Statement Case Management ConferenceCal. Super. - 6th Dist.April 1, 2020ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, Stale Berne ser end edd ass( Aanchal V. Sanghvi, Esq./S.B.N. 315053Law Offices of Stephenson, Acquisto & Colman, Inc303 N. Glenoaks Blvd., Suite 700 FOR COURT USE OIYL Y CM-110 Burbank, CA 91502 TELEPHONENO 818-559-4477 FAHNo (opronair 818 - 559-5484 EMAIL ADDREss (opto ali asanghvi8 sac f irm. corn ATTORNEYFOR(Nam I Plainti f f SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA sTREETADDREss 191 N. 1st Street MAILING ADDRESS. DITYANDzipcoDE San Jose, CA 95113 BRANCH NAME'LAINTIFF/PETITIONER. STANFORD HEALTH CARE DEFENDANT(RESPONDENT(COVENTRY HEALTH CARE, INC. CASE MANAGEMENT STATEMENT (Checkone)( Mx UNLIMITED CASE ~ LIMITED CASE 20CV365904 (Amount demanded (Amount demanded is $25,000 exceeds $25,000) orless) A CASE MANAGEMENT CONFERENCE is scheduled as follows: Date: 9/7/2021 Time: 10: 00 am Dept.: 7 Dive Address of court (if different from lhe address above): Room: ~x Notice of Intent to Appear by Telephone, by(name)( Aanchal V. Sanghvi, Esq. INSTRUCTIONS: All applicable boxes must be checked, and the specified information must be provided. 1. Party or parties (answer one): a. ~x This statement is submitted by party(name)(Plaintiff, Stanford Health Careb. ~ This statement is submitted jointly by parties (names)( 2. Complaint and crossH:omplatnt (to be answered by plaintiffs and cross-compisinan(s only)a. The complaint was filed on (date): 4/1/2020 b. ~ The cross-complaint, if any, was filed on (date): 3. Service (io be answered by plaintiffs and cross-compiainanis only) a. ~x All parties named in the complaint and cross-complaint have been served, have appeared, or have been dismissed.b. The following parties nained in the complaint or cross-complaint (1) ~ have not been served (specify names and explain why not): (2) 3 have been served but have not appeared and have not been dismissed (specify names): (3) I have had a default entered against them (speciiy names): c. ~ The following additional parties may be added (specify names, nature ofinvo/vementin case, snd dale by whichthey may he served): 4. Description of case a. Type of case in Lx I complaint ~ cross-complaint (Describe, including causes of aclion)(Breach of Written Contract; Breach of Implied-In-Fact Contracti QuantumMeruit; and Common Counts-Good and Services Rendered Fom Adopted for Mandalmy Use Jad olel Coundl o( Caefomra CM-110 IRe July I, 20111 CASE MANAGEMENT STATEMENT s.&t. (Pb, Pjus Pa 1o(5 Cel Rules o(Court, rules 3 720-3 730 Electronically Filed by Superior Court of CA, County of Santa Clara, on 8/6/2021 4:26 PM Reviewed By: System System Case #20CV365904 Envelope: 7015662 20CV365904 Santa Clara - Civil System System PLAINTIFF/PETITIONER: STANFORD HEALTH CARE DEFENDANT/RESPONDENT:COVENTRY HEALTH CARE, INC. CASE NUMSER 20CV365904 CNI-110 4. b, Provide a brief statement of the case, including any damages. (If personal Injury damages are sought, specify the injury anddamages claimed, including medical expenses Io dale (indicate source and amount), estimaled future medical expenses, lostearnings to date, and estimated future last earnings. If equitable relief is sought, describe the nature of the relief)Plaintiff provided medically necessary services aud supplies to insured of De eodaut's health plan. Uponcompletion of treatment, discharge, acd demand for said services aod supplies, Defendant failed toproperly reimburse plaintiff. Defendant caused damages ic an amount to be proven at tri.al according toproof, but in Do event less than $ 107,900.05,~ (If more space is needed, check this box and attach a page designated as Affachmenl 4b.j 5. Jury or nonjury trial The party or parties request ~ a jury trial ~x a nonjury trial. (If more than one party, provide the name of each partyrequesting ajury triaij: 6. Trial date a. ~ The trial has been set for (date)l b. L x+ No trial date has been set. This case will be ready for trial within 12 months of the date of the filing of the complaint (Ifnot, explain): c. Dates on which parties or attorneys will not be available for trial (specify dates and explain reasons for unavailability):Please see attached 7. Estimated length of trial The party or parties estimate that the trial will take (check one): a. ~x days {specify number): 3 - 4 b. I hours (short causes) (specify): 8. Trial representation (to be answered for each party) The party or parties will be represented at trial ~x by the attorney or party listed in the caption ~ by the following:a. Attorney: b. Firm: c. Address: d. Telephone number: f. Fax number: e. E-mail address: g. Party represented:M Additional representation is described in Attachment 8. 9. Preference~ This case is entitled to preference (specify code section): 10. Alternative dispute resolution (ADR) a. ADR information package. Please note that different ADR processes are available in different courts and communities; readthe ADR information package provided by the court under rule 3.221 for information about the processes available through thecourt and community programs in this case. (1) For parties represented by counsel: Counsel ~x has ~ has not provided the ADR information package identifiedin rule 3.221 to the client and reviewed ADR options with the client. (2) For self-represented parties: Party ~ has ~ has not reviewed the ADR information package identified in rule 3.221. b. Referral to judicial arbitration or civil action mediation (if available). (1) ~Q This matter is subject to mandatory judicial arbitration under Code of Civil Procedure section 1141.11 or to civil actionmediation under Code of Civil Procedure section 1775.3 because the amount in controversy does not exceed thestatutory limit (2) ~ Plaintiff elects to refer this case to iudicial arbitration and agrees to limit recovery to the amount specified in Code ofCivil Procedure section 1141.11. {3) ~I This case is exempt from judicial arbitration under rule 3.811 of the California Rules of Court or from civil actionmediation under Code of Civil Procedure section 1775 et seq. (specify exemption): cM-110 IRe July 1, 2011I CASE MANAGEMENT STATENIENT Page 2 oi 5 PLAINTIFF/PETITIONER: STANFORD HEALTH CARE EFENDANT/RESPONDENT: COVENTRY HEALTH CARE J INC CASE NUMBER 20CV365904 CM-110 10. c. Indicate the ADR process or processes that the party or parties are willing to participate in, have agreed to participate in, orhave already participated in (check a/I that apply and provide /he specified mforma/ion)i The party or parties completing If the party or parties completing this form in the case have agreed tothis form are willing to participate in or have already completed an ADR process or processes,participate in the following ADR indicate the status of the processes (a/tach a copy of/he parlies'DRprocesses (check a/I that app/y): stipulation): (1) Mediation ~x Mediation session not yet scheduled~ Mediation session scheduled for (date): Agreed to complete mediation by (date):~ Mediation completed on(date): (2) Settlement conference ~x Settlement conference not yet scheduled~ Settlement conference scheduled for (date)i~ Agreed to complete settlement conference by (date)i~ Settlement conference completed on (date): (3) Neutral evaluation L, Neutral evaluation not yet scheduled~ Neutral evaluation scheduled for (dale):~ Agreed to complete neutral evaluation by (dale):~ Neutral evaluation completed on (date): (4) Nonbinding judicial arbitration i Judicial arbitration not yet scheduled j Q Judicial arbitration schedu/ed for (dale):~ Agreed to complete judicial arbitration by (date): Judicial arbitration completed on (dale): (5) Binding private arbitration I Private arbitration not yet scheduled~ Private arbitration scheduled for (dale):~ Agreed to complete private arbitration by (date)i~ Pdvate arbitration completed on (dale): (6) Other (specify): ~ ADR session not yet scheduled ADR session scheduled for (date):~ Agreed to complete ADR session by (dale): ADR completed on (date): CM-110 IRe July 1,2011l CASE MANAGEMENT STATEMENT P0003013 PLAINTIFF/PETITIONER: STANFORD HEALTH CARE DEFENDANT/RESPONDENT: COVENTRY HEALTH CARE, INC . CASE NUMBER'0CV365904 CM-110 11. Insurance a. M Insurance carrier, if any, for party filing this statement (nama): b. Reservauon of rights: ~ Yes ~ No c. ~ Coverage issues will significantly affect resolution of this case (explain): 12. Jurisdiction Indicate any matters that may affect the court's jurisdiction or processing of this case and describe the status. Bankruptcy ~ Other (specify): Status: 13. Related cases, consolidation, and coordination a. ~ There are companion, underlying, or related cases. (1) Nameofcase: (2) Name of court: (3) Case number: (4) Status: Additional cases are described in Attachment 13a. b. ~ A motion to ~ consolidate ~ coordinate will be filed by (name party): 14. Bifurcation M The party or parties intend to file a motion for an order bifurcating, severing, or coordinating the following issues or causes ofaction (specify moving parfy, type of motion, and reasons): 15. Other motions~ The party or parties expect to file the following motions before trial (specify moving party, type of motion, and issues): 16. Discovery a. ~ The party or parties have completed all discovery. b. ~x The following discovery will be completed by the date specified (describe ail anticipated discovery): Party Descriotion DatePlaintiff Form Interrogatories; Special Pursuant toInterrogatories C.C.P. CodePlaintiff Request for Admission; Request Pursuant tofor Production of Documents C.C.P. CodePlaintiff Deposition Pursuant to C.C.P. Code c. M The following discovery issues, including issues regarding the discovery of electronically stored information, areanticipated (specify): CM-110 [Reu July 1, 2011I CASE MANAGEMENT STATEMENT Pese 4 ef 0 PLAINTIFF/PETITIONER: STANFORD HEALTH CARE DEFENDANT/RESPONDENT. COVENTRY HEALTH CARE, INC. CASE NUMBER. 20CV365904 CM-110 17. Economic litigation a. ~ This is a hmited civil case (i.e., the amount demanded is $25,000 or less) and the economic litigation procedures in Codeof Civil Procedure sections 90-98 will apply to this case. b. ~ This is a limited civil case and a motion to withdraw the case from the economic litigation procedures or for additional discovery will be filed (If checked, explain specilically why economic litigation procedures relating io discovery or trialshould not apply to this case): 18. Otherissues~ The party or parties request that the following additional matters be considered or determined at the case management conference (specify): 19. Meet and confer a. ~ The party or parties have met and conferred with ail parties on ag subjects required by rule 3.724 of the Cahfornia Rules of Court (if not, explain): b. After meeting and conferring as required by rule 3.724 of the California Rules of Court, the parties agree on the following (specify): 20. Total number of pages attached (if any)) 1 I am completely familiar with this case and will be fully prepared to discuss the status of discovery and alternative dispute resolution,as well as other issues raised by this statement, and will possess the authority to enter into stipulations on these issues at the time ofthe case management conference, including the written authority of the party where required. Date; August 5, 2021 Aanchal V. Sanahvi. Esa. (TYPE OR PRINT NAME) (SIGNATURdo f PARTY OR ATTORNEY) (TYPE OR PRINT NAME) (SIGNATURE OF PARTY OR ATTORNEY) Additional signatures are attached. CM-110(Re .Jelyf,goi(i CASE MANAGEMENT STATEMENT Pege5015 SHDRTTITLFc STANFORD HEALTH CARE VS. COVENTRY HEALTH ) cwsuuusss CARE, INC. ! 20CV365904 ¹6c 3 10/18/21-10/22/21 Arb; 11/1/21-11/5/21 Trial; 12/6/21-12/10/21 Arbi 12/13/21- 4 12/17/21 Arbi 2/22/22-2/25/22 Arbi 3/7/22-3/10/22 Arbi 4/4/22-4/8/22 Arb; 5 5/2/22-5/6/22 Trial; 5/23/22-5/27/22 Arb; 6/27/22-7/8/22 Arb; 8/1/22-8/5/22 8 Trial; 9/19/22-9/30/22 Trial; 10/18/21-10/22/21 Arbi ll/1/21-11/5/21 Trial; 7 11/9/21-11/12/21 Arb; 11/15/21-11/19/21 Arbi 12/6/21-12/10/21 Arbi 12/13/21- 8 12/17/21 Arbi 1/10/22-1/14/22 Arbi 1/19/22-1/21/22 Arbi 1/28/22-2/4/22 9 Trial; 2/7/22-2/10/22 Arb; 37/22/22-3/10/22 Arb; 4/4/22-4/8/22 Arbi 5/2/22- 10 5/6/22 Trial; 5/11/22-5/14/22 Trial; 5/23/22-5/27/22 Arbi 6/10/22-6/14/22 11 Trial; 6/27/22-7/8/22 Arbi 8/1/22-8/5/22 Trial; 9/19/22-9/30/22 Trial; 12 11/3/22-11/4/22 Arb; ll/7/22-11/11/22 Arb 13 14 15 17 19 20 21 22 23 24 25 26 (Required for verified pleading) The items on this page stated on information and belief (specify item numbers, not linenumbers): 27 This page may be used with any Judicial Council form or any other paper filed with this court. page 6 ADDITIONAL PAGE Attach to Judicial Council Form or Other Court Paper SO tt ns. Q Btts PROOF OF SERVICE I am employed in the county of Los Angeles, State of California. I am overthe age of 18 and not a party to the within action; my business address is 303 NorthGlenoaks Boulevard, Suite 700, Burbank, California 91502-3226. On 6 August2021, I served the foregoing document(s) entitled: 6 CASE MANAGEMENT STATEMENT 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 by placing a true copy thereof enclosed in a sealed envelope addressed per theattached Service List. [ ] BY U.S. MAIL: I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing. Under that practice it would be deposited with the United States Postal Service on that same day with postage thereon fully prepaid at Burbank, California in the ordinary courseof business. I am aware that on motion of the party served, service is presumed invalid ifpostal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. [C.C.P. 1013a(3);F.R.C.P. 5(b)] BY FEDERAL EXPRESS: I caused such envelope(s), with overnightFederal Express Delivery Charges to be paid by this firm, to be deposited with the Federal Express Corporation at a regularly maintained facility onthe aforementioned date. [C.C.P. 1013(c) 1013(d)] BY PERSONAL SERVICE: I caused the above-stated document(s) to beserved by personally delivering a true copy thereof to the individuals identified above. [C.C.P. 1011(a); F.R.C.P. 5(b)] BY EXPRESS MAIL: I caused such envelope(s), with postage thereon fully prepaid and addressed to the party(s) shown above, to be deposited in afacility operated by the U.S. Postal Service and regularly maintained for thereceipt ofExpress Mail on the aforementioned date. [C.C.P. 1013(c)] [ ] BY TELECOPIER: Service was effected on all parties at approximately am/pm by transmitting said document(s) from this firm's facsimile machine (818/559-4477) to the facsimile machine number(s) shown above. Transmission to said numbers was successful as evidenced by aTransmission Report produced by the machine indicating the documents hadbeen transmitted completely and without error. C.R.C. 2008(e), Cal. Civ.Proc. Code $ 1013(e). [ X ] BY ELECTRONIC SERVICE: By emailing true and correct copies to the persons at the electronic notification address(es) shown on the accompanying service list. The document(s) was/were served electronically and the transmission was reported as complete and without error. [ X ] State: I declare under penalty ofperjury under the laws of the State ofCalifornia that the above is true and correct. Executed on 6 August 2021 in Burbank, California. 10 (,~ AIDA GRIGORJAN 12 13 14 15 16 17 19 20 21 22 23 25 26 27 SERVICE LIST PROSPERA LAW, LLP Richard J. Decker, Esq. Mare Berkemeier, Esq. Sean O'Neal, Esq. 1901 Avenue of the Stars, Suite 480 Los Angeles, CA 90067 Email: rdeckertknrosperalaw.corn mberkemeier&orosneralaw.corn soneal nrosneralaw.corn 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28