RX Date/Time 2014 1426 9817899083 eae e rom 17899083 page 2 1 || Jeremy O. Arnaiz, Esq. FILED , 2 || Law Office of Jeremy 0. Amaiz superior Court of California j SBN 151241 Upeunty of Los Angeles 3 || Frank E. Harrigan y SBN 196730 OCT 07 2014 4/6690 Alessandro Bivd., Suite B ster, Exqgutve OffcerCleth 5 ||Riverside, CA 92506 oo et ee Tel. (951) 789-6291 Lo ‘aul Sanche? Fax (951) 789-9083 Attorney for Defendants: Narinder S. Grewal; and, Narinder S. Grewal M.D., 8 lla medical corporation; G3 Healthcare zp || business as SANTA CLARITA : SURGERY CENTER FOR 21 | ADVANCED PAIN MANAGEMENT, And Does 1 through 25, inclusive, " SUPERIOR COURT OF THE STATE OF CALIFORNIA Ce IN AND FOR THE COUNTY OF LOS ANGBLES, CENTRAL DISTRICT 2 \ || pPy ENTERPRISES, INC.,aNevada ) Case Number: BC 427192 15 || Corporation ) Plaintiff, ) 16 |Iv. ) JEREMY O. ARNAIZ DECLARATION | } RE: DISPOSITION OF EXHIBITS ” ) { || NARINDER S. GREWAL, an ) IG 6 individual; NARINDER S. GREWAL ) pr | 19|[M.D., a medical corporation, doing} ) ) ) ) ) 2 fs Defendants, e ) f 24 || AND CROSS-COMPLAINT ) . = 28 \I), Jeremy O. Arnaiz, declare: ‘ 8 : 1. Tam an attorney duly admitted to appear before all courts of the . 2 State of California. I am the attorney of record for Defendants and Cross- cs Complainants in the above-entitled matter. My business address is 6690 ED ORIGINALRX Date/Time 1 14 14:26 9517899083 e@ P.003 Oct 07 2014 0021 New York UfeM@17899083 page 3 " 2 2 14 18 7 8 19 an 2 2 24 2% 6 Fa 2 Alessandro Blvd. Suite B, Riverside CA 92506. I have personal knowledge of the matters set forth below and if called upon to testily, will testify as set forth below. 2. L emailed the proposed Stipulation Regarding Disposition of Exhibits to Plaintiff and Cross-Defendants’ attorney, Michael Hemming, on October 5, 2014. |A true and correct copy of the proposed Stipulation Regarding Disposition of Exhibits is attached and incorporated as Exhibit A. In my email, I requested Mr, Hemming to add in the exhibits his client wished to remain in the court’s possession, sign the stipulation and return the stipulation to my office by 5:00 pm on October 6, 2014. I did not receive any response to my email. 3. On October 6, 2014, at approximately 2:45 pm, | sent Mr. Hemming a text stating that I would wait until 9:00 am October 7, 2014 before I had the stipulation filed with the court. | did not reccive any response to my text. 4. Since I did not receive any response to my communications and the proposed stipulation, | am filing the instant declaration to inform the court of the status of this matter and to identify Plaintiff's Exhibits that Defendants and Cross-Complainants wish the court to maintain possession. As stated previously, Defendants and Cross-Complainants wish the court to maintain possession of the identified Plaintiff's Exhibits because copies of these Exhibits were not provided to Defendants and Cross-Defendants prior to the Exhibits being admitted as evidence and/or the Exhibits were modified by Plaintiff prior to the Exhibits being admitted as evidence. 5. Defendants and Cross-Complainants’ request that the court maintain possession of the following Exhibits until the time to file an appeal in this matter has expired or an appeal has been filed and heard by the Appeals Court, whichever time period expires later:RX DatesTime 14 14:26 9517899083 e P.004 Oct 07 2014 0021 New York Life 4917899083, page 4 18 20 a 2 23 a 28 2 2 28 Plaintiff's Exhibits: i. Exhibit Number 38 (Binder 29 and 30, Checks exchanged with Dr. Grewal post-6/3/2007) 2. Exhibit Number 32 (Fax regarding Aetna letter) 3. Exhibit Number 35 (Santa Clarita/Dr. Grewal Consultation/Surgical Log) 4, Exhibit Number 72 (Santa Clarita/Dr. Grewal Patient Count) 5. Exhibit Number 36 (Blue Cross and Medicare Patients) 6. Exhibit Number 40 (Checks received post 6/3/2007) 7. Exhibit Number 108 (Printout of alleged overpayment) 8. Exhibit Number 41 (Patients allegedly billed by Dr. Grewal] 9. Exhibit Number 9 (Patients not billed by HBSG1) 10. Exhibit Number 44 11. Exhibit Number 60 12. Exhibit Number 77 13. Exhibit Number 109. 14. Exhibit Number 110 15. Exhibit Number 111 (Alleged Reconcil tion Performed by Basu) 16. Exhibit Number 51 (Collection Report) 17. Exhibit Number 95 I declare under the penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on October 7, 2014 at Riverside, California. Date: 49/4 /i Ww Jegémy O-Arnaiz cs