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2. Almost one and a half years ago, Defendants claimed they were interested in
buying Plaintiff's practice. In good faith, Plaintiff opened its books and records to Defendants,
and entered into negotiations with them.
3. In reality, Defendants did not intend to buy Plaintiff's practice at a fair market
value. Instead, they set out to destroy a family-focused medical practice that treated the
underserved, primarily Latino community, with complete disregard for patient needs.
4. On information and belief, Defendants encouraged Plaintiff's employed physicians
to leave Plaintiff and join Defendants' laborist physician panel, as well as directed Defendants'
contracted physicians to terminate their coverage of Plaintiff's patients and instead, provide
coverage only to Defendants. All of these actions were to the detriment of Plaintiff's practice and
patients.
5. As a result, Plaintiff was deprived of adequate staff to care for its patients, which
caused two major health centers to terminate their referral relationship with Plaintiff. Plaintiff was
forced to close shortly after that, and Plaintiff's patients had to then use Defendants' facilities and
staff, both of which were new and unfamiliar to them during a vulnerable time of their lives.
6. Accordingly, Plaintiff seeks at least $5,000,000 in compensatory damages, as well
as treble damages, punitive damages, injunctive relief, attorney's fees, litigation costs, and any and
all other relief ordered by the Court.
THE PARTIES
7. Plaintiff Citrus Obstetrics & Gynecology Medical Associates, Inc. ("Plaintiff') is a
California corporation whose principal place of business is in this County.
8. Defendant Citrus Valley Health Partners, Inc. ("CV Health Partners") is a
California corporation whose principal place of business is in this County.
9. Defendant Citrus Valley Medical Center, Inc. ("CV Medical Center") is a
California corporation whose principal place of business is in this County.
10. Defendant Citrus Valley Physician Partners, Inc. ("CV Physician Partners") is a
California corporation whose principal place of business is in this County.
- 2 -Complaint
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11. Plaintiff has no knowledge of the true names and capacities of the defendants sued
herein as Does 1-25, inclusive (the "Doe Defendants"), and therefore, pursuant C.C.P. § 474, sues
these Doe Defendants by such fictitious names. Plaintiff shall seek leave to amend this Complaint
to allege the true names and capacities of said Doe Defendants if and when their identities and
roles are ascertained. Each of said fictitiously named Doe Defendants are legally responsible in
some manner for the occurrences and damages alleged herein, and Plaintiff's damages as herein
alleged were proximately caused by the acts of these Doe Defendants.
12. At all times herein mentioned, all Defendants were the agents, servants, employees,
instrumentalities, representatives, co-venturers, partners, and/or alter egos of the other Defendants.
In doing the things hereafter alleged, such Defendants were acting in the scope of their authority
as agents, servants, employees, instrumentalities, representatives, co-venturers, partners, and/or
alter egos, and with the permission and consent of all other Defendants, and as such share liability
with each other in respect to the matters complained of herein.
JURISDICTION AND VENUE
13. The Court has personal jurisdiction over all Defendants because they are all citizens
of California.
14. Pursuant to C.C.P. § 395.5, venue is proper as to all Defendants because their
principal places of business are in this County and judicial district, and their liability to Plaintiff
arises in this County and judicial district.
COMMON ALLEGATIONS
15. Plaintiff is a medical practice that provided birth delivery and other medical
services in obstetrics and gynecology ("OB/GYN") for sixteen years.
16. Defendants CV Health Partners and CV Medical Center operate, among other
things, Queen of the Valley Hospital, also referred to as Citrus Valley Medical Center - Queen of
the Valley Campus (the "Hospital").
17. Defendant CV Physician Partners is a "captive" medical group of physicians
consisting of the Hospital's acquired medical practices. Defendant CV Physician Partners
- 3 -Complaint
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provides referred patients and related services to CV Health Partners, CV Medical Center, and the
Hospital.
18. Plaintiff employed or had independent contractor agreements with the following
physicians: Dr. Jason Begley; Dr. Arthur Escamillo; Dr. Ann Terai (a.k.a. Ann Terai Escamillo);
and Dr. Zaid Chaudry. Due to its number of patients, Plaintiff also depended on Defendants to
allow five of Defendants' contracted laborist physicians to provide OB/GYN services and
coverage for Plaintiff's patients, which Defendants had agreed to provide and did provide.
19. Plaintiff had contracts to provide OB/GYN services to two major health centers:
AltaMed Health Services ("AltaMed") and Central City Community I-Tealth Center, Inc. ("Central
City"). Plaintiff's annual revenues from its contracts with AltaMed and Central City averaged at
least $1,400,000.
20. Plaintiff paid Defendants' affiliated physicians at agreed-to sums each time they
provided services to Plaintiff and its patients. Defendants benefitted because their affiliated
physicians would get extra work and more pay than they would have otherwise received for
performing services only for Defendants.
21. Beginning in December 2016, as a part of Defendants' physician practice
acquisition strategy and development of hospital based clinics, Defendants expressed interest in
purchasing Plaintiff's practice and merging it with their in-house OB/GYN laborist group.
22. To facilitate that process, Plaintiff and Defendants entered into a Confidentiality
Agreement on or about January 5, 2017. After entering that agreement, Plaintiff disclosed to
Defendants its financial performance and business model as part of good faith negotiations.
23. In May 2017, Defendants obtained a purported fair market valuation of Plaintiff's
practice at $595,000 to $727,000. Plaintiff informed Defendants that the valuation was too low,
and Defendants stated that they were amenable to a higher range of prices.
24. In about late July 2017, Defendants obtained from its own consultants another fair
market valuation of Plaintiff's practice, this time at $950,000 to $968,000, and informed Plaintiff
of such valuation. That amount was about one-fifth of the true market value of Plaintiff's practice.
Nevertheless, given this increased valuation by Defendants, Plaintiff continued negotiating with
- 4 -Compl aint
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Defendants for a higher price as well as other consideration, including Defendants' employment of
Plaintiffs principal Carlos Beharie, M.D. for at least six months at similar compensation as
Defendants chief medical officer.
25. However, Defendants did not actually intend to buy Plaintiff s practice for
approximately $968,000 and other, related consideration. Rather, Defendants were stringing
Plaintiff along with sham discussions.
26. In reality, Defendants decided to and did formulate a plan to obtain those benefits
for nothing — Plaintiffs patients, its contracts with AltaMed and Central City, and Plaintiffs other
HMO and independent practice association revenue streams, such as Blue Cross, Blue Shield,
Aetna, United Health, Champus, MediCal, and Medicare. As such, Defendants would save
themselves millions and avoid the obligation to employ Dr. Beharie for at least six months.
27. Accordingly, Defendants embarked on an unlawful scheme to drive Plaintiff out of
business, bring Plaintiffs business in-house, and take over and divert Plaintiffs contracts,
patients, and revenues for themselves.
28. It was far from a coincidence that in approximately August 2017, shortly after
Defendants decided not to acquire Plaintiffs practice through legitimate means and at a valuation
acceptable to Plaintiff, two physicians affiliated with Defendants who previously covered for
Plaintiff— Dr. Bill Tang and Dr. Daniel Barajas — informed Plaintiff that they would no longer
provide patient coverage to Plaintiff. On information and belief, Dr. Tang and Dr. Daniel Barajas
did so on the instruction of Defendants' managing agents, particularly Dr. Anna Leung, the head
of Defendants' laborist program. (The "laborist" program provides for one or more OB/GYN
physicians to be on-site 24 hours a day, 7 days a week, so that if an expectant mother came to the
Hospital in labor and would give birth within minutes, a physician could support her even if the
mother's regular OB/GYN physician was off-site).
29. On information and belief, Dr. Leung and other managing agents of Defendants
directed Dr. Tang and Dr. Daniel Barajas to stop taking shifts to cover Plaintiff and its patients,
and Dr. Tang and Dr. Daniel Barajas complied with such orders to preserve their relationships and
working arrangements with Defendants. Dr. Tang and Dr. Daniel Barajas now
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provide the same coverage to the OB/GYN practice owned by Defendants, which coverage was
denied to Plaintiff.
30. Beginning in August 2017 and continuing through November 2017, Plaintiff
repeatedly sought help from Defendants to provide laborist physicians to cover Plaintiff's patients,
but Defendants failed to provide such support. On the contrary, Defendants instructed its affiliated
laborist physicians to withhold support from Plaintiff, and did so with the intention of hurting
Plaintiff's ability to practice and driving Plaintiff out of business so that they could take over
Plaintiff's patients and the revenue streams from them.
31. In particular, Plaintiff was the only physician group in the geographic area who
could provide the services required by AltaMed and Central City, including treating high risk
obstetric patients who were likely to deliver premature babies who would then be cared for at
Defendants' neonatal intensive care unit. Thus, Defendants were aware that if they drove Plaintiff
out of business by taking its physicians and contracts, a significant proportion of the patients who
would have been treated by Plaintiff would come instead to Defendants, thereby increasing
Defendants' income base.
32. On information and belief, during approximately October 2017, Defendants
induced Plaintiff's physicians Dr. Jason Begley, Dr. Arthur Escamillo, and Dr. Ann Terai to
breach their employment and contractor agreements with Plaintiff so that they can be employed by
or enter into services contracts with Defendants. Defendants also later hired Plaintiff's physician
Dr. Zaid Chaudry, who started working with Defendants after the failure of Plaintiff's practice.
33. On or about November 30, 2017, due to Defendant's unlawful interference, Dr.
Begley, Dr. Escamillo, and Dr. Terai tendered their resignations to Plaintiff effective January 1,
2018; i.e. , with barely over 30 days' notice. They did this despite the fact that (a) Dr. Begley's
contract automatically renewed for two years as of November 1, 2017, and allowed him to
terminate only 90 days before the end of the current term (or no earlier than August 2019); (b) Dr.
Escamillo's contract required 120 days' notice; and (c) Dr. Terai's contract required 90 days'
notification. Defendants also induced Dr. Begley and Dr. Escamillo (and later Dr. Chaudry) to
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abandon Plaintiff by agreeing to pay for their "tail" malpractice insurance coverage, worth almost
$150,000 in premiums.
34. If only one of Dr. Begley, Dr. Escamillo, and Dr. Terai had left Plaintiff, or if all
three left but over a more prolonged period, Plaintiff would have been able to continue its practice.
However, the departure of all of them on the same day crippled Plaintiff and made it virtually
impossible for Plaintiff to continue servicing its contracts and patients.
35. Defendants had now taken several of Plaintiff's employed physicians and hired
these physicians themselves, and directed their own physicians to refrain from providing coverage
to Plaintiff. Defendants' scheme ensured Plaintiff did not have the capability to treat all of its
patients.
36. During about the same period, Defendants intervened with Plaintiff's clients
AltaMed and Central City and signed contracts to provide OB/GYN services in place of Plaintiff,
including through Plaintiff's former physicians Dr. Begley, Dr. Escamillo, and Dr. Terai whom
Defendants had wrongfully induced to abandon Plaintiff.
37. During that period, Plaintiff attempted to save its contracts with AltaMed and
Central City. For instance, Plaintiff informed AltaMed that it was attempting to hire new
physicians to service AltaMed's patients, and that Plaintiff was also negotiating with Defendants
to obtain coverage from their laborist OB/GYN physicians. However, Defendants misled Plaintiff
by falsely representing that they were attempting to seek coverage of Plaintiff's patients by
Defendants' physicians, when in truth Defendants were doing the opposite — directing their
physicians to discontinue lending any services to Plaintiff.
38. AltaMed informed Plaintiff that because Dr. Begley, Dr. Escamillo, and Dr. Terai,
who had been hired by Defendants, had already received credentials from AltaMed and admission
privileges at the Hospital (when they worked for Plaintiff), whereas any new permanent or locum
tenens physicians hired by Plaintiff would require three or four months to be credentialed by
AltaMed, AltaMed would engage Defendants so that it could serve Plaintiff's patients right away.
39. Due to the sudden and simultaneous departures of Dr. Begley, Dr. Escamillo, and
Dr. Terai, Plaintiff was unable to recruit additional physicians in time. During this same
- 7 -Complaint
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approximate period, Plaintiff interviewed six physicians. Although at least two of those
physicians were amenable to the terms of employment offered by Plaintiff, including their
compensation packages, all six individuals declined to work with Plaintiff, specifically citing the
elimination of Plaintiff's physician group structure due to the simultaneous departures of Dr.
Begley, Dr, Escamillo, and Dr. Terai that was induced by Defendants.
40. Central City informed Plaintiff on or about November 15, 2017, and AltaMed
informed Plaintiff on or about December 7, 2017, that they would terminate their services
contracts with Plaintiff, and instead engage Defendants to provide OB/GYN services. AltaMed
and Central City also refused Plaintiff's offer to provide locums tenens physicians to replace Dr.
Begley, Dr. Escamillo, and Dr. Terai, since Defendants had already acquired the services of those
physicians to treat AltaMed and Central City's referred patients.
41. During the same approximate period, Plaintiff was offered the opportunity to
provide OB/GYN services to patients referred by a different health care facility, Regal Medical
Group / Greater Covina Medical Group. If Plaintiff had been able to service those patients,
Plaintiff would have realized significant additional revenues per year. However, since Defendants
destroyed Plaintiff's ability to hire new doctors, it could not take advantage of that opportunity.
42. On or about January 26, 2018, Plaintiff's practice failed due to Defendants' raiding
of its physicians, Defendants' refusal to provide Plaintiff coverage by its own physicians, the loss
of AltaMed and Central City as clients, the loss of other revenue sources, and the inability to
safely service patients with the physicians who were still affiliated with Plaintiff.
43. This is not the first time that Defendants have done something like this. In an
action entitled Hunter Donaldson, LLC v. Citrus Valley Health Partners, Los Angeles Superior
Court, Case No. BC48974 (filed Aug. 7, 2012), it was alleged that after entering a contract with
plaintiff vendor to obtain a patient claims resolution service, defendant Citrus Valley
misappropriated the vendor's proprietary system and business methods by copying and creating
one in-house.
- 8 -Complaint
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FIRST CAUSE OF ACTION
INTENTIONAL INTERFERENCE WITH CONTRACTUAL RELATIONS
44. Plaintiff incorporates by reference paragraphs 1 to 43 above as though they were
fully stated here.
45. There were separate contracts between Plaintiff and each of the following parties:
AltaMed; Central City; Dr. Jason Begley; Dr. Arthur Escamillo; and Dr. Ann Terai.
46. Defendants knew about the foregoing contracts between Plaintiff and AltaMed,
Central City, Dr. Jason Begley, Dr. Arthur Escamillo, and Dr. Ann Terai.
47. Defendants' conduct prevented performance of the foregoing contracts or made
their performance more expensive or difficult.
48. Defendants intended to disrupt the performance of the foregoing contracts, and/or
knew that disruption of performance was certain or substantially certain to occur.
49. Plaintiff was harmed by Defendants' conduct, in that, among other things, Plaintiff
lost the revenues and income that it would have realized from providing OB/GYN services to
AltaMed, Central City, and other patient sources.
50. Defendants' conduct was a substantial factor in causing Plaintiff's harm.
SECOND CAUSE OF ACTION
INDUCING BREACH OF CONTRACT
51. Plaintiff incorporates by reference paragraphs 1 to 43 above as though they were
fully stated here.
52. There were separate contracts between Plaintiff and each of the following parties:
Dr. Jason Begley; Dr. Arthur Escamillo; and Dr. Ann Terai.
53. Defendants knew about the foregoing contracts between Plaintiff and Dr. Jason
Begley, Dr. Arthur Escamillo, and Dr. Ann Terai.
54. Defendants intended to cause Dr. Jason Begley, Dr. Arthur Escamillo, and Dr. Ann
Terai to breach their respective contracts with Plaintiff.
55. Defendants' conduct caused Dr. Jason Begley, Dr. Arthur Escamillo, and Dr. Ann
Terai to breach their respective contracts with Plaintiff.
- 9 -Complaint
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56. Plaintiff was harmed by Defendants' conduct, in that, among other things, without
the medical services of Dr. Jason Begley, Dr. Arthur Escamillo, and Dr. Ann Terai, Plaintiff was
unable to service and lost the revenues and income that it would have realized from providing
OB/GYN services to AltaMed, Central City, and other patient sources.
57. Defendants' conduct was a substantial factor in causing Plaintiff's harm.
THIRD CAUSE OF ACTION
INTENTIONAL INTERFERENCE WITH PROSPECTIVE ECONOMIC RELATIONS
58. Plaintiff incorporates by reference paragraphs 1 to 43 above as though they were
fully stated here.
59. Plaintiff and the following parties were in an economic relationship that probably
would have resulted in economic benefits to Plaintiff: AltaMed; Central City; Dr. Jason Begley;
Dr. Arthur Escamillo; and Dr. Ann Terai.
60. Defendants knew of the foregoing economic relationship between Plaintiff and
AltaMed, Central City, Dr. Jason Begley, Dr. Arthur Escamillo, and Dr. Ann Terai.
61. Defendants engaged in conduct that was wrongful, including but not limited to
encouraging its affiliated physicians to discontinue providing coverage to Plaintiff; inducing Dr.
Jason Begley, Dr. Arthur Escamillo, and Dr. Ann Terai to abandon Plaintiff in violation of their
contractual obligations; and misleading Plaintiff that Defendants were trying to find physicians
who could service Plaintiff's patients, when in fact Defendants were doing the opposite.
62. By engaging in the foregoing conduct, Defendants intended to disrupt the economic
relationship between Plaintiff and the aforementioned parties, and/or knew that disruption of the
relationship was certain or substantially certain to occur.
63. The foregoing economic relationship was disrupted, and Plaintiff was harmed
thereby.
64. Defendants' conduct was a substantial factor in causing Plaintiff's harm.
- 10 -Complaint
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FOURTH CAUSE OF ACTION
UNFAIR BUSINESS PRACTICES
BUSINESS AND PROFESSIONS CODE 17200, ET SEQ.
65. Plaintiff incorporates by reference paragraphs 1 to 64 above as though they were
fully stated here.
66. Defendants' acts and omissions as alleged herein constitute unlawful and/or unfair
business practices prohibited by Business & Professions Code § 17200, et seq. Such conduct by
Defendants caused actual harm to Plaintiff, including its loss of the contracts with AltaMed and
Central City and the revenues from its medical practice.
67. Unless Defendants are restrained from such conduct, they will continue to engage
in the same,
68. Accordingly, Plaintiff seeks a permanent injunction against such conduct by
Defendants, and any and all other relief provided for under Business & Professions Code § 17200,
et seq.
FIFTH CAUSE OF ACTION
VIOLATION OF CART WRIGHT ACT
BUSINESS AND PROFESSIONS CODE 16700, ET SEQ.
69. Plaintiff incorporates by reference paragraphs 1 to 64 above as though they were
fully stated here.
70. Although Defendants CV Health Partners, CV Medical Center, and CV Physician
Partners are affiliated with one another, they are separate and distinct entities.
71. Defendants, in concert with one another as well as with other co-participants,
agreed and conspired not to deal with Plaintiff so that they can drive it out of business.
72. Specifically, Defendants and other co-participants agreed not to provide OB/GYN
physician coverage to Plaintiffs patients although they knew that Plaintiff would be unable to
service all of its patients without such coverage and support. Moreover, Defendants disguised
their actions so that by the time that Plaintiff realized what they were doing, it was too late for
Plaintiff to recruit sufficient physicians and obtain credentials and admission privileges for them.
- 11-Complaint
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73. The foregoing refusal to deal by Defendants constitutes a violation of California's
Cartwright Act, Business & Professions Code § 16700, et seq.
74. Plaintiff was harmed by Defendants' acts of refusal to deal.
75. Defendants' conduct was a substantial factor in causing Plaintiff's harm.
SIXTH CAUSE OF ACTION
AIDING AND ABETTING
76. Plaintiff incorporates by reference paragraphs 1 to 75 above as though they were
fully stated here.
77. One or more of Defendants knew that certain tortious, wrongful acts were being
committed or would be committed by other Defendants against Plaintiff; namely, intentional
interference with Plaintiff's contractual relations; inducing breach of contract; intentional
interference with Plaintiff's prospective economic relations, unfair business practices; and
violation of the Cartwright Act.
78. One or more Defendants gave substantial assistance or encouragement to the other
Defendants in engaging in such tortious, wrongful acts against Plaintiff.
79. Defendants' conduct was a substantial factor in causing Plaintiff's harm.
PRAYER FOR RELIEF
80. Whereas, based on the foregoing factual allegations and causes of action asserted
here, Plaintiff Citrus Obstetrics & Gynecology Medical Associates, Inc. prays for the following
relief against Defendants, jointly and severally.
81. Plaintiff prays for compensatory damages in an amount to be proven at trial, but no
less than $5,000,000.
82. By reason of Defendants' violation of the Cartwright Act, Plaintiff is entitled to
treble damages in an amount to be proven at trial.
83. Defendants engaged in the above alleged conduct with malice, oppression, or fraud.
Such conduct constituting malice, oppression, or fraud was committed by one or more officers,
directors, or managing agents of Defendants, who acted on behalf of Defendants; was authorized
by one or more officers, directors, or managing agents of Defendants; and/or one or more officers,
- 12 -Complaint
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directors, or managing agents of Defendants knew of the conduct constituting malice, oppression,
or fraud and adopted or approved that conduct after it occurred.
84. Additionally, Defendants acted with intent to cause injury to Plaintiff, and/or
Defendants' conduct was despicable and was done with a willful and knowing disregard of the
rights or safety of Plaintiff and Plaintiff's patients. Accordingly, Plaintiff is entitled to an award
of punitive damages in an amount to be proven at trial up to the Constitutional limits.
85. Plaintiff prays for an award of litigation costs
86. Plaintiff prays for an award of attorneys' fees to the extent allowable by law,
including but not limited to the Cartwright Act.
87. Plaintiff pleads for injunctive relief against Defendants.
88. Plaintiff further pleads for any and all other relief that the Court may deem
appropriate.
Dated: June 19, 2018 CALLAHAN & BLAINE,
By: dward SusolikRaphael Cung
Attorneys for Plaintiff CITRUS OBSTETRICS& GYNECOLOGY MEDICAL ASSOCIATES,INC.
- 13 -Complaint
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DEMAND FOR JURY TRIAL
Pursuant to the Seventh Amendment of the United States Constitution, the Constitution of
California, and any and all other applicable law, Plaintiff Citrus Obstetrics & Gynecology Medical
Associates, Inc. hereby requests a jury trial in this action for all claims so triable.
Dated: June 19, 2018 CALLAHAN & BLAINE, AP
By:Edward SusolikRaphael Cung
Attorneys for Plaintiff CITRUS OBSTETRICS& GYNECOLOGY MEDICAL ASSOCIATES,INC.
- 14 -Complaint