Request DismissalCal. Super. - 6th Dist.April 10, 2020AT TDRNE Y QR pARTY wITHDU T ATTDRNEY (Name, sfale Bar numoar and address) Karlene Rogers-Aberman (237883) Stephenson, Acquisto & Co(man, Inc. 303 N. Glenoaks Blvd. «700, Burbank, CA 91502-3226 E HDNE No (818) 559"4477 Fnx No Iopm I) (818) 559 5484 E-MAIL ADDRESS (Oplanag »»RNEY «R I"'a') Plaintiff. STANFORD HEALTH CARE supERIDR coURT oF GALIFoRNIA, coUNTY DF Santa Clara-Unlimited Jurisdiction sTREETADDREss 191 N. First Street MAILING ADDRESS same CITYANDEIPCDDE San Jose, California 95113-1090 BRANOH NAME Downtown Superior Court PLAINTIFF/PETiTIONER: STANFORD HEALTH CARE DEFENDANT/RESPONDENT: BLUE CROSS OF CALIFORNIA FOR COURT USE ONLY CIV-110 REQUEST FOR DISMISSAL CASE NUMBER 20CV366076 A conformed copy will not be returned by the clerk unless a method of return is provided with the document. This form may not be used for dismissal of a derivative action or a class action or of any party or cause of action in a class action. (Cal. Rules of Court, rules 3.760 and 3.770.) 1. TO THE CLERK. Please dismiss this action as fofioww a. (1) ~J'ith prejudice (2) ~ Without prejudice b (1) ~ Complaint (2) ~ Petition (3) ~ Cross-complaint filed by (nsme): on (date): (4) ~ Cross-complaint filed by (name): on (date): (5) MY Entire action of afi parties and afi causes ofaction (6)~ Other (specify):* 2. (Complete in a/I cases except femdy law cases.) The court ~ did Z] did not waive court fees and costs for a party in this case. (This information msy be obtained from ihe clerk. (r court fees end costs were waived, the declaration on the tleck o 's fo m,be comp ted). Date: 7/23/2020 )IAARLENE (to(DERsrABERMAN (TYPE OR PRINT NAME OF ~ ATTORNEY ~ PARTY WITHOUT ATTORNEY) (SIGNATURE) *If dismissal requested is of specified parties only of speafied causes of action Attcrney Or party WithOut attOrney far: o y, o sp afR cms~mplsinu only, so state snd idensfy the Parties. ~g plaintiff/petit(oner ~ Defendant/Resp(causes of action, or cross-complaints to be dismissed Cross-Complainant 3. TO THE CLERK: Consent to the above dismissal is hereby given Date: (TYPEOR PRINT NAMEOF ~ ATTORNEY ~ PARTYIMTHOUTATTORNEY) * If a cross-complaint-or Response (Family Law) seeking affirmative relmf - is on file, the attorney for cross-complainant (mspondent) must sign this consent d required by code of civil procedure section Ssl (i) o (i) (To be completed by clerk) 4 ~ Dismissal entered as requested on (date); (SIGNATURE) Attorney or party without attorney for: Plaintiff/Petitioner ~ Defendant/Respondent Cross-Complainant 5 ~ Dismissal entered on (date): as to only (name): 6. ~ Dismissai not entered as requested for the following reasons (specify): 7. a. M Attorney or party without attorney notified on (date): b. ~ Attorney or party without attorney not notified. Filing party failed to provideH a copy to be conformed H means to return conformed copy Date Form Adopted for Mmdalory Use Judiaal Caunal of Caldomia Clu-110 [Rev Jen I, 2D13) Clerk, by REQUEST FOR DISMISSAL , Deputy Page 1 of 2 Cods of Ova Procedure, g SBI et ssq. Gov Code, g SSS3T(c). Csl Rules of Court rule 3 1390 www cauda ca.go v X X /s/ A. Floresca /s/ A. Floresca Clerk of Court 7/30/2020 4:56 PM 7/30/2020 4:56 PM 7/30/2020 4:56 PM Electronically Filed by Superior Court of CA, County of Santa Clara, on 7/30/2020 4:56 PM Reviewed By: A. Floresca Case #20CV366076 Envelope: 4688615 20CV366076 Santa Clara - Civil A. Floresca PLAINTIFF/PETITIONER STANFORD HEALTH CARE DEFENDANT/RESPONDENT: BLUE CROSS OF CALIFORNIA ! CASE NUMBER'0CV366076 CIV-110 COURT'S RECOVERY OF WAIVED COURT FEES AND COSTS If a party whose court fees and costs were initially waived has recovered or will recover $ 10,000 ormore in value by way of settlement, compromise, arbitration award, mediation settlement, or other means, the court has a statutory lien on that recovery The court may refuse to dismiss the case untilthe lien is satisfied. (Gov. Code, g 68637.) Declaration Concerning Waived Court Fees 1. The court waived court fees and costs in this action for (name): 2. The person named in item 1 is (check one below) e C7 not recovering anything of value by this action. b ~ recovering less than $10,000 in value by this action c. ~ recovering $ 10,000 or more in value by this action. (If item 2c is checked, item 3 must he completed.) 3. C] All court fees and court costs that were waived in this action have been paid to the court (check one): ~ Yes M No I dedare under penalty of perjury under the laws of the State of California that the information above is true and correct. Date: (TYPE OR PRINT NAME OF ~ ATTORNEY~ PARTY MAKING DECLARATION) (SIGNATURE) CIV110[Reu January1,2013] REQUEST FOR DISNIISSAL Page 2 of 2 PROOF OF SERVICE I am employed in the county of Los Angeles, State of California. I am over the age of 18 and not a party to the within action; my business address is 303 North Glenoaks Boulevard, Suite 700, Burbank, California 91502-3226. On 30 July 2020, I served the foregoing document(s) entitled: 9 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 REQUEST FOR DISMISSAL - ENTIRE ACTION by placing a true copy thereof enclosed in a sealed envelope addressed per the attached Service List. BY 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 course ofbusiness. 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 PERSONAL SERVICE: I caused the above-stated document(s) to be served by personally delivering a true copy thereof to the individuals identified above. [C.C.P. 1011(a); F.R.C.P. 5(b)] 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 a Transmission Report produced by the machine indicating the documents had been transmitted completely and without error. C.R.C. 2008(e), Cal. Civ. Proc. Code $ 1013(e). BY FEDERAL EXPRESS: I caused such envelope(s), with overnight Federal Express Delivery Charges to be paid by this firm, to be deposited with the Federal Express Corporation at a regularly maintained facility on the aforementioned date. [C.C.P. 1013(c) 1013(d)] 26 27 28 [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] BY ELECTRONIC SERVICE [BY COURT]: by causing the foregoing document(s) to be electronically filed using the Court's Electronic Filing System which constitutes service of the filed document(s) at the electronic service address of the individual(s) listed on the attached mailing list. [ ] State: I declare under penalty ofperjury under the laws of the State of California that the above is true and correct. 9 10 [X] Federal: I declare that I am employed in the office of a member of the bar of this court at whose direction the service was made. 12 Executed on 30 July 2020 in Burbank, California 13 14 15 16 UU ) ANGELA DEMERS 17 18 19 20 21 22 23 24 25 26 27 SERVICE LIST TROUTMAN SANDERS LLP Chad R. Fuller, Esq. Jenna Nguyen, Esq. 5 Park Plaza, ite 1400 Irvine, CA 92614-2545 chad.fuller@troutman.corn jerma.nguyen@troutman.corn 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 \OOONOUIAUJNr-A NNNNNNNNNt-dr-tp-An-sr-tp-ip-nr-Av-‘p-a OOQQUIAUJNF-‘OOOONQUIAUJNHO . ul r, s . guyen, s . l , , u ler@troutman.com j nn nguyen@t 0utm com