SUPERIOR COURT OF CALIFORNIA IN AND FOR THE COUNTY OF SACRAMENTO. Plaintiff, Defendants.

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1 JILL P. TELFER, State Bar No LAW OFFICES OF JILL P. TELFER A Professional Corporation 331 J Street, Suite 200 Sacramento, Caiifomia Telephone: (916) Facsimile: (916) itelfer(g>telferlaw.com Attorney for Plaintiff DONNA ROBBERECHT SUPERIOR COURT OF CALIFORNIA IN AND FOR THE COUNTY OF SACRAMENTO DONNA ROBBERECHT, Plaintiff, THE PERMANENTE MEDICAL GROUP, INC.; KAISER FOUNDATION HOSPITALS; KAISER FOUNDATION HEALTH PLAN INC.; BHC SIERRA VISTA HOSPITAL INC., doing business as SIERRA VISTA HOSPITAL; MOIRA SHARMA; UNIVERSAL HEALTH SERVICES INC., and DOES I through 20, inclusive Defendants. CASE NO: SECOND AMENDED COMPLAINT FOR DAMAGES: RETALIATION AND DEFAMATION JURY TRIAL REQUESTED ** COMES NOW PLAINTIFF, DONNA ROBBERECHT, and alleges as follows: PARTIES 1. Plaintiff DONNA ROBBERECHT (hereinafter referred to as "Plaintiff) is a qualified licensed clinical social worker ("LCSW") who was employed collectively with Defendants THE PERMANENTE MEDICAL GROUP, INC., KAISER FOUNDATION HEALTH PLAN, INC. and KAISER FOUNDATION HOSPITALS, the group of which is commonly referred to as Kaiser Permanente, for approximately thirteen years overall at the time of her tennination on or about August 1 SECOND AN4ENDED COMPLAfNT FOR DAMAGES

2 1 17, Plaintiffhas worked as an LCSW for over 25 years. She received exemplary performance 2 evaluations during her tenure with the Kaiser Defendants. She was a conscious employee performing 3 mental health treatment to Kaiser patients Defendants KAISER HEALTH PLAN, INC.. ("KFHP") and KAISER 5 FOUNDATION HOSPITALS ("KFH") are corporations organized and existing under the laws of 6 Cali fornia, each consisting with over 1000 employees, with their principal place of business located at 7 1 Kaiser Plaza, Oakland, Caiifomia THE PERMANENTE MEDICAL GROUP ("TPMG") is organized in form only as 9 a partnership under the laws of California, with over 1000 employees, with its principal place of 10 business located in Alameda County at 1950 Franklin Street, Oakland, Caiifomia KFHP, KFH and TPMG do business jointly, and with other entities owned and controlled 12 by KFHP under the name or brand "Kaiser Permanente." Kaiser Permanente is an "integrated" health 13 care delivery system compromised of the insurance company, KFHP, its doctors, organized as TPMG, 14 and its hospitals, which are wholly owned and/or controlled by KFHP through its captive entity, KFH, 15 which has no separate existence or identity apart from KFHP KFHP is an insurance company which purports to provide comprehensive total medical 17 care to its members. KFPH describes itself as the largest Health Maintenance Organization in the 18 country. KFHP exercises total control over Defendants KFH, TPMG. Patient "FW"' was a member of 19 KFHP who alleged to have been raped while being treated by Kaiser physicians and Sierra Vista staff 20 at SieiTa Vista Hospital on July 7, 8 and 9"' 2011,where she was involuntarily hospitalized. The Kaiser 21 Defendants and BHC Sierra Vista Hospital have a lucrative business relationship and did not want the 22 public disclosure of the allegation of rape, especially given recent exposure of other potential safety 23 issues KFHP's total dominance over KFH and TPMG is evidenced by the fact that KFH and 25 TPMG's entire annual budget is set by, controlled by, and approved by KFHP; all funds for KFH and 26 TPMG's operations comefi-omkfhp; KFHP detemiines what "profit" if any TPMG is allowed to make; 27 The patient's true name is not used to protect her right of privacy. 2

3 1 money that TPMG uses to pay bonuses to its doctors comes fi-om KFHP; TPMG does not bill any 2 patients for most of its services; barring emergencies or extremely rare instances; and TPMG's only 3 source of money is from KFHP. KFHP provides virtually all legal, human resources, insurance, 4 communications, advertising, billing, and other necessary services for KFH and TPMG. In this case, 5 those KFHP and KFH employees involved in the retaliation and defamation of Plaintiff include Mary 6 Hogarty, Londa Freeman, Jeremiah Gill, Dr. Stephen Melcher, Regional Human Resources, and 7 Regional Legal Members buying health care coverage only pay money to KFHP, not to TPMG; they buy 9 insurance from KFHP and they receive services through TPMG. Advertising for the health care offered 10 by KFHP as health insurance and provided through TPMG doctors is done predominantly by KFH P, as 11 advertising as "Kaiser Pennanente" as seen in the multi-million dollar "Thrive" advertising campaign. 12 TPMG does not own hospitals, medical buildings, or the clinics where they work; they are owned by 13 KFHP. KFHP provides all telephone, fax, and services for TPMG. KFHP also provides health 14 insurance and medical malpractice insurance to TPMG's doctors. KFHP lawyers routinely render legal 15 advice and counsel to KFH, TPMG, and have unfettered access to KFH and TPMG's records; KFHP's 16 Human Resources department routinely investigates any EEOC/DFEH or other complaints of 17 discrimination, as well as compliance and risk management, regarding KFH and TPMG's practices and 18 employees, reporting to KFHP's legal department on all such investigations; KFHP lawyers and human 19 resources staff do not obtain privacy waivers when seeking records of KFH and/or TPMG employees 20 or investigating their claims; KFHP provides and pays for all facilities in which KFH and TPMG 21 conduct business Defendants KFHP, KFH and TPMG, if not separately noted are hereinafter collectively 23 referred to as "Kaiser." These defendants are collectively liable under either a joint employer theory or 24 a single enterprise theory. Therefore, Plaintiffis informed and believes Kaiser is PlaintifPs employer 25 and it/they conspired to take the illegal acts against Plaintiff with the remaining corporate Defendants 26 as more ftilly described herein. 27 /// 28 /// 3

4 1 9. Defendant BHC SIERRA VISTA HOSPITAL, INC., doing business as SIERRA 2 VISTA HOSPITAL (hereinafter refen-ed to as "Sierra Vista") is an employer of over 50 persons. 3 Sierra Vista had a lucrative contractual business relationship vvith KFH and TPMG to provide in patient 4 psychiatric services to Kaiser patients, members of KFHP. TPMG physicians worked at Sierra Vista 5 Hospital along with Sierra Vista medical staff, who at all relevant times were overseen by Quality Chief 6 Dr. Stephen Melcher who, at all relevant times, was employed by both TPMG and Sien-a Vista Hospital 7 until he resigned on or about March, 2012 after pleading guilty to child molestation allegedly for acts 8 which occurred while off duty Plaintiff is informed and believes Defendant Sien-a Vista is a wholly owned subsidiaiy 10 of Defendant UNIVERSAL HEALTH SERVICES, INC. ("hereinafter referred to as "Universal 11 Health") is a Fortune 500 Company authorized to do business in the State of Caiifomia. Plainti ff is 12 informed and believes the Kaiser PMG Defendants and Universal Health have a close business 13 relationship and may involve similar shareholders 14 II. Individual Defendant Moira Shamia ("Sharina") at all relevant times was the TPMG 15 Adult Outpatient Psychiatry Manager, and a resident of Sacramento County. She engaged in acts of 16 malice against Plaintiff by defaming her to undermine her creditbil ity. Plaintiffis informed and believes 17 she is an employee of TPMG. In addition, other employees of TPMG and employees of KFH and 18 KFHP, Mary Hogarty, Londa Freeman, Marge Geaiy, Carrie Clark, Jeremiah Gill, Ulrike Morrison and 19 others of each of the Kaiser entities engaged in malicious acts toward Plaintiff, including defamation, 20 as more fully described herein The true names and capacities of the defendants named herein as DOES I through 20, 22 inclusive, whether individual, corporate, associate or otherwise, are unknown to Plaintiff who therefore 23 sue such defendants byfictitiousnames. Plaintiffis informed and believes that the DOE defendants are 24 responsible in some manner for the occurrences herein alleged and that Plaintiffs injuries were 25 proximately caused by the aforesaid defendants. Plaintiff will amend this complaint to show such true 26 names and capacities when they have been determined. 27 /// 28 /// 4

5 1 13. Plaintiffis informed and believes, and thereby alleges that each ofthe defendants herein 2 was at all times relevant hereto the agent, employee or representative and/or joint venturer of the 3 remaining defendants, and was acting at least in part within the course and scope of such relationship. 4 Plaintiff is further infonned and believes, and thereon alleges, that each of the defendants herein gave 5 consent to, ratified, and authorized the acts alleged herein to each of the remaining defendants Plaintiff alleges on information and belief that, at all times relevant herein, defendants, 7 and each of them, have actively participated in the defamation of, and/or retaliation against Plaintiff 8 because of her protected activity of knowing about health and safety violations by the Defendants 9 regai-ding the rape allegation of FW and all Defendants feared that Plaintiff would report said violations 10 which would expose all Defendants to civil liability and penalties from the California Department of 11 Public Health and other oversight commissions The managing agents for the corporate Defendants knew and/or should have known of 13 the retaliation and defamation. Despite having been informed of, or having reasonable knowledge of 14 said unlawful activity, these managing agents have refused to take any action to abate it and in fact 15 participated in it All ofthe described conduct, acts, and failures to act are attributed to agents and 17 employees under the direction and control, and with the permission, consent and authorization of the 18 remaining Defendants. Said acts, conduct and failures to act are within the scope of such agency and/or 19 employment Defendant Sierra Vista published to the Kaiser Defendants including TPMG the Daily 21 Census Report identifying all KFHP patients hospitalized at Sierra Vista, including their name, medical 22 number, whether or not the padent was voluntarily or involuntarily hospitalized, how long she/he 23 hospitalized and their treating psychiatrist who together published it to the Kaiser Department of 24 Psychiati-y at the South Sacramento Facility where Plaintiff worked. This report has personal health 25 infonnation ("PHI") of Kaiser patients. The articulated purpose was to determine if staff could assist 26 in a posifive resolution to a patient's situation listed on the census report. As a result, Kaiser staff 27 understood their employer felt a business need existed for them to have this PHI. This information alone 28 proves the corporate Defendants are condoning the relay of PHI between them and their respective 5

6 1 employees, including Plaintiff. Plainfiff is infonned and believes this is done without the knowledge 2 and/or consent of the patients. As a result of receiving the census from the Defendants, Plaintiff 3 Robberecht formed the good faith belief she had a business reason to access FW records and determine 4 if she could assist FW in a successful discharge from Sieira Vista Plaintiff performed family therapy for over two years specifically with a husband and 6 wife hereinafter called "FW Parents" and on occasion with their daughter, herein after "FW " FW's name appeared on the census provided to Plaintiff in the summer of from the Kaiser Defendants. F W was a Kaiser patient hospitalized at Sierra Vista Hospital by Defendant 9 Kaiser. Given the Defendants provided Plaintiff the PHI of FW and did not preclude her access to FW's 10 medical records. Plaintiff understood she had authority and business need to access FW's medical 11 records to detennine how she could assist with the discharge plan of release of FW to FW's Parents 12 because of Plaintiff s performance of family therapy of FW's Parents and FW. As a result. Plaintiff 13 accessed patient's records and learned FW alleged she was raped while hospitalized at Sierra Vista on 14 several occasions Kaiser Defendants were aware of FW's rape allegation because a TPMG employee 16 was her attending psychiatrist at Sierra Vista and the allegation was part of her Sierra Vista medical chart 17 which was thereafter scanned by case managers, including Ulrike Moirison, so that it became part of the 18 Kaiser medical chart. In addition, FW called Kaiser while sfill hospitalized on or about July 14, herself to infonn the entity she had been raped and sought an examination. As a result, Manageinent 20 of all the Defendant Corporate entities were aware of the rape allegation on or before July 14, On August 2, 2011 Plaintiff contacted Sien-a Vista and spoke to Ulrike Morrison and 22 requested to be part of FW's discharge once she secured releases for herself and the parents Defendants, in fear of Plaintiff s disclosure of these serious breaches of safety, retaliated 24 against Plaintiff by tenninating her and discrediting her, claiming she breached confidentiality bu 25 accessing the medical records of a family friend, which was not true. FW was not a family friend but 26 a patient she had previously treated. The Kaiser Defendants, including but not limited to Ulrike 27 Morrison, Dr Parik, Dr. Zimmerman, Jackie Rittenhouse, Mary Hogarty, and Londa Freeman defamed 28 Plaintiff by publishing and republishing to others, including the California Department of Public Heath 6

7 1 that Plaintiff accessed the medical records ofa familyfriendwhich would clearly be illegal and without 2 a business need. These publications continued into the fall of 2012, even though these individuals were 3 aware the statements were untrue. There has been a pattern and practice of these serious health and 4 safety breaches for Kaiser patients while hospitalized at Sien-a Vista which the parties were attempting 5 to cover up given their lucrative business relationship Defendants, including Sien-a Vista, sought to cover up the rape by conducting a 7 meaningless investigation, refijsing to even physically examine FW, which would have proved 8 someone engaged in sexual relations with her while she had been hospitalized, which would have 9 exposed Defendants to liability and government reporting. Further, although the Kaiser Defendant's 10 reported to California Department of Public Health Plaintiff accessed the medical records of a family 11 friend, it did not infonn FW of the alleged breach, which it is mandated to do under Health and Safety 12 Code The failure to notify FW of the alleged breach exposes the Kaiser Defendants to 13 penalties up to $250,000. However, Defendants did not want FW to know that Plaintiff was aware of 14 the rape because it was anticipated she would seek Plaintiffs assistance to pursue legal action and 15 reporting to the California Department of Public Health. 16 L 17 FIRST CLAIM FOR RELIEF 18 Defamation 19 (Against All Defendants) Plaintiff realleges and incorporates herein the allegations in paragraphs 1 through as set forth above Plaintiffs are infonned and believe the Defendants, and each of them, by the herein- 23 described acts, conspired to, and in fact, did negligently, recklessly, and intentionally caused 24 excessive and unsolicited internal and extemal publications of defamation, of and conceming Plaintiff, 25 to third persons and to the community in violation of Civil Code section 45, et seq. These false and 26 defamatory statements included express and implied: accusation that Plaintiff violated the Health 27 Insurance Poitability and Accountability Act ("HIPAA"), the accusation Plaintiff was told she should 28 not access a patient's medical records by a nurse and physician at Sien-a Vista and continued to do so 7

8 1 even after security measures were put in place to protect the records, Plaintiff was dishonest, 2 inappropriately accessed patient records without a work related need, and that Plaintiff inappropriately 3 accessed a family friend's medical records While the precise dates of these publications are not known to Plaintiff, she is aware of 5 the statements Plaintiff violated HIPAA on or about August 3,2011, by Moira Sharina, and a statement 6 Plaintiff inappropriately accessed family friend's records was published in an einail from Kaiser 7 employee Ulrike Morrison to KFH employee Londa Freeman, Robeit Zimmerman, Stephen Melcher 8 (einployed by TPMG and Sierra Vista), M.D., Marge Geary, Mary Hogarty, Jeremiah Gill einployed by 9 KFH and Defendant Sharma who is einployed by TPMG and thereafter was republished to Defendants 10 Sierra Vista, KFHP and TPMG, and Defendants' personnel which continues to the present. These 11 comments have continued up to the present time for the iinproper purpose of scape-goating Plaintiff for 12 the wrongfijl acts of Kaiser TPMG, Sierra Vista and Universal Health of providing the confidential 13 information of patients hospitalized and to find a means to tenninate her and cover up the rape allegation 14 where the patient who made the allegation threatened to sue. The stateinents were later published and 15 forseeably republished to first cause, and then justify the discipline and termination. These publications 16 were outrageous, negligent, reckless, intentional, and maliciously published and republished by 17 Defendants, and each of them. Plaintiff is informed and believes that the negligent, reckless, and 18 intentional publications by Defendants, their agents and employees, recipients, in the community. 19 Plaintiff hereby seek damages for these publications and all foreseeable republications discovery up to 20 the fime of trial. These defamatory verbal stateinents included Plaintiff "violated the law, including 21 HIPPA", that were made by Defendant Sharma to Jeremiah Gill, Marge Geary and others. Likewise, 22 Ulrike Momson made the comment that Plaintiff was a family friend of FW in an effort to cover up the 23 allegation of rape to Shanna and other Kaiser and TPMG employees. In August 2011, based on 24 publications from Londa Freeman and Mary Hogarty, Jackie Rittenhouse published to V.P. Patricia 25 Rodriguez, Tara Brady, Medical Group Administrator Deborah Royalty, Dr. Stephen Melcher and Mark 26 Kauffman, that Donna Robberecht accessed the medical records of a family friend. These individuals 27 republished the allegations to Dr. Sterling Alexander, Carol Higginson, Laureen Campana, Michael 28 Zauner and Dr. Parikh, who thereafter made further publications. Again in the fall of 2012, Londa 8

9 1 Freeman of KFH, and Mary Hogarty of KFHP published the same statement again to the California 2 Department of Public Health ("CDPH") and other executives with Defendant Kaiser, knowing the 3 infonnation was untrue in order to maliciously harm Plaintiff and cover up Defendants' unlawful 4 conduct During the above-described time-frame, the Defendants, and each of them, conspired to, 6 and in fact, did negligently, recklessly, and intentionally cause excessive and unsolicited publication of 7 defamation, of and conceming Plaintiff, to third persons, who had no need or desire to know. Those 8 third person(s) to whom these Defendants published this defamation are believed to include, but not 9 limited to, all of whom are known to Defendants, and each of them, but unknown at this time to Plaintiff The defamatoi-y publications consisted of oral and written, including s and 11 documents sent to the California Department of Public Health, which was thereafter sent to individuals 12 in executive management of Kaiser and TPMG and to Defendant Sieira Vista and Defendant Universal 13 Health who continued to publish the comments to third parties causing Plaintiff further damage, 14 knowingly false and unprivileged communications, tending direcfiy to injure Plaintiff and Plainfiffs 15 personal, business and professional reputation. These publications included the following false and 16 defamatory statements (in violation of Civil Code 45 and 46(3)(5)) with the meaning and/or substance 17 that Plaintiff was dishonest and violated HIPAA, accessed a family friend's medical records, continued 18 to access records without a business need after she was instructed not to. These statements vvere in both 19 written and verbal form and were made by Defendant Shanna, Londa Freeman, Mary Hogarty, Marge 20 Geary, Jeremiah Gill, and republished by other employees of Defendants Plaintiffis infonned, believes and fears that these false and defamatory per se stateinents 22 will continue to be published by Defendants, and each of them, and will be foreseeably republished by 23 their recipients, all to the ongoing hann and injury to Plaintiffs business, professional, and personal 24 reputations. Plaintiff also seeks redress in this action for all foreseeable republications, including their 25 own compelled self-publication of these defamatory statements The defamatory meaning of all of the above-described false and defamatory stateinents 27 and their reference to Plaintiff were understood by these above-referenced third person recipients and 28 other members of the community who are known to Defendants, and each of them, but unknown to 9

10 1 Plaintiff at this time None of Defendants' defamatory publications against Plaintiff referenced above are true The above defamatory statements were understood as assertions of fact, and not as 4 opinion. Plainfiff is infonned and believes this defamafion will continue to be negligently, recklessly, 5 and intentionally published and foreseeably republished by Defendants, and each of them, and 6 foreseeably republished by recipients of Defendants' publications, thereby causing additional injury and 7 damages for which Plaintiff seeks redress by this action Each of these false defamatory per se publications (as set forth above) were negligently, 9 recklessly, and intenfionallypublished in a inanner equaling malice and abuse ofany alleged conditional 10 privilege (which Plaintiff deny existed), since the publications, and each of them, vvere made with hatred, 11 ill will, and an intent to vex, harass, annoy, and injure Plaintiff because of her anticipated complaint to 12 the Caiifomia Department of Public Health Each of these publications by the Defendants, and each of them, were made with 14 knowledge that no investigation supported the unsubstantiated and obviously false statements. The 15 Defendants, published these stateinents knowing them to be false, unsubstantiated by any reasonable 16 investigation and the product of hostile witnesses. These acts of publication were known by Defendants, 17 and each of them, to be negligent to such a degree as to be reckless. In fact, not only did Defendants, 18 and each of them, have no reasonable basis to believe these stateinents, but they also had no belief in the 19 tmth of these statements, an din fact knew the stateinents to be false. Defendants, and each of them, 20 excessively, negligently, and recklessly published these statements to individuals vvith no need to know, 21 and who made no inquiry, and who had a mere general or idle curiosity of this information The above complained-of publications by Defendants, and each of them, vvere made vvith 23 hatred and ill will towards Plaintiff and the design and intent to injure Plaintiff, Plaintiffs good name, 24 her reputafion, employment and employability. Defendants, and each of them, published these 25 stateinents, not with an intent to protect any interest intended to be protected by any privilege, but with 26 negligence, recklessness and/or an intent to injure Plaintiff and destroy her reputation. Therefore, no 27 privilege existed to protect any of the Defendants from liability for any of these aforementioned 28 publications or republications. 10

11 1 36. As a proximate result of the publication and republication of these defamatory statements 2 by the Defendants, and each of them, Plaintiff has suffered injury to her personal, business and 3 professional reputation including suffering embarrassment, humiliation, severe emotional distress, 4 shunning, anguish, fear, loss of employment, and employability, and significant economic loss in the 5 form of lost wages and future earnings, all to Plaintiffs economic, emotional, and general damage in 6 an amount according to proof The Defendants, and each of them, committed the acts alleged herein recklessly, 8 maliciously,fraudulently,and oppressively, with the wrongful intention on injuring Plaintiff, for an 9 improper and evil motive amounting to malice (as described above), and which abused and/or precented 10 the existence of any conditional privilege, which in fact did not exist, and vvith a reckless and conscious 11 disregard of Plaintiffs rights. 12 H. 13 SECOND CLAIM FOR RELIEF 14 (Retaliation and Wrongful Termination in Violation of Health and Safety Code ) 15 (Against KFHP, KFH and TPMG Only) Plaintiff incor]dorates paragraphs 1 through 37 as though fully set forth herein At all times relevant to this matter. Plaintiff was an employee and healthcare worker, 18 as defined under this code working at Kaiser and their health facilities. In addifion. Defendants were 19 owners and operators of health facilities Given Plaintiffs family therapy of FW and FW's parents, which 21 included Plaintiff, coupled with Defendants providing Plaintiff with inforination of FW's 22 hospitalizafion at Sien-a Vista and anticipated discharge. Plaintiff accessed FW's records and learned 23 of a rape allegation while Daughter Patient was hospitalized at Defendant Sierra Vista in July The Kaiser Defendants have an obligation to keep its/their patients safe, especially 25 vvhen said patients are being involuntarily hospitalized vvith Defendcint Sierra Vista, who has a 26 lucrative relationship with Kaiser Defendants. This obligation includes notifying government entities 27 of suspected unsafe patient care and conditions. In particular, all Defendants had an obligation to 28 inform the Police Department and the Caiifomia Department of Public Health of a rape allegation M

12 and thoroughly investigate. However, they failed to do so. As such, PlaintifFs knowledge of these potential violations caused Defendants to believe she would be a whistle blower and that she needed to be silenced and discredited. As a result. Defendants engaged in preemptive retaliation. 42. Defendants and each of them determined the best way to silence Plaintiff and to protect itself against the health and safety violations and Defendants' HIPPA violations would be to publish to the State, to patients and the public PlaintifF inappropriately accessed a family friend's medical records without a business need, and continued to access said records after being instructed by a physician and a nurse, and even with security measures in place, continued to access said records in violation of the law. 43. As a proximate result of Defendants' retaliatory conduct, Plaintiffhas been damaged in an amount according to proof, but in an amount in excess of the jurisdiction of this Court. Plaintiff also seeks "affirmative relief or prospective relief as defined by Health and Safety Code As a proximate result of Defendants' willful and intentional conduct, Plaintiffhas lost wages, benefits and other out of pocket expenses. 45. As a proximate result of Defendants' conduct, Plaintiff has incurred and continues to incur legal costs and attomey fees. 46. As a proximate result of the aforementioned acts of Defendant, PlaintifF has become mentally upset, distressed and aggravated. PlaintifF claims general damages for mental and emotional distress in an amount according to proof at time of trial. 47. The above described actions were done with malice, fraud, oppression and in reckless disregard of PlaintifFs rights. Defendants' actions were authorized, ratified or perpetrated by a managing agent, officer or Director of Defendants. Further, said actions were despicable in character and warrant the imposition of punitive damages in a sum sufficient to punish and deter Defendant's fiiture conduct. PRAYER 1. Award PlaintifF compensatory damages, according to proof, for lost wages, medical and psychiatric care expenses and pain and suffering; 12

13 DATED: For punitive damages according to proof; Reinstatement pursuant to Health and Safety Code ; Reasonable attorneys' fees; Reasonable costs of suit; For any other relief that the Court deems just and proper. Februaiy 24,2014 LAW OFFICES OF JILL P. TELFER A Professional Corporation tomey for Plaintiff DONNA ROBBERECHT 13 SECOND AMENDED COiaPLAINT FOR DAMAGES

14 PROOF OF SERVICE CASE: Robberecht v Kaiser Permanente; Sierra Vista Hospital, et al. COURT: SACRAMENTO COUNTY SUPERIOR COURT CASE NO.: , the undersigned, declare 1 am employed in the County of Sacramento, State of California. 1 am over the age of eighteen years and not a party to the within-entitled action. My business address is 331 J Street, Suite 200, Sacramento, CA I am readily familiar with this firm's practice for collection and processing of con-espondence for mailing with the United States Postal Service. On the date indicated below, 1 served the following documents by: [ ] facsimile transmission, and, [X] placing a true copy thereof in a sealed envelope vvith postage thereon fully prepaid in the designated area for outgoing mail and addressed as indicated below. Said documents will be deposited with the U.S. Postal Service at Sacrainento, Caiifomia on this date in the ordinary course of business. 1 understand that upon motion ofa party served service shall be assumed invalid if the postal cancellation date or postage meter date on the envelope is more than one (1) day after the date of deposit for mailing as contained in this declaration [ ] Hand-delivery : RETALIATION AND DEFAMATION ADDRESSED TO : David R. McNamara Christina Tillman MCCORMICK, BARSTOW, SHEPPARD WAYTE & CARRUTH P.O. Box Fresno CA Fax:(559) Ms. Alice Conway Powers Lewis Brisbois Bisgaard & Sinith LLP 333 Bush Street, Suite 1100 San Francisco, CA Fax: (415) I declare under penalty of perjury' that the foregoing is true and correct. Executed on February 24, 2014, at Sacrainento, California. Patiifck Growl 1-4' SECOND AMENDED.CdNlPLAlNT FOR DAMAGES

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