Ghaemmaghami v. Dignity Health

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WO
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF ARIZONA
Vafa Ghaemmaghami,
Plaintiff,
v.
Dignity Health,
Defendant.
No. CV-24-00052-PHX-KML
ORDER
Pursuant to this court’s order (Doc. 100), plaintiff Vafa Ghaemmaghami and
defendant Dignity Health (“Dignity”) submitted a joint statement outlining each party’s
proposed definitions and topics for Ghaemmaghami’s upcoming 30(b)(6) deposition of
Dignity. (Doc. 101.) The 30(b)(6) deposition shall be conducted using the following
definitions and topics.
I. Definitions
“Dignity Health, Inc.”
Ghaemmaghami’s Proposal: “Dignity Health,” “Dignity,” “You,” and/or “Your” means
Defendant Dignity Health; its present or former officers; directors; agents (whether actual,
apparent or otherwise); subsidiaries, divisions, sister corporations, affiliates, holding
companies, any of which are designated on a contract as the employer of a Physician
working in Arizona and where Dignity leave policies apply to physicians, Dignity
processes physicians’ payroll, and Dignity governs or operates the facilities in which the
physicians work; or persons acting on its behalf.
Case 2:24-cv-00052-KML Document 102 Filed 03/10/26 Page 1 of 3

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“Paid Time Away”
Ghaemmaghami’s Proposal: “Paid Time Away” and/or “PTA” refers to physician time
away, paid time off for physicians, or any other paid leave for physicians.
“Physician Compensation Manual”
Ghaemmaghami’s Proposal: “Physician Compensation Manual” means, for the time
period beginning in 2021 to evaluate compensation related to paid sick time and for the
time period beginning in 2023 to evaluate compensation related to PTA, the Dignity Health
Compensation Manual as referenced in Dignity’s contracts with Physicians or any other
Compensation Manuals that Dignity uses for its Physicians, including the compensation
manuals for Physicians who work for Barrow Neurological Institute and Dignity Health at
St. Joseph’s.
II. Deposition Topics
Topic 1
Ghaemmaghami’s Proposal: Your Physician paid leave, paid time off, or PTA benefits,
including, but not limited to, any Physician Benefits Summary that discusses any form of
paid leave, paid time off, or PTA, any paid leave, paid time off, or PTA benefits offered,
Dignity locations where those paid leave benefits are offered, the categories of Physicians
who receive paid leave, paid time off, or PTA benefits, and how Dignity disseminates
updates to those paid leave, paid time off, or PTA benefits to Physicians from 2020 to
present.
Topic 2
Ghaemmaghami’s Proposal: Dignity’s physician employment agreements and contracts,
including, but not limited to, the positions and employer of the employer signatories from
2021 to present; the terms related to benefits, expected hours, policies, and compensation;
who drafted the template contract forms or amendments used by Dignity since 2021; and
any differences between employment agreements at the Dignity locations.
Case 2:24-cv-00052-KML Document 102 Filed 03/10/26 Page 2 of 3

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Topic 7
Ghaemmaghami’s Proposal: Since 2021, the scope and application of the Physician
Compensation Manual and how Dignity disseminates any updates of the Physician
Compensation Manual to Physicians.
Topic 11
Dignity’s Proposal: Since 2021, Dignity’s organizational entity structure.
Topic 13
Ghaemmaghami’s Proposal: Dignity’s explanations or statements to Physicians
regarding, or Dignity’s position on, the availability and any explanation of paid sick time
or PTA from 2021 to present.
Topic 15
Dignity’s Proposal: Dignity’s compensation structure and reconciliation process for its
Arizona-employed physicians as it relates to paid leave from 2021 to present.
Topic 17
Ghaemmaghami’s Proposal: The reason for retaining Dr. Christine Oh at Dignity Health
Medical Group on guaranteed compensation and delaying a transition to a productivity
model as well as Dignity’s shadow sheets or reconciliation documents for Dr. Oh.
Topic 18
Dignity’s Proposal: None.
Accordingly,
IT IS ORDERED the parties shall use the above definitions and topics in the
30(b)(6) deposition.
Dated this 10th day of March, 2026.
Case 2:24-cv-00052-KML Document 102 Filed 03/10/26 Page 3 of 3