Motion OtherCal. Super. - 6th Dist.August 25, 2021LALEZARY LAW FIRM, LLP 8370 Wilshire Blvd, Suite 205 Beverly Hills, California 90211 KOOOQQUI-hUJNr-k NNNNNNNNNr-dr-tr-tr-AHr-Ar-kr-tr-tr-t OOQO‘xUl-PUJNHOKOOOQONUl-RUJNF-‘O 21 CV388295 Santa Clara - Civil SherVin Lalezary, Esq. (SBN 260567) Shawn Lalezary, Esq. (SBN 291733) Timothy C. Walker-Dupler, Esq. (SBN 322257) LALEZARY LAW FIRM, LLP 8370 Wilshire B1Vd., Suite 205 Beverly Hills, California, 90211 Phone: (310) 550-8888 Fax: (310) 550-8988 tc@bhfirm.com service@bhfirm.com Attomeys for Plaintiff, Meiying Liu SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA MEIYING LIU, an individual; Plaintiff, V. XU HU, an individual; XI LIU, individual; and DOES 1 t0 50, inclusive; an Defendants. M. Domin Electronically Filed by Superior Court of CA, County of Santa Clara, on 1/6/2022 11:24 AM Reviewed By: M. Dominguez Case #21 CV388295 Envelope: 7997268 Case N0.: 21CV388295 Judge: Hon. Peter Manoukian Dept: 20 PLAINTIFF’S NOTICE OF MOTION; MOTION FOR AN ORDER GRANTING PREFERENCE PURSUANT TO CODE OF CIVIL PROCEDURE § 36 [Filed concurrently with Declaration 0f Timothy C. Walker-Dupler and [Proposed] Order] Filing date: 8/25/21 Trial date: Not set PLAINTIFF’S NOTICE OF MOTION AND MOTION FOR AN ORDER GRANTING PREFERENCE PURSUANT TO CODE OF CIVIL PROCEDURE § 36 1 guez Dept.20 9:00am 3-3-22 LALEZARY LAW FIRM, LLP 8370 Wilshire Blvd, Suite 205 Beverly Hills, California 90211 KOOOQOUl-hUJNr-k NNNNNNNNNr-dr-tr-tr-tr-Ar-Ar-kr-tr-tr-t OOQO‘xUl-bUJNHOKOOOflQUl-RUJNF-‘O TO THE COURT, ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTE THAT 0n March 3, 2022 at 9:00 a.m. or soon thereafter as the matter may be heard, PlaintiffMEIYING LIU (“Plaintiff”) will move the Santa Clara Court, located at 72 W Santa Clara St, Ventura, CA 93001, Department 20, for an Order granting a preference for trial-setting to the above entitled action on grounds that Plaintiff is over the age of 70, that Plaintiff has substantial interest in the case as a Whole, and that Plaintiff” s health makes trial preference necessary to prevent prejudice t0 Plaintiff” s interest in the lawsuit. Additionally, this motion is made pursuant to Code of Civil Procedure § 36(a), (c)(1)(2) and (f), California Rules of Court 3.1335(a), relevant case law and the following grounds: 1. On February 25, 2020, Plaintiff (then 81 years of age was severely injured when Defendants’ dog viciously bit and attacked her as she was walking on a public sidewalk. The incident caused, among other things, puncture wounds in her left ankle/shin, resulting in 17 stitches, puncture to her right breast, puncture wounds to her right thumb and emotional injuries. 2. On August 25, 2021, Plaintiff filed a lawsuit against Defendants Xu Hu and Xi Liu for her injuries. 3. Plaintiff is diagnosed with anemia and hyperlipidemia. 4. A preference request can be claimed by notice motion “at any time” during the pendency ofthe litigation. C.P.C. § 36(c)(2). This motion is further based upon this notice, the attached memorandum 0f points and authorities, the Declaration 0f Timothy C. Walker-Dupler, the [proposed] order filed concurrently herewith, and all papers, records, and documents on file herein, and upon evidence, oral and documentary, to be presented at the hearing of this motion. DATED: January 6, 2022 LALEZARY LAW FIRM, LLP aw Timothy C. Walker-Dupler, Esq. Attorneys for Plaintiff, MEIYING LIU By: PLAINTIFF’S NOTICE OF MOTION AND MOTION FOR AN ORDER GRANTING PREFERENCE PURSUANT TO CODE OF CIVIL PROCEDURE § 36 2 LALEZARY LAW FIRM, LLP 8370 Wilshire Blvd, Suite 205 Beverly Hills, California 90211 KOOOQQUI-hUJNH NNNNNNNNNHHHHHHHHHH OOQONM-bUJNHOKOOOQONmAmNt-O MEMORANDUM OF POINTS AND AUTHORITIES I. INTRODUCTION PlaintiffMEYING LIU (“Plaintiff”), brings this motion pursuant t0 California Code 0f Civil Procedure § 36, for an order granting a preference for trial setting 0n the grounds that Plaintiff is over the age 0f 70, that Plaintiffhas a substantial interest in the case as a whole, and that Plaintiff” s health makes a preference necessary to prevent prejudice t0 Plaintiff” s interest in the lawsuit. Plaintiff filed this lawsuit 0n August 25, 2021, against Defendants Xu Hu and Xi Liu for injuries sustained in a dog attack 0n February 25, 2020. Plaintiff (DOB: 4/15/38) is currently 83 years of age. Plaintiffhas been diagnosed anemia and hyperlipidemia, as detailed in the Declaration of Timothy C. Walker-Dupler, attached hereto. II. PLAINTIFF’S REQUEST FOR PREFERENCE IN SETTING THE TRIAL DATE CAN BE MADE AT ANY TIME BY NOTICED MOTION A preference can be claimed by notice motion “at any time” during the pendency of the litigation.g § 36(c)(2). III. PLAINTIFF IS ENTITLED TO TRIAL PREFERENCE Pursuant to Code 0f Civil Procedure § 36(a): A party t0 a civil action Who is over 70 years 0f age may petition the court for a preference which the court shall grant if the court makes both of the following findings: (1) The party has a substantial interest in the action as a Whole (2) The health 0f the party is such that a preference is necessary t0 prevent prejudicing the party’s interest in the litigation. C.C.P. § 36 (a). Plaintiff meets the requirements of these mandatory provisions: 1. Plaintiff is currently 82 years 01d. Declaration 0f Timothy C. Walker-Dupler 1] 3. 2. Plaintiff has a substantial interest in the case as a whole. She claims negligence, strict liability for animal with known dangerous propensities, and strict liability through Civil Code § 3342, for injuries caused by Defendants’ dog, which resulted in substantial damages t0 her person and wellbeing. Dupler Decl. 11 4. PLAINTIFF’S NOTICE OF MOTION AND MOTION FOR AN ORDER GRANTING PREFERENCE PURSUANT TO CODE OF CIVIL PROCEDURE § 36 3 LALEZARY LAW FIRM, LLP 8370 Wilshire Blvd, Suite 205 Beverly Hills, California 90211 KOOOQQUI-hUJNH NNNNNNNNNHHHHHHHHHH OOQONM-bUJNHOKOOOQONmAmNt-O 3. Based on Plaintiff’s elderly age 0f 82, and the fact that her physical condition is declining over time, and is 0f reasonable concern, trial should be set Within 120 days 0f hearing this motion. Dupler Decl. 1] 5. A declaration supporting a motion for § 36(a) preference may be signed by the attorney for the party seeking preference based upon the information and belief as to the medical condition 0f the party seeking preference. C.P.C. § 36.5. 4. Plaintiff suffered major injuries in the subject incident and suffers concurrent medical problems that place her health seriously at risk. Plaintiff has chronic health problems including anemia and hyperlipidemia Which limits her life span. Dupler Decl. 1] 6, EX. 1. 5. Plaintiff’s chronic health conditions and age put her at increased risk 0f suffering from severe symptoms 0r mortality from COVID-19. Dupler Decl. 1] 7, EX. 2. A prognosis of Plaintiff’s life expectancy is not required, so long as sufficient information is provided about the Plaintiff’s diagnosis. FOX V. Superior Court (2018) 21 Cal. App. 5th 529. In m, the appellate court found that the trial court abused its discretion in denying a plaintiff” s motion for trial preference based 0n the plaintiff’s health and being over 70 years 0f age, where it was uncontroverted that the plaintiff has Stage IV lung cancer, severe coronary artery disease, and a deteriorated mental stated. As the plaintiff in FOX, Plaintiff” s health is in severe distress. Over time, Plaintiff” s health conditions Will only get worse, t0 the point she will be unable t0 protect her interests in this lawsuit and may not even survive t0 the due process trial date that has not yet been set. In addition to Plaintiff” s advanced age, her health conditions put her at increased risk, should she become infected with COVID-19. Plaintiff is the only person who can protect her interests in this matter. Accordingly, Plaintiff is entitled t0 an order granting trial preference. IV. IF THE COURT GRANTS A MOTION FOR PREFERENCE UNDER CODE OF CIVIL PROCEDURE §36(A), THE TRIAL DATE CANNOT BE DELAYED If the court grants a motion for preference underE § 36(a), it must set the case for trial within 120 days after the motion is granted. C.C.P. §36(f); see Sprowl V. Superior Court (Ravmark Industries) 1990 219 Cal.App.3d 777, 780 (failure to set not excused by court congestion); Miller PLAINTIFF’S NOTICE OF MOTION AND MOTION FOR AN ORDER GRANTING PREFERENCE PURSUANT TO CODE OF CIVIL PROCEDURE § 36 4 LALEZARY LAW FIRM, LLP 8370 Wilshire Blvd, Suite 205 Beverly Hills, California 90211 KOOOQOUl-hUJNr-k NNNNNNNNNr-dr-tr-tr-tr-Ar-Ar-kr-tr-tr-t OOQO‘xUl-PUJNHOKOOOQQUI-RUJNF-‘O V. Superior Court (Simpson) 1990 221 Cal.App.3d 1200, 1202-03 (entitled t0 priority over “fast track” cases). Moreover, if a C.C.P. § 36(a) preference is granted, the court has n0 discretion to delay the trial setting. Vinokur V. Superior Court (Azevedo) (1988) 198 Cal.App.3d 500, 502-03. The court cannot balance conflicting interests of opposing litigants. Thus, trial must be set Within 120 days even ifopposing parties have not completed discovery 0r pretrial preparations. Swaithes V. Superior Court gHunterg 212 Cal.App.3d 1082, 1086. V. CONCLUSION For the reasons stated above, Plaintiff respectfully requests that the court grant this motion and order that the trial date be scheduled for a date within the next 120 days and entitled to preference. DATED: January 6, 2022 LALEZARY LAW FIRM, LLP . W Timothy C. Walker-Dupler, Esq. Attorneys for Plaintiff, MEIYING LIU PLAINTIFF’S NOTICE OF MOTION AND MOTION FOR AN ORDER GRANTING PREFERENCE PURSUANT TO CODE OF CIVIL PROCEDURE § 36 5 HRCI May 25 2021 10:296m P003/012 )t 00c! PATIENT: Meiying Liu DATE OF BIRTH: 04/15/1938 DATE: 01/07/2021 10:40 AM HISTORIAN: self and daughter PROVIDER: Wang Ping Zhao MD VESiT TYPE: Office Visit This is a Telehealth visit Mode of communication: audio/video (Zoom) Call initiated by me (physician) to f/up her chronic disease in-person Visit converted into te§ehealth visit due to COV|D~19 pandemic Connection was Synchronous Verbal consent by patient Performed at clinic office (patient at home) Interpreter needed: No This 82 year old female presents for follow up of elevated AST. History of Present illness: 1. Follow Up of elevated AST She has mild elevated AST. She has been asymptomatic. Recheck labs on 12/29/2020 still showed: borderline elevated AST 34, other LFTs WNL. She had abdominal US 0n 9/10/2020 at VRI, IMPRESSION: Slight fatty tnfittration of the liver. Single cyst each kidney, incidental finding. PROBLEMLIST: u m A __ _ _‘ P'ro blem Description .1 3‘ -; (Oris’etiwD‘aitiéi‘yfl 2 I Anemia, unspecified Osteoporosis, unspecified 1mpaired fasting glucose Lumbago with sciatica Hypercholesterolemia MedicaI/Surgical/lnterim History Reviewed, no changes. Last detailed document date: 09/01/2020. Family History: Liu, Meiying 000000001212 04/15/1938 01/07/2021 10:40 AM 1/3 HHCI May 28 2021 10:29am P004/012 Reviewed, no changes, Last detailed document date: 09/01/2020. Social History: Reviewed, no changes. Last detailed document date: 09/01/2020. Medications Reconciled/Reviewed Medications reconciled Adherence 7 :JMedIcatIon N'ame ,gDesc‘” '7 Status taking as directed Caicium Vitamin D OTC Verified taking as directed Mapap (acetaminophen) 325 take 1-2 tablet by oral route every 8 N Verified mg tablet hours as needed for pain Medications (AH Active) AllActive - ‘ ., ‘ Sig Desc ‘ “ , Mapap (acetaminophen) 325 take 1 -2 tablet by oral route every 8 N mg tablet hours as needed for pain Calcium-Vitamin D OTC Y Allergies No known aliergles Ingredient No KNOWN ALL‘E‘éGaEs Reviewed, n0 changes. Review of Systems System '_ I j ,Neg/Po’s‘ ‘ Details » ‘j Constitutional Negative Fatigue and Weight loss. GI Negative Abdominal pain, Decreased appetite, Diarrhea, Nausea and Vomiting. Psych Negative Feeling down, depressed 0r hopeless and Little interest or pleasure in doing things‘ lntegumentary Negative Jaundice and Pruritus‘ Physicai Exam (through video, physicai exam limited due to teiehealth) Exam Fmdmgs Details ‘ _ , 3' v ‘ w a Constitutional Level of distress - no acute distress Nourishment - well nourished. Overall appearance - age appropriate. Neck Exam Normal Inspection - Normal. Respiratory Normal Inspection - Normal‘ Effort - Normai. Skin Normal Inspection - Normal. Extremity Normal No edema, Psychiatric Normai Appropriate mood and affect. Completed Orders (this encounter) 7 _ I Order ' 7 , ‘ Details Reason Side‘ Interpretation jResul‘t Init‘ia‘le'reatm'ent Date Region Decline COVlD-19 Testing Liu, Meiying 000000001212 04/1 5/1938 01/07/2021 10:40 AM 2/3 Depression Screening (PHQ-Z) Assessment/Plan # " ”i Detail Type 1. Assessment Impression 2. Assessment Provider Plan 3. Assessment Plan Orders 4. Assessment ' Plan Orders ??,Descriptlon HRCI May 25 2021 10:30am P005/012 Elevated AST (SGOT) (R74 01) Likely, it is caused by her fatty live. Stable. She has been asymptomatic. Fatty liver (K760). 1) She was counseled on low-fat diet and exercise/physical activities at least 3O minutes daily. Negative depression screening (213.31). The patient had the folfowing test(s) completed today: Depression Screening (PHQ-Z). Procedure and treatment not carried out because of patient's decisionfor unspecified reasons (253.20). The patient had the following test(s) completed today: Decline COVlD-1 9 Testing. She is to schedule a foliow-up visit with Zhao, Wangping MD 6 Months. The patient was checked out at 12:06 PM by Linda Fong. Provider: Zhao, Wang Ping 01/16/2021 4:08 PM Document generated by Wangping Zhao 01/16/2021 04:08 PM AACI Health Center 2400 Moorpark Avenue, Suite 319, CA 95128 Electronically signed by Wang Ping Zhao MD on 01/16/2021 04:15 PM Liu, Meiying 000000001212 04/15/1938 01/07/2021 10:40 AM 3/3 1/4/22, 4:27 PM Anemia is associated with severe coronavirus disease 201 9 (COVlD-1 9) infection 8 Try out PMC Labs and tell us what you think. Learn More. UOHDQIIUO KQUQfiJQLUE LHIEQH Dllqnd JQIE‘LQSIE UOHDQIIOO KOUQEJQLUE LHIEQH Dllqnd JQII‘LQSIB lllqfld JQII‘LQSIE Elsevier Public Health Emergency Collection Fifi“: I-Ieallll Emu'gmcy CGVID-‘Ifl hitia'liu Transfus Apher Sci. 2020 Aug 28 : 102926. PMCID: PMC7452827 doi: 10.1016/i.transci.2020.102926 [Epub ahead of print] PMID: 32893135 Anemia is associated with severe coronavirus disease 2019 (COVlD-19) infectionWym Pelita Harapan University, Faculty of Medicine, Boulevard Jendral Sudirman, Karawaci, Tangerang, Banten, 15811, Indonesia * Andree Kurniawan Pelita Harapan University, Faculty of Medicine, Department of Internal Medicine, Boulevard Jendral Sudirman, Karawaci, Tangerang, Banten, 15811, Indonesia Dear Editor, Until recently, the number of positive and death cases from coronavirus disease 2019 (COVID-19) is still increasing. This pandemic disease has caused a significant impact and burden on all aspects of life, especially on the economic and health aspect. Therefore, identification of risk factors that contribute to the development of the severe disease is very important to enable risk stratification, optimize hospital resources reallocation, and guide public health recommendations and interventions. A previous study has shown that anemia was common in patients With community-acquired pneumonia (CAP) and was associated with a higher 90-day mortality rate [1]. Unfortunately, no study provides clear evidence regarding the link between anemia and COVID-19. This article aims t0 explore the potential association between anemia and the severity of COVID-19 infection. A search 0f the literature was conducted 011 Google scholar using the keywords "anemia" OR “hematologic” OR "clinical characteristics" OR "comorbidities" OR "risk factors" AND "coronavirus disease 2019" OR "COVID-19", until July 21st, 2020) With language restricted to English only. The title, abstract, and fill] text of all articles identified that matched the search criteria were assessed, and those reporting the rate 0f anemia in COVID-19 patients With a clinically validated definition 0f "severe disease" were included in this meta-analysis. A meta-analysis was performed using Review Manager 5.4 (Cochrane Collaboration) software. Dichotomous variables were calculated using the Mantel-Haenszel formula with random-effects models. We used the 12 statistic to assess the heterogeneity, value of< 25 %, 26-50 %, and > 50 % https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7452827/ 1/4 1/4/22, 4:27 PM Anemia is associated with severe coronavirus disease 201 9 (COVlD-1 9) infection considered as 10W, moderate, and high degrees of heterogeneity, respectively. The effect estimate was reported as odds ratio (OR) along With its 95 % confidence intervals (CIs) for dichotomous variables, respectively. P-Value was two-tailed, and the statistical significance set at 50.05. A total of 17,200 records were obtained through systematic electronic searches and other ways. After screening titles, abstracts, and full texts, 7 studies [[2], [i], [A], [j], [Q], [l], [§]] With a total of 9,912 COVID-19 patients were included in the meta-analysis. The essential characteristics 0f the included studies and the cut-off value for anemia diagnosis are summarized in Table 1 . Most 0f the included uouuenog AavuafiJeLug LumeH c studies define anemia when the hemoglobin (Hb) levels were below 13 g/L, while one included study use the cut-off value ofHb <11 g/L to define anemia. The individual and pooled ORs for anemia predicting severe COVID-19 are shown in fig; . Our pooled analysis showed a significant association 0f anemia with severe COVID-19, with moderate heterogeneity [OR 2.44 (95 % CI 1.75-3.40), p < 0.00001, I 2 = 47 %, random-effect modelling]. Table 1 Characteristics of included studies. uouuenog AauefiJewg uueeH crnqnd Jamesg Severe patients Non-severe patients Sample Anemia Study Design size cut-off n (%) Age n (%) Age (years) (years) Cai Y et a1. [g] 432 Retrospective Hb <13 gm 125 (28.9 59.6 i 307 (71.1 50.1 :I: 2020 cohort %) 16.6 %) 16.2 Ji W et a1. [_3_] 7341 Case-control Hb <13 g/L 954 (12.9 67 i 15.1 6387 (87.1 44 i 17.7 2020 %) %) m g Xu P et a1. [fl] 703 Retrospective Hb <13 g/L 55 (7.8 60.5 i 648 (92.2 44.9 :t g 2020 cohort %) 17.2 %) 14.3 E Zhang J et a1. [i] 663 Retrospective Hb <13 gm 409 (61.6 63.4 :t 17 254 (38.4 48.7 i r: g 2020 cohort %) %) 18.5 I g Zhao J et a1. [é] 29 Retrospective Hb <13 gm 21 (72.4 60.8 :I: 8 (27.6 %) 36.7 :I: § 2020 cohort %) 19.6 20.3 r'n g Zhao JN et a1. [Z] 583 Retrospective Hb <13 g/L 84 (14.4 57.2 i 499 (85.6 45.3 :I: 17 g5; 2020 cohort %) 12.3 %) \ 3 3 Zheng F et a1. [§] 161 Retrospective Hb <11 g/L 30 (18.6 56.5 i 131 (81.4 40.6 i E 2020 cohort %) 14.4 %) 14.8 ‘ 5 E. a3 Qpen in a separate Window 3llqnd JQIASSIE https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7452827/ 2/4 1/4/22, 4:27 PM Anemia is associated with severe coronavirus disease 201 9 (COVlD-1 9) infection uonuanoo muefiJewa uneeH uonsanoo flauefiJeLua LmEQH cruqnd Jamesg uonaenoo filauefiJeLug uueeH auqnd Jamese H Ollqnd JQIAQSB Anemla Non-Anemia Odds Ratio Odds Ratiom or Subgrogp Events Total Events Total Weight M-H. Random. 95960 M-H. Random. 95% Cl Cal Y e: al. 2020 ? 13 113 419 7.396 2.98 [0.98. 9.041 Ji Wetal. 2020 140 505 814 6836 34.596 2.84 [2.30. 3.49] I- Xu P et al. 2020 18 195 37 508 17.7% 1.29 [0.72. 2.33] --- Zhang] et al. 2020 168 219 241 444 2?.096 2.77 [1.93. 4.00] + ZhaoJ et al. 2020 15 16 6 13 2.0% 17.50 [1.76. 174.42] -'-“ Zhau JN at al. 2020 5 15 79 568 ?.496 3‘09 [103. 9.29] -'_ Zheng F 2t al. 2020 2 13 28 148 4.1.96 0.73 [0.16. 3.?1] -"- Total (959$ Cl) 976 8936 100.0% 2.44 [1.75. 3.40] O Total events 355 1323 Heterogeneity: Tau‘ = 0.07; Chi“ = 11.23. df= 6 (F = 0.08}: F = 47% 1001 0:1 110 mo- Test for overall effect; Z = 5.26 (P < 0.00001} Fm”; Anemia Favours NM_Anemia Eig- 1 Forest plot that demonstrates the association of anemia with severe outcome of COVID-19 infection. Events means the severe disease outcome, While non-events means the non-severe disease outcome. Based on a contrite meta-analysis of available data, anemia seems t0 be associated with an enhanced risk of severe COVID-19 infection. The possible pathophysiological link between anemia and severe COVID-19 can be explained by these reasons. Patients With anemia Will have 10W hemoglobin levels. In the circulation system, hemoglobin serves as a carrier for oxygen to target organs in the body. When the concentration of the hemoglobin in the circulation is low, the transport of oxygen t0 several organs in the body Will be disrupted, therefore causing hypoxia that will eventually result in multiple organ dysfunction, especially respiratory organ dysfunction [2]. Multiple organ dysfunction will contribute to the development 0f severe outcomes in COVID-19 infection. Moreover in COVID-l9 infections, the state of anemia in the patients could be worsened. First, SARS-CoV-Z can interact With hemoglobin molecules 0n the erythrocyte through ACE2, CD147, and CD26 receptors. This Viral-hemoglobin interaction will cause the Virus t0 attack the heme 0n the 1-beta chain of hemoglobin and causing hemolysis [m]. Second, SARS-CoV-2 may mimic the action 0f hepcidin which increases circulating and tissue ferritin (affecting liver, spleen, bone marrow, and muscles mainly), while inducing serum iron deficiency and lack of hemoglobin, by consequence. The resulting hyperferritinemia will give rise to ferroptosis, with high oxidative stress and lipoperoxidation that can precipitate the inflammatory/immune over-response (cytokine storm) and causing a severe outcome 0f the disease [m]. Patients With anemia should hence be advised to take extra precautions to minimize risk exposure to the Virus. Physicians should be engaged in close monitoring of anemic patients with suspected COVID-19, for timely detecting signs of disease progression. Finally, the presence of anemia shall be regarded as an important factor in future risk stratification models for COVID-19. CRediT authorship contribution statement Timotius Ivan Hariyanto: Conceptualization, Data curation, Methodology, Investigation, Validation, Visualization, Writing - original draft, Writing - review & editing. Andree Kurniawan: Conceptualization, Validation, Resources, Writing - original draft, Writing - review & editing, Supervision. References 1. Reade M.C., Weissfeld L., Angus D.C., Kellum J.A., Milbrandt E.B. The prevalence of anemia and its association with 90-day mortality in hospitalized community-acquired pneumonia. BMC Pulm Med. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7452827/ 3/4 1/4/22, 4:27 PM Anemia is associated with severe coronavirus disease 201 9 (COVlD-1 9) infection uouaenog KavuefiJeLug uuueH auqnd Jamesg uonaeuog $011351er unee mefiJeLug uueeH crnqnd Jamesg 2. Cai Y.Q., Zhang X.B., Zeng H.Q., Wei X.J., Zhang Z.Y., Chen L.D. Prognostic value 0f neutrophil- to-lymphocyte ratio, lactate dehydrogenase, D-Dimer and CT score in patients with COVID-19. Res Square. 2020 doi: 10.21203/rs.3.rs-30959/V1. [CrossRet] [mgle Scholar] 3. Ji W., Huh K., Kang M., Hong J., Bae G.H., Lee R. Effect of underlying comorbidities on the infection and sevefity of COVID-19 in Korea: a nationwide case-control study. JKorean Med Sci. 2020;35(25):6237. doi: 10.3346/jkms.2020.35.e237. [PMC free article] [PubMed] [CrossRefl [G_00gle Scholar] 4. Xu P.P., Tian R.H., Luo S., Zu Z.Y., Fan B., Wang X.M. Risk factors for adverse clinical outcomes with COVID-19 in China: a multicenter, retrospective, observational study. Theranostics. 2020;10(14):6372-6383. doi: 10.7150/thn0.46833. [PMC free article] [PubMed] [CrossRef] [@gle Scholar] 5. Zhang J., Wang X., Jia X., Li J., Hu K., Chen G. Risk factors for disease severity, unimprovement, and mortality in COVID-19 patients in Wuhan, China. Clin Microbial Infect. 2020;26(6):767-772. doi: 10.1016/j.cmi.2020.04.012. [PMC free article] [PubMed] [CrossRef] [mgle Scholar] 6. Zhao J., Gao H.Y., Feng Z.Y., Wu Q.J. A retrospective analysis of the clinical and epidemiological characteristics of COVID-19 patients in Henan Provincial People’s Hospital, Zhengzhou, China. Front Med (Lausanne) 2020;7z286. doi: 10.3389/fmed.2020.00286. [PMC free article] [PubMed] [CrossRef] [@gle Scholar] 7. Zhao J., Zhu M., Su X., Huang M., Yang Y., Huang J. Clinical characteristics and risk factors for severe-critically ill COVID-19 adult patients in Jiangsu, China: a multiple-centered, retrospective study. Res Square. 2020 doi: 10.21203/rs.3.rs-28628/V1. [CrossRef] [mgle Scholar] 8. Zheng F., Tang W., Li H., Huang Y.X., Xie Y.L., Zhou Z.G. Clinical characteristics of 161 cases 0f corona Virus disease 2019 (COVID-19) in Changsha. Eur Rev Med Pharmacol Sci. 2020;24(6):3404- 3410. doi: 10.26355/eurrev_202003_20711. [PubMed] [CrossRef] [Google Scholar] 9. Hemauer S.J., Kingeter A.J., Han X., Shotwell M.S., Pandharipande P.P., Weavind L.M. Daily lowest hemoglobin and risk of organ dysfunctions in critically ill patients. Crit Care Med. 2017;45(5):e479-e484. doi: 10.1097/CCM.0000000000002288. [PMC free article] [PubMed] [CrossRef] [mgle Scholar] 10. Cavezzi A., Troiani E., Corrao S. COVID-19: hemoglobin, iron, and hypoxia beyond inflammation. A narrative review. Clin Pract. 2020;10(2):1271. doi: 10.4081/cp.2020.1271. [PMC free article] [PubMed] [CrossRet] [Google Scholar] https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7452827/ 4/4 Beverly Hills, California 90211 T: (310) 550-8888 |F: (310) 550-8988 |www.BHFIRM.c0m 8370 Wilshire Blvd, Suite 205 Lalezary Law Firm , LLP .p \DOOQONUI 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE STATE OF CALIFORNIA, COUNTY OF SANTA CLARA I am employed in the County 0f Los Angeles, State 0f California. I am over the age 0f 18 and not a party t0 the within action; my business address is: 8370 Wilshire B1Vd., Suite 205, Beverly Hills, CA 9021 1. On January 6, 2022, I served the foregoing documents described as: [PROPOSED] ORDER RE: PLAINTIFF’S MOTION FOR AN ORDER GRANTED PREFERENCE PURSUANT TO CODE OF CIVIL PROCEDURE § 36 DECLARATION OF TIMOTHY C. WALKER-DUPLER IN SUPPORT OF PLAINTIFF’S MOTION FOR AN ORDER GRANTING PREFERENCE PURSUANT TO CODE OF CIVIL PROCEDURE § 36 PLAINTIFF’S NOTICE OF MOTION: MOTION FOR AN ORDER GRANTING PREFERENCE PURSUANT TO CODE OF CIVIL PROCEDURE § 36 BY MAIL: I caused such envelope With postage thereon fully prepaid to be placed in the United States Mail at Los Angeles, California. BY MAIL - CALIFORNIA ONLY: I am readily familiar With this business' practice for collection and processing of correspondence for mailing with the United States Postal Service. This document Will be deposited With the United States Postal Service 0n the same day as the execution 0f this document in the ordinary course 0f business. This document was sealed and placed for collection and mailing 0n the same day as the execution 0f this document at the address given for deposit in the United States Postal Service and following ordinary business practices. BY PERSONAL SERVICE: By having a true copy thereof personally delivered to the person(s) at the address(es) as set forth below. X BY ELECTRONIC MAIL (E-MAIL): By electronically mailing an Adobe .pdf version from e-mail address tania@bhfirm.com Via LALEZARY LAW FIRM’S electronic mail system to the person(s) at the e-mail address(es) as set forth below. BY FACSIMILE: By sending a copy from facsimile number (3 10) 550-8988 t0 the person(s) at the facsimile number(s) as set forth below. I served above referenced document on: Attorney for Defendants; Xu Hu, Xi Liu Jeanette N. Little & Associates Aron K. Liang, Esq. 4450 Rosewood Drive, Suite 450 Pleasanton, California 94588 E: aron.liang@statefarm.com E: cali.law-pleasanton-eservice.08 1002@statefarm.com E: selene.inguanzo.Xavr@statefarm.com Executed on January 6, 2022, at Beverly Hills, California. I declare, under penalty 0f perjury, under the laws 0f the State of California, that the above is true and correct. 1 PROOF OF SERVICE m m e m m A L L m m nR D EmVRESF0F00RP 2 6 7 00 9 01 1 2 3 4 5 r0 7 0 0 9 1 1 1 1 1 1 1 1 1 8 0 0 . 2m a m m é §_ wmow dmm 6 3 “m_ wwwm dmm 8 5 é : 80 3 8 0 : 6 “m a m 3 5 5 m mom 3 3m 6 2m 8 .32 39 8mm A A A . SH E 3 5 A ? w N fl w ‘H O2 12 22 32 42 52 62 72 002
