FREEMAN, FREEMAN SMILEY. LLP 1 888 CENTURY PARK EAST, SUITE 1 900 Los ANGELES. CALIFORNIA 90067 (310) 255?61 00 00 ox LIL-B b) b?tSTEPHEN M. LOWE (BAR NO. 45534) stephen.lowe@ffslaw.Com 7 JOHN P. GODSIL (BAR NO. 174356) john. godsil@ffslaw.com THOMAS C. AIKIN (BAR NO. 241411) thomas.aikin@ffslaw.com FREEMAN, FREEMAN SMILEY, LLP 1888 Century Park East, Suite 1900 Los Angeles, California 90067 Telephone: (310) 255-6100 Facsimile: (310) 255-6200 Attorneys for Plaintiff SAINT HEALTH CENTER FOUNDATION SAINT HEALTH CENTER FOUNDATION, a California corporation, Plaintiff, vs. PAULA KENT MEEHAN FOUNDATION, a California corporation; WENDY KARZIN, in her capacity as Co-Trustee of the PAULA KENT MEEHAN TRUST, dated April 14, 1994, as amended, and Co-Executor of the ESTATE OF PAULA KENT MEEHAN, MARCIA HOBBS in her capacity as Co- Trustee of the PAULA KENT MEEHAN TRUST, dated April 14, 1994, as amended, and Co-Executor of the ESTATE OF PAULA KENT and JPMORGAN CHASE, NA, in its capacity as Co-Trustee of the PAULA KENT MEEHAN TRUST, dated April 14, 1994, as amended, and Co-Executor of the ESTATE OF PAULA KENT and DOES 1 through 25, inclusive, Defendants. 0/38 m\ (JAM SUPERIOR COURT OF THE STATE OF CALIFORNIA hereby alleges as follows: i 24894252 7829-350 Plaintiff SAINT HEALTH CENTER FOUNDATION, a California .choq' Sugerlergyg?g?al?omia 01mm of ms Anneles JUN 1 9 2015 Shea-1R. .137: Onica?CIe?: 0568 COUNTY OF LOS ANGELES, CENTRAL DISTRICT Case No. 8 5 COMPLAINT FOR: 1. BREACH OF AND 2. PROMISSORY ESTOPPEL E11 "if .qi?1::Iug InGeri3 [phl- i" *3 . Gr ?r [3131: Up (I II I IDID El?n 33;; EDIZIC3ID in 1 COMPLAINT VP. 5# are: :3 13912193 a . 3 #330." H31 i??H?firn 11- a. 5.1 FREEMAN, FREEMAN SMILEY. LLP 1888 CENTURY PARK EAST, SUITE 1 900 Los ANGELES. CALIFORNIA 90067 (31 0) 255THE PARTIES 1. At all times mentioned herein, Plaintiff SAINT HEALTH CENTER FOUNDATION Foundation? or ?Plaintiff?) was, and is, a California nonpro?t corporation, with its principal place of business in Santa Monica, California. 2. Plaintiff is informed and believes, and based thereon alleges, that Paula. Kent Meehan was an individual who resided in Beverly Hills, California. Ms. Meehan died on June 23, 2014. Plaintiff is informed and believes, and based thereon alleges, that Paula Kent Meehan established a revocable trust known as the PAULA KENT MEEHAN TRUST dated April 14, 1994 (the ?Meehan Trust?). The Meehan Trust became irrevocable upon Paula Kent Meehan?s death. 3. Plaintiff is informed and believes, and based thereon alleges, that at all times mentioned herein, Defendant PAULA KENT MEEHAN FOUNDATION (?Meehan Foundation?) was, and now is, a California nonpro?t organization of an unknown type established on or about July 5, 2006. 4. Plaintiff is informed and believes, and based thereon alleges, that at all times mentioned herein, Defendant WENDY KARZIN (?Karzin?) is a resident of California, and a duly appointed and acting Co-Trustee of the Meehan Trust. Plaintiff is informed and believes, and based thereOn alleges, that at all times mentioned herein, Karzin is also a duly appointed and acting Co-Executor of the ESTATE OF PAULA KENT MEEHAN (the ?Estate?). 5. Plaintiff is informed and believes, and based thereon alleges, that at all times mentioned herein, Defendant MARCIA HOBBS (?Hobbs?) is a resident of California, and a duly appointed and acting Co-Trustee of the Meehan Trust. Plaintiff is informed and believes, and based thereon alleges, that at all times mentioned herein, Defendant Hobbs is also a duly appointed and acting Co-Executor of the Estate. 6. Plaintiff is informed and believes, and based thereon alleges, that at all times mentioned herein, Defendant JPMORGAN CHASE, NA, Morgan?) is a national banking association doing business in California, and a duly appointed and acting Co-Trustee of the Meehan Trust. Plaintiff is informed and believes, and based thereon alleges, that at all times 24894252 7829?350 2 COMPLAINT FREEMAN, FREEMAN SMILEY, LLP 1888 CENTURY PARK EAST. SUITE 1900 Los ANGELES. CALIFORNIA 90067 (31 0) 255@900 430) NH mentioned herein, JP Morgan is also a duly appointed and acting Co?Executor of the Estate. 7. Karzin, Hobbs and JP Morgan are sometimes hereinafter collectively referred to as the ?Fiduciary Defendants?. 8. The true names and capacities, whether individual, corporate, associate or otherwise, of those defendants named herein as Does 1 through 25, inclusive, are presently unknown to Plaintiff, and therefore Plaintiff sues said defendants by such ?ctitious names. Plaintiff is informed and believes, and based thereon alleges, that each such defendant participated in the acts complained of herein or otherwise is liable therefore, and that Plaintiffs damages as alleged herein were directly and proximately caused by the acts of each such defendants. When the true names and capacities of ?said defendants are ascertained, Plaintiff Will seek leave of Court to amend this complaint accordingly. 9. Whenever appearing in this complaint, each and every reference to ?Defendant(s)? is intended to be, and shall bedeemed, a reference to all defendants in this action, and each of them, named and unnamed, including all ?ctitiously named defendants. A 10. Plaintiff is informed and believes, and based thereon alleges, that each defendant was the agent, servant, employee, of?cer, partner, joint venturer, principal, master, employer, associate, alter ego, and/or co-conspirator of each, all, andlevery one of the other defendants, was at all times acting _within the course and scope of such relationship, and is liable to Plaintiff, directly and/or vicariously, for the acts, conduct, and/or omissions herein alleged. 11. The Meehan Trust is administered in Los Angeles County, California. The Estate?s administration is proceeding in Los Angeles County, California. - GENERAL ALLEGATIONS 12. SJHC Foundation is a charitable foundation associated with Providence Saint John?s Health Center leading hospital located in Santa Monica, California. SJHC has served Santa Monica and Westside communities since 1942 and has earned a reputation for clinical excellence and award-winning care. I SJHC Foundation?s mission is to provide leadership and support to SJHC. SJHC Foundation is tasked with, among other things, community outreach and fundraising on behalf of SJ HC. 24394252 7329?350 3 COMPLAINT FREEMAN, FREEMAN SMILEY. LLP I 1888 CENTURY PARK EAST, SUITE 1900 Los ANGELES, CALIFORNIA 90067 (31 0) 255?61 00 co \1 UI 13. Ms. Meehan was a prominent businesswoman and philanthrOpist iniLos Angeles County. Ms. Meehan was a longtime supporter of SJHC. 14. On November 12, 2007, Ms. Meehan and SJHC Foundation entered into a Saint John?s Health Center Foundation Estate Pledge Commitment (Estate Note) (hereinafter the ?Estate Note?). A true and correct copy of the Estate Note is attached as Exhibit and incorporated into the Complaint by this reference. 15. In the Estate Note, Ms. Meehan agreed to give, at her death, a minimum of $5,000,000 (hereinafter the ?Pledge?) to SJHC Foundation. Ms. Meehan agreed that the Pledge would be paid upon her death from the Meehan Trust, and to the extent not made from the Meehan Trust, the Pledge would be made from the Meehan Foundation. The Estate Note also provides that the Pledge is ?in-addition to what Saint John?s may receive from the PK. Foundation.? The Estate Note includes Ms. Meehan?s statement, wish to document my commitment by execution of this Estate Note and intend that my commitment shall be fully enforceable against the Meehan Trust, the [Meehan] Foundation and my estate. This commitment shall be an obligation legally?binding on me and my heirs, executors, administrators, personal representatives, and assigns.? 16. SJHC Foundation?s obligations under the Estate Note were and are (1) that the SJHC Foundation will solicit planned gifts from other donors and may disclose Ms. Meehan?s Pledge as a means of encouraging support from other donors; (2) SJHC Foundation will restrict the Pledge to ?The Challenge to Lead Campaign?; (3) SJHC Foundation promised to recognize Ms. Meehan?s donation in a manner equivalent with others who make similar gifts, including but not l;mited to the Saint John?s Legacy Wall; and (4) SJHC Foundation agreed that Ms. Meehan would be accorded membership in Saint John?s Friends for the-Future. 17. The Estate Note also provides that Ms. Meehan would be recognized by a tree named for her on the SJHC campus. The idea to have a tree named for her was Ms. Meehan?s own and held personal significance to her. 24894232 7829-350 COMPLAINT 1 18. During her lifetime, Ms. Meehan received considerable positive publicity as a 2 philanthrOpist as a result of her charitable contribution to Saint John?s through the Estate Note. 3 Ms. Meehan was interviewed in two separate Saint ohn?s publications recognizing the Pledge. 4 a. In the Spring 2008 issue of Saint John?s Magazine, Ms. Meehan was 5 featured in the Foundation section in an article entitled ?Growing a Legacy? wherein she discussed 6 the Pledge and that it was her idea to receive recognition speci?cally through planting a tree 7 bearing her name. Ms. Meehan was quoted as follows: 8 wanted my gift to be recognized by something that was living. 9 Saint John?s has many beautiful gardens and areas surrounding the 10 Health Center. So I thought ?Wouldn?t it be nice to name something 8 11 that could be enjoyed by patients and visitors alike? I love the trees :1 12 around my home and one day it occurred to me that a tree would be 2 13 nice that could be enjoyed by many people for a long a 5i . I: 14 t1me.?.? ?g 15 b. Ms. Meehan was again recognized for the Pledge in the Fall 2008 issue of 16 Challenge to Lead. This pro?le of Ms. Meehan identi?ed her support of Saint John?s as including 3 17 $5,000,000 to a support a ?living legacy? in the form of a Jacaranda tree as a representation of her 18 Pledge. 19 19. In 2008 SJHC Foundation planted this tree which it paid to install and continues to 20 pay to maintain. The tree is adorned with a plaque identifying Ms. Meehan?s Pledge. As Ms. 21 Meehan desired, other donors?have chosen to have gifts identi?ed in the garden where her tree is 22 planted. i3". 23 20. Ms. Meehan?s Pledge has also been recognized. in several other places, as follows: 24 a. Cumulative Giving Wall, a wall found in SJHC, near the atrium and main 25' entrance identifmg maior donors. During her lifetime, Ms. Meehan donated approximately ON $1,366,874 outright. Since 2008, and because of the Estate Note, Ms. Meehan is listed at the ?4 $5,000,000 to $9,999,999 level, also known as the Distinguished Benefactors level. But for the Estate Note, Ms. Meehan would have been recognized two levels lower, at the $1,000,000 to 24394252 7829-350 5 COMPLAINT i on FREEMAN. FREEMAN SMILEY. LLP 1888 CENTURY PARK EAST, SUITE 1900 Los ANGELES, CALIFORNIA 90067 (31 0) 255-6100 (EN woo-Jason?$2,499,999 level. b. Friends for the Future Wall (Planned Giving Donor wall). This Wall is also located near the atrium and main entrance to SJHC. It is comprised solely of donors who have made a planned gift bene?tting Saint John?s. This was an express term of the Estate Note that SJHC Foundation has performed. - I i i c. Annual Giving Report. Since 2008, Ms. Meehan has been recognized in the Annual Giving Report, a publication with circulation of more than 34,000., as a donor'in the $5,000,000? $9,999,999 level. 21. On March 19, 2013, representatives of Ms. Meehan sent a letter purportedly reneging on Ms. Meehan?s obligations under the Estate Note. - 22. The recognition and positive publicity received by Ms. Meehan during her lifetime, and prior to March 19, 2013, as a result of the Estate Note was material and was a bargained for exchange. 23. SJHC Foundation has upheld and performed its obligations under the Estate Note. Ms. Meehan has been appropriately recognized for her' Pledge. SJHC Foundation has incurred expenses to plant and maintain the tree, it has undertaken the expense and effort to add Ms. Meehan to donor walls, and has published articles lauding Ms. Meehan?s philanthropic endeavors. These actions all occurred prior to March 19, 2013. 24. As noted ab0ve, Ms. Meehan died on June 23, 2014. Upon information and belief, the Fiduciary Defendants became successor Co-Trustees of the Meehan Trust upon Ms. Meehan?s death. I 25. The Estate Note provides that the Pledge will be payable within a reasonable period after Ms. Meehan?s death, and to the extent not paid by the Meehan Trust, or the Meehan Foundation, will be treated as a valid charge again her estate. 26. On September 17, 2014, SJHC Foundation sent a letter to Ms. Meehan?s representatives requesting that they perform Ms. Meehan?s obligations under the Estate Note. 27. On October 17, 2014, Ms. Meehan?s representatives sent a letter refusing to honor Ms. Meehan?s commitments under the Estate Note. 24894252 7829-350 6 . COMPLAINT (I . . J. 28. On November 7, 2014, SJHC Foundation sent a second letter to Ms. Meehan?s representatives formally demanding payment of $5,000,000 pursuant to the Estate Note. No response to this letter has been received. 29. On March 4, 2015, SJ HC Foundation sent a letter to Ms. Meehan?s representatives relaying that it intended to bring an action to enforce the Estate Note against, among others, Ms. Meehan?s estate and inquired whether a probate had been opened so that the claim procedure of the Probate Code could be completed in order to name Ms. Meehan?s estate as a defendant. Thereafter, and on March 17, 2015, Karzin and Hobbs filed a Petition seeking to appoint the Fiduciary Defendants as co-executors of Ms. Meehan?s estate. That Petition was approved on 6 April 20, 2015, and letters testamentary were subsequently issued to the Fiduciary Defendants. y?n 30. On May 18, 2015, SJHC Foundation ?led and served a creditor?s claim against the p?n Estate for payment of $5,000,000 pursuant to the Estate Note. No part of the creditor?s claim has been paid by (1) the Fiduciary Defendants as Co-Trustees of the Meehan Trust, (2) the Meehan Foundation, (3) the Fiduciary Defendants as Co-Executors. 31. i The statutory period for the Fiduciary Defendants to accept or reject the claim on (3 1 0) 255?6 1 00 behalf of the Estate has passed and SJHC Foundation elected to treat the claim as rejected. FREEMAN, FREEMAN SMILEY, LLP 1888 CENTURY PARK EAST. SUITE 1900 Los ANGELES, CALIFORNIA 90067 FIRST CAUSE OF ACTION r?nr-t cox! (Breach of Contract against All Defendants) 32. Plaintiff realleges and incorporates herein by this reference the allegations enumerated above. 33. As alleged above, On or about November 12, 2007, SJHC and Ms. Meehan entered NN NH into the Estate Note. (Exhibit 1.) b) 34. Ms. Meehan pledged $5,000,000 to SJHC payable upon her death and agreed that the $5,000,000 would be paid by the Meehan Trust, the Meehan Foundation and/or her Estate. 35. . Defendants have failed and refused to pay the amounts owed to SJHC Foundation 1 ON pursuant to the Estate Note. \l 36. SJHC Foundation has performed each and every duty and obligation required of it co pursuant to the Estate Note. 24894252 7829-350 7 COMPLAINT 0 0 As a result of Defendants? failures to perform their obligations under the Estate 37. Note, SJHC has been damaged in the amount of $5,000,000.00, plus interest as allowed by law. SECOND CAUSE OF ACTION (For Promissory Estoppel against All Defendants) 38. Plaintiff realleges and incorporates herein by this reference the allegations enumerated above. 39. On November 12, 2007, Ms. Meehan promised in Writing in the Estate Note that SJHC Foundation would receive $5,000,000 upon her death. The Estate Note was and remains clear and unambiguous. 40. SJHC Foundation relied, reasonably and foreseeably, on Ms. Meehan?s promises in good faith and to its detriment. SJHC Foundation?s reliance prior to March 19, 2013 included i?I expending money in planting and maintaining the tree, recognizing Ms. Meehan?s Pledge, and p?A DJ furthering a donor program based upon Ms. Meehan?s desire to have SJHC Foundation donors p?L recognized in a garden with trees. SJHC Foundation also relied on Ms. Meehan?s Pledge in (31 0) 255-61 00 soliciting other gifts which it stands-to lose should Defendants not honor the Pledge. (II 41. Defendants have breached their respective promises as stated above by failing to Los ANGELES. CALIFORNIA 90067 pay The. monies owed to Plaintiff. As a direct and proximate result of Defendants? failure to \l FREEMAN SMILEY, LLP 1888 CENTURY PARK EAST, SUITE 1900 00 perform according to the promises and representations made by Ms. Meehan, Foundation sustained damages in the amount of $5,000,000 plUs alloWable interest. The only way that further Nil?t cu: injustice can be avoided is by enforcing Ms. Meehan?s promises against Defendants and aWarding SJHC Foundation $5,000,000, the minimum amount pledged 'by Ms. Meehan under the Estate Note. Prayer for Relief WHEREFORE, SJHC Foundation prays for judgment against Defendants, and each of them, as follows: On the First Cause of Action: NM \16\ 1. For damages in the amount of $5,000,000 plus interest on this sum as allowed by co law; 24894252 7829-350 8 COMPLAINT FREEMAN. FREEMAN SMILEY. LLP 1888 PARK EAST, SUITE 1900. Los ANGELES, CALIFORNIA 90067 (31 0) 255-6100 On the Second Cause of Action: 1. For damages in the amount of $5,000,000 plus interest on this sum as allowed by law; On All Causes of Action: 1. For costs of suit; and 2. For such other and further relief to which SJHC Foundation may be entitled and as this Court deems just and proper. DATED: June 2015 FREEMAN, FREEMAN SMILEY, LLP STWOWE JO P. GODSIL THOMAS C. AIKTN Attorneys for Plaintiff SAINT HEALTH CENTER FOUNDATION 24894252 7829-350 9 COMPLAINT EXHIBIT 1 SAINT HEALTH CENTER FOUNDATION ESTATE PLEDGE COMMITMENT (Estate Note) As an expression of my support for Saint'John's Health Center, I hereby agree to give at my death, a minimum of $5,000,000 (the to Saint ohn's Health Center Foundation (hereinaiter referred to as "Saint This Gift shall be made on my death from my revocable trust entitled the PAULA KENT MEET-IAN TRUST dated April 14, 1994, as it may be amended during my lifetime and which becomes irrevocable at my death (herein, the ?Meehan Trust"), and, to the extent not made by the Meehan Trust, the Gift shall be made by the revocable trust known as the PAULA KENT MEEHAN FOUNDATION (the "Foundation") established by me on July 5, 2006, as it may be amended during my lifetime and which becomes irrevocable at my death. I wish to document my commitment by execution of this Estate Note and intend that my commitment be fully enforceable against the Meehari Trust, the Foundation and my estate. This commitment shall be an obligation legally binding on me and my heirs, executors, administrators, personal representatives, and assigns. Recognition for my planned gift will be tree named for me on the Saint ohn's Health Center Campus. I understand that this recognition opportunity is contingent upon the receipt of this Estate Note and will not be in force until an original copy has been executed by me and returned to Saint John's. (The second original will be retained by me for my records.) The Gift is in addition to what Saint John's may receive ?'om the PIC Foundation. . It is my understanding that: (1) Saint ohn's will solicit planned gifts from other donors and may disclose this pledge as a means of encouraging support from other donors; (2) Saint John's will honor my request that distributions of my funds will be restricted to The Challenge to Lead Campaign; (3) Saint John?s promises to use the pledged funds only for the purposes described herein; (4) Saint John's promises to recognize my donation in amanner equivalent with others who make similar gifts, including but not limited to the Saint John's Legacy Wall; and (5) Saint John's ?irther agrees that] will be accorded membership in Saint John's Friends for the Future. It is my intention that this pledge will be payable within a reasonable period alter my death, as above set forth, will be binding upon my estate, and, to the extent not paid by the Meehan Trust, - as a valid charge against DonorN . 1M Sigma Address?!? 132.. Begging! Phone: Witness: I #73. Date: .- 7- '0 7 i For the SJHC Founda?onW Vice President .- . Please indicate donor's name ?ncludt'ng title) exactly as it is to be listed in recognition materials: PAULA KENT 6M 60955732 CM-010 ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, St ATTORNEY FOR (Name): Plaintiff Saint John's Health Center Foundation number, and address): . FOR COURT USE ONLY Stephen M. Lowe SBN 45534; Th 3 C. Aikin SBN 341411 Freeman, Freeman Smiley, LLP 1888 Century Park East, Suite 1900 Los Angeles, CA 90067 TELEPHONE NO.: (310) 255-5100 FAX N0.: (310) 255-6200 ., -- SUPERIOR COURT OF CALIFORNIA, COUNTY OF [.05 '3 ourtot California nimhinfl STREET ADDRESS: 111 North Hill Street 1 9 CITY AND ZIP CODE: LOS Angeles, CA 90012 BRANCH NAME: Central District 51'1me Umwum CASE NAME: SAINT HEALTH CENTER FOUNDATION V. PAULA KENT By - MEEHAN FOUNDATION, et al. 8? CIVIL CASE COVER SHEET Complex Case Designation CASE NUMBERBC 5 8 5 6 0 Unlimited 1:1 L'm'ted Counter Joinder 7 (Amount (Amount JUDGE. demanded demanded is Filed with ?rst appearance by defendant exceeds $25,000) $25,000 or less) (Cal. Rules of Court, rule 3.402) DEPT: Items 1?6 below must be completed (see instructions on page 2). . Check one box below for the case type that best describes this case: Auto Tort Contract Auto (22) K1 Breach of contract/warranty (06) Uninsured motorist (46) Rule 3.740 collections (09) Other (Personal Injury/Property Other collections (09) DamageNVrongful Death) Tort Insurance coverage (18) El Asbestos (04) Other contract (37) Product liability (24) Real Property Medical malpraCtice (45) Eminent Other (23) condemnation (14) (Other) Tort Wrongful eviction (33) Business tort/unfair business practice (07) Other real property (26) Civil rights (08) Unlawful Detainer Defamation (13) Commercial (31) El Provisionally Complex Civil Litigation (Cal. Rules of Court, rules 3.400-3.403) Antitrust/Trade regulation (03) Construction defect (10) Mass tort (40) Securities litigation (28) Environmental/Toxic tort (30) insurance coverage claims arising from the above listed provisionally complex case types (41) Enforcement of Judgment Enforcement of judgment (20) Miscellaneous Civil Complaint RICO (27) Other complaint (not speci?ed above) (42) Fraud (16) Residential (32) Intellectual property (19) CI Drugs (38) . . . . El Professional negligence (25) Judicial Review Miscellaneous CIVII Petition Other tort (35) Asset forfeiture (05) Partnership and corporate governance (21) Petition re: arbitration award (11) Other petition that speci?ed above) (43) Writ of mandate (02) Other judicial review (39) Employment Wrongful termination (36) 1:1 Other employment (15) El 2. This case is is not complex under rule 3.400 of the California Rules of Court. If the case is complex, mark the factors requiring exceptional judicial management: a. Large number of separately represented parties d. Large number of witnesses b. [3 Extensive motion practice raising dif?cult or novel e. Coordination with related actions pending in one or more courts issues that will be time-consuming to resolve in other counties, states, or countries, or in a federal court c. Substantial amount of documentary evidence f. Substantial postjudgmentjudiciai supervision 3. Remedies sought (check all that apply): a. IE monetary b. CI nonmonetary; declaratory or injunctive relief c. punitive 4. Number of causes of action (specify): 2 5. This case is is not a class action suit. 6 {Cthere are a known related cases, ?le and serve a notice of related case. (You -015.) 2015 Stephen M. Lowe A, (TYPE OR PRINT NAME) I (SIGNATURE OF PARTY 0R ATTORNEY FOR PARTY) 0 (Plaintiff must ?le this cover sheet with the ?rst paper ?led in the action or proceeding (except small claims cases or cases ?led 0 lithis case is complex under rule 3.400 et seq. of the California Rules of Court, you must serve a copy of this cover sheet on all 0 (Unless this is a collections case under rule 3.740 or a complex case, this cover sheet will be used for statistical purposes only. - NOTICE Under the Probate Code, Family Code, or Welfare and Institutions Code). (Cal. Rules of Court, rule 3.220.) Failure to ?le may result in sanctions. (Elle this cover sheet in additionto any cover sheet required by local court rule. 5other parties to the action or proceeding. Page 1 of 2 I J-f'i Form Adopted for Mandatory Use Judicial Council of California (Rev. July 1, 2007] Cal. Rules of Court, rules 2.30, 3.220, 3.400-3.403, 3.740; Cal. Standards of Judicial Administration, std. 3.10 CIVIL CASE COVER SHEET art- SHORT TITLE: SAINT HEALTH V. PAULA KENT MEEHAN FOUNDATION, et al. CASE NUMBER 805 85 670 . CIVIL CASE COVER SHEET ADDENDUM AND STATEMENT OF LOCATION (CERTIFICATE OF GROUNDS FOR ASSIGNMENT TO COURTHOUSE LOCATION) This form is required pursuant to Local Rule 2.3 in all new civil case filings in the Los Angeles Superior Court. Item I. Check the types of hearing and fill in the estimated length of hearing expected for this case: JURY YES CLASS El YES LIMITED YES TIME ESTIMATED FOR TRIAL 5 El DAYS Item II. Indicate the correct district and courthouse location (4 steps If you checked "Limited Case", skip to Item Pg. 4): Step 1: After first completing the Civil Case Cover Sheet form, ?nd the main Civil Case Cover Sheet heading for your case in the left margin below, and, to the right in Column A, the Civil Case Cover Sheet case type you selected. Step 2: Check 5% Superior Court type of action in Column below which best describes the nature of this case. Step 3: In Column C, circle the reason for the court location choice that applies to the type of action you have checked. For any exception to the court location; see Local Rule 2.3. Applicable Reasons for Choosing Courthouse Location (see Column below) 1. Class actions must be ?led in the Stanley Mosk Courthouse, central district. 2. May be filed in central (other county, or no bodily injury/property damage). 3. Location where cause of action arose. 6. Location of property or permanently garaged vehicle. 7. Location where petitioner resides. 8. Location wherein defendant/respondent functions wholly. 4. Location where bodily injury, death or damage occurred. 9. Location where one or more of the parties reside. 5. Location where performance required or defendant resides. 10. Location of Labor Commissioner Of?ce . . 11. Mandatory Filing Location (Hub Case) Step 4: Fill in the information requested on page 4 in Item complete Item IV. Sign the declaration. A ?0 Civil Case Cover Sheet Type of Action Applicable Category No. (Check only one) Reasons -See Step 3 Above 0 Auto (22) A7100 Motor Vehicle - Personal Injury/Property DamageNVrongful Death 1.. 2.. 4. =3 Uninsured Motorist (46) A7110 Personal Injury/Property DamageNVrongful Death Uninsured Motorist 1.. 2.. 4. A (04) A6070 Asbestos Property Damage 2. 5 es os E- A7221 Asbestos - Personal Injury/Wrongful Death 2. .3 O. Product Liability (24) El A7260 Product Liability (not asbestos or toxic/environmental) 1-. 2-. 3-. 4-. 8- .4330.) an I A7210 Medical Malpractice - Physicians Surgeons 1.. 4. 5 Medical Malpractice (45) I I 73.. A7240 Other Professronal Health Care Malpractice 1., 4. . Egg (3 A7250 Premises Liability slip and fall) 1' 4- 2:222? El A7230 Intentional Bodily Injuryi'Property Damage/Wrongful Death 1 4 3-8 Damage Wrongful assault, vandalism, etc.) 1 3 Death (23) A7270 Intentional lnfliction of Emotional Distress El A7220 Other Personal Injury/Property Damage/Wrongful Death 1" 4' LACIV 109 (Rev. 03/15) CIVIL CASE COVER SHEET ADDENDUM Local Rule 2.3 LAEC Approved 03-04 AND STATEMENT OF LOCATION American LegnlNet, Inc. wwa rm wc SHORT TITLE: SAINT HEALTH CENTER FOUNDATION v. PAULA KEN MEEHAN FOUNDATION, et al. I CASE NQR A . Civil Case Cover Sheet Type of Action Applicable Category NO- (Check only one) Reasons -See Step 3 - . Above BUSiness Tort (07) A6029 Other Commercial/Business Tort (not fraud/breach of contract) 1.. 3- 1: ,2 Civil Rights (08) A6005 Civil Rights/Discrimination 1.. 2.. 3 0 2: Defamation (13) DA6010 Defamation (slander/libel) 1-. 2.. 3 3 Fraud (16) A6013 Fraud (no contract) 1" 2" 3 3 . A6017 Le al Mal ractice 1., 2., 3 3 3, Professional Negligence (25) A6050 Other Professional Malpractice (not medical or legal) 1.. 2.. 3 2 8 Other (35) A6025 Other Non-Personal Injury/Property Damage tort 2.. 3. Wrongful Termination (36) A6037 Wrongful Termination 1-. 2.. 3 E. .9 El A6024 Other Employment Complaint Case 1., 2., 3. 2- Other Employment (15) LL, A6109 Labor Commissioner Appeals 10. [j A6004 Breach of Rental/Lease Contract (not unlawful detainer or wrongful 2 5 eviction) Breach of Contract! Warranty 2? 5? A6008 Contract/Warranty Breach -Seller Plaintiff (no fraudlne ligence) (06) 9 (not 'nsurance) El A6019 Negligent Breach of Contract/Warranty (no fraud) 1" 2" 5' A6028 Other Breach of ContracWVarranty (not fraud or negligence) 1" 4-: A6002 Collections Case?Seller Plaintiff 2? 5.. 5. 11 Collections (09) A6012 Other Promissory Note/Collections Case 2., 5, 11 A6034 Collections Case-Purchased Debt (Charged Off Consumer Debt 5, 6, 11 Purchased on or after January 1. 2014) Insurance Coverage?(18) El A6015 Insurance Coverage (not complex) 1.. 2.. 5-. 8- DAsoos Contractual Fraud 1., 2.. 3.. 5. Other Contra? (37) A6031 Tortious Interference 1.. 2.. 3.. 5. A6027 Other Contract Dispute(not 1.. 2., 3.. 8. Em?gigteaog?r? 3358 A7300 Eminent Domain/Condemnation Number of parcels 2. Wrongful Eviction (33) A6023 Wrongful Eviction Case 2-. 5- D. A6018 Mortgage Foreclosure 2., (B Other Real Property Quiet A6060 Other Real Property (not eminent domain, landlord/tenant. foreclosure) .. unlanUI Datig?rtcommerc'al A6021 Unlawful Detainer-Commercial (not drugs or wrongful eviction) 2.. 6. . . . r8: unlanUI Detggir'ReS'dent'al El A6020 Unlawful Defamer-Residential (not drugs or wrongful eviction) 2.. 6. '5 Unlawful Detainer: . Post_Foreclosure (34) A6020F Unlawful DetaIner-Post-Foreclosure 2.. 6- .: . . Unlawful Detainer-Drugs (38) El A6022 Unlawful Detainer-Drugs 2-. 5- LAqu 109 (Rev- 03115) 01er CASE COVER SHEET ADDENDUM Local Rule 2-3 Approved 03-04 Page 2 of 4 AND STATEMENT OF LOCATION American LegnlNef, Inc. 1' my SHORT TITLE: SAINT HEALTH CENTER FOUNDATION v. PAULA KENT MEEHAN FOUNDATION. et a1. CASE NUMBER .i A . Civil Case Cover Sheet Type of Action Applicable Category No. (Check only one) Reasons -See Step 3 4. Above Asset?Forfeiture (05) A6108- Asset Forfeiture Case 2n 5- 5 Petition re Arbitration (11) A6115 Petition to CompellCon?rm/Vacate Arbitration 2.. 5. A6151 Writ - Administrative Mandamus 8. 2% Writ of Mandate (02) El A6152 Writ - Mandamus on Limited Court Case Matter 2. 5; A6153 Writ - Other Limited Court Case Review 2. Other Judicial Review (39) A6150 Other Writ/Judicial Review 2., 8. Antitrust/Trade Regulation (03) A6003 Antitrust/Trade Regulation 1.. 2., 8 Eu Construction Defect (10) A6007 Construction Defect 1-. 2-. 3 .3 .2 C'a'ms ?"2339 Mass. A6006 Claims involving Mass Tort 1.. 2.. 8 .. .. . Securltles thlgatlon (28) A6035 Securities Litigation Case 1.. 2.. 8 ?76 Toxic Tort . . .3 Environmental (30) A6036 TOXIC Tort/Enwronmental 1 .2.. 3.. 6 '3 2 Insurance Coverage Claims . a. from Complex Case (41) A6014 Insurance Coverage/Subrogatlon (complex case only) 1.. 2.. 5.. 8- A6141 Sister State Judgment 2.. 9. Abstract ofJudgment 2.. 6. a Enforcement El A6107 Confession of Judgment (non-domestic relations) 2.. 9. 3 0f JUdeent (20) El A6140 Administrative Agency Award (not unpaid taxes) 2.. 8. lf. ?5 El A6114 Petition/Certi?cate for Entry ofJudgment on Unpaid Tax 2.. 8. A6112 Other Enforcement of Judgment Case an 9. .n RICO (27) A6033 Racketeering (RICO) Case 1A6030 Declaratory ReliefOnly 1Othencomplaints A6040 Injunctive Relief Only (not domestic/harassment) I 2., a, (Not Spec'?ed Above) (42) El A6011 Other Commercial Complaint Case (non-tortlnon-complex) 1., 2n 3_ I: A6000 Other Civil Complaint (non-tort/non-compiex) 1.. 2.. 8. Partnershi Cor oration . {an} Governpanceam) A6113 Partnership and Corporate Governance Case 2.. 8- A6121 Civil Harassment 2.. 3.. 9. 0" U) E?s-g A6123 Workplace Harassment 2.. 3.. 9. Q) chi-3? Other Pletnions A6124 Elder/Dependent Adult Abuse Case 2.. 3., 9. at?? (Not SpeCIerd Above) A6190 Election Contest 2. 43 529 A6110 Petition for Change of Name 2., 7. A6170 Petition for Relief from Late Claim Law 3., 8. El A6100 Other Civil Petition 2.. 9. 03115) CIVIL CASE COVER SHEET ADDENDUM Local Rule 23- LAsc'. Approved 03-04 Page 3 0f 4 AND STATEMENT OF LOCATION American LegulNet. Inc. 99m i . . ?4 . SHORT TITLE: CASE NUMBER SAINT HEALTH CENTER FOUNDATION v. PAULA KENT MEEHAN FOUNDATION, et al. Item Statement of Location: Enter the address of the accident, party's residence or place of business, performance, or other circumstance indicated in Item II., Step 3 on Page 1, as the proper reason for filing in the court location you selected. ADDRESS: REASON: Check the appropriate boxes for the numbers shown 2121 santa Monica under Column for the type of action that you have selected for this case. D1. D2. D3. D6. D7. D8. D9. D10. D11. CITY: STATE: ZIP CODE: Santa Monica CA 90404 Item IV. Declaration of Assignment: I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct and that the above-entitled matter is properly ?led for assignment to the Stanley Mosk Courthouse courthouse in the Central District of the Superior Court of California, County of Los Angeles [Code Civ. Proc., 392 et seq., and Local Rule 2.3, Dated: June lg, 2015 (SIGNAQAE 0F ATT Step en M. we . PLEASE HAVE THE FOLLOWING ITEMS COMPLETED AND READY TO BE FILED IN ORDER TO PROPERLY COMMENCE YOUR NEW COURT CASE: 1. Original Complaint or Petition. 2 If filing a Complaint, a completed Summons form for issuance by the Clerk. 3. Civil Case Cover Sheet, Judicial Council form CM-O10. 4 Civil Case Cover Sheet Addendum and Statement of Location form, LACIV 109, LASC Approved 03-04 (Rev. 03/15). Payment in full of the filing fee, unless fees have been waived. 6. A signed order appointing the Guardian ad Litem, Judicial Council form if the plaintiff or petitioner is a minor under 18 years of age will be required by Court in order to issue a summons. 7. Additional copies of documents to be conformed by the Clerk. Copies of the c0ver sheet and this addendum must be served along with the summons and complaint, or other initiating pleading in the case. Wit/109 (Rev- 03115) CIVIL CASE COVERSHEET ADDENDUM Local Rule 2-3 LAS-GiApproved 03-04 AND STATEMENT OF LOCATION ggn]