MOTION TO STRIKE Amended COMPLAINT
Matter on the Law & Motion and Discovery Calendar for Tuesday, August 4, 2026, Line 9, DEFENDANTS JACQUELINE BROOKS, MFT, KAISER FOUNDATION HEALTH PLAN, INC., AND THE PERMANENTE MEDICAL GROUP, INC.'S MOTION TO STRIKE FIRST AMENDED COMPLAINT.
Defendants' motion to strike the punitive damages allegations in the first amended complaint filed by plaintiff Isabel Jendrysik is granted as to all the punitive damages allegations without prejudice to seek leave to amend to allege punitive damages allegations if and when Jendrysik is able in good faith to allege sufficient facts to support punitive damages on some or all of her claims against some or all of the defendants.
Wholly apart from the applicability of inapplicability of CCP 425.13 to any of defendants or any of Jendrysik's claims, none of the claims alleged in the first amended complaint sufficiently allege either malice, fraud or oppression, the predicates for punitive damages, or authorization, ratification, or participation in the malicious, fraudulent, or oppressive conduct by an officer, director or managing agent of the entity defendants.
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