Application and Order Ex Parte

Cal. Super. - 6th Dist.April 1, 2021

on 5/26/2021 10:36 AM Reviewed By: R. Nguyen Envelope: 6523710 CM-020 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address): Kenneth M. Sigelman, Esq. State Bar No. 100238 Kenneth M. Sigelman & Associates 1901 First Avenue, 2nd Floor San Diego, CA 92101 TELEPHONE No.: (61 9) 238-381 3 FAX No. (Optional): (61 9) 238-1 866 E-MAIL ADDRESS (Optional): ken@sigelmanaSSOCiateS.60m ATTORNEY FOR(Name).- Plaintiff Brayden Le, a minor, etc. SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA STREET ADDRESS: 191 North First Street MAILING ADDRESS: CITY AND ZIP CODE: San Jose, CA 951 13 BRANCH NAME: PLAINTIFF/PETITIONER: Brayden Le, a Minor, etc. DEFENDANT/RESPONDENT: Good Samaritan Hospital, et al. FOR COURT USE ONLY PLEADING AND g ORDER EXTENDING TIME TO SERVE AND g ORDER CONTINUING CASE MANAGEMENT CONFERENCE CASE NUMBER:EX PARTE APPLICATION FOR EXTENSION OF TIME TO SERVE 21CV381451 (See Cal. Rules of Court, rule 3.1207(2).) 1. Applicant (name): Brayden Le, a Minor, By and Through His Guardian Ad Litem, Is Thanhtuyen Thi Dinh DEPT.: Note: This ex parte application will be considered without a personal appearance. HEARING DATE: TIME: plaintiff cross-complainant petitioner defendant cross-defendant respondent other (describe): DDDEDEE 2. The complaint or other initial pleading in this action was filed on (date): April 1, 2021 3. Applicant requests that the court grant an order extending time for service of the following pleading: a. g Complaint b. D Cross-complaint c. D Petition d. D Answerorotherresponsive pleading e. D Other (describe): 4. Service and filing of the pleading listed in item 3 is presently required to be completed by (date): June 1, 2021 5. Previous applications, orders, or stipulations for an extension of time to serve and file in this action are: a. g None b. D The following (describe all, including the length of any previous extensions): 6. Applicant requests an extension of time to serve and file the pleading listed in item 3 on the following parties (name each): Defendants Good Samaritan Hospital, HCA Health Services of California, |nc., C-HCA, |nc., and Allison Chan, M.D. FoJrrré/ApTrgvedfglarggtifipal use EX PARTE APPLICATION FOR EXTENSION OF TIME CM-ozo [Rev. January 1. 20081 TO SERVE PLEADING AND ORDERS Page 1 of 2 Cal. Rules of Court, rules 3.1 10, 3.1200-3.1207 www.courtinfo.ca.gov American LegalNet, Inc. www.FormsWorkflow.com Filed June 30, 2021 County of Santa Clara Superior Court of CA Clerk of the Court 21CV381451 By: RNguyen CM-020 CASE NAME: CASE NUMBER: Brayden Le, etc. v. Good Samaritan Hospital, et al. 21CV381451 7. The pleading has not yet been filed and served on the parties listed in item 6 for the following reasons (describe the efforts that have been made to serve the pleading and why service has not been completed): See response to No. 8 below. D Continued on Attachment 7. 8. An extension of time to serve and file the pleading should be granted for the following reasons: Plaintiff has been unable to serve defendants because the Civil Lawsuit Notice has not yet been received from Court. Plaintiff’s request an additional 45 days to allow time to receive the Civil Lawsuit Notice and effect service on all defendants. D Continued on Attachment 8. 9. If an extension of time is granted, filing and service on the parties listed in item 6 wi|| be completed by (date): July 16, 2021 10. Notice of this application under rules 3.1200-3.1207 D has been provided as required (describe all parties or counsel to whom notice was given; the date, time, and manner of giving notice; what the parties or counsel were told and their responses; and whether opposition is expected) or E is not required (state reasons): Defendants have not yet been served. D Continued on Attachment 10. 11. Number of pages attached: | declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Date: 05/26/2021 Kenneth M. Sigelman, Esq. >/MM (TYPE OR PRINT NAME OF APPLICANT OR ATTORNEY FOR APPLICANT) kIGNATURE OF APPLICANT ORMORNEY Order on Application is E below D on a separate document. ORDER . The application for an order extending time to serve and file the pleading is D granted D denied. NA . The pleading must be served and filed no later than (date): 9’ D The case management conference is rescheduled to: a. Date: b. Time: c. Place: 4. Otherorders: 5. A copy of this application and order must be served on all parties or their counsel that have appeared in the case. Date: JUDICIAL OFFICER CM-OZO IReV- Januawt 20°81 Ex PARTE APPLICATION FOR EXTENSION 0F TIME ”992°” To SERVE PLEADING AND ORDERS Amman LegalNet, m www.FormsWorkf/ow.com x JULY 31, 2021 June 29, 2021 Signed: 6/29/2021 05:58 PM