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Case 8:23--cv-00504 Document 1 Filed 03/20/23 Page 17 of 45 Page lD #:17 1 ("HCH") program under section 330(h) of the Public Health Service Act. SOS currently 2 provides health services to children, adults, and seniors as well as comprehensive care at 3 its four medical facilities in Costa Mesa, Santa Ana, Mission Viejo, and Newport Beach. 4 56. The full names and capacities, whether individual, corporate, associate or 5 otherwise, of the defendants herein named as DOES 1 through 10, inclusive, are 6 presently unknown to SOS, who, therefore, sues such defendants by such fictitious 7 names. SOS will amend this Complaint to show their true names and capacities when 8 the same have been ascertained. SOS alleges on information and belief that all of the 9 defendants fictitiously named as DOES 1 through 10 are jointly and severally liable and 10 at fault in some manner for the acts and omissions herein alleged and complained of, and 11 caused the injury and damage to MW as alleged herein. 12 57. SOS alleges on information and belief that in performing the acts and 13 omissions alleged herein, each of the Defendants was the agent and employee of each of 14 the other Defendants and was at all times acting within the course and scope of such 15 agency and employment. 16 IV. GENERAL ALLEGATIONS 17 A. SOS And Turner Exist To Provide Healthcare To Communities That 18 Lack Adequate Health Resources. 19 58. FQHCs, such as SOS, are regulated by the Health Resources and Services 20 Administration ("HRSA) of the United States Government. FQHCs receive an annual 21 grant from HRSA for each approved site at which services are provided. In addition, 22 FQHCs receive a higher reimbursement rate for seeing Medicaid (MediCal) patients 23 than do hospitals, non-FQHCs, or practitioners. 24 59. In exchange for. the HRSA grant and higher reimbursement rate, FQHCs 17 Complaint of Share Our Selves