Order: Sorrentino-Poggi Rita Vs Centrastate Healthca Re

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                                MON-L-000535-23
           MON-L-000535-23
                       07/14/2023
                             08/01/2023
                                  3:45:42Pg
                                          PM1 ofPg4 1 Trans
                                                      of 4 Trans
                                                            ID: LCV20232227375
                                                                  ID: LCV20232088285




Jonathan Shub, Esq.
NJ Bar ID No. 317842020
Benjamin F. Johns, Esq.
NJ Bar ID No. 038182005
Samantha E. Holbrook, Esq.
NJ Bar ID No. 034162011
SHUB & JOHNS LLC
200 Barr Harbor Drive, Suite 400
Conshohocken, PA 19428
T: (610) 477-8635
jshub@shublawyers.com
bjohns@shublawyers.com
sholbrook@shublawyers.com

RITA SORRENTINO-POGGI, individually                   SUPERIOR COURT OF NEW JERSEY
and on behalf of all others similarly situated,       LAW DIVISION
                                                      MONMOUTH COUNTY
                    Plaintiff,
                                                      Case No. MON-L-000535-23
v.

CENTRASTATE HEALTHCARE SYSTEM,

                    Defendant.


         STIPULATION AND [PROPOSED] CONSENT ORDER ON ACCEPTANCE OF
     SERVICE AND STAY PENDING APPOINTMENT OF INTERIM CLASS COUNSEL

        WHEREAS, on February 17, 2023, Plaintiff Natalie Tornese, individually and on behalf

of all others similarly situated, filed a putative class action in this Court against Defendant

CentraState Healthcare System (Case No. MON-L-000504-23);

         WHEREAS, on February 20, 2023, Plaintiff Rita Sorrentino-Poggi, individually and on

behalf of all others similarly situated, filed a putative class action in this Court against Defendant

CentraState Healthcare System (“Defendant” or “CentraState”);

        WHEREAS, on February 22, 2023, the Parties filed a consent order in the related Tornese

Action indicating that Defendant agreed to accept service of the complaints filed by Natalie

Tornese and Rita-Sorrentino-Poggi as of February 22, 2023 (without waiving any defenses), and



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                                                          ID: LCV20232227375
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the Parties agreed that Defendant need not respond until after the filing of a Consolidated

Amended Complaint;

       WHEREAS, the Parties hereby incorporate by reference the provisions set forth in the

[Proposed] Consent Order on Motion to Consolidate Cases and Appoint Interim Class Counsel

filed in Tornese filed on February 22, 2023 [MON-L-000504-23, Trans ID: LCV2023671522];

       WHEREAS, after the filing of other actions against CentraState and other motions for the

appointment of interim class counsel, the Court held a hearing on May 12, 2023 regarding

consolidation and the appointment of interim class counsel;

       WHEREAS, during the May 12, 2023 hearing before the Honorable Mara Zazzali-Hogan,

J.S.C., the Court reserved decision and indicated that Defendant’s obligation to respond to the

Complaint(s) is stayed until a leadership Order is entered and a consolidated complaint is filed.

       NOW THEREFORE, the Parties through their undersigned respective counsel hereby

stipulate and agree that:

       1. As previously stipulated, Defendant agrees to accept service of the complaint as of

           February 22, 2023 (without waiving any defenses);

       2. As ordered by the Court during the May 12, 2023 hearing, the case is stayed and

           Defendant need not respond to the complaint in this matter until a Consolidated

           Amended Complaint is filed or the Court provides further direction.

                                             Agreed to by:
Dated: July 14, 2023                         SHUB & JOHNS LLC
                                             Attorneys for Plaintiff Rita Sorrentino-Poggi

                                             By: /s/ Samantha E. Holbrook




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     MON-L-000535-23
         MON-L-000535-23
                     07/14/2023
                           08/01/2023
                                3:45:42Pg
                                        PM3 ofPg4 3 Trans
                                                    of 4 Trans
                                                          ID: LCV20232227375
                                                                ID: LCV20232088285




Dated: July 14, 2023                    BAKER & HOSTETLER LLP
                                        Attorneys for Defendant CentraState Healthcare
                                        System

                                        By: /s/ Eric R. Fish
                                                Eric R. Fish

IT IS SO ORDERED.



          August 1
Dated: ______________, 2023             _________________________________________
                                        HONORABLE MARA ZAZZALI-HOGAN, J.S.C.




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     MON-L-000535-23
         MON-L-000535-23
                     07/14/2023
                           08/01/2023
                                3:45:42Pg
                                        PM4 ofPg4 4 Trans
                                                    of 4 Trans
                                                          ID: LCV20232227375
                                                                ID: LCV20232088285




                                   ATTESTATION OF FILER
       The undersigned hereby certifies that all above signatories consent to this filing and have

authorized their electronic signatures.

                                                     /s/ Jonathan Shub




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