KAISER FOUNDATION HEALTH PLAN, INC. v. SUPERIOR COURT OF LOS ANGELES COUNTY KAISER FOUNDATION HEALTH PLAN, INC. , et al. , Petitioners, v. THE SUPERIOR COURT OF LOS ANGELES COUNTY, Respondent. INTRODUCTION Anna Rahm and her parents, Lynnette and James Rahm, filed a complaint against Kaiser Foundation Health Plan and two Kaiser health care providers. Plaintiffs' Complaint On July 15, 2010, Anna and her parents filed a complaint against Kaiser Foundation Health Plan (Kaiser Health Plan or Health Plan), which administered Anna's health care plan. The complaint also named Kaiser Foundation Hospitals (Kaiser Hospitals) and Southern California Permanente Medical Group (SCPMG), which contract with Kaiser Health Plan to provide hospital and medical services to the Plan's insureds. First, the complaint sought punitive damages from Kaiser Foundation Health Plan, which is a "licensed health care service plan" under California's Knox-Keene Health Care Service Plan Act of 1975 (Health & Saf.

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