SUMMARY JUDGMENT

January 3, 2024

Eun Jung Lim
17192 Murphy Avenue #17723
Irvine, California [92623]

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF ORANGE

EUN JUNG LIM,
Plaintiff,
v.
HOAG MEMORIAL HOSPITAL
PRESBYTERIAN; and HERBERT
CONRAD, in his official and individual
capacity,
Defendants.

Case No.: 30-2022-01242187

NOTICE OF CONTINUANCE OF THE
SUMMARY JUDGMENT HEARING

Judge: Linda S. Marks
Department: C25

NOTICE TO DEFENDANTS HOAG MEMORIAL HOSPITAL PRESBYTERIAN,
HERBERT CONRAD AND TO THEIR ATTORNEY(S) OF RECORD:
NOTICE IS HEREBY GIVEN that on August 1, 2022, the above captioned matter was
called for hearing for the Plaintiff’s motion for Summary Judgment. At the hearing, Plaintiff
asked that the hearing be rescheduled so that Plaintiff may have a court reporter.
Notably:
i. On or about July 25, 2022, Plaintiff had requested for a court reporter for the
scheduled August 1, 2022 hearing;
ii. Clerk C. Townsend informed the Court that there was no court reporter at the
August 1 2022 hearing;
iii. The presiding Judge, Richard Oberholzer (hereinafter “the Judge”) was aware

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NOTICE OF CONTINUANCE OF THE SUMMARY JUDGMENT HEARING
that no court reporters was available on the day he rescheduled;
iv. Besides, Clerk C. Townsend had informed the Court that court reporters are
usually not available on Mondays;
v. In a bid to protect her right to a court reporter, the Plaintiff asked for continuance
until such a time when a court reporter would be available;
vi. The Judge should have only moved the hearing to a different date other than
Monday, to such a time when a court reporter would be available. However, the
Judge told Plaintiff outrightly that she would not get the court reporter for free.
The Judge further insinuated that Plaintiff would have to pay the Defendant’s
attorney fees, and pay the court reporter’s fees if she continued the case;
vii. The Plaintiff made a mistake and rescinded her court reporter acceptance due to
her inability to pay the high costs and judge rejecting her waiver of fees for a
court reporter;
viii. The Court then continued the summary judgment to another Monday on
August 22, 2022, where court reporters are not available. Further, the Plaintiff
would be responsible for the court reporter fees.
ix. The Plaintiff never willfully waived her right to a court reporter; and
x. The Plaintiff cannot afford the price of a court reporter.

In the August 1, 2022 hearing, Plaintiff filed a Motion for Court Reporter and Fee Wiver.
Plaintiff has also filed a Motion to Recuse the Judge, and a Complaint against the Judge.

Dated: ____________

Respectfully submitted,

______________________________
EUN JUNG LIM

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NOTICE OF CONTINUANCE OF THE SUMMARY JUDGMENT HEARING

CERTIFICATE OF SERVICE

I hereby certify that on _________, copies of the foregoing document have been sent by
United States Mail to the Defendant in the following address:
CARROLL, KELLY, TROTTER & FRANZEN
MICHAEL J. TROTTER (SBN 139034)
JO LYNN VALOFF (SBN 177081)
111 West Ocean Boulevard, 14th Floor
Post Office Box 22636
Long Beach, California 90801-5636
Telephone No. (562) 432-5855 / Facsimile No. (562) 432-8785
mjtrotter@cktflaw.com / jlvaloff@cktflaw.com
Attorneys for Defendant, Hoag Memorial Hospital Presbyterian

DATED: _____________

Respectfully submitted,

_________________________
EUN JUNG LIM

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