482 Crawley, Stevens, Cheryl (CCO) Vernon SCC005483 SCC005495 Crawley, Stevens, Cheryl (CCO) Vernon SCC005496 SCC005505 Crawley, Stevens, Cheryl (CCO) Vernon SCC005506 Crawley, Stevens, Cheryl (CCO) Vernon SCC005507 Crawley, Stevens, Cheryl (CCO) Vernon SCC005508 SCC005509 Crawley, Stevens, Cheryl (CCO) Vernon SCC005510 SCC005514 Crawley, Kraja, Sabahete; Stevens, Vernon Cheryl (CCO) SCC005515 SCC005518 Crawley, K.raja, Sabahete; Stevens, Vernon Cheryl (CCO) SCC005519 SCC005522 Crawley, Kraja, Sabahete; Stevens, Vernon Cheryl (CCO) SCC005523 SCC005525 Crawley, Stevens, Cheryl (CCO) Vernon SCC005526 Crawley, Kraja, Sabahete; cc: Stevens, Vernon Cheryl (CCO) SCC005527 Crawley, Stevens, Cheryl(CCO); Vernon Kraja, Sabahete SCC005528 SCC005530 Crawley, Hayes, Teresa; cc: Stevens, Vernon Cheryl (CCO) SCC005531 SCC005538 Crawley, Stevens, Cheryl (CCO) Vernon SCC005539 SCC005953 Crawley, Stevens, Cheryl (CCO) Vernon 3 County's Supplemental Privilege Log in Response to Request for Production of Documents Set One Date File Type Privilege Type 12/15/2016 Email Attorney Client Privilege 12/5/2016 Email Attorney Client Privilege 12/5/2016 Email Attorney Client Privilege 11/28/2016 Email Attorney Client Privilege 11/23/2016 Email Attorney Client Privilege 11/23/2016 Email Attorney Client Privilege 7/11/2016 Email Attorney Client Privilege 7/11/2016 Email Attorney Client Privilege 7/11/2016 Email Attorney Client Privilege 6/20/2016 Email Attorney Client Privilege 3/9/2017 Email Attorney Client Privilege 2/8/2017 Email Attorney Client Privilege; Work Product Privilege 12/27/2016 Email Attorney Client Privilege 12/22/2016 Email Attorney Client Privilege 5/23/2017 Email Attorney Client Privilege; Work Product Privilege 17-CV-317480 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Begin Bates End From To Bates SCC005954 SCC005955 Romero, Logan, Aimee (CCO) Nancy SCC005956 SCC005964 Tabrizi, Comstock, Curt; McBeth, Payam Jessica SCC005965 SCC005966 Tabrizi, Abbi, Gaurav; Comstock, Payam Curt; Krygier, Jeffrey; McBeth, Jessica; Bogatch, Michael SCC005967 SCC005969 Tabrizi, Comstock, Curt; Lodewyk, Payam Natalie SCC005970 SCC005972 Tabrizi, Comstock, Curt Payam SCC005973 SCC005979 Crawley, Sundberg, Tia Vernon SCC005980 SCC005986 Crawley, Kraja, Sabahete Vernon SCC005987 SCC005993 Crawley, Kraja, Sabahete Vernon SCC005994 SCC005995 Crawley, Kraja, Sabahete; Stevens, cc: Vernon Cheryl (CCO); Arnold, Jeffrey SCC005996 SCC005997 Crawley, Kraja, Sabahete; cc: Stevens, Vernon Cheryl (CCO) SCC005998 SCC006003 Arnold, Kraja, Sabahete; Jeffrey cc: Crawley, Vernon; Siegel, John; Stevens, Cheryl (CCO) SCC006004 SCC006018 Crawley, Kraja, Sabahete Vernon SCC006019 SCC006023 Crawley, Donald A. Larkin (CCO) Vernon SCC006024 Crawley, Stevens, Cheryl (CCO) Vernon SCC006025 SCC006036 Crawley, Kraja, Sabahete; cc: Stevens, Vernon Cheryl (CCO) SCC006037 Crawley, Stevens, Cheryl (CCO) Vernon SCC006038 SCC006039 Harris, Comstock, Curt; Stephen Philip, Bridget 4 County's Supplemental Privilege Log in Response to Request for Production of Documents Set One Date File Type Privilege Type 5/8/2017 Email Attorney Client Privilege; Work Product Privilege 4/13/2016 Email Evidence Code 1157 6/23/2016 Email Evidence Code 1157 5/7/2015 Email Evidence Code 1157 3/23/2015 Email Evidence Code 1157 3/2/2015 Email Attorney Client Privilege 3/2/2015 Email Attorney Client Privilege 3/2/2015 Email Attorney Client Privilege 10/21/2014 Email Attorney Client Privilege 10/20/2014 Email Attorney Client Privilege 1/22/2015 Email Attorney Client Privilege 10/16/2014 Email Attorney Client Privilege 6/9/2014 Email Attorney Client Privilege 4/7/2015 Email Attorney Client Privilege 3/26/2015 Email Attorney Client Privilege 6/9/2014 Email Attorney Client Privilege 3/19/2013 Email Evidence Code 1157 17-CV-317480 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Begin Bates End From To Bates SCC006040 SCC006041 Crawley, K.raja, Sabahete; Vernon cc: Stevens, Cheryl (CCO); Arnold, Jeffrey SCC006042 Crawley, Cheryl Stevens (CCO) Vernon SCC006043 SCC006044 Crawley, K.raja, Sabahete; cc: Stevens, Vernon Cheryl (CCO); Arnold, Jeffrey SCC006045 SCC006050 Arnold, Leung, Luke; Larkin, Donald Jeffrey (CCO); Russell, Paul SCC006051 SCC006056 Arnold, Nevitt, Andrew; Nancy Jeffrey Clark; Theresa Fuentes (CCO) SCC006057 SCC006061 Arnold, Nevitt, Andrew; cc: Fuentes, Jeffrey Theresa (CCO); Clark, Nancy SCC006062 SCC006064 Arnold, Fuentes, Theresa (CCO); Jeffrey Lorenz, Paul E SCC006065 SCC006067 Arnold, Nancy Clark (CCO) Jeffrey SCC006068 SCC006069 Arnold, Nancy Clark (CCO) Jeffrey SCC006070 SCC006072 Arnold, Dumanowski, Lisa; Poole, Jeffrey Sandra J; Coelho, Robert (CCO); Clark, Nancy (CCO) SCC006073 SCC006074 Arnold, Coelho, Robert (CCO) Jeffrey SCC006075 SCC006076 Arnold, Coelho, Robert (CCO) Jeffrey SCC006077 SCC006078 McLarin, Nevitt, Andrew; Adams, Benita Dawn; Fuentes, Theresa (CCO) SCC006079 SCC006080 Gallego, Krygier, Jeffrey; King, Gail; Alex cc: Nevitt, Andrew; McLarin, Benita; Fuentes, Theresa (CCO); Siegel, John SCC006081 McLarin, Krygier, Jeffrey; King, Gail; Benita cc: Nevitt, Andrew; McLarin, Gallego, Alex, Theresa (CCO); Siegel, John SCC006082 SCC006086 Clements, Fuentes, Theresa (CCO) Sue 5 County's Supplemental Privilege Log in Response to Request for Production of Documents Set One Date File Type Privilege Type 10/21/2014 Email Attorney Client Privilege 6/9/2014 Email Attorney Client Privilege 10/21/2014 Email Attorney Client Privilege 6/30/2014 Email Attorney Client Privilege 7/10/2014 Email Attorney Client Privilege 7/9/2014 Email Attorney Client Privilege 12/15/2014 Email Attorney Client Privilege; Evidence Code 1157 2/19/2014 Email Attorney Client Privilege 2/19/2014 Email Attorney Client Privilege 2/19/2014 Email Attorney Client Privilege 9/28/2016 Email Attorney Client Privilege 9/28/2016 Email Attorney Client Privilege 4/14/2017 Email Attorney Client Privilege 4/14/2017 Email Attorney Client Privilege 4/14/2017 Email Attorney Client Privilege 10/23/2016 Email Attorney Client Privilege 17-CV-317480 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Begin Bates End From To Bates SCC006101 Marchelle Fuentes, Theresa (CCO); Hammond Comstock, Curt SCC006112 SCC006118 Crawley, Vernon SCC006125 SCC006126 Desmond, Comstock, Curt Elizabeth SCC006167 SCC006168 Fuentes, Arnold, Jeffrey Theresa (CCO) Ill Ill Ill Ill Ill Ill Ill Ill Ill Ill Ill Ill Ill Ill Ill Ill Ill Ill Ill Ill 6 County's Supplemental Privilege Log in Response to Request for Production of Documents Set One Date File Type Privilege Type 1/20/2017 Email Attorney Client Privilege 3/25/2015 Memorandum Attorney Client Privilege 4/11/2013 Email Evidence Code 1157 1/2/2017 Email Attorney Client Privilege l 7-CV-317480 2 3 4 5 6 7 8 9 10 11 · 12 13 14 15 16 17 18 19 20 21 22 23 24 . 25 26 27 28 Begin Bates End From Bates SCC006170 SCC006172 Siegel, John Dated: May 15, 2018 1776642 To Date Arnold, Jeffrey; 8/25/2016 in response to an email from Lorenz, Paul to Fuentes, Theresa (CCO); Sanders, Pauline; Brown, Carolyn; Naqvi Mugler, Alice; Edmonson, Terry; Siegel, John; McLarin, Benita; Herrera, Adriana; in response to an email from Fuentes, Theresa (CCO) to Lorenz, Paul; in response to an email from Sanders, Pauline to Paul Lorenz; cc: Siegel, John; Shepherd Kimberly; Bommarito, Gina; Adams, Uawn; Alcaraz, Irma; Arnold, Jeffrey; Botha, Winifred (CCO); Brown, Carolyn; Calderon, Frances; Edmonson, Terry; Fuentes, Theresa (CCO); Glenn, Laura Elaine; Haw~ Ofelia; Houston, Felicia; Karanas, Yvonne, Kiniyalocts, Melissa (CCO); Lorenz, Paul; Menzies, Sofia; Murphy, Melissa; Naqvi Mugler, Alice; Nevitt, Andrew; Nguyen, Phuong; Russell, Paul; Sanders, Pauline; Schoendaler, David; Sprinkles, Jennifer (CCO); Wentzien, Thomas; Ziebell, Cynthia Respectful I y submitted, JAMES R. WILLIAMS C~I By: ?"~~ ~y AN K. ANDERSON Deputy County Counsel Attorneys for Defendants File Type Email Privilege Type Attorney Client Privilege COUNTY OF SANTA CLARA AND CURT COMSTOCK. M.D. 7 County's Supplemental Privilege Log in Response to Request for Production of Documents Set One l 7-CV-317480 2 3 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANT A CLARA PROOF OF SERVICE BY MAIL 4 Tabrizi v. Countv of Santa Clara, et al. 17-CV-317480 5 6 I, Geraldine Fann, say: · I am now and at all times herein mentioned have been over the age of eighteen years, 7 employed in Santa Clara County, California, and not a party to the within action or cause; that my business address is 70 West Hedding Street, East Wing, 9th Floor, San Jose, California 95110-1770. 8 I am readily familiar with the County's business practice for collection and processing of correspondence for mailing with the United States Postal Service. I served a copy of the 9 DEFENDANT COUNTY OF SANTA CLARA'S SUPPLEMENTAL PRIVILEGE LOG IN RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS SET ONE by placing IO said copy in an envelope addressed to: 11 Sharon R. Vinick LEVY VINICK BURRELL & HY AMS 12 180 Grand Avenue, Suite 1300 Oakland, California 94612 13 14 Supreeta Sampath THE SAMP A TH LAW FIRM 3 51 California Street, Suite 700 San Francisco, California 94104 15 which envelope was then sealed, with postage fully prepaid thereon, on May 15, 2018, and placed for collection and mailing at my place of business following ordinary business practices. Said 16 correspondence will be deposited with the United States Postal Service at San Jose, California, on the above-referenced date in the ordinary course of business; there is delivery service by United 17 States mail at the place so addressed. 18 I declare under penalty of perjury under the laws of the State of California that the above is true and correct, and that this declaration was executed on May 15, 2018, at San Jose, California. 19 20 21 Geraldine Fann 22 1776642 23 24 25 26 27 28 1 Proof of Service by Mail 17-CV-317480 Exhibit 4 xhibit 8/15/2018 GIVING & VOLUNTEERING ~ SANTA CLARA .... VALLEY MEDICAL CENTER Hospital & Clinics Our Services I Psychiatry I Santa Clara Valley Medical Center CAREERS NEWSROOM FOR PROVIDERS CONTACT US T FIND A PROVIDER CLINICS & LOCATIONS PATIENTS & VISITORS HEALTH CARE SERVICES EDUCATION & TRAINING ABOUT US MYHEALTH ONLINE HOME/ HEALTH CARE SERVICES/ PSYCHIATRY Overview Our Services Our Doctors & Staff For Patients For Professionals Resources PSYCHIATRY OUR SERVICES A wide array of specialty services are provided through the Department of Psychiatry. SPECIALIZATION https:/lwww.scvmc.org/health-care-services/Psychiatry/Pages/Our-Services.aspx 1/5 8/15/2018 Our Services I Psychiatry I Santa Clara Valley Medical Center INPATIENT ADULT PSYCHIATRY AT SCVMC Medication, psychotherapy, psychological testing and treatment, and occupational therapy are provided to patients admitted to the psychiatric hospital units. https://www.scvmc.org/health-care-services/Psychiatry/Pages/Our-Services.aspx EMERGENCY AND CRISIS SERVICES AT SCVMC Evaluation, treatment, and referral services are provided to involuntary and voluntary patients admitted to EPS and the mental health urgent care clinic. 2/5 8/15/2018 Our Services I Psychiatry I Santa Clara Valley Medical Center CUSTODY PSYCHIATRY SERVICES AT COUNTY CUSTODY FACILITIES Medication management, psychotherapy, psychological testing and treatment, are provided to patients admitted to the main jail psychiatric hospital unity, and to inmates in the general population at the main jail, Elmwood, and Correctional Center for Women facilities. ADULT AND CHILD OUTPATIENT PSYCHIATRIC SERVICES Medication, counseling, case management, psychological testing, and substance use treatment services are provided to patients in Ambulatory Services and Behavioral Health Services Department clinics. FULL LIST OF SERVICES 1. Emergency psychiatric services, including evaluation of involuntary psychiatric detentions, and treatment and stabilization of acute psychiatric illness 2. Voluntary and involuntary inpatient psychiatric treatment 3. Consultation services to medical, surgical, and pediatric patients hospitalized at SCMVC https://www.scvmc.org/health-care-services/Psychiatry/Pages/Our-Services.aspx 3/5 8/15/2018 Our Services I Psychiatry I Santa Clara Valley Medical Center 4. Post-hospital care services 5. Walk-in crisis services through mental health urgent care 6. Screening, triage, and appointment services for access to outpatient psychiatric treatment (can be reached through 1 (800) 704-0900) 7. Outpatient case management services for children and adults 8. Outpatient counseling services for children and adults 9. Medication management services for children and adults 10. Re-entry transition services for patients released from custody facilities 11. Substance use treatment services for adolescents and adults 12. Screening, triage, and appointment services for access to substance use treatment services (can be reached through 1 (800) 488-9919) 13. Telephone suicide hotline services (at 1 (855) 278-4204 24/7) https://www.scvmc.org/health-care-services/Psychiatry/Pages/Our-Services.aspx 4/5 8/15/2018 Our Services I Psychiatry I Santa Clara Valley Medical Center Santa Clara Valley Valley Health Patient Services Medical Center Centers Follow Us+ Stay Healthy 11 You(imm 751 S Bascom Ave San Jose, CA 95128 Get Directions Phone ( 408) 885- 5000 TTY Phone: ( 408) 971-4068 Santa Clara Valley Medical Center I 751 S. Bascom Ave, San Jose, CA 95128 All Content Copyright © 2018, Santa Clara Valley Medical Center, County of Santa Clara, CA Valley Health Center Bascom Valley Health Center Downtown Valley Health Center East Valley Valley Health Center Gilroy Valley Health Center Lenzen Valley Health Center Milpitas Valley Health Center Moorpark Valley Health Center Sunnyvale Valley Health Center Tully Valley Specialty Center Valley Homeless Health Care Program (VHHP) Urgent Care and Express Care Ambulatory Health Education Customer Relations Chaplain & Spiritual Care Services Financial Services Language Services Legal Assistance Programs Patient Rights & Responsibilities PACE Clinic Dental Clinic Locations & Hours Laboratory Locations & Hours Pharmacy Locations & Hours Site Usage Accessibility Contact SCCGOV Links Policy Privacy Policy Terms of Use • SANTA CLARA ~ VALLEY MEDICAL CENTER Hospital & Clinics https:/lwww.scvmc.org/health-care-services/Psychiatry/Pages/Our-Services.aspx 5/5 Exhibit 5 xhibit SANTA CLARA VALLEY :MEDICAL CENTER A~6521/6553-02 Page 1 of 2 POST ANESTHESIA CARE AND AMBULATORY SURGERY UNITS POLICY MANUAL ORGANIZATION AND RESPONSffiILITIES I. POLICY The Director of Perioperative Services has overall responsibility for the medical care in the Post Anesthesia Care Unit (PACU) and Ambulatory Surgery Unit (ASU). The Director of Nursing, Critical Care, Surgical and Administrative Services and Nurse Manager, OR Services are responsible for the nursing care and coordination of ancillary services in PACU and ASU. TI1e Chair of the Department of Anesthesiology is responsible for anesthetic care, as provided in the Medical Staff bylaws and Medical Executive Committee-approved policies and procedures, which are not superceded by this nursing policy. The OR Services Nurse Manager, with relevant education, training and demonstrated competence is responsible for the nursing care and nursing management of the PACU and ASU. He/she reports to the Director of Nursing,, Critical Care, Surgical Services and Administrative Services. There will be a sufficient mix of licensed nurses and unlicensed personnel assigned to meet patient care needs • II. PURPOSE To comply with Title 22 and the Hospital Medical Bylaws. III. PROCESS 1. The Chair of the Department of Anesthesiology, in consultation with the Director of Perioperative Services, will appoint a Director of PACU and ASU (Director). 2. The Director is responsible for Medical Supervision. 3. The Director of Nursing, Critical Care, Surgical Services and Administrative Services. is responsible for overall nursing care 4. The Nurse Manager is responsible for 24 hour unit operations 5. The Assistant Nurse Manager is responsible for daily unit management. ORGANIZATIONAL CHART ChiefNursing Officer Trudy Johnson, MA, RN, NEA-BC I Director of Nursing, Critical Care, Surgical Services and Administrative Services Jackie Lowther, MSN, MBA, RN Ext. 56707 I Nurse Manager, Operating Room Se1vices Sharon Malindzak, RN (interim) Ext.55228 I I \ Assistant Nurse Managers: Assistant Nurse Manager Aileen Cayabyab, RN (OR) Zenaida Gonulez, RN (OR) I , .. Chmcal Nurses OR Technicians OR Aides OR Clerks Susan Stabell, RN (P ACU/ ASU) I Clinical Nurses (RN and L VN) Hospital Service Assistants Medical unit Clerks OR Aides Date DatJ 1 A-6S21/6SS3-02 Page2 of2 ,, .. 5'-l'f Exhibit 6 xhibit 8/15/2018 Overview I Valley Health Center Bascom I Santa Clara Valley ~edical Center GIVING & VOLUNTEERING SANTA CLARA CAREERS NEWSROOM FOR PROVIDERS CONTACT US T "V' VALLEY MEDICAL CENTER Hospital & Clinics FIND A PROVIDER CLINICS & LOCATIONS PATIENTS & VISITORS HEALTH CARE SERVICES EDUCATION & TRAINING ABOUT US MYHEALTH ONLINE HOME/ CLINICS & LOCATIONS/ VALLEY HEALTH CENTER BASCOM VALLEY HEALTH CENTER BASCOM 750 S. Bascom Avenue, San Jose, CA 95128 · Phone: ( 408) 885-5000 · TTY: ( 408) 971- 4068 Overview Health Care Services OVERVIEW The Bascom outpatient clinic is one of 11 operated county-wide by Santa Clara Valley Medical Center (SCVMC), and opened its doors in 1985. Here, you'll https://www.scvmc.org/clinics-and-locations/Bascom/Pages/overview.aspx 1/6 8/15/2018 Overview I Valley Health Center Bascom I Santa Clara Valley Medical Center find the same high-quality care and coordination available at all SCVMC locations. Our friendly and highly-qualified doctors, nurses, and staff offer a wide variety of services, including children's urgent care, adult care, 08/GYN, pediatrics and pediatric specialties, lab, radiology/diagnostic imaging, convenient on-site pharmacy, and more. PHONE NUMBERS APPOINTMEN AFTER PHARMACY TS & ADVICE HOURS REFILLS (24 (888) 334- NURSE HOURS) 1000 ADVICE (408) 977- (888) 334- 3500 1000 LAB DIAGNOSTIC MEDICAL (408) 885- IMAGING RECORDS 4636 (408) 885- (408) 885- 4628 5125 OBGYN PEDIATRIC CLINIC CLINIC (888) 334- (888) 334- 1000 1000 HOURS https://www.scvmc.org/clinics-and-locations/Bascom/Pages/overview.aspx 2/6 8/15/2018 Overview I Valley Health Center Bascom I Santa Clara Valley Medical Center URGENT OBSTETRICS PEDIATRICS CARE (MATERNITY) Monday -AND Monday - GYNECOLOG Friday Friday Y (08/GYN) 8:30am - 8:30am - Suite 300,330 5:00pm 9:00pm and 335 Except first Saturday Monday - Wednesday Friday 9:30am - 9:00am - 8:30am - 5:00pm 8:00pm 5:00pm Except first Saturday - Sunday Thursday Sunday 9:00am - 10:00am - Closed 5:00pm 5:00pm Holidays Holidays Suite 335 Closed (except Evening Thanksgiving Monday and and Wednesday Christmas) 8:30am - 5:00pm - 9:00pm 5:00pm Saturday - Sunday Closed Holidays Closed https://www.scvmc.org/clinics-and-locations/Bascom/Pages/overview.aspx 3/6 8/15/2018 Overview I Valley Health Center Bascom I Santa Clara Valley Medical Center COMPREHENS IVE PERINATAL SERVICES PROGRAM(CP SP) Monday - Friday 8:00am - 5:00pm Saturday - Sunday Closed Holidays Closed DIAGNOSTIC IMAGING (RADIOLOGY) General X-Ray and Screening Mammograph y Monday - Friday 7:40am - 7:00pm Saturday - Sunday Closed Holidays Closed LABORATORY PHARMACY Monday - Monday - Friday Friday 7:15am - 9:00am - 5:30pm 9:00pm Saturday - Saturday -Sunday Sunday Closed 8:30am - Holidays 5:00pm (Close for lunch Closed 12:30pm- 1:00pm) Holidays (except Thanksgiving and Christmas) 8:30am - 5:00pm HEALTH CARE SERVICES https://www.scvmc.org/clinics-and-locations/Bascom/Pages/overview.aspx 4/6 8/15/2018 Overview I Valley Health Center Bascom I Santa Clara Valley Medical Center URGENT CARE URGENT CARE SPECIALTY CARE PRIMARY CARE PRIMARY CARE OTHER SERVICES VIEW ALL SERVICES SPECIALTY CARE VISITOR INFORMATION & PARKING Valley Health Center Bascom 750 S. Bascom Avenue San Jose, CA 95128 Get Driving Directions PUBLIC TRANSPORTATION VTA Bus 25, 61, 62 For Bus schedules and more information, please contact Santa Clara VTA Customer Service Call Center: (408) 321-2300 or visit their website. (http://www.vta.org) https://www.scvmc.org/clinics-and-locations/Bascom/Pages/overview.aspx OTHER SERVICES 5/6 8/15/2018 Overview I Valley Health Center Bascom I Santa Clara Valley Medical Center Follow Us+ Stay Healthy 11 YouiD - Santa Clara Valley Medical Center 751 S Bascom Ave San Jose, CA 95128 Get Directions Phone (408) 885- 5000 TTY Phone: (408) 971-4068 Santa Clara Valley Medical Center I 751 S. Bascom Ave, San Jose, CA 95128 All Content Copyright © 2018, Santa Clara Valley Medical Center, County of Santa Clara, CA https://www.scvmc.org/clinics-and-locations/Bascom/Pages/overview.aspx Valley Health Centers Valley Health Center Bascom Valley Health Center Downtown Valley Health Center East Valley Valley Health Center Gilroy Valley Health Center Lenzen Valley Health Center Milpitas Valley Health Center Moorpark Valley Health Center Sunnyvale Valley Health Center Tully Valley Specialty Center Valley Homeless Health Care Program (VHHP) Patient Services Urgent Care and Express Care Ambulatory Health Education Customer Relations Chaplain & Spiritual Care Services Financial Services Language Services Legal Assistance Programs Patient Rights & Responsibilities PACE Clinic Dental Clinic Locations & Hours Laboratory Locations & Hours Pharmacy Locations & Hours Site Usage Accessibility Contact SCCGOV Links Policy Privacy Policy Terms of Use ~ SANTA CLARA .... VALLEY MEDICAL CENTER Hospital & Cl inics 6/6 Exhibit 7 xhibit w. C I 0 California's largest public pay and pension database .t:f.Q.rru!..(L). I Salarles 'David Schoendaler' search results ~czg-Dayid+Schoendaler&s=name). David schoendaler (lsalarles120111santa-c1ara- ~/day1d-schoendaler/). pavid Schoendafec (lsafarjes/201§/santa-dara- '2Ylllv.tdayid-schoendaler/). David Schoendarer (lsalaries/2014/santa-dara- ~v./dayid-schoendaler/). David Schoendaler (lsalarles/201s1santa-clara- countv./dayid-schoendarer/). Dayld Schoendarer (lsaranes120111santa-c1ara- .@!.!!!1Y./dayid-schoendaler/). David Schoendarer (lsalaries/2012/santa-clara- countv./dayid-schoendarer/). David Schoendaler (/salaries/2013/santa-clara- ~Y.{david-schoendaler/). 7 employee records found Search within these records: David Schoendaler Year " Search Job title Chl=Pavld+Schoendaler&s=tltlel J..i2.till!tv. Clajms Adj~(lsalaries/search/? g~DJo2oc1a1mso/o20Adjuster%20111). 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Santa Clara Countv.....Z.0.U..(lsalarles/2013/santa-clara-countd). « Previous © 2018 Transparent California !m.l.U.Y. & benefits (1. g::Dayid+Schoenda!er&s=- tm.t). $118,421.08 $114,927.42 $111,703.65 $111,145.59 $109,377.99 $106,799.86 $104,182.11 About (/pages/about/) I Contact (/pages/contact/) I Blog (https://blog.transparentcalifornia.com/) I Disclaimer (/pages/disclaimer/) I FAQ (/pages/faq/) I Donate (/donate/) Exhibit 8 xhibit DedicaJed to the Health of the Whole Community SANTA Cl.ARA VALLEY MEDICAL CENTER 4) HousestaffCoordinator's Office reviews application and all documentation and contacts Program Director. The Program Director and SCVMC Medical Director review and approve/disapprove the Observership ~xperience. 5) If approved, the applicant will obtain from Housestaff Coordinator's Office a fonn allowing him/her to secure VMC Identification Badge. 6) Program Director will contact applicant and Observership/Mentorship can begin. 7) Note that at the end of the mentorsmp, you are required to submit a written summary of your experience or a program-specific evaluation to the Program Director, who will then send you any appropriate summative or fonnative evaluations. Selection Criteria: A very limited number of observerships are available. Participants will be selected based upon candidate,s expression of career interests, scheduling logistics, and follow up interview(s) conducted by phone, email, and/or in person by the Program Director and/or his/her designees. Below is a list of available observership opportunities as the Program Director for each department: Department Anesthesiology Emergency Medicine Medicine/Medical Subspecialties Neurology Orthopedic Surgery Pathology and Laboratory Medicine Pediatrics Radiology Radiation Oncology Program Director Sarah Namath, MD Chris Mills, MD Steve Roey, MD, MSEd Peter Lin, MD Jessica McBeth MD Elisabeth Mailhot, MD Steve Harris, MD Raju! Pandit, MD TriDo,MD SCC001935 Exhibit 9 xhibit 8/15/2018 1 O Things to Know About Santa Clara Valley Medical Center Elecker's Healthcare : Hosp ital Review I .1\SC Re\'iew I Sµine Peview I Infection Cont:·ol I Health IT & CIO I CF·O I DP-ntai Review I 1.800 .417 .203S I Erna ii Us BECKER'S---------- Search ... -,f1 SEA~ l H OSP TAL REVIEW I . - --· - -· - ------ ·1 Print Issue Current Issue Past Issues Current Issue - Becker's Clinical Leadership & Infection Control Past Issues - Becker's Clinical Leadership & Infection Control Change Address Subscribe E-Weeklies Sign-Up for Our Free E-Weeklies Becker's Hospital Review E-Weekly Becker's Hospital CEO Report E-Weekly Becker's Hospital CFO Report E-Weekly Becker's Health IT and CIO Report E-Weekly Becker's Clinical Leadership & Infection Control E-Weekly Becker's Revenue Cycle E-Weekly Becker's Supply Chain E-Weekly Becker's Payer Issues E-Weekly Becker's Business Review E-Weekly Conferences Becker's Hospital Review 4th Annual Health IT + Revenue Cycle Conference Becker's Hospital Review 7th Annual CEO + CFO Roundtable Becker's Hospital Review 10th Annual Meeting Becker's Hospital Review Health IT+ Clinical Leadership 2019 Conferences and Events Call for Speakers Exhibiting & Sponsoring Webinars Upcoming Webinars Past Webinars White Papers Current White Papers Archives Multimedia E-Books E-Book Archives Podcasts Roundtables Videos 2015 CIO/HIT + Rev Cycle Summit Keynote Video i i -----·- l https:/lwww.beckershospitalreview.com/hospital-profile/10-things-to-know-about-santa-clara-valley-medical-center.html Sign up for our FREE E-Weeklies i ! 1/6 8/15/2018 Lists Nominations 50 states of population health 12018 1 O Things to Know About Santa Clara Valley Medical Center 100 Hospital & Health System CMOs to Know I 2018 50 Rural Hospital CEOs to Know I 2018 105 Hospital and Health System CIOs to Know I 2018 100 Infection Control Products to Know I 2018 130 women hospital and health system leaders to know I 2017 All Lists 183 nonprofit hospital and health system CEOs to know 2017 100 hospitals and health systems with great orthopedic programs 2017 60 of the greenest hospitals in America I 2017 58 Hospitals and Health Systems with Innovation Programs 2017 100 Hospitals with Great Heart Programs 2017 112 Physician Leaders to Know I 2017 100 Hospital and Health Systems With Great Oncology Programs 2017 61 Critical Access Hospital CEOs to Know I 2017 62 Critical Access Hospitals to Know I 2017 100 Great Community Hospitals I 2017 100 Great Hospitals in America I 2017 150 Top Places to Work in Healthcare I 2017 60 Rural Hospital CEOs to Know 2017 About Us About Becker's Hospital Review Contact Us Request Media Kit Reprints Channels Physicians Leadership Executive Moves Transaction & Valuation Human Capital & Risk Patient Flow Facilities Management Tele health Supply Chain Business Patient Engagement Pharmacy ACOs Population Health Legal & Regulatory Compensation Payers Opioids Rankings & Ratings EDs Post-Acute Care Workforce https://www.beckershospitalreview.com/hospital-profile/10-things-to-know-about-santa-clara-valley-medical-center.html 2/6 8/15/2018 1 O Things to Know About Santa Clara Valley Medical Center 10 Things to Know About Santa Clara Valley Medical Center September 06, 2012 I Print I Email i\"/ ( ?f : l [:.:] G+ Santa Clara Valley Medical Center in San Jose, Calif., is a safety net hospital and is part of the Santa Clara Valley Health and Hospital System. Here are 10 things to know about Santa Clara Valley Medical Center: 1 . The interim CEO is Trudy Johnson. 2. Dave McGrew serves as the CFO. 3. SCVMC has 554 beds. 4. The hospital has 4,578 employees. 5. Santa Clara Valley Medical Center recorded $2.1 billion in gross charges and a net income of $17 .8 million in 2011, as reported by the American Hospital Directory. 6. SCVMC discharged a total of 21,545 patients in 2011. The hospital performed 3,300 inpatient surgeries and 9,000 outpatient surgeries in 2011. There were 4,500 births at the hospital last year. 7. In 2010, SCVMC was recognized by Consumer Reports as one of 105 hospitals in the nation that reported no central-line infections. 8. The County Hospital was built in 1876, where SCVMC currently stands, due to the efforts of Dr. Benjamin Cory, San Jose's first medical practitioner. 9. SCVMC made Becker's Hospital Review list of the top 25 grossing public hospitals in 2011. 10. The hospital is accredited by The Joint Commission. If you have additional information you'd like included on the hospital featured above, or would like to recommend a hospital to be profiled in the future, please contact Lindsey Dunn. editor in chief, Becker's Hospital Review at ldunn@beckershealthcare.com. Correction: A previous version of this article incorrectly listed Linda Smith as CEO of Santa Clara Valley Medical Center. Ms. Smith was released from the hospital in June 2011. We apologize for the error. More Articles on Hospital Profiles: 10 Things to Know About University of California Irvine Medical Center 10 Things to Know about Cedars-Sinai Medical Center 10 Things to Know About Keck Hospital of USC © Copyright ASC COMMUNICATIONS 2018. Interested in LINKING to or REPRINTING this content? View our policies by clicking here. To receive the latest hospital and health system business and legal news and analysis from Becker's Hospital Review, sign-up for the free Becker's Hospital Review E-weekly by clicking here. https://www.beckershospitalreview.com/hospital-profile/10-things-to-know-about-santa-clara-valley-medical-center.html 3/6 8/15/2018 10 Things to Know About Santa Clara Valley Medical Center 0 Comments Becker's Hospital Review <:? Recommend ~ Share Start the discussion ... LOG INWITH OR SIGN UP WITH DISQUS {1) Name Login " Sort by Oldest .. Be the first to comment. ALSO ON BECKER'S HOSPITAL REVIEW Amazon, other shippers ask Trump administration not to raise postal rates 1 ,;nn11nent • '2 ' foster - Or, put more appropriately, 82% of admissions had no out-of-network billing. A significant portion of inpatient admissions had NO out-of-network Top 40 Articles from the Past 6 Months 1. 100 great hospitals in America I 2016 2. 150 top places to work in healthcare I 2018 3. 100 great hospitals in America I 2018 Johns Hopkins Medicine chief diversity officer resigns for new role at Vanderbilt: 5 notes TheBerean - Our Dean of Diversity left his wife I guess for spousal diversity. Parents help teen daughter 'escape' from Mayo Clinic Annr arrell27 - This is not the first story of odd behavior by the Mayo's. Clinicians at a different organization much closer to the situation believe that the Mayo Clinic did not 4. Survey: 8 in 10 nurses believe nonphysician practitioners play larger role in managing patient care 5. 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Colorado hospital terminates CFO days after ousting 2 execs, CEO 16. Michigan hospital sues 3 patient relatives over Facebook post: 8 things to know 17. With 8k more physicians than Kaiser, Optum is 'scaring the crap out of hospitals' 18. 17 of the highest-paid CEOs in healthcare 19. Secret team to 'kill the old healthcare model' launches at Florida Hospital 20. Colorado health system sues patient over $229K surgery bill, jury awards $766 21. Correction: 10 states with the most overworked nurses 22. 100 great leaders in healthcare 12018 23. MD Anderson slapped with $4.3M penalty for HIPAA violations 24. Wake Forest Baptist at risk of losing Medicare contract over cancer misdiagnoses 25. Patient too large for MRI machine sues Oregon hospital for $7M 26. Physician and surgeon average salary for all 50 states 27. Nurse accused of stealing more than $550k from New York hospital 28. 10 medical schools with the lowest acceptance rates 29. Rising stars: 90 healthcare leaders under 40 30. Miami hospital files for bankruptcy: 4 things to know 31. CHS lays off more than 70 corporate employees 32. CMS releases 2019 IPPS proposed rule: 10 things to know 33. A Walmart-Humana giant scares hospitals: 5 reasons why 34. 13 hospitals with the most ER visits I 2018 35. CMS terminates Kansas hospital's Medicare billing privileges: 5 things to know 36. 23-hospital system enters $14M settlement with feds over improper physician payments 37. Memorial Hermann hit with $1 M retaliation suit by former employee 38. Second body found at San Francisco hospital in 1 week 39. Amazon quietly launches exclusive OTC product line: 7 things to know 40. 100 great community hospitals 12018 https://www.beckershospitalreview.com/hospital-profile/10-things-to-know-about-santa-clara-valley-medical-center.html 5/6 8/15/2018 Other Becker's Websites ASC Review Spine Review Infection Con1rol Hea lth IT 8: CIO CFO Denta l Review 10 Things to Know About Santa Clara Valley Medical Center Conferences Becker's Hospital Review 9th /.\nnual Meeting Becker's Hospital Review Health IT ; Clinical Leadership 2018 Becker's Hospital Review 4th Annual Hea lth IT + Revenue Cycle Conference Becker's Hospital Rev iew 7th Annual CEO + CFO Roundtable Contact Us 1 .800 .417 .2035 becker@beckershea!thcare.com Copyright© 2018 Becker's Healthcare . All Rights Reserved. Interested in linking to or reprinting our content? View our policies by clicking here . https ://www .beckershospitalreview.com/hospital-profile/10-things-to-know-about-santa-clara-valley-medical-center.html 6/6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 PROOF OF SERVICE ST A TE OF CALIFORNIA, COUNTY OF ALAMEDA I am employed in the County of Alameda, State of California; I am over the age of 18 years and not a party to the within entitled action; my business address is 180 Grand A venue, Suite 1300, Oakland, California 94612. On August 1 7, 2018, I served the foregoing documents, described as • DECLARATION OF SHARON R. VINICK IN SUPPORT OF PLAINTIFF'S MEMORANDUM OF POINTS AND AUTHORITIES IN OPPOSITION TO DEFENDANT COUNTY OF SANTA CLARA'S MOTION FOR PROTECTIVE ORDER on the interested parties to said action by the following means: D D D D (By Facsimile Transmission) By transmitting via facsimile the document(s) listed above to the fax number( s) set forth below. 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I declare under penalty of perjury and under the laws of the State of California that the 18 above is true and correct and that that I am employed in the office of a member of the bar of this court at whose direction the service was made. 19 20 21 22 23 24 25 26 27 ?R Executed on August 17, 2018, at Oakland, California. ~ .(Jfo . ~ Davi Fans NAME AND ADDRESS/EMAIL OF EACH PERSON SERVED: Gregory J Charles Bryan K. Anderson OFFICE OF THE COUNTY COUNSEL 70 West Hedding Street, East Wing, 9th Floor San Jose, CA 95110-1770 Gregory. Charles@cco.sccgov.org Bryan.anderson@cco.sccgov.org Proof of Service Case No. 17 CV 317480