Request Judicial Notice

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 Cyrus Tabari SB No. 133842 Adam Stoddard SB N0. 272691 SHEUERMAN, MARTINI, TABARI, ZENERE & GARVIN A Professional Corporation 1033 Willow Street San Jose, California 95 125 (408) 288-9700 Fax: (408) 295-9900 Electronically Filed by Superior Court of CA, County of Santa Clara, on 2/5/2021 10:14 AM Reviewed By: F. Miller Case #20CV373797 Envelope: 5787410 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. COOK, Plaintiff, vs. GOOD SAMARITAN HOSPITAL, Defendant TO PLAINTIFF: Case No.2 20CV373797 REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF MOTION TO DEEM PLAINTIFF A VEXATIOUS LITIGANT PURSUANT TO C.C.P. § 391; REQUEST THAT PLAINTIFF FURNISH SECURITY PURSUANT TO C.C.P. § 391.1 & 391.3; REQUEST THAT PLAINTIFF BE PRECLUDED FROM FILING ADDITIONAL CASES Complaint Filed: December 2, 2020 Date: Time: 9:00 a.m. Dept: 2 Defendant GOOD SAMARITAN HOSPITAL, L.P. hereby requests this Court take judicial notice of the following cases Which have been filed by Plaintiff, CAROLINE COOK, in propria persona within the last two years. Judicial notice is requested pursuant t0 Evidence Code 452(d). The following are examples 0f litigations filed by Plaintiff in propria persona, Which have been adjudicated against her in the last two years as well as examples 0f repeated attempts t0 relitigate the same matter against the same parties: REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF MOTION TO DEEM PLAINTIFF A VEXATIOUS LITIGANT PURSUANT TO C.C.P. § 391; REQUEST THAT PLAINTIFF FURNISH SECURITY PURSUANT TO C.C.P. § 391.1 & 391 .3; REQUEST THAT PLAINTIFF BE PRECLUDED FROM FILING ADDITIONAL CASES - 1 ©OONONU1-5WNH NNNNNNNNNr-tr-tr-tr-tr-tr-tr-tr-tr-tr-t OONONU‘I-hUJNHOKDOOflO‘xUl-bWNP-‘O 0 Caroline Cook V. CHOMP (20CV003220) Monterey County Superior Court filed December 1, 2020: Complaint for general negligence and other various causes of action. Defendant’s counsel also represented CHOMP in that matter, filed a motion to deem Plaintiff a vexatious litigant, and then Plaintiff filed a dismissal 0f the case. Please see a copy 0f the Complaint and printout from the court docket confirming the matter was dismissed, attached to the Request for Judicial Notice (“RJN”) as Exhibit A. 0 Caroline Cook V. Mike Fuson (21CV000203) Monterey County Superior Court filed January 25, 2021: Securities Litigation. Please see a copy of a printout from the court docket confirming the matter was dismissed, attached to the RJN as Exhibit B. o Caroline Cook V. Robert Goetze, et a1. (20CV003535) Monterey County Superior Court filed December 29, 2020: Civil Harassment. Please see a copy 0f the printout from the court docket confirming the matter was dismissed, attached t0 the RJN as Exhibit C. 0 Caroline Cook V. Kathleen Smith (20CV003545) Monterey County Superior Court filed December 30, 2020: Civil Harassment. Please see a copy of the printout from the court docket confirming the matter was dismissed, attached to the RJN as Exhibit D. o Caroline Cook V. Robert Taylor, et a1. (20CV003533) Monterey County Superior Court filed December 29, 2020. PI/PD/WD. Please see a copy of the printout from the court docket confirming the matter was dismissed, attached t0 the RJN as Exhibit E. 0 Caroline Cook V. Monterey County Public Defenders Office (21CV000049) Monterey County Superior Court filed January 7, 2021. PI/PD/WD. Please see a copy of the printout from the court docket confirming the matter was dismissed, attached t0 the RJN as Exhibit G. o Caroline Cook V. Kenneth Trudell (21DV003533) Monterey County Superior Court filed January 12, 202 1. Domestic Violence without minor children. Please see a copy REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF MOTION TO DEEM PLAINTIFF A VEXATIOUS LITIGANT PURSUANT TO C.C.P. § 391; REQUEST THAT PLAINTIFF FURNISH SECURITY PURSUANT TO C.C.P. § 391.1 & 391.3; REQUEST THAT PLAINTIFF BE PRECLUDED FROM FILING ADDITIONAL CASES - 2 ©OONONU1-5WNH NNNNNNNNNr-tr-tr-tr-tr-tr-tr-tr-tr-tr-t OONONU‘I-hUJNHOKDOOflO‘xUl-bWNP-‘O 0f the printout from the court docket confirming the matter was dismissed, attached t0 the RJN as Exhibit H. 0 Caroline Cook V. David Trudell (21DV000018) Monterey County Superior Court filed January 12, 2021. Domestic Violence without minor children. Please see a copy of the printout from the court docket confirming the matter was dismissed, attached to the RJN as Exhibit I. o Caroline Cook V. Mike Fuson (21CV000203) Monterey County Superior Court filed January 25, 2021. Securities Litigation. Please see a copy of the printout from the court docket confirming the matter was dismissed, attached to the RJN as Exhibit J. o Caroline Cook V. Sue Selfridge (20CH009268) Santa Clara County Superior Court filed April 6, 2020. TRO. Please see a copy of the printout from the court docket confirming the TRO was denied multiple times and the matter was dismissed, attached to the RJN as Exhibit K. o Caroline Cook V. Bruce McGlynn (20DV00027 1) Santa Clara County Superior Court filed April 10, 2020. TRO. Please see a copy 0f the printout from the court docket confirming the TRO was denied, attached to the RJN as Exhibit L. o Caroline Cook V. A1 James (20DV000270) Santa Clara County Superior Court filed April 10, 2020. TRO. Please see a copy 0f the printout from the court docket confirming the TRO was denied multiple times and the matter was dismissed, attached t0 the RJN as Exhibit M. 0 Caroline Cook V. Robert Goetze (20DV000274) Santa Clara County Superior Court filed April 13, 2020. Domestic Violence TRO. Please see a copy of the printout from the court docket confirming the TRO was denied multiple times and the matter was dismissed, attached t0 the RJN as Exhibit N. o Caroline Cook V. Kathleen Smith (20CH009284) Santa Clara County Superior Court filed April 14, 2020. Civil Harassment TRO. Please see a copy 0f the printout from the court docket confirming the TRO was denied multiple times and the matter was dismissed, attached to the RJN as Exhibit O. REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF MOTION TO DEEM PLAINTIFF A VEXATIOUS LITIGANT PURSUANT TO C.C.P. § 391; REQUEST THAT PLAINTIFF FURNISH SECURITY PURSUANT TO C.C.P. § 391.1 & 391.3; REQUEST THAT PLAINTIFF BE PRECLUDED FROM FILING ADDITIONAL CASES - 3 ©OONONU1-5WNH NNNNNNNNNr-tr-tr-tr-tr-tr-tr-tr-tr-tr-t OONONU‘I-hUJNHOKDOOflO‘xUl-bWNP-‘O Caroline Cook V. John Nolan (20DV000381) Santa Clara County Superior Court filed June 2, 2020. Domestic Violence Prevention without Minor. Please see a copy of the printout from the court docket confirming matter was dismissed, attached to the RJN as Exhibit P. Caroline Cook V. Allan James (20DV000414) Santa Clara County Superior Court filed June 12, 2020. Domestic Violence Prevention Without Minor. Please see a copy 0f the printout from the court docket confirming the TRO was denied multiple times and the matter was dismissed, attached t0 the RJN as Exhibit Q. Caroline Cook V. Mike Fuison (20DV000507) Santa Clara County Superior Court filed July 16, 2020. Domestic Violence Prevention Without Minor. Please see a copy 0f the printout from the court docket confirming the TRO was denied multiple times and the matter was closed, attached t0 the RJN as Exhibit R. Caroline Cook V. Jose Barbosa Resende (20DV0007 1 6) Santa Clara County Superior Court filed October 1, 2020. Domestic Violence Prevention without Minor. Please see a copy 0f the printout from the court docket confirming the TRO was denied and the matter was closed, attached t0 the RJN as Exhibit S. Caroline Cook V. Juan Peirria (20DV000733) Santa Clara County Superior Court filed October 8, 2020. Domestic Violence Prevention Without Minor. Please see a copy of the printout from the court docket confirming the TRO was denied and the matter was closed, attached to the RJN as Exhibit T. Caroline Cook V. Kathleen Hudgens (20CV373442) Santa Clara County Superior Court filed November 20, 2020. Defamation. Please see a copy of the printout from the court docket confirming the matter was dismissed, attached to the RJN as Exhibit U. Caroline Cook V. Monterey County Public Defender’s Office (20CV373619) Santa Clara County Superior Court filed November 24, 2020. PUPD/WD. Please see a copy of the printout from the court docket confirming the matter was dismissed, attached to the RJN as Exhibit V. REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF MOTION TO DEEM PLAINTIFF A VEXATIOUS LITIGANT PURSUANT TO C.C.P. § 391; REQUEST THAT PLAINTIFF FURNISH SECURITY PURSUANT TO C.C.P. § 391.1 & 391.3; REQUEST THAT PLAINTIFF BE PRECLUDED FROM FILING ADDITIONAL CASES - 4 ©OONONU1-5WNH NNNNNNNNNr-tr-tr-tr-tr-tr-tr-tr-tr-tr-t OONONU‘I-hUJNHOKDOOflO‘xUl-bWNP-‘O 0 Caroline Cook V. David Trudell (20CV373663) Santa Clara County Superior Court filed November 30, 2020. Professional Negligence. Please see a copy of the printout from the court docket confirming the matter was dismissed, attached to the RJN as Exhibit W. o Caroline Cook V. Kenneth Trudell (20CV373662) Santa Clara County Superior Court filed November 30, 2020. Professional Negligence. Please see a copy 0f the printout from the court docket confirming the matter was dismissed, attached t0 the RJN as Exhibit X. o Caroline Cook V. Kenny Trudell (20CH009447) Santa Clara County Superior Court filed July 20, 2020. Civil Harassment. Please see a copy 0f the printout from the court docket confirming the matter was dismissed, attached to the RJN as Exhibit Y. o Caroline Cook V. Michelle Doty (20CH009460) Santa Clara County Superior Court filed July 24, 2020. Civil Harrassment. Please see a copy of the printout from the court docket confirming the TRO was denied and the matter was dismissed, attached t0 the RJN as Exhibit Z. 0 Caroline Cook V. Pat Starling (20CH009459) Santa Clara County Superior Court filed July 24, 2020. Civil Harassment. Please see a copy 0f the printout from the court docket confirming the TRO was denied and the matter was dismissed, attached to the RJN as Exhibit AA. o Caroline Cook V. John Nolan (20CH009464) Santa Clara County Superior Court filed July 27, 2020. Civil Harassment. Please see a copy 0f the printout from the court docket confirming the TRO was denied and the matter was dismissed, attached t0 the RJN as Exhibit BB. o Caroline Cook V. Bruce McGlynn (20CH009463) Santa Clara County Superior Court filed July 27, 2020. Civil Harassment. Please see a copy 0f the printout from the court docket confirming the TRO was denied and the matter was dismissed, attached t0 the RJN as Exhibit CC. When a party requests that the Court take notice of such matters and gives the other parties sufficient notice 0f the request t0 enable the adverse party t0 meet the request, and REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF MOTION TO DEEM PLAINTIFF A VEXATIOUS LITIGANT PURSUANT TO C.C.P. § 391; REQUEST THAT PLAINTIFF FURNISH SECURITY PURSUANT TO C.C.P. § 391.1 & 391.3; REQUEST THAT PLAINTIFF BE PRECLUDED FROM FILING ADDITIONAL CASES - 5 ©OOQO\UI#UJI\JH NNNNNNNNNr-tr-tr-tr-tr-tr-tr-tr-tr-tr-t OOQQUI-bUJNHOOOOflONLh-bUJNV-‘O furnishes the Court With sufficient information t0 enable it t0 take judicial notice of the matter, judicial notice is mandatory. (Evidence Code § 453.) SHEUERMAN, MARTINI, TABARI, ERE GARVIN Date: February 5, 2021 By: CYRUS A. TABARI ADAM M. STODDARD Attorneys for Defendant GOOD SAMARITAN HOSPITAL, L.P. REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF MOTION TO DEEM PLAINTIFF A VEXATIOUS LITIGANT PURSUANT TO C.C.P. § 391; REQUEST THAT PLAINTIFF FURNISH SECURITY PURSUANT TO C.C.P. § 391.1 & 391.3; REQUEST THAT PLAINTIFF BE PRECLUDED FROM FILING ADDITIONAL CASES - 6