Motion Amended

Cal. Super. - 6th Dist.December 2, 2020

©OONONU1-5WNH NNNNNNNNNr-tr-tr-tr-tr-tr-tr-tr-tr-tr-t OONONU‘I-hUJNHOKDOOflO‘xUl-bWNP-‘O 200V373797 Santa Clara - Civil Electronically Filed Cyrus Tabari SB No. 133842 b - y Superior Court of CA,Adam Stoddard SB N0. 272691 county of Santa Clara, SHEUERMAN, MARTINI, TABARI, ZENERE & GARVIN on 3/12/2021 9:03 AMA Professional Corporation Reviewed By- M Scrum 1033 willowrsftregt Case #20CV373797 San Jose, Ca 1 ornla 95125 Enve|ope: 6020906 (408) 288-9700 Fax; (408) 295-9900 Attorneys for Defendant GOOD SAMARITAN HOSPITAL, L.P. SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF SANTA CLARA CAROLINE M. COOK DBA CAROLINE M. Case N0.: 20CV373797 COOK, AMENDED NOTICE OF MOTION TO . . DEEM PLAINTIFF A VEXATIOUS Plalmlffl LITIGANT PURSUANT T0 C.C.P. § 391; VS. REQUEST THAT PLAINTIFF FURNISH SECURITY PURSUANT TO C.C.P. § GOOD SAMARITAN HOSPITAL, 391,1 & 3913; REQUEST THAT PLAINTIFF BE PRECLUDED FROM FILING ADDITIONAL CASES PURSUANT TO C.C.P. § 391.7(A) Complaint Filed: December 2, 2020 Defendant Date: May 6, 2021 Time: 9:00 a.m. Dept: 2 TO PLAINTIFF: PLEASE TAKE NOTICE that on May 6, 2021 at 9:00 a.m. or as soon thereafter as the matter can be heard in Department 2 ofthe above-entitled court, located at 191 North First Street, San Jose, California 951 13, Defendant GOOD SAMARITAN HOSPITAL, L.P. will move this Court for an order deeming Plaintiff a vexatious litigant pursuant t0 C.C.P. § 391; request that Plaintiff furnish security pursuant to C.C.P. § 39 1 .1 and 39 1 3(a); and order that Plaintiff cannot file another lawsuit in California Without first being granted leave of Court pursuant t0 C.C.P. § 391.7(a). AMENDED NOTICE 0F MOTION T0 DEEM PLAINTIFF A VEXATIOUS LITIGANT PURSUANT To C.C.P. § 391; REQUEST THAT PLAINTIFF FURNISH SECURITY PURSUANT T0 C.C.P. § 391.1 & 391.3; REQUEST THAT PLAINTIFF BE PRECLUDED FROM FILING ADDITIONAL CASES PURSUANT T0 C.C.P. § 391.7(A) _ 1 M. Sorum ©OOQO\Ul-RUJI\JH NNNNNNNNNr-tr-tr-tr-tr-tr-tr-tr-tr-tr-t OOQQUr-bwwv-‘OKOOOQONUI-bwwr-io This motion will be based upon this notice, the Memorandum 0f Points and Authorities filed herewith, the Declaration 0f Adam M. Stoddard, the Request for Judicial Notice, the pleadings and papers on file herein, and upon such oral and/or documentary evidence that may be presented at the time of the hearing. The Court follows CRC 3.1308(a)(1) for those departments that have elected t0 issue tentative rulings in civil law and motion and discovery matters. Counsel and litigants are responsible for determining Whether the department hearing their motion has made this election. Those departments issuing tentative rulings Will do so generally by 2:00 p.m., and n0 later than 3:00 p.m., on the court day preceding the scheduled hearing. If the Court has not directed oral argument, a party contesting a tentative ruling must give notice 0f its intention t0 appear t0 the other side and the Court no later than 4:00 p.m. 0n the court day preceding the scheduled hearing. Appearances may be made by telephone (through CourtCall) or in person. The tentative ruling Will automatically become the order of the Court 0n the scheduled hearing date if the Court has not directed oral argument and if the contesting party fails to timely notice an objection t0 the other side and the Court. Tentative rulings Will be posted 0n the Court's website, www.scscourt.0rg, Where further information may be found. If a party does not have access to the intemet, the tentative ruling may be accessed by calling Court Services at (408) 882-2515. Questions about these procedures may be addressed t0 the specific department where the matter is t0 be heard. Date: March 12 2021 SHEUERMAN, MARTINI, TABARI, IN By: CYRUS A. TABARI ADAM M. STODDARD Attorneys for Defendant GOOD SAMARITAN HOSPITAL, L.P. AMENDED NOTICE 0F MOTION T0 DEEM PLAINTIFF A VEXATIOUS LITIGANT PURSUANT To C.C.P. § 391; REQUEST THAT PLAINTIFF FURNISH SECURITY PURSUANT T0 C.C.P. § 391.1 & 391.3; REQUEST THAT PLAINTIFF BE PRECLUDED FROM FILING ADDITIONAL CASES PURSUANT T0 C.C.P. § 391.7(A) - 2