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1 -0-rdd Doc 0 Filed 0/0/ Entered 0/0/ :: Main Document Pg of Hearing Date: August, 0 at :00 a.m. (Eastern Time) BINDER & SCHWARTZ LLP Eric B. Fisher Tessa B. Harvey Madison Avenue, th Floor New York, New York 0 Telephone: () -00 Facsimile: () - Attorneys for Dignity Health (d/b/a Marian Regional Medical Center) UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK x In re: st CENTURY ONCOLOGY HOLDINGS, INC., et al., Chapter Case No. -0 (RDD) (Jointly Administered) Debtors x CALIFORNIA RADIATION THERAPY MANAGEMENT SERVICES, INC. AND U.S. CANCER CARE, INC., against Plaintiffs, DIGNITY HEALTH (d/b/a MARIAN REGIONAL MEDICAL CENTER); CENTRAL COAST MEDICAL ONCOLOGY CORP., Adversary Proceeding Case No. -0 (RDD) Defendants x DECLARATION OF ERIC B. FISHER IN SUPPORT OF THE OBJECTION OF DIGNITY HEALTH TO DEBTORS MOTION FOR ENTRY OF AN ORDER EXENDING THE AUTOMATIC STAY OR, IN THE ALTERNATIVE, GRANTING PRELIMINARY AND PERMANENT INJUNCTIVE RELIEF HALTING THE PROSECUTION OF THE DIGNITY HEALTH LITIGATION

2 -0-rdd Doc 0 Filed 0/0/ Entered 0/0/ :: Main Document Pg of I, Eric B. Fisher, declare as follows:. I am a Partner with Binder & Schwartz LLP, counsel for Dignity Health (d/b/a Marian Regional Medical Center) ( Dignity Health ) in the above-captioned adversary proceeding. I make this declaration in support of Dignity Health s Objection to the Debtors Motion for Entry of an Order Extending the Automatic Stay or, in the Alternative, Granting Preliminary and Permanent Injunctive Relief Halting the Prosecution of the Dignity Health Litigation (Adv. Pro. Dkt. No. ).. Attached hereto as Exhibit A is a true and correct copy, without exhibits, of Dignity Health s Complaint for () Common Law Unfair Competition; () Unfair Competition in Violation of Business and Professions Code section 00, et seq.; () Intentional Interference with Existing Contractual Relations; () Intentional Interference with Prospective Business Advantage; () Injunctive Relief; and () Declaratory Relief, filed on February, 0, in Dignity Health v. Coastal Radiation Oncology Medical Group, Inc., et al., Case No. CV000 (Cal. Superior Court Santa Barbara County - Santa Maria Division) (the Santa Maria Action ).. Attached hereto as Exhibit B is a true and correct copy of the Request for Dismissal of defendant st Century Oncology of California from the Santa Maria Action, filed on August, 0, in the Santa Maria Action. I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. Dated: August, 0 /s/eric B. Fisher Eric. B. Fisher

3 -0-rdd Doc 0- Filed 0/0/ Entered 0/0/ :: Exhibit A Pg of Exhibit A

4 -0-rdd Doc 0- Filed 0/0/ Entered 0/0/ :: Exhibit A Pg of I l I _ - n EISNER JAFFE, APC JAMES TURKEN (SBN ) j turken@eisnerlaw.com KATHLEEN C. HTPPS. (SBN 0) kcemiglia@eisnerlaw. com 0 Wilshire Boulevard, Suite 00 Beverly Hills, California 0 Telephone: () -00 Facsimile: () -0 Attomeys for Plaintiff Dignity Health ELECTRONICALLY FILED Superior Court of California County of Santa Barbara Darrel E. Parker, Executive Officer 0 ::PM By. John Tennant, Deputy I I rj rft ^ tl UN r-r - la c o< gie < tr J< E q i+ ze-= rn=' - A>, tl rdle E E H r{i t tt Itt lq lli :t :l DIGNITY HEALTH, a Califomia nonprofit public benefit corporation, dba MARIAN REGIONAL MEDICAL CENTER, vs. SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SANTA BARBARA - Plaintiff COASTAL RADIATION ONCOLOGY MEDICAL GROUP, INC., a Califomia professional corporation; CASE H. KETTING, M.D., an individual; JEFFREY K. WU, M.D., an individual: r' CENTURY 0NCOL0GY OF CALIFORNIA, a Caiifornia corporation; CENTRAL COAST MEDICAL ONCOLOGY CORP., a California corporation; and DOES l-, Defendants. SANTA MARIA DIVISION Case No. CV000 FOR: (l) Common Law Unfair Competition; () Unfair Competition in Violation of Business and Professions Code section 00, et seq.; () Intentional Interference with Existing Contractual Relations; () Intentional Interference with Prospective Business Advantnge; () Injunctive Relief; and () Declaratory Relief DEMAND FOR JURY TRIAL :,.r l t-i "l (! l COMPLATNT 00v

5 -0-rdd Doc 0- Filed 0/0/ Entered 0/0/ :: Exhibit A Pg of Plaintiff DIGNITY HEALTH, a California nonprofit public benefit corporation, doing business as MARIAN REGIONAL MEDICAL CENTER, hereby complains of Defendants COASTAL RADIATION ONCOLOGY MEDICAL GROUP, INC., a California professional corporation; CASE H. KETTING, M.D., an individual; JEFFREY K. WU, M.D., an individual; st CENTURY ONCOLOGY OF CALIFORNIA, A MEDICAL CORPORATION, a California corporation formerly known as U.S. CANCER CARE, INC., CALIFORNIA RADIATION THERAPY SERVICES, INC., and ONCURE MEDICAL CORP.; CENTRAL COAST MEDICAL ONCOLOGY CORP., a California corporation; and DOES through (collectively, 0~~ 0 W N F. O ~~a w ' w~~ ~; h W J a=~ W mj z ~_ W~ ~= ~ N J w ~ ~ ~m ' Barbara County. 0 "Defendants"), and alleges as follows: JURISDICTION AND VENUE. This Court has jurisdiction over this action pursuant to California Code of Civil Procedure section. on the basis that the wrongful acts complained of herein occurred within California. Further, the amount in controversy exceeds the jurisdictional minimum of this Court.. Venue is proper in this Court, pursuant to Code of Civil Procedure section, on the basis that the wrongful acts and injuries complained of in this Complaint occurred within Santa NATURE OF ACTION. This action arises from multiple breaches of multiple agreements, and the improper diversion of patients, with subterfuge, from Dignity Health's cancer center in Santa Maria, the Mission Hope Cancer Center, which was established and constructed to bring world-class medical care to the greater Santa Maria community. THE PARTIES. Plaintiff DIGNITY HEALTH is a California nonprofit public benefit corporation, doing business as, inter alia, MARIAN REGIONAL MEDICAL CENTER ("Plaintiff' or "Dignity Health"). Dignity Health owns the real property at E. Church Street, Santa Maria, California, upon which the Mission Hope Cancer Center is located. Dignity Health also owns and operates the Marian Regional Medical Center at 00 E. Church Street, Santa Maria, California, which is adjacent to the Mission Hope Cancer Center.

6 -0-rdd Doc 0- Filed 0/0/ Entered 0/0/ :: Exhibit A Pg of 0 0 n f- w o ~ ~~Q w ' w~~ Q;~ i' W J a/ ~ U W m~ z W~ ~_..N~ LS Wow ~w m m 0. Dignity Health is informed and believes, and on that basis alleges, that Defendant COASTAL RADIATION ONCOLOGY MEDICAL GROUP, INC. ("Coastal"), is a professional medical corporation organized and existing under the laws of the State of California, with its principal place of business in San Luis Obispo, California, in addition to operating nine locations throughout California, including a location in Santa Barbara County.. Dignity Health is informed and believes, and on that basis alleges, that Defendant ST CENTURY ONCOLOGY OF CALIFORNIA, A MEDICAL CORPORATION, formerly known as U.S. CANCER CARE, INC., CALIFORNIA RADIATION THERAPY SERVICES, INC., and ONCURE MEDICAL CORP. (collectively, " S~ Century"), is a corporation organized and existing under the laws of California, with its principal place of business in Santa Maria, California.. Dignity Health is informed and believes, and on that basis alleges, that Defendant CASE H. KETTING, M.D. ("Ketting"), is an individual residing in the State of California, working in and maintaining businesses in Santa Maria and the County of Santa Barbara. Dignity Health is informed and believes, and on that basis alleges, that Ketting is an owner of Coastal.. Dignity Health is informed and believes, and on that basis alleges, that Defendant JEFFREY K. WU, M.D. ("Wu"), is an individual residing in the State of California, working in and maintaining businesses in Santa Maria and the County of Santa Barbara. Dignity Health is informed and believes, and on that basis alleges, that Wu is an owner of Coastal.. Dignity Health is informed and believes, and on that basis alleges, that Defendant CENTRAL COAST MEDICAL ONCOLOGY CORP. ("Central Coast"), is a corporation organized and existing under the laws of California, with its principal place of business in Santa Maria, California.. At this time, Dignity Health does not know the true names and capacities of Defendants DOES through, inclusive, and therefore sues these Defendants under fictitious names pursuant to California Code of Civil Procedure section. Dignity Health is informed and believes, and on that basis alleges, that each Defendant designated herein as DOES through is responsible in some manner for the acts, omissions and occurrences alleged herein, whether such acts, omissions and occurrences were committed intentionally, negligently, recklessly or otherwise,

7 -0-rdd Doc 0- Filed 0/0/ Entered 0/0/ :: Exhibit A Pg of ~~ o a W N r ~ W w ~a~ w~~ Q; ~J W J ~ U wm~ z ~_ w~ nn ~= N Y J W ~ W J ~W ~m 0 and that each said DOE Defendant is liable therefor to Dignity Health for the damages suffered by Dignity Health as hereinafter set forth. As Dignity Health is presently unaware of the true names and capacities of the Defendants named herein as DOES through, it will seek leave of Court to '' ~ amend this Complaint when the identities of such fictitiously named Defendants become known. Any mention of or reference to any named Defendant, and any allegation or cause of action stated in this Complaint against any named Defendant, also is intended to include and apply to DOES through.. Dignity Health is informed and believes, and on that basis alleges, that at all times relevant hereto, each of the Defendants, including the fictitiously named Defendants DOES through, was, and is, in some manner responsible to Dignity Health for the obligations, acts, omissions and occurrences alleged herein, that each of the Defendants was and is an cider and abettor, joint tortfeasor, alter ego, agent, representative, employee and/or affiliate of other Defendants, in whole or in part, and that each of the Defendants, in doing the things alleged herein, acted and continues to act within the scope of that agency, representation and/or employment with the knowledge and consent of said other Defendants. Dignity Health further is informed and believes, and on that basis alleges, that Defendants, and each of them, conspired together and willfully formed a deliberate design and purpose to, and/or entered into a scheme to, commit the acts and/or omissions herein alleged, and in pursuance thereof, did and/or caused to be done such acts and/or omissions, and that all of said acts and/or omissions were participated in and were done by all of these Defendants, or any one or more of them, as steps in furtherance of said conspiracy and for the unlawful purposes set forth herein. FACTUAL BACKGROUND. Dignity Health owns the real property at E. Church Street, Santa Maria, California (the "Property"), upon which the Mission Hope Cancer Center building and improvements are located (the "Premises" or "Mission Hope Cancer Center").. From the beginning, Dignity Health's intent with the Mission Hope Cancer Center was to serve the greater Santa Maria community by providing it with aworld-class cancer center.. Dignity Health ground leases the Property to MHCC, LLC ("MHCC") under the

8 -0-rdd Doc 0- Filed 0/0/ Entered 0/0/ :: Exhibit A Pg of 0 0 ~~ W N F- ~ w~ ' w ~na G ~ ~ Qa LL lyj J a ~ U wm~ z w~ ~_ ~_} ~ ~ J W ~ ~W ~m 0 Ground Lease dated September, 0 (the "Ground Lease"), a true and correct copy of which is attached hereto as Exhibit "A." MHCC is the ground tenant under the Ground Lease and owner of the Mission Hope Cancer Center building and improvements.. MHCC in turn leases office space on the Premises back to Dignity Health under an Office Space Lease dated September, 0 (the "Office Space Lease"), a true and correct copy of which is attached hereto as Exhibit "B," and an Office Space Lease dated May, 0, a true and correct copy of which is attached hereto as Exhibit "C.". Dignity Health is informed and believes, and on that basis alleges, that MHCC also leases office space in the Mission Hope Cancer Center to other entities.. Dignity Health is informed and believes, and on that basis alleges, that Ketting and Wu both work in Coastal's office located in the Mission Hope Cancer Center, and they are also affiliated with S` Century.. Dignity Health's concept of having aworld-class cancer center put physicians and medical groups in a position to obtain patients because of their affiliation with Dignity Health.. Accordingly, the Ground Lease between Dignity Health and MHCC prohibits certain "Disqualified Persons" from using and occupying the Premises. See Exh. "A" at section.a(b)(iii). The Ground Lease defines a Disqualified Person as follows: Any Person or any Affiliate of a Person that directly or indirectly engages in activities within [Santa Barbara] County or within San Luis Obispo County, California that are `directly competitive' with [Dignity Health]. 0. Dignity Health is informed and believes, and on that basis alleges, that the "Disqualified Person" restriction in the Ground Lease is incorporated by express reference in section. of the September, 0 master lease between MHCC and Central Coast (the "Master Lease").. The "Disqualified Person" restriction applies to any subtenant of Central Coast as well, and Dignity Health is informed and believes, and on that basis alleges, that the "Disqualified Person" restriction is incorporated by reference in Central Coast's subleases with it subtenants.. Dignity Health is informed and believes, and on that basis alleges, that Defendant St Century entered into a sublease with Central Coast in 0 (the "Sublease").

9 -0-rdd Doc 0- Filed 0/0/ Entered 0/0/ :: Exhibit A Pg of. Dignity Health is informed and believes, and on that basis alleges, that the Sublease also incorporates the "Disqualified Person" restriction at sections. and... Dignity Health is informed and believes, and on that basis alleges, that S~ Century and Central Coast are also parties to the Amended and Restated Management Services Agreement dated October, 0 (the"msa"), a true and correct copy of which is attached hereto as Exhibit 0~~ 0 W N F O w ' ~ N Q ~ K Q ~ i' W J ~I ~ U wm~ z ~_ w~ ~ ~'_} ~ J W ~ W ~m ~w 0 IfiL~~i. Dignity Health is informed and believes, and on that basis alleges, that S` Century has been engaging for no less than two years in at least the following activities that are directly competitive with Dignity Health, in violation of the "Disqualified Person" restriction: (a) First, in conjunction with Coastal, S` Century organized and facilitates a medical facility in Lompoc, which is in Santa Barbara County, for the purpose of providing medical services that will compete with those provided by Dignity Health. Coastal's own website states: Our newest center, Lompoc Radiation Oncology Medical Center, part of the Coastal Radiation Oncology Medical Group makes world-class cancer treatment available to residents of Lompoc and surrounding communities. The dedicated team of physicians, radiation therapist, physicists, dosimetrists, and the rest of our staff are committed to delivering individualized treatments with compassion and expertise. The Lompoc treatment team offers a full range of advanced treatment options, including Intensity-Modulated Radiation Therapy (IMRT), Image-Guided Radiation Therapy (IGRT), and D Radiation Treatment Planning. Available at (emphasis added). (b) Additionally, Dignity Health is informed and believes, and on that basis alleges, that Coastal has entered into a contractual relationship with Lompoc Valley Medical Center and affiliates (collectively, "Lompoc"), whereby Coastal is collaborating with Lompoc to manage, operate, and promote Lompoc's competing cancer treatment facility. This is in direct violation of the agreements referred to hereinafter.. Coastal's agents, including but not limited to its owners, Ketting and Wu, in ~ collaboration with Coastal, have redirected multiple Mission Hope Cancer Center patients for ~

10 -0-rdd Doc 0- Filed 0/0/ Entered 0/0/ :: Exhibit A Pg of 0 ~~ o a W o ~~ W ~ ~ to Q L:. ~ K Q j O W J a/ ~ U w m J z W J ~ _ V~ _ ~ N J W ~ ~m o w 0 treatment at a competing cancer center in Lompoc, California, owned and operated by Lompoc. These patients now receive many medical services, including but not limited to imaging, infusion, and lab services at Lompoc rather than from Dignity Health's facilities at the Mission Hope Cancer Center and Marian Regional Medical Center.. Dignity Health is informed and believes, and on that basis alleges, that patients at Lompoc do not receive the same quality of treatment that they would receive at Mission Hope Cancer Center because, among other things: (a) Mission Hope Cancer Center is an integrated cancer center that was specifically developed to help cancer patients heal through state-of-the-art oncology treatment, imaging, and research, as well as a wide array of outreach programs and support services, including nutritional counseling, nurse navigators, social workers, physical therapy and exercise rehabilitation, support groups, psychosocial counseling with a clinical psychologist, patient transportation, a financial assistance program, cancer screening and education, and mindbody approaches, such as yoga and meditation; (b) when patients are transferred away from Mission Hope Cancer Center, they are deprived of the opportunity to receive follow-up care with Central Coast's team of medical oncologists; and (c) Mission Hope Cancer Center offers more up-to-date radiation equipment. For example, Mission Hope Cancer Center patients are treated with a modern TrueBeam Linear Accelerator, which provides more precise treatment than the older Rapid Arc machine used at Lompoc.. Coastal and Lompoc's improper contractual relationship, together with Coastal's actions in redirecting Mission Hope Cancer Center patients to Lompoc's cancer center, constitute activities in Santa Barbara County that are directly competitive with Dignity Health, despite the clear prohibition found in Section.A(b)(iii) of the Ground Lease. Exh. "A" at p... Second, St Century has proposed transferring Wu, a highly qualified and skilled radiation oncologist, from Mission Hope Cancer Center to Lompoc, and replacing him with a less experienced physician, in order to train that new physician before moving her to Lompoc.

11 -0-rdd Doc 0- Filed 0/0/ Entered 0/0/ :: Exhibit A Pg of 0. Third, in conjunction with Coastal, St Century installed a CT scanner at the San Luis Obispo facility that competes with services currently provided by Dignity Health's San Luis Obispo location. This redirects as many as 0 scans per month from Dignity Health.. Additionally, Defendants Coastal, S~ Century, Ketting, and Wu have been, among other things: (a) using Dignity Health's proprietary information to broker and enter a deal with ~~ o a W N H ~ w ' ~~< w ~ ~ Q; i' W J U W J z W~ ~_ --NJ IS WSW ~W m m I 0 Lompoc Valley Medical Center; (b) having ownership interests in the competing Lompoc center; and (c) redirecting patients to Lompoc, without having legitimate medical reasons, simply because they are paid more for their services at Lompoc.. Pursuant to Section.B of the Ground Lease, if a violation of Section occurs and is not cured within 0 days after written notice, Dignity Health is entitled to seek injunctive relief against MHCC and any subtenant to restrain the violation of Section. Exh. "A" at p... Thus, Dignity Health is informed and believes, and on that basis alleges, that Central Coast gave S` Century notice via a letter dated July, 0 that it was, among other things, in breach of the Sublease.. Dignity Health is informed and believes, and on that basis alleges, that St Century failed to cure its breaches within 0 days of the written notice, despite an in-person meeting with counsel on July 0, 0, among other discussions.. Dignity Health gave MHCC written notice via letter dated January, 0 that MHCC was, among other things, in breach of the Ground Lease, and demanded that MHCC cure within 0 days of its letter.. Dignity Health is informed and believes, and on that basis alleges, that MHCC failed to cure its breaches within 0 days of the written notice, despite correspondence between counsel. // // // //

12 -0-rdd Doc 0- Filed 0/0/ Entered 0/0/ :: Exhibit A Pg of 0 0 ~~ W N H ~ w ~ N Q ~ ~ K Q ; O w J ~ U w~m J z W J ~ _ C/] _ ~ ~ J W~~ o w ~m 0 FIRST CAUSE OF ACTION (Common Law Unfair Competition Against Defendants Coastal, Century, Ketting, Wu and Does -). Dignity Health realleges and incorporates by reference each allegation contained in paragraphs through above as though set forth fully herein.. Defendants Coastal, S` Century, Ketting, and Wu have engaged in willful unfair competition under common law by, among other things: (a) using Dignity Health's proprietary information to broker and enter a deal with Lompoc Valley Medical Center; (b) having ownership interests in the competing Lompoc center; and (c) redirecting patients to Lompoc, without having legitimate medical reasons, simply because they are paid more for their services at Lompoc.. Defendants' unfairly competitive actions are costing the Mission Hope Cancer Center millions of dollars in lost revenue, which directly impacts Dignity Health's ability to upgrade and provide the community with aworld-class cancer center. 0. As a direct, proximate and foreseeable result of Defendants Coastal, St Century, Ketting, and Wu's willful conduct, Dignity has suffered and will continue to suffer substantial damages in an amount to be proven at trial.. Defendants' foregoing actions were done willfully and in bad faith with the intent to cause Dignity injury, and constitute despicable, malicious, and oppressive conduct that subjected Dignity to cruel and unjust hardship, in conscious disregard of Dignity Health's rights, so as to justify an award of exemplary and punitive damages in an amount to be proven at trial.. Defendants Coastal, St Century, Ketting, and Wu have been unjustly enriched as a result of their conspiracy and conduct alleged herein, and therefore Dignity Health is entitled to an order requiring restitution of all amounts received by Defendants as a result of their acts of unfair competition. // //

13 -0-rdd Doc 0- Filed 0/0/ Entered 0/0/ :: Exhibit A Pg of 0 0 n W N H ~ w= w`~a w ~ ~ Q ~ o ~' W J a ~~ w m J z W J = V] _ ~ N J w ~ ~ ~m O W 0 SECOND CAUSE OF ACTION (Violation of California Business &Professions Code, 00 et seq. Against Defendants Coastal, Century, Ketting, Wu and Doesl-). Dignity Health realleges and incorporates by reference each allegation contained in paragraphs through above as though set forth fully herein.. California Business Professions Code, section 00 prohibits "any unlawful, unfair or fraudulent business act or practice." For the reasons described in this Complaint, Coastal, St Century, Ketting, and Wu have engaged in unlawful and/or unfair business acts or practices in violation of California Business and Professions Code section 00.. These actions include, but are not limited to: (a) using Dignity Health's proprietary information to broker and enter a deal with Lompoc Valley Medical Center; (b) having ownership interests in the competing Lompoc center; and (c) redirecting patients to Lompoc, without having legitimate medical reasons, simply because the physicians are paid more for their services at Lompoc.. Dignity Health is informed and believes and on that basis alleges that Ketting and Wu have also violated California law prohibiting physicians from referring a patient to a facility which provides, inter alia, radiation oncology or diagnostic imaging if that physician has a financial interest in the facility that receives the referral.. Dignity Health is also informed and believes, and on that basis alleges, that Ketting and Wu have failed to disclose their financial interests in Lompoc in writing to patients they have referred to Lompoc, and have also failed to advise those patients that they are free to go elsewhere for the services, in violation of Business &Professions Code section... Defendants' unfair competitive actions are costing the Mission Hope Cancer Center millions of dollars in lost revenue, which directly impacts Dignity Health's ability to upgrade and provide the community with aworld-class cancer center.

14 -0-rdd Doc 0- Filed 0/0/ Entered 0/0/ :: Exhibit A Pg of 0 0 r r W N F- ~ w ' N Q GTi ~ ~ d;~ ~! W J U W J z W~ ~_ ~ ~' = J W ~ ~ ~W ~m 0. As a direct, proximate and foreseeable result of Defendants Coastal, S` Century, Ketting, and Wu's willful conduct, Dignity has suffered and will continue to suffer substantial damages in an amount to be proven at trial. 0. Defendants' foregoing actions were done willfully and in bad faith with the intent to cause Dignity injury, and constitute despicable, malicious, and oppressive conduct that subjected Dignity to cruel and unjust hardship, in conscious disregard of Dignity Health's rights, so as to justify an award of exemplary and punitive damages in an amount to be proven at trial.. Defendants Coastal, St Century, Ketting, and Wu have been unjustly enriched as a result of their conspiracy and conduct alleged herein, and therefore Dignity Health is entitled to an order requiring restitution of all amounts received by Defendants as a result of their acts of unfair competition, and Dignity Health is further entitled to recover its cost of suit, including its attorneys' fees. THIRD CAUSE OF ACTION (Intentional Interference with Existing Contractual Relations Against Defendants Coastal, St Century, Ketting, Wu and Does -). Dignity Health realleges and incorporates by reference each allegation contained in ~ paragraphs through above as though set forth fully herein.. Commencing in or about 0 and continuing to the present time, Defendants Coastal, S` Century, Ketting, and Wu willfully, knowingly, oppressively and maliciously conspired and agreed among themselves to refer patients to Lompoc instead of to the Mission Hope Cancer Center. Such conduct is specifically prohibited under, among other statutes, California Business & Professions Code sections 0 and 00.. Pursuant to such conspiracy and agreement, Defendants Coastal, St Century, Ketting, and Wu: (a) used Dignity Health's proprietary information to broker and enter a deal with Lompoc Valley Medical Center; (b) obtained ownership and/or proprietary interests in Lompoc; and

15 -0-rdd Doc 0- Filed 0/0/ Entered 0/0/ :: Exhibit A Pg of (c) redirected patients to Lompoc, without having legitimate medical reasons, in order 0~~ 0 ~~ w~ w ~a ' w~~ d;~ ~! W J ~ U wmj z ~_ w~ =_> ~ J W W "' m m to make more money for themselves.. At all relevant times herein, Defendants Coastal, S` Century, Ketting, and Wu were aware of the existence of the Ground Lease, the Master Lease, and the Sublease, and the ~ "Disqualified Person" restriction applying to each contract and each party to those contracts.. At all relevant times herein, Defendants Coastal, St Century, Ketting, and Wu knew or should have known that competing with Dignity in Santa Barbara and San Luis Obispo Counties in violation of the "Disqualified Person" restriction would, and in fact did: (a) cause those patients who were referred away from Mission Hope Cancer Center to receive substandard treatment in the Lompoc facility (because Lompoc does not have Dignity Health's support services, Central Coast's team of medical oncologists, or the equipment and technology available at Mission Hope Cancer Center, as explained above); and (b) cause Dignity to lose significant income.. Defendants Coastal, St Century, Ketting, and Wu's actions, as alleged herein, ~ proximately caused: (a) those patients who were referred away from Mission Hope Cancer Center to receive substandard treatment in the Lompoc facility (because Lompoc does not have Dignity Health's support services, Central Coast's team of medical oncologists, or the equipment and technology available at Mission Hope Cancer Center, as explained above); and 0 (b) Dignity to lose significant income.. As a direct, proximate and foreseeable result of Defendants Coastal, S` Century, ~ Ketting, and Wu's actions, Dignity has suffered and will continue to suffer substantial damages in an amount to be proven at trial.. As alleged herein, the aforementioned acts of Defendants Coastal, St Century, Ketting, and Wu were done willfully and in bad faith with the intent to cause Dignity injury, and constitute despicable, malicious, and oppressive conduct that subjected Dignity to cruel and unjust hardship, in conscious disregard of Dignity Health's rights, so as to justify an award of exemplary and punitive damages in an amount to be proven at trial.

16 -0-rdd Doc 0- Filed 0/0/ Entered 0/0/ :: Exhibit A Pg of 0~~ 0 W N H ~ ~~ w ' w~~ Z Q;~ ~! W J a=~ w~ m N z W J ~ _ ~_} ~ N J W ~ ~ ~W ~m 0 FOURTH CAUSE OF ACTION (Intentional Interference with Prospective Business Relations Against Defendants Coastal, St Century, Ketting, Wu and Does -) 0. Dignity Health realleges and incorporates by reference each allegation contained in ~ ~ paragraphs through above as though set forth fully herein.. Commencing in or about 0, and continuing to the present, Defendants Coastal, Sc Century, Ketting, and Wu willfully, knowingly, oppressively and maliciously conspired and agreed among themselves to refer cancer patients to Lompoc for the purpose of diverting business away from the Mission Hope Cancer Center and to a substandard facility in which they have financial interests (Lompoc), rather than to the most qualified specialty physicians and highest quality facility in the area. Such conduct is specifically prohibited under, among other statutes, Business &Professions Code sections 0 and 00.. At all relevant times herein, Defendants Coastal, St Century, Ketting, and Wu were aware of the fact that Mission Hope Cancer Center doctors were well-respected, Board Certified oncologists and radiologists, and that Mission Hope Cancer Center, and those doctors practicing on the Premises, maintained an existing patient base due to their affiliation with Dignity Health.. At all relevant times herein, Defendants Coastal, St Century, Ketting, and Wu were aware of the fact that if Mission Hope Cancer Center lost patients its ability to maintain a worldclass treatment facility would be jeopardized.. Notwithstanding such knowledge, Defendants Coastal, S~ Century, Ketting, and Wu conspired and agreed among themselves to intentionally interfere, and in fact did interfere, with relationships, existing and potential, between Dignity and its patients, and between Dignity and those physicians affiliated with Dignity by, among other things: (a) using Dignity Health's proprietary information to broker and enter a deal with Lompoc Valley Medical Center; (b) having ownership interests in the competing Lompoc center; and (c) redirecting patients to Lompoc, without having legitimate medical reasons, simply because they are paid more for their services at Lompoc.

17 -0-rdd Doc 0- Filed 0/0/ Entered 0/0/ :: Exhibit A Pg of 0 0 n W N H m w= w ~Q w~ Z ~ QQ a W J a ~~ w~m J z W J K = C/] _ ~ N J W ~ ~m o W ~i 0. As a proximate cause of Defendants Coastal, St Century, Ketting, and Wu's actions, Dignity Health is losing significant revenue, which has damaged, and continues to damage, its ability to maintain aworld-class cancer center:. As alleged herein, the aforementioned acts were done willfully and in bad faith with the intent to cause Dignity injury, and constitute despicable, malicious, and oppressive conduct that subjected Dignity to cruel and unjust hardship, in conscious disregard of Dignity Health's rights, so as to justify an award of exemplary and punitive damages in an amount to be proven at trial. FIFTH CAUSE OF ACTION (Injunctive Relief Against Defendants Coastal, St Century, Ketting, Wu, and Does -). Dignity Health realleges and incorporates by reference each allegation contained in paragraphs through above as though set forth fully herein.. Defendants Coastal, S` Century, Ketting, and Wu conspired and agreed among themselves to intentionally interfere, and in fact continue to interfere, with relationships, existing and potential, between Dignity and its patients, and between Dignity and its physician referral base by, among other things: (a) using Dignity Health's proprietary information to broker and enter a deal with Lompoc Valley Medical Center; Coastal; and (b) having ownership interests in the Lompoc center, either individually or through (c) redirecting patients to Lompoc, without having legitimate medical reasons, simply because they are paid more for their services at Lompoc.. Unless restrained, Defendants Coastal, S` Century, Ketting, and Wu will continue to refer patients to the Lompoc and San Luis Obispo facilities in violation of the "Disqualified Person" restriction and California law. 0. Dignity has no adequate remedy at law for these injuries, and unless Defendants are restrained from their continued wrongful conduct, the Santa Maria community will be deprived of a world-class cancer center.

18 -0-rdd Doc 0- Filed 0/0/ Entered 0/0/ :: Exhibit A Pg of 0~~ 0 W N H ~ ~~ w ' w~~ d; ~' W J J U W m J z ~_ W~ ~ ~' = ~ J W ~ W J ~m"' 0 SIXTH CAUSE OF ACTION (Declaratory Relief Against Defendant Central Coast). Dignity Health realleges and incorporates by reference each allegation contained in paragraphs through 0 above as though set forth fully herein.. Dignity Health is informed and believes, and on that basis alleges, that Dignity Health's rights pursuant to the "Disqualified Person" restriction in the Ground Lease is incorporated by express reference in the September, 0 Master Lease between MHCC and Central Coast.. Dignity Health is informed and believes, and on that basis alleges, that the "Disqualified Person" restriction applies to any subtenant of Central Coast as well, and Dignity Health is informed and believes, and on that basis alleges, that the "Disqualified Person" restriction is incorporated by reference in Central Coast's subleases with it subtenants.. Dignity Health is informed and believes, and on that basis alleges, that Defendant Sc Century's Sublease with Central Coast also incorporates the "Disqualified Person" restriction.. A genuine and material dispute exists between Dignity Health and Central Coast concerning whether St Century is in breach of the Sublease with Central Coast due to the competitive actions it has taken in Santa Barbara and San Luis Obispo Counties, in violation of the "Disqualified Person" restriction.. Defendant S` Century cannot reasonably dispute that it is in breach of the Sublease due to the competitive actions it has taken in Santa Barbara and San Luis Obispo Counties, in violation of the "Disqualified Person" restriction, including but not limited to: (a) using Dignity Health's proprietary information to broker and enter a deal with Lompoc Valley Medical Center; (b) having ownership interests in the competing Lompoc center; and (c) redirecting patients to Lompoc, without having legitimate medical reasons, simply '~ because the physicians are paid more for their services at Lompoc.. Dignity therefore seeks a declaration that Defendant S` Century is in breach of its Sublease with Central Coast. I//

19 -0-rdd Doc 0- Filed 0/0/ Entered 0/0/ :: Exhibit A Pg of 0~~ 0 ~~ W~ ~~a w ' w~~ Qa~ ~ W J a! ~ U W m~ z ~_ W~ ~ ~ J W W ~m ~w 0 I' :: _ WHEREFORE, Dignity Health prays for judgment against Defendants Coastal, S` Century, Ketting, and Wu, and each of them, as follows:. For general damages in an amount in excess of the jurisdictional limit of this Court to be proven at trial;. For exemplary and punitive damages in an amount to be proven at trial;. For costs of suit incurred herein;. For an order enjoining Defendants Coastal, Century, Wu and Ketting from violating the "Disqualified Person" restriction;. For an order enjoining Defendants Coastal, St Century, Wu and Ketting from referring patients to facilities that are substandard to Mission Hope Cancer Center and/or in which they have a financial interest;. For a declaration that St Century is in breach of its Sublease with Central Coast; and. For such other and further relief as the Court deems just and proper. DEMAND FOR JURY TRIAL Plaintiff Dignity Health hereby demands a trial by jury on all claims properly triable to a ~ ury. Dated: February, 0 EISNER JAFFE APC By: Kathleen C. Hipps Attorneys for Plaintiff Dignity Health

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