Request,Application: Gabriela Judith Anacona vs Dignity Health

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                                ELECTRONICALLY FILED
                                                                   Superior Court of California
                                                                   County of Santa Barbara
                                                                   Darrel E. Parker, Executive Officer
                                                                   3/27/2024 9:56 AM
                                                                   By: Michael Rosales , Deputy
 1   Hugh S. Spackman, State Bar No. 150204
     J. Lynn Stokes-Pena, State Bar No. 223300
 2   CLINKENBEARD, RAMSEY, SPACKMAN & CLARK, LLP
     P.O. Box 21007
 3   Santa Barbara, CA 93121
     Phone: (805) 965-0043
 4   Fax: (805) 965-8894
 5
     Attorneys for Defendant Dignity Health dba
 6   Marian Regional Medical Center
 7

 8                     SUPERIOR COURT OF THE STATE OF CALIFORNIA
 9                              FOR THE COUNTY OF SANTA BARBARA
10                                            COOK DIVISION
11   GABRIELA ANACONA through her guardian ad              CASE NO. 24CV00455
     litem DENISSE ANACONA MARTINEZ, an                    Complaint Filed: 01-29-24
12   individual,                                           Assigned: Honorable James F. Rigali
13                            Plaintiff,
                                                           Date: April 30, 2024
14   V.                                                    Time: 8:30 a.m.
                                                           Dept: SM-2
15   DIGNITY HEALTH dba MARIAN REGIONAL
     MEDICAL CNETER, AND DOES 1-100,                       REQUEST FOR JUDICIAL NOTICE IN
16   inclusive                                             SUPPORT OF DEFENDANT DIGNITY
                                                           HEALTH dba MARIAN REGIONAL MEDICAL
17                            Defendants.                  CENTER'S DEMURRER TO PLANTIFF'S
                                                           COMPLAINT
18
                                                           [Memorandum of points and authority, Declaration
19                                                         filed concurrently]
20           Defendant DIGNITY HEAL TH dba MARIAN REGIONAL MEDICAL CENTER respectfully

21   requests that the Court take judicial notice of Exhibit A (complaint) under Evidence Code §452(d) as

22   records of this court.

23   Dated: March 27, 2024                   CLINKENBEARD, RAMSEY, SPACKMAN & CLARK, LLP

24

25                                           By:
                                                   Hugh Sf ${Sackman,
26                                                 J. Lynn 'Stokes Pena,
                                                   Attorneys for Defendant DIGNITY HEAL TH dba
27                                                 MARIAN REGIONAL MEDICAL CENTER
28

                                       RFJN ISO MRMC'S DEMURRER TO COMPLAINT- 1
 1                                            PROOF OF SERVICE
                                                  [C.C.P. §1013a]
 2   COUNTY OF SANTA BARBARA:
 3   STATE OF CALIFORNIA:
 4   I am a citizen of the United States and am employed in the County of Santa Barbara, State of California.
     I am over the age of eighteen ( 18) years and not a party to the within action. My business address is
 5   3938 State St., P.O. Box 21007, Santa Barbara, CA 93121.
6    On the date set forth below, I served the foregoing document described as REQUEST FOR JUDICIAL
     NOTICE IN SUPPORT OF DEFENDANT DIGNITY HEALTH dba MARIAN REGIONAL
 7   MEDICAL CENTER'S DEMURRER TO PLAINTIFF'S COMPLAINT by placing copies thereof in
     sealed envelopes, addressed as follows:
 8

 9    Attorneys For Plaintiff
10
      Adam Feldman, Esq.
11    Adam Feldman Law, APC
      5850 Canoga Avenue, Suite 400
12    Woodland Hills, CA 91367
      Tel.: 818 710 3833
13    Fax: 818 710 3802
14    Emails:
      adam@adamfeldmanlaw.com
15    info@adamfeldmanlaw.com
      peggy@adamfeldmanlaw.com
16

17

18   _ _ (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 U.S. postal service on
19   that same day with postage thereon fully prepaid First Class at Santa Barbara, California in the ordinary
     course of business. I am aware that, on motion of party served, service is presumed invalid if postal
20   cancellation date or postage meter date is more than one day after the date of deposit for mailing in
     affidavit.
21
       xx (By E-Mail) I caused all of the pages of the above-entitled document to be sent to the
22   recipient(s) noted above via e-mail at the respective e-mail address indicated above.
23           (By Federal Express/Overnight Mail) I caused the above-described document to be served on
     the interested parties noted above by Federal Express/Overnight Mail.
24
            (By Personal Service) I delivered such envelope(s) by hand to the offices of the addressee(s).
25
     I declare under penalty of perjury under the laws of the State of California that the foregoing is true and
26   correct. Executed on March 27, 2024, at Santa Barbara, California.
27

28                                                 D~ienecke