Jeffrey Mor, In And Through His Successor-In-Interest, Jeffrey S.Reisbeck, Et Al. Vs Montrose Springs Skilled Nursing & Wellness Center, Et Al.

Motion to Compel - MOTION TO COMPEL DEPOSITION OF JOSHUA KAUFFMAN

Civil Case Cover Sheet

Petition (Complaint)

Summons (on Petition)

Notice of Case Assignment - Unlimited Civil Case

Notice of Posting of Jury Fees

Declaration (Complaint)

Proof of Personal Service

Proof of Mailing (Substituted Service)

Separate Statement

Motion to Compel Further Discovery Responses

Motion to Quash (Deposition Subpoena re Terri Hansen, RN)

Offer to Compromise and Acceptance Under Code of Civil Procedure Section 998

Memorandum of Points & Authorities

Civil Case Cover Sheet

Notice of Case Assignment - Unlimited Civil Case

Summons - SUMMONS ON PETITION

Declaration - DECLARATION COMPLAINT

Notice of Case Management Conference

Notice of Posting of Jury Fees

Proof of Personal Service

Proof of Mailing (Substituted Service)

Proof of Service by Substituted Service

Proof of Service by Mail

Notice and Acknowledgment of Receipt

Answer

Case Management Statement

Notice - NOTICE NOTICE OF CMC

Ex Parte Application - EX PARTE APPLICATION EX PARTE APPLICATION FOR ORDER TO ADVANCE PLAINTIFF'S MOTION FOR TRIAL PREFERENCE

Proof of Service (not Summons and Complaint)

Opposition - OPPOSITION OPPOSITION TO PLAINTIFFS’ EX PARTE APPLICATION FOR AN ORDER TO ADVANCE THE DATE OF PLAINTIFFS’ MOTION FOR PREFERENCE

Minute Order - MINUTE ORDER (HEARING ON EX PARTE APPLICATION FOR ORDER TO ADVANCE PLAINTI...)

Notice of Ruling

Case Management Statement

Notice of Posting of Jury Fees

Reply - REPLY TO OPPOSITION TO PLAINTIFF'S MOTION FOR TRIAL PREFERNECE PURSUANT TO C.C.P. SECTION 36(A); DECLARATION OF LISA TRINH FLINT, ESQ.

Opposition - OPPOSITION TO MOTION

Request for Judicial Notice

Memorandum of Points & Authorities

Minute Order - MINUTE ORDER (CASE MANAGEMENT CONFERENCE; HEARING ON MOTION FOR TRIAL PREFE...)

Declaration - DECLARATION OF I. HOOSHIE BROOMAND IN SUPPORT OF DEFENDANTS’ MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION OF STEVEN STROLL

Declaration - DECLARATION DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF EX PARTE APPLICATION FOR ODER SHORTENING TIME TO HEAR DEFENDANTS’ MOTION FOR PROTECTIVE ORDER

Ex Parte Application - EX PARTE APPLICATION EX PARTE APPLICATION FOR ORDER SHORTENING TIME TO HEAR DEFENDANTS’ MOTION FOR PROTECTIVE ORDER

Memorandum of Points & Authorities

Memorandum of Points & Authorities

Declaration - DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANTS’ MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR

Motion to Compel - MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR

Application And Order For Appointment of Guardian Ad Litem - APPLICATION AND ORDER FOR APPOINTMENT OF GUARDIAN AD LITEM MARIE

Motion for Protective Order

Declaration - DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANTS’ MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION OF SHLOMO RECHNITZ

Memorandum of Points & Authorities

Declaration - DECLARATION OF SHLOMO RECHNITZ IN SUPPORT OF DEFENDANTS’ MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION SHLOMO RECHNITZ

Separate Statement

Declaration - DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANTS’ MOTION TO COMPEL PLAINTIFF MARIE MOR’S VERIFIED RESPONSES TO DISCOVERY

Memorandum of Points & Authorities

Motion to Compel - MOTION TO COMPEL PLAINTIFF MARIE MOR’S VERIFIED RESPONSES TO DISCOVERY

Declaration - DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES FROM PLAINTIFF MARIE MOR TO REQUEST FOR ADMISSION, SET ONE, NOS. 3 AND 4

Motion to Compel - MOTION TO COMPEL FURTHER RESPONSES FROM PLAINTIFF MARIE MOR TO REQUEST FOR ADMISSION, SET ONE, NOS. 3 AND 4

Motion to Compel - MOTION TO COMPEL PLAINTIFF MARIE MOR’S RESPONSES TO SPECIAL INTERROGATORIES, SET ONE, NOS. 101 AND 103

Declaration - DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF MOTION TO COMPEL PLAINTIFF MARIE MOR’S RESPONSES TO SPECIAL INTERROGATORIES, SET ONE, NOS. 101 AND 103

Memorandum of Points & Authorities

Ex Parte Application - EX PARTE APPLICATION EX PARTE APPLICATION FOR ORDER SHORTENING TIME TO HEAR DEFENDANTS’ MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION OF SHLOMO RECHNITZ

Ex Parte Application - EX PARTE APPLICATION EX PARTE APPLICATION FOR ORDER SHORTENING TIME TO HEAR DEFENDANTS’ MOTION TO COMPEL PLAINTIFF MARIE MOR’S RESPONSES TO SPECIAL INTERROGATORIES, SET ONE, NOS

Ex Parte Application - EX PARTE APPLICATION EX PARTE APPLICATION FOR ORDER SHORTENING TIME TO HEAR DEFENDANTS’ MOTION TO COMPEL PLAINTIFF MARIE MOR’S VERIFIED RESPONSES TO DISCOVERY

Ex Parte Application - EX PARTE APPLICATION EX PARTE APPLICATION FOR ORDER SHORTENING TIME TO HEAR DEFENDANTS’ MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR

Declaration - DECLARATION DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF EX PARTE APPLICATION FOR SHORTENING TIME TO HEAR DEFENDANTS’ MOTION TO COMPEL PLAINTIFF MARIE MOR’S VERIFIED RESPONSES TO DI

Declaration - DECLARATION DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF EX PARTE APPLICATION FOR SHORTENING TIME TO HEAR DEFENDANTS’ MOTION TO COMPEL PLAINTIFF MARIE MOR’S RESPONSES TO SPECIAL INT

Motion to Trifurcate

Declaration - DECLARATION DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF EX PARTE APPLICATION FOR SHORTENING TIME TO HEAR DEFENDANTS’ MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION OF SHLOMO

Declaration - DECLARATION DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF EX PARTE APPLICATION FOR ORDER SHORTENING TIME TO HEAR DEFENDANTS’ MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR

Declaration - DECLARATION DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF EX PARTE APPLICATION FOR SHORTENING TIME TO HEAR DEFENDANTS’ MOTION TO COMPEL FURTHER RESPONSES FROM PLAINTIFF MARIE MOR TO

Opposition - OPPOSITION PLAINTIFFS'OMBINED OPPOSITION TO DEFENDANTS'X PARTE APPLICATIONS FOR AN ORDER SHORTENING TIME FOR THK HEARING ON DEFENDANTS'OTIONS; DECLARATION OF PHILIP J. SPINAZZK IN SUPPORT

Minute Order - MINUTE ORDER (HEARING ON EX PARTE APPLICATION FOR ORDER SHORTENING TIME TO ...)

Motion in Limine - MOTION IN LIMINE NO. 7 TO RESTRICT EXPERT TESTIMONY ON UNSUPPORTED ALLEGATIONS OF UNDERSTAFFING; DECLARATION OF HEATHER-ANN T. YOUNG

Motion in Limine - MOTION IN LIMINE NO. 6 PRECLUDING PLAINTIFFS FROM ASKING WITNESSES ABOUT THEIR OPINIONS AND CONCLUSIONS OF THE LAW; DECLARATION OF HEATHER-ANN T. YOUNG

Motion in Limine - MOTION IN LIMINE NO. 4 TO PRECLUDE PLAINTIFFS’ EVIDENCE OF INJURIES TO OTHER INDIVIDUALS; DECLARATION OF HEATHER-ANN T. YOUNG

Motion in Limine - MOTION IN LIMINE NO. 5 TO EXCLUDE OR LIMIT AS EVIDENCE PLAINTIFF MARIE MOR’S CLAIM OF LOSS OF INCOME; DECLARATION OF HEATHER-ANN T. YOUNG

Motion in Limine - MOTION IN LIMINE NO. 2 TO PRECLUDE MICHELE MOR FROM TESTIFYING ON BEHALF OF MARIE MOR AS HER GUARDIAN AD LITEM AND ANSWERING HYPOTHETICAL QUESTIONS REGARDING CARE; DECLARATION OF HE

Motion in Limine - MOTION IN LIMINE NO. 10 TO PRECLUDE FROM REFERRING TO PLAINTIFFS OR DECEDENTS AS A VICTIM OR ANY OTHER INFLAMMATORY NOUN; DECLARATION OF HEATHER-ANN T. YOUNG

Motion in Limine - MOTION IN LIMINE NO. 3 TO EXCLUDE LAY WITNESS OPINION AT TRIAL; DECLARATION OF HEATHER-ANN T. YOUNG

Motion in Limine - MOTION IN LIMINE NO. 12 TO LIMIT EXPERTS TO OPINIONS EXPRESSED AT THEIR DEPOSITIONS

Motion in Limine - MOTION IN LIMINE NO. 8 TO PRECLUDE PRIOR LITIGATION DECISIONS RE DEFENDANT; DECLARATION OF HEATHER-ANN T. YOUNG

Motion in Limine - MOTION IN LIMINE NO. 9 TO PRECLUDE ARGUMENT OF ALLEGED “PROFIT OVER PATIENT CARE” AND PRECLUSION OF FINANCIAL STATEMENTS; DECLARATION OF HEATHER-ANN T. YOUNG

Motion in Limine - MOTION IN LIMINE NO. 15 REQUESTING USE OF ATTACHED JURY QUESTIONNAIRE

Motion in Limine - MOTION IN LIMINE NO. 14 TO PRECLUDE EXPERTS FROM OPINING THE DECEDENT’S CARE WAS RECKLESS OR THE LIKE; DECLARATION OF HEATHER-ANN T. YOUNG

Motion in Limine - MOTION IN LIMINE NO. 17 REQUESTING 48 HOUR ADVANCE NOTICE TO WITNESSES

Motion in Limine - MOTION IN LIMINE NO. 16 REQUESTING PRODUCTION OF DEMONSTRATIVE EVIDENCE

Ex Parte Application - EX PARTE APPLICATION EX PARTE APPLICATION FOR ORDER TO SPECIFICALLY SET HEARING DATE FOR P'S MOTION TO COMPEL DEPOSITION

Motion in Limine - MOTION IN LIMINE NO. 13 TO PRECLUDE TESTIMONY RE: MEDICAL TEXT AND PUBLICATIONS; DECLARATION OF HEATHER-ANN T. YOUNG

Motion in Limine - MOTION IN LIMINE NO. 11 LIMITING NON-RETAINED EXPERT WITNESS TESTIMONY; DECLARATION OF HEATHER-ANN T. YOUNG

Motion in Limine - MOTION IN LIMINE NO. 1 TO PRECLUDE REFERENCES TO INVESTIGATIONS OR COMPLAINTS TO CALIFORNIA DEPARTMENT OF PUBLIC HEALTH, STATE OF CALIFORNIA MEDICAL BOARD, THE CALIFORNIA BOARD OF N

Minute Order - MINUTE ORDER (HEARING ON EX PARTE APPLICATION FOR ORDER TO SPECIFICALLY SET...)

Informal Discovery Conference

Minute Order - MINUTE ORDER (HEARING ON MOTION FOR PROTECTIVE ORDER)

Minute Order - MINUTE ORDER (INFORMAL DISCOVERY CONFERENCE (IDC); HEARING ON EX PARTE APPL...)

Separate Statement

Ex Parte Application - EX PARTE APPLICATION PLAINTIFFS' EX PARTE APPLICATION FOR ORDER ADVANCING THE HEARING DATES OF PLAINTIFFS MOTIONS TO COMPEL

Motion to Compel Further Discovery Responses

Exhibit List

Jury Instructions

Witness List

Ex Parte Application - EX PARTE APPLICATION EX PARTE APPLICATION FOR ORDER SHORTENING TIME TO HEAR DEFENDANTS’ MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR

Statement of the Case

Declaration - DECLARATION DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF EX PARTE APPLICATION FOR ORDER SHORTENING TIME TO HEAR DEFENDANTS’ MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR

Minute Order - MINUTE ORDER (HEARING ON EX PARTE APPLICATION PLAINTIFFS' EX PARTE APPLICAT...)

Memorandum of Points & Authorities

Notice - NOTICE OF TAKING MOTION TO COMPEL PLAINTIFF MARIE MOR’S RESPONSES TO SPECIAL INTERROGATORIES, SET ONE, NOS. 101 AND 103 OFF CALENDAR

Notice - NOTICE DEFENDANTS’ NOTICE OF TAKING MOTION TO COMPEL PLAINTIFF MARIE MOR’S VERIFIED RESPONSES TO DISCOVERY OFF CALENDAR

Opposition - OPPOSITION PLAINTIFFS’ OPPOSITION TO DEFENDANTS’ MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION OF SHLOMO RECHNITZ; REQUEST FOR MONETARY SANCTIONS IN THE AMOUNT OF $5,250.00; DECLA

Notice - NOTICE OF TAKING MOTION TO COMPEL FURTHER RESPONSES FROM PLAINTIFF MARIE MOR TO REQUEST FOR ADMISSION, SET ONE, NOS. 3 AND 4 OFF CALENDAR

Declaration - DECLARATION DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANT’S OPPOSITION TO PLAINTIFFS’ MOTION TO COMPEL RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE

Request for Judicial Notice

Opposition - OPPOSITION DEFENDANT ROCKPORT ADMINISTRATIVE SERVICES, LLC’S OPPOSITION TO PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE; REQUEST FOR MONE

Opposition - OPPOSITION PLAINTIFFS' OPPOSITION TO DEFENDANTS' MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR; DECLARATION OF ALESSANDRA HORII, ESQ.

Response - RESPONSE DEFENDANT VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC DBA MONTROSE SPRINGS’S RESPONSE TO PLAINTIFF JEFFREY MOR’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER

Response - RESPONSE DEFENDANT SHLOMO RECHNITZ’S RESPONSE TO PLAINTIFF JEFFREY MOR’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE,

Opposition - OPPOSITION DEFENDANT SHLOMO RECHNITZ’S OPPOSITION TO PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE; REQUEST FOR MONETARY SANCTIONS IN THE

Declaration - DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANT’S OPPOSITION TO PLAINTIFF’S MOTION TO COMPEL RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE

Opposition - OPPOSITION DEFENDANT VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC’S OPPOSITION TO PLAINTIFF’S MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET ONE; REQUEST FOR

Response - RESPONSE DEFENDANT ROCKPORT ADMINISTRATIVE SERVICES, LLC’S RESPONSE TO PLAINTIFF JEFFREY MOR’S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION

Declaration - DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANTS’ REPLY TO MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR

Reply - REPLY IN SUPPORT OF DEFENDANTS’ MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION OF SHLOMO RECHNITZ

Reply - REPLY IN SUPPORT OF DEFENDANTS’ MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR

Declaration - DECLARATION OF SHLOMO RECHNITZ IN SUPPORT OF DEFENDANTS' REPLY RE: MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION SHLOMO RECHNITZ

Reply - REPLY TO DEFENDANT'S OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, FROM DEFENDANT ROCKPORT ADMINISTRATIVE SERVICES, LLC

Certificate of Mailing for - CERTIFICATE OF MAILING FOR (HEARING ON MOTION FOR PROTECTIVE ORDER; HEARING ON MOTION TO ...) OF 12/15/2020

Offer to Compromise and Acceptance Under Code of Civil Procedure Section 998

Ex Parte Application - EX PARTE APPLICATION DEFENDANTS’ EX PARTE APPLICATION FOR ______________ REGARDING THE DEPOSITION OF GENEVIEVE BAUTISTA; DECLARATION OF HEATHER-ANN T. YOUNG

Opposition - OPPOSITION PLAINTIFFS' OPPOSITION TO DEFENDANTS' EX PARTE APPLICATION REGARDING THE DEPOSITION OF GENEVIEVE BAUTISTA

Declaration - DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANTS’ MOTION TO QUASH DEPOSITION SUBPOENA TO GENEVIEVE BAUTISTA

Motion to Quash - MOTION TO QUASH DEPOSITION SUBPOENA TO GENEVIEVE BAUTISTA

Memorandum of Points & Authorities

Notice of Ruling

Minute Order - MINUTE ORDER (HEARING ON EX PARTE APPLICATION FOR _______ REGARDING THE DEP...)

Memorandum of Costs (Summary)

Motion for Attorney Fees

Motion to Quash - MOTION TO QUASH DEPOSITION SUBPOENA

Ex Parte Application - EX PARTE APPLICATION EX PART APPLICATION TO ADVANCE MOTION TO QUASH

Minute Order - MINUTE ORDER (HEARING ON EX PARTE APPLICATION EX PART APPLICATION TO ADVANC...)

Notice - NOTICE DEFENDANTS’ NOTICE OF TAKING MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR OFF CALENDAR

Trial Brief

Opposition - OPPOSITION PLAINTIFFS' OPPOSITION TO DEFENDANTS' MOTION TO QUASH DEPOSITION SUBPOENA TO GENEVIEVE BAUTISTA

Opposition - OPPOSITION DEFENDANTS’ OPPOSITION TO PLAINTIFFS’ MOTION TO QUASH DEFENDANTS’ DEPOSITION SUBPOENA FOR PERSONAL APPEARANCE AND AMENDED NOTICE OF TAKING DEPOSITION OF NON-RETAINED EXPERT TER

Stipulation and Order - STIPULATION AND ORDER STIPULATION TO SPECIALLY SET HEARING DATE FOR PLAINTIFFS’ MOTION TO QUASH DEFENDANTS’ DEPOSITION SUBPOENA FOR PERSONAL APPEARANCE TO TERRI HANSEN, RN; [PR

Declaration - DECLARATION DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANTS’ OPPOSITION TO PLAINTIFFS’ MOTION TO QUASH DEFENDANTS’ DEPOSITION SUBPOENA FOR PERSONAL APPEARANCE AND AMENDED NO

Minute Order - MINUTE ORDER (FINAL STATUS CONFERENCE)

Memorandum of Points & Authorities

Notice - NOTICE OF ENTRY OF ORDER

Reply - REPLY P'S REPLY TO D'S OPP

Minute Order - MINUTE ORDER (COURT ORDER RE ADVANCING MOTION TO QUASH)

Reply - REPLY IN SUPPORT OF DEFENDANTS’ MOTION TO QUASH DEPOSITION SUBPOENA TO GENEVIEVE BAUTISTA

Ex Parte Application - EX PARTE APPLICATION DEFENDANTS’ EX PARTE APPLICATION FOR ORDER CONTINUING FINAL STATUS CONFERENCE AND TRIAL

Declaration - DECLARATION DECLARATION OF I. HOOSHIE BROOMAND IN SUPPORT OF DEFENDANTS’ EX PARTE APPLICATION FOR ORDER CONTINUING FINAL STATUS CONFERENCE AND TRIAL

Certificate of Mailing for - CERTIFICATE OF MAILING FOR (COURT ORDER RE ADVANCING MOTION TO QUASH) OF 01/19/2021

Opposition - OPPOSITION (P'S) TO D'S APP TO CONTINUE TRIAL

Minute Order - MINUTE ORDER (HEARING ON EX PARTE APPLICATION FOR ORDER CONTINUING FINAL ST...)

Minute Order - MINUTE ORDER (HEARING ON MOTION TO QUASH DEPOSITION SUBPOENA TO GENEVIEVE B...)

Exhibit List - EXHIBIT LIST JOINT

Statement of the Case - STATEMENT OF THE CASE [PROPOSED] JOINT STATEMENT OF CASE

Witness List - WITNESS LIST JOINT

Jury Instructions - JURY INSTRUCTIONS JOINT

Minute Order - MINUTE ORDER (FINAL STATUS CONFERENCE)

Opposition - OPPOSITION [PLAINTIFFS'] TO DEFENDANTS' MOTION IN LIMINE NO. 6

Opposition - OPPOSITION [PLAINTIFFS'] TO DEFENDANTS' MOTION IN LIMINE NO. 14

Opposition - OPPOSITION [PLAINTIFFS'] TO DEFENDANTS' MOTION IN LIMINE NO. 13

Opposition - OPPOSITION [PLAINTIFFS'] TO DEFENDANTS' MOTION IN LIMINE NO. 9

Opposition - OPPOSITION [PLAINTIFFS'] TO DEFENDANTS' MOTION IN LIMINE NO. 12

Opposition - OPPOSITION [PLAINTIFFS'] TO DEFENDANTS' MOTION IN LIMINE NO. 3

Opposition - OPPOSITION [PLAINTIFFS'] TO DEFENDANTS' MOTION IN LIMINE NO. 2

Opposition - OPPOSITION [PLAINTIFFS'] TO DEFENDANTS' MOTION IN LIMINE NO. 1

Opposition - OPPOSITION [PLAINTIFFS]' TO DEFENDANTS' MOTION IN LIMINE NO. 17

Minute Order - MINUTE ORDER (FINAL STATUS CONFERENCE)

Minute Order - MINUTE ORDER (FINAL STATUS CONFERENCE)

Minute Order - MINUTE ORDER (FINAL STATUS CONFERENCE)

Notice Re: Continuance of Hearing and Order

Notice - NOTICE OF CONTINUANCE OF PLAINTIFFS' MOTION FOR ATTORNEY'S FEES AND COSTS

Minute Order - MINUTE ORDER (FINAL STATUS CONFERENCE)

Notice of Settlement

Minute Order - MINUTE ORDER (COURT ORDER RE NOTICE OF SETTLEMENT)

Petition Complaint; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner); As to: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Summons on Petition; Issued and Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); As to: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Declaration Complaint; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner); As to: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Proof of Personal Service; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); As to: SHLOMO RECHNITZ (Respondent); Service Cost Waived: No

Notice of Case Assignment - Unlimited Civil Case; Filed by: Clerk

Proof of Mailing (Substituted Service); Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner); As to: Montrose Springs Skilled Nursing & Wellness Center (Respondent); Mailing Date: ; Service Cost: 98.50; Cost Waived: No

Notice and Acknowledgment of Receipt; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); As to: ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent)

Civil Case Cover Sheet; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner); As to: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Proof of Service by Substituted Service; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner); As to: Montrose Springs Skilled Nursing & Wellness Center (Respondent); Proof of Mailing Date: ; Service Cost: 98.50; Service Cost Waived: No

Notice of Case Management Conference; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); As to: Marie Mor (Petitioner)

Notice of Posting of Jury Fees; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Proof of Service by Mail; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); As to: ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent)

Notice of Case Management Conference; Filed by: Clerk

Notice and Acknowledgment of Receipt; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); As to: BRIUS MANAGEMENT CO., INC. (Respondent)

Declaration DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF EX PARTE APPLICATION FOR ODER SHORTENING TIME TO HEAR DEFENDANTS? MOTION FOR PROTECTIVE ORDER; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Request for Judicial Notice; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Declaration OF STEVEN STROLL IN SUPPORT OF DEFENDANTS? MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION OF STEVEN STROLL; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Declaration OF I. HOOSHIE BROOMAND IN SUPPORT OF DEFENDANTS? MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION OF STEVEN STROLL; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Updated -- Motion for Trial Preference: Filed By: Marie Mor (Petitioner),Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Result: Granted; Result Date:

Reply to Opposition to Plaintiff's Motion for Trial Prefernece Pursuant to C.C.P. Section 36(a); Declaration of Lisa Trinh Flint, Esq. Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Declaration of IHB; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Updated -- Ex Parte Application for order shortening time to hear Defendants' Motion for Protective Order: Filed By: Montrose Springs Skilled Nursing & Wellness Center (Respondent),BRIUS MANAGEMENT CO., INC. (Respondent),ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent),SHLOMO RECHNITZ (Respondent),VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); Result: Granted; Result Date:

Declaration OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANTS? MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Notice of Posting of Jury Fees; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Memorandum of Points & Authorities; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Case Management Statement; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Motion for Trial Preference; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner); As to: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Motion for Protective Order Precluding the Deposition of Steven Stroll; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Notice Notice of CMC; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); As to: Montrose Springs Skilled Nursing & Wellness Center (Respondent)

Declaration OF SHLOMO RECHNITZ IN SUPPORT OF DEFENDANTS? MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION SHLOMO RECHNITZ; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Declaration DECLARATION OF I. HOOSHIE BROOMAND IN SUPPORT OF DEFENDANTS? EX PARTE APPLICATION FOR ORDER CONTINUING FINAL STATUS CONFERENCE AND TRIAL; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Motion for Attorney Fees; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Updated -- Ex Parte Application to Advance Motion to Quash: Filed By: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Result: Granted; Result Date:

Updated -- Motion to Quash Deposition Subpoena re Terri Hansen, RN: Filed By: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Result: Granted; Result Date:

Opposition [Plaintiffs]' to Defendants' Motion in Limine No. 17; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Ex Parte Application DEFENDANTS? EX PARTE APPLICATION FOR ORDER CONTINUING FINAL STATUS CONFERENCE AND TRIAL; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent); As to: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Notice of Ruling; Filed by: Marie Mor (Petitioner)

Reply IN SUPPORT OF DEFENDANTS? MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Opposition [Plaintiffs'] to Defendants' Motion in Limine No. 16; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Updated -- Motion to Quash Deposition Subpoena to Genevieve Bautista: Filed By: Montrose Springs Skilled Nursing & Wellness Center (Respondent),VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent),SHLOMO RECHNITZ (Respondent),ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent),BRIUS MANAGEMENT CO., INC. (Respondent); Result: Denied; Result Date:

Ex Parte Application Ex Part Application to Advance Motion to Quash; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); As to: Marie Mor (Petitioner)

Opposition [Plaintiffs'] to Defendants' Motion in Limine No. 4; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Opposition Plaintiffs' Opposition to Defendants' Motion to Quash Deposition Subpoena to Genevieve Bautista; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Jury Instructions JOINT; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Declaration OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANT?S OPPOSITION TO PLAINTIFF?S MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET ONE; Filed by: VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent)

Trial Brief; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Statement of the Case [PROPOSED] JOINT STATEMENT OF CASE; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Reply to Defendant's Opposition to Plaintiff's Motion to Compel Further Responses to Request for Production of Documents, Set One, from Defendant Shlomo Rechnitz; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Declaration DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANT?S OPPOSITION TO PLAINTIFFS? MOTION TO COMPEL RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE; Filed by: ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent)

Response DEFENDANT SHLOMO RECHNITZ?S RESPONSE TO PLAINTIFF JEFFREY MOR?S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, NOS 9-11 AND 18-20; Filed by: SHLOMO RECHNITZ (Respondent)

Updated -- Motion to Compel Further Discovery Responses to Request for Production of Documents, Set One, from Defendant, Rockport Administrative Services, LLC; Request for Monetary Sanctions in the amount of $2,500.00: Filed By: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Result: Granted; Result Date:

Offer to Compromise and Acceptance Under Code of Civil Procedure Section 998; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Opposition P's Supplemental Opposition; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Exhibit List JOINT; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Updated -- Stipulation and Order STIPULATION TO SPECIALLY SET HEARING DATE FOR PLAINTIFFS? MOTION TO QUASH DEFENDANTS? DEPOSITION SUBPOENA FOR PERSONAL APPEARANCE TO TERRI HANSEN, RN; [PROPOSED] ORDER: Filed By: SHLOMO RECHNITZ (Respondent),ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent),VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent),BRIUS MANAGEMENT CO., INC. (Respondent),Montrose Springs Skilled Nursing & Wellness Center (Respondent); Result: Granted; Result Date:

Opposition [Plaintiffs'] to Defendants' Motion in Limine No. 12; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Opposition [Plaintiffs'] to Defendants' Motion in Limine No. 10; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Opposition DEFENDANT VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC?S OPPOSITION TO PLAINTIFF?S MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET ONE; REQUEST FOR MONETARY SANCTIONS IN THE AMOUNT OF $2,500.00; Filed by: VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent)

Updated -- Ex Parte Application for Order continuing Final Status Conference and Trial: Filed By: VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent),SHLOMO RECHNITZ (Respondent),ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent),Montrose Springs Skilled Nursing & Wellness Center (Respondent),BRIUS MANAGEMENT CO., INC. (Respondent); Result: Granted; Result Date:

Opposition [Plaintiffs'] to Defendants' Motion in Limine No. 5; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

On the Petition filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck, et al. on , entered Order for Dismissal without prejudice, does 1-60

Motion to Quash Deposition Subpoena to Genevieve Bautista; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Declaration DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANTS? OPPOSITION TO PLAINTIFFS? MOTION TO QUASH DEFENDANTS? DEPOSITION SUBPOENA FOR PERSONAL APPEARANCE AND AMENDED NOTICE OF TAKING DEPOSITION OF NON-RETAINED EXPERT TERRI HANSEN, RN; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Notice of Continuance of Plaintiffs' Motion for Attorney's Fees and Costs; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner); As to: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Memorandum of Costs (Summary); Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Declaration OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANTS? MOTION TO QUASH DEPOSITION SUBPOENA TO GENEVIEVE BAUTISTA; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Witness List JOINT; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Opposition [Plaintiffs'] to Defendants' Motion in Limine No. 14; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Opposition [Plaintiffs'] to Defendants' Motion in Limine No. 9; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Memorandum of Points & Authorities; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Notice Re: Continuance of Hearing and Order; Filed by: Clerk

Opposition [Plaintiffs'] to Defendants' Motion in Limine No. 7; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Certificate of Mailing for (Hearing on Motion for Protective Order; Hearing on Motion to ...) of ; Filed by: Clerk

Updated -- Motion to Compel Further Discovery Responses to Special Interrogatories, Set One, from Defendant, Verdugo Valley Skilled Nursing & Wellness Centre, LLC dba Montrose Springs Skilled Nursing & Wellness Centre; Request for Monetary Sanctions in the amount of $2,500.00: Filed By: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Result: Granted; Result Date:

Memorandum of Points & Authorities; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Declaration OF SHLOMO RECHNITZ IN SUPPORT OF DEFENDANTS' REPLY RE: MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION SHLOMO RECHNITZ; Filed by: SHLOMO RECHNITZ (Respondent)

Notice OF ENTRY OF ORDER; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent); As to: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Reply P's Reply to D's Opp; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Opposition PLAINTIFFS' OPPOSITION TO DEFENDANTS' MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR; DECLARATION OF ALESSANDRA HORII, ESQ. Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Declaration OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANTS? REPLY TO MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Reply IN SUPPORT OF DEFENDANTS? MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION OF SHLOMO RECHNITZ; Filed by: SHLOMO RECHNITZ (Respondent)

Opposition [Plaintiffs'] to Defendants' Motion in Limine No. 6; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Opposition Plaintiffs' Opposition to Defendants' Ex Parte Application Regarding the Deposition of Genevieve Bautista; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Reply to Defendant's Opposition to Plaintiff's Motion to Compel Further Responses to Request for Production of Documents, Set One, from Defendant Rockport Administrative Services, LLC; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Reply Plaintiff's Reply to Defendant's Opposition to Plaintiff's Motion to Compel Further Responses to Special Interrogatories, Set One, from Defendant Verdugo Valley Skilled Nursing & Wellness Centre, LLC; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Opposition [Plaintiffs'] to Defendants' Motion in Limine No. 2; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Jury Instructions Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Motion to Quash Deposition Subpoena; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Updated -- Motion to Compel Further Discovery Responses to Request for Production of Documents, Set One, from Defendant, Shlomo Rechnitz; Request for Monetary Sanctions in the amount of $2,500.00: Filed By: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Result: Denied; Result Date:

Opposition DEFENDANT ROCKPORT ADMINISTRATIVE SERVICES, LLC?S OPPOSITION TO PLAINTIFF?S MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE; REQUEST FOR MONETARY SANCTIONS IN THE AMOUNT OF $2,500.00; Filed by: ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent)

Response DEFENDANT ROCKPORT ADMINISTRATIVE SERVICES, LLC?S RESPONSE TO PLAINTIFF JEFFREY MOR?S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, NOS 14-15, 21, 46, 49-50 AND 54-62; Filed by: ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent)

Request for Judicial Notice; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Certificate of Mailing for (Court Order re Advancing Motion to Quash) of ; Filed by: Clerk

Opposition DEFENDANTS? OPPOSITION TO PLAINTIFFS? MOTION TO QUASH DEFENDANTS? DEPOSITION SUBPOENA FOR PERSONAL APPEARANCE AND AMENDED NOTICE OF TAKING DEPOSITION OF NON-RETAINED EXPERT TERRI HANSEN, RN; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Reply IN SUPPORT OF DEFENDANTS? MOTION TO QUASH DEPOSITION SUBPOENA TO GENEVIEVE BAUTISTA; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Updated -- Motion for Protective Order: Filed By: Montrose Springs Skilled Nursing & Wellness Center (Respondent),VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent),BRIUS MANAGEMENT CO., INC. (Respondent),ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent),SHLOMO RECHNITZ (Respondent); Result: Denied; Result Date:

Opposition [Plaintiffs'] to Defendants' Motion in Limine No. 13; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Response DEFENDANT VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC dba MONTROSE SPRINGS?S RESPONSE TO PLAINTIFF JEFFREY MOR?S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET ONE, NOS 32, 63, 70, 71, 120 AN; Filed by: VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent)

Ex Parte Application DEFENDANTS? EX PARTE APPLICATION FOR ______________ REGARDING THE DEPOSITION OF GENEVIEVE BAUTISTA; DECLARATION OF HEATHER-ANN T. YOUNG; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent); As to: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Updated -- Ex Parte Application DEFENDANTS? EX PARTE APPLICATION FOR ______________ REGARDING THE DEPOSITION OF GENEVIEVE BAUTISTA; DECLARATION OF HEATHER-ANN T. YOUNG: Filed By: VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent),Montrose Springs Skilled Nursing & Wellness Center (Respondent),BRIUS MANAGEMENT CO., INC. (Respondent),ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent),SHLOMO RECHNITZ (Respondent); Result: Denied; Result Date:

Notice DEFENDANTS? NOTICE OF TAKING MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR OFF CALENDAR; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent); As to: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Response (DEFENDANT ROCKPORT ADMINISTRATIVE SERVICES, LLC?S RESPONSE TO PLAINTIFF JEFFREY MOR?S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, NOS 14-15, 21, 46, 49-50 AND 54-62) Filed by ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent)

Declaration (DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF EX PARTE APPLICATION FOR ODER SHORTENING TIME TO HEAR DEFENDANTS? MOTION FOR PROTECTIVE ORDER) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Opposition (PLAINTIFFS'OMBINED OPPOSITION TO DEFENDANTS'X PARTE APPLICATIONS FOR AN ORDER SHORTENING TIME FOR THK HEARING ON DEFENDANTS'OTIONS; DECLARATION OF PHILIP J. SPINAZZK IN SUPPORT THEREOF) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Exhibit List Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Minute Order ( (Hearing on Motion for Protective Order)) Filed by Clerk

Separate Statement Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Declaration (Complaint) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Notice of Case Assignment - Unlimited Civil Case Filed by Clerk

Proof of Service by Mail Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Notice of Posting of Jury Fees Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Opposition (OPPOSITION TO PLAINTIFFS? EX PARTE APPLICATION FOR AN ORDER TO ADVANCE THE DATE OF PLAINTIFFS? MOTION FOR PREFERENCE) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Motion in Limine (NO. 5 TO EXCLUDE OR LIMIT AS EVIDENCE PLAINTIFF MARIE MOR?S CLAIM OF LOSS OF INCOME; DECLARATION OF HEATHER-ANN T. YOUNG) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Motion for Protective Order Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Informal Discovery Conference Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Ex Parte Application (for Order to specifically set hearing date for P's Motion to Compel Deposition) Filed by Marie Mor (Petitioner)

Motion to Compel Further Discovery Responses (to Request for Production of Documents, Set One, from Defendant, Rockport Administrative Services, LLC; Request for Monetary Sanctions in the amount of $2,500.00) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Declaration (OF SHLOMO RECHNITZ IN SUPPORT OF DEFENDANTS? MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION SHLOMO RECHNITZ) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Memorandum of Points & Authorities Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Minute Order ( (Case Management Conference; Hearing on Motion for Trial Prefe...)) Filed by Clerk

Separate Statement Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Opposition OPPOSITION TO PLAINTIFFS EX PARTE APPLICATION FOR AN ORDER TO ENFORCE THE SETTLEMENT UNDER CALIFORNIA CODE OF CIVIL PROCEDURE 664.6 PURSUANT TO THE EXECUTED RELEASE; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Motion to Compel (PLAINTIFF MARIE MOR?S VERIFIED RESPONSES TO DISCOVERY) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Opposition (PLAINTIFFS' OPPOSITION TO DEFENDANTS' MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR; DECLARATION OF ALESSANDRA HORII, ESQ.) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Declaration (DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF EX PARTE APPLICATION FOR SHORTENING TIME TO HEAR DEFENDANTS? MOTION TO COMPEL PLAINTIFF MARIE MOR?S RESPONSES TO SPECIAL INTERROGATORIES, SET ONE, NOS. 101 AND 103) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Motion in Limine (NO. 9 TO PRECLUDE ARGUMENT OF ALLEGED ?PROFIT OVER PATIENT CARE? AND PRECLUSION OF FINANCIAL STATEMENTS; DECLARATION OF HEATHER-ANN T. YOUNG) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Answer Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Petition (Complaint) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Ex Parte Application (for Order Shortening Time to Hear Defendants' Motion for Protective Order Precluding the Deposition of Shlomo Rechnitz) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Declaration (OF HEATHER-ANN T. YOUNG IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES FROM PLAINTIFF MARIE MOR TO REQUEST FOR ADMISSION, SET ONE, NOS. 3 AND 4) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Notice (of Case Management Conference) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Ex Parte Application (for Order Advancing the Hearing Dates of Plaintiffs Motions to Compel) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Case Management Statement Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Motion in Limine (NO. 14 TO PRECLUDE EXPERTS FROM OPINING THE DECEDENT?S CARE WAS RECKLESS OR THE LIKE; DECLARATION OF HEATHER-ANN T. YOUNG) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Motion in Limine (NO. 10 TO PRECLUDE FROM REFERRING TO PLAINTIFFS OR DECEDENTS AS A VICTIM OR ANY OTHER INFLAMMATORY NOUN; DECLARATION OF HEATHER-ANN T. YOUNG) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Ex Parte Application Plaintiffs' Ex Parte Application to be Filed Under Seal Per Court Minute Order dated May 7, 2021; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner); As to: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Opposition - OPPOSITION [PLAINTIFFS'] TO DEFENDANTS' MOTION IN LIMINE NO. 16

Opposition - OPPOSITION [PLAINTIFFS'] TO DEFENDANTS' MOTION IN LIMINE NO. 4

Opposition - OPPOSITION [PLAINTIFFS'] TO DEFENDANTS' MOTION IN LIMINE NO. 10

Opposition - OPPOSITION [PLAINTIFFS'] TO DEFENDANTS' MOTION IN LIMINE NO. 5

Opposition - OPPOSITION [PLAINTIFFS'] TO DEFENDANTS' MOTION IN LIMINE NO. 7

Certificate of Mailing for - CERTIFICATE OF MAILING FOR (COURT ORDER RE NOTICE OF SETTLEMENT) OF 04/14/2021

Notice - NOTICE NOTICE OF ORDER TO SHOW CAUSE RE DISMISSAL

Declaration - DECLARATION DECLARATION OF I. HOOSHIE BROOMAND IN SUPPORT OF OPPOSITION TO PLAINTIFFS’ EX PARTE APPLICATION FOR AN ORDER TO ENFORCE THE SETTLEMENT UNDER CALIFORNIA CODE OF CIVIL PROCEDUR

Minute Order - MINUTE ORDER (HEARING ON EX PARTE APPLICATION FOR AN ORDER TO ENFORCE THE ...)

Opposition - OPPOSITION OPPOSITION TO PLAINTIFFS EX PARTE APPLICATION FOR AN ORDER TO ENFORCE THE SETTLEMENT UNDER CALIFORNIA CODE OF CIVIL PROCEDURE 664.6 PURSUANT TO THE EXECUTED RELEASE

Ex Parte Application - EX PARTE APPLICATION PLAINTIFFS' EX PARTE APPLICATION FOR AN ORDER TO ENFORCE THE SETTLEMENT UNDER CCP 664.6

Ex Parte Application - EX PARTE APPLICATION PLAINTIFFS' EX PARTE APPLICATION TO BE FILED UNDER SEAL PER COURT MINUTE ORDER DATED MAY 7, 2021

Request for Dismissal

Declaration (OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANTS? MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION OF SHLOMO RECHNITZ) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Opposition (PLAINTIFFS? OPPOSITION TO DEFENDANTS? MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION OF SHLOMO RECHNITZ; REQUEST FOR MONETARY SANCTIONS IN THE AMOUNT OF $5,250.00; DECLARATION OF LISA TRINH FLINT, ESQ.) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Ex Parte Application Plaintiffs' Ex Parte Application for an Order to Enforce the Settlement under CCP 664.6; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner); As to: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Minute Order ( (Hearing on Ex Parte Application Plaintiffs' Ex Parte Applicat...)) Filed by Clerk

Civil Case Cover Sheet Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Motion in Limine (NO. 17 REQUESTING 48 HOUR ADVANCE NOTICE TO WITNESSES) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Motion for Trial Preference Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Notice (Notice of CMC) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Certificate of Mailing for (Court Order re Notice of Settlement) of ; Filed by: Clerk

Motion to Compel (PLAINTIFF MARIE MOR?S RESPONSES TO SPECIAL INTERROGATORIES, SET ONE, NOS. 101 AND 103) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Ex Parte Application (to Advance Plaintiff's Motion for Trial Preference) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Motion to Compel Further Discovery Responses (to Special Interrogatories, Set One, from Defendant, Verdugo Valley Skilled Nursing & Wellness Centre, LLC dba Montrose Springs Skilled Nursing & Wellness Centre; Request for Monetary Sanctions in the amount of $2,500.00) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Ex Parte Application (for Order Shortening Time to Hear Defendants' Motion to Compel Plaintiff Marie Mor's Responses to Special Interrogatories, Set One, Nos. 101 AND 103) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Opposition (to Motion) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Motion to Compel Further Discovery Responses (to Request for Production of Documents, Set One, from Defendant, Shlomo Rechnitz; Request for Monetary Sanctions in the amount of $2,500.00) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Memorandum of Points & Authorities Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Motion in Limine (NO. 13 TO PRECLUDE TESTIMONY RE: MEDICAL TEXT AND PUBLICATIONS; DECLARATION OF HEATHER-ANN T. YOUNG) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Declaration (DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF EX PARTE APPLICATION FOR ORDER SHORTENING TIME TO HEAR DEFENDANTS? MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Notice of Posting of Jury Fees Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Notice and Acknowledgment of Receipt Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Declaration (OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANTS? MOTION TO COMPEL PLAINTIFF MARIE MOR?S VERIFIED RESPONSES TO DISCOVERY) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Proof of Service (not Summons and Complaint) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Ex Parte Application (for Order shortening time to hear Defendants' Motion to Compel Deposition of Plaintiff Marie Mor) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Notice Notice of Order to Show Cause re Dismissal; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner); As to: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Memorandum of Points & Authorities Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Declaration (of IHB) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Motion in Limine (NO. 3 TO EXCLUDE LAY WITNESS OPINION AT TRIAL; DECLARATION OF HEATHER-ANN T. YOUNG) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Notice (OF TAKING MOTION TO COMPEL PLAINTIFF MARIE MOR?S RESPONSES TO SPECIAL INTERROGATORIES, SET ONE, NOS. 101 AND 103 OFF CALENDAR) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Memorandum of Points & Authorities Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Motion in Limine (NO. 1 TO PRECLUDE REFERENCES TO INVESTIGATIONS OR COMPLAINTS TO CALIFORNIA DEPARTMENT OF PUBLIC HEALTH, STATE OF CALIFORNIA MEDICAL BOARD, THE CALIFORNIA BOARD OF NURSING, OR OTHER STATE AGENCY, INCLUDING CENTERS FOR MEDICARE) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Notice of Case Management Conference Filed by Clerk

Informal Discovery Conference Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Declaration (OF STEVEN STROLL IN SUPPORT OF DEFENDANTS? MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION OF STEVEN STROLL) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Case Management Statement Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Request for Judicial Notice Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Witness List Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Declaration (DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF EX PARTE APPLICATION FOR SHORTENING TIME TO HEAR DEFENDANTS? MOTION TO COMPEL PLAINTIFF MARIE MOR?S VERIFIED RESPONSES TO DISCOVERY) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Motion for Protective Order (Precluding the Deposition of Steven Stroll) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Notice (DEFENDANTS? NOTICE OF TAKING MOTION TO COMPEL PLAINTIFF MARIE MOR?S VERIFIED RESPONSES TO DISCOVERY OFF CALENDAR) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Motion in Limine (NO. 12 TO LIMIT EXPERTS TO OPINIONS EXPRESSED AT THEIR DEPOSITIONS) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Motion in Limine (NO. 11 LIMITING NON-RETAINED EXPERT WITNESS TESTIMONY; DECLARATION OF HEATHER-ANN T. YOUNG) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Motion in Limine (NO. 7 TO RESTRICT EXPERT TESTIMONY ON UNSUPPORTED ALLEGATIONS OF UNDERSTAFFING; DECLARATION OF HEATHER-ANN T. YOUNG) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Motion in Limine (NO. 6 PRECLUDING PLAINTIFFS FROM ASKING WITNESSES ABOUT THEIR OPINIONS AND CONCLUSIONS OF THE LAW; DECLARATION OF HEATHER-ANN T. YOUNG) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Notice (OF TAKING MOTION TO COMPEL FURTHER RESPONSES FROM PLAINTIFF MARIE MOR TO REQUEST FOR ADMISSION, SET ONE, NOS. 3 AND 4 OFF CALENDAR) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Application And Order For Appointment of Guardian Ad Litem (Marie) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Statement of the Case Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Declaration (OF HEATHER-ANN T. YOUNG IN SUPPORT OF MOTION TO COMPEL PLAINTIFF MARIE MOR?S RESPONSES TO SPECIAL INTERROGATORIES, SET ONE, NOS. 101 AND 103) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Ex Parte Application (for Order Shortening Time to hear Defendants' Motion to Compel Deposition of Plaintiff Marie Mor) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Ex Parte Application (for Order Shortening time to hear Defendants' Motion to Compel Further Responses from Plaintiff Marie Mor to Request for Admissions, Set One, Nos. 3 and 4) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Declaration (DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF EX PARTE APPLICATION FOR SHORTENING TIME TO HEAR DEFENDANTS? MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION OF SHLOMO RECHNITZ) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Motion in Limine (NO. 4 TO PRECLUDE PLAINTIFFS? EVIDENCE OF INJURIES TO OTHER INDIVIDUALS; DECLARATION OF HEATHER-ANN T. YOUNG) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Minute Order ((Hearing on Ex Parte Application FOR ORDER SHORTENING TIME TO ...)) Filed by Clerk

Motion in Limine (NO. 8 TO PRECLUDE PRIOR LITIGATION DECISIONS RE DEFENDANT; DECLARATION OF HEATHER-ANN T. YOUNG) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Order (re Ex Parte Application for Order to Advance Plaintiff's Motion for Trial Preference) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Notice of Ruling Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Motion in Limine (NO. 2 TO PRECLUDE MICHELE MOR FROM TESTIFYING ON BEHALF OF MARIE MOR AS HER GUARDIAN AD LITEM AND ANSWERING HYPOTHETICAL QUESTIONS REGARDING CARE; DECLARATION OF HEATHER-ANN T. YOUNG) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Stipulation and Order (to specially set hearing date for Plaintiffs' Motion to Quash Defendants' Deposition Subpoena for personal appearance to Terri Hansen, RN) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Minute Order ( (Hearing on Motion for Protective Order; Hearing on Motion to ...)) Filed by Clerk

Memorandum of Points & Authorities Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Opposition (Plaintiffs' Opposition to Defendants' Ex Parte Application Regarding the Deposition of Genevieve Bautista) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Minute Order ( (Final Status Conference)) Filed by Clerk

Notice (DEFENDANTS? NOTICE OF TAKING MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR OFF CALENDAR) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Minute Order ( (Hearing on Ex Parte Application FOR _______ REGARDING THE DEP...)) Filed by Clerk

Opposition (DEFENDANTS? OPPOSITION TO PLAINTIFFS? MOTION TO QUASH DEFENDANTS? DEPOSITION SUBPOENA FOR PERSONAL APPEARANCE AND AMENDED NOTICE OF TAKING DEPOSITION OF NON-RETAINED EXPERT TERRI HANSEN, RN) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Reply (P's Reply to D's Opp) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Offer to Compromise and Acceptance Under Code of Civil Procedure Section 998 Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Declaration (OF SHLOMO RECHNITZ IN SUPPORT OF DEFENDANTS' REPLY RE: MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION SHLOMO RECHNITZ) Filed by SHLOMO RECHNITZ (Respondent)

Declaration (OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANT?S OPPOSITION TO PLAINTIFF?S MOTION TO COMPEL RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE) Filed by SHLOMO RECHNITZ (Respondent)

Declaration (DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANT?S OPPOSITION TO PLAINTIFFS? MOTION TO COMPEL RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE) Filed by ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent)

Reply (IN SUPPORT OF DEFENDANTS? MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Minute Order ( (Hearing on Motion to Quash Deposition Subpoena to Genevieve B...)) Filed by Clerk

Reply (to Defendant's Opposition to Plaintiff's Motion to Compel Further Responses to Request for Production of Documents, Set One, from Defendant Rockport Administrative Services, LLC) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Certificate of Mailing for ((Hearing on Motion for Protective Order; Hearing on Motion to ...) of ) Filed by Clerk

Reply (IN SUPPORT OF DEFENDANTS? MOTION TO QUASH DEPOSITION SUBPOENA TO GENEVIEVE BAUTISTA) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Trial Brief Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Declaration (DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANTS? OPPOSITION TO PLAINTIFFS? MOTION TO QUASH DEFENDANTS? DEPOSITION SUBPOENA FOR PERSONAL APPEARANCE AND AMENDED NOTICE OF TAKING DEPOSITION OF NON-RETAINED EXPERT TERRI HANSEN, RN) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Opposition (DEFENDANT SHLOMO RECHNITZ?S OPPOSITION TO PLAINTIFF?S MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE; REQUEST FOR MONETARY SANCTIONS IN THE AMOUNT OF $2,500.00) Filed by SHLOMO RECHNITZ (Respondent)

Ex Parte Application (to Advance Motion to Quash) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Opposition (DEFENDANT ROCKPORT ADMINISTRATIVE SERVICES, LLC?S OPPOSITION TO PLAINTIFF?S MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE; REQUEST FOR MONETARY SANCTIONS IN THE AMOUNT OF $2,500.00) Filed by ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent)

Ex Parte Application (DEFENDANTS? EX PARTE APPLICATION FOR ______________ REGARDING THE DEPOSITION OF GENEVIEVE BAUTISTA; DECLARATION OF HEATHER-ANN T. YOUNG) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Notice of Ruling Filed by Marie Mor (Petitioner)

Memorandum of Costs (Summary) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Response (DEFENDANT SHLOMO RECHNITZ?S RESPONSE TO PLAINTIFF JEFFREY MOR?S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, NOS 9-11 AND 18-20) Filed by SHLOMO RECHNITZ (Respondent)

Declaration (DECLARATION OF I. HOOSHIE BROOMAND IN SUPPORT OF DEFENDANTS? EX PARTE APPLICATION FOR ORDER CONTINUING FINAL STATUS CONFERENCE AND TRIAL) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Certificate of Mailing for ((Court Order re Advancing Motion to Quash) of ) Filed by Clerk

Opposition (Plaintiffs' Opposition to Defendants' Motion to Quash Deposition Subpoena to Genevieve Bautista) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Reply (to Defendant's Opposition to Plaintiff's Motion to Compel Further Responses to Request for Production of Documents, Set One, from Defendant Shlomo Rechnitz) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Declaration (OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANT?S OPPOSITION TO PLAINTIFF?S MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET ONE) Filed by VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent)

Motion to Quash (Deposition Subpoena to Genevieve Bautista) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Minute Order ((Hearing on Ex Parte Application Ex Part Application to Advanc...)) Filed by Clerk

Opposition (P's Supplemental Opposition) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Motion to Quash (Deposition Subpoena re Terri Hansen, RN) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Minute Order ((Court Order re Advancing Motion to Quash)) Filed by Clerk

Declaration (OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANTS? MOTION TO QUASH DEPOSITION SUBPOENA TO GENEVIEVE BAUTISTA) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Reply (IN SUPPORT OF DEFENDANTS? MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION OF SHLOMO RECHNITZ) Filed by SHLOMO RECHNITZ (Respondent)

Trial Brief Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Ex Parte Application (for Order continuing Final Status Conference and Trial) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Motion for Attorney Fees Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Response (DEFENDANT VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC dba MONTROSE SPRINGS?S RESPONSE TO PLAINTIFF JEFFREY MOR?S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET ONE, NOS 32, 63, 70, 71, 120 AN) Filed by VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent)

Reply (Plaintiff's Reply to Defendant's Opposition to Plaintiff's Motion to Compel Further Responses to Special Interrogatories, Set One, from Defendant Verdugo Valley Skilled Nursing & Wellness Centre, LLC) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Opposition ((P's) to D's App to Continue Trial) Filed by Marie Mor (Petitioner)

Opposition (DEFENDANT VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC?S OPPOSITION TO PLAINTIFF?S MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET ONE; REQUEST FOR MONETARY SANCTIONS IN THE AMOUNT OF $2,500.00) Filed by VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent)

Declaration (OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANTS? REPLY TO MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Memorandum of Points & Authorities Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Minute Order ( (Hearing on Ex Parte Application FOR ORDER CONTINUING FINAL ST...)) Filed by Clerk

Notice (OF ENTRY OF ORDER) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Minute Order ( (Court Order re Notice of Settlement)) Filed by Clerk

Opposition ([Plaintiffs'] to Defendants' Motion in Limine No. 12) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Opposition ([Plaintiffs'] to Defendants' Motion in Limine No. 6) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Notice of Settlement Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Ex Parte Application (for an Order to Enforce the Settlement under CCP 664.6) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Minute Order ( (Hearing on Ex Parte Application for an Order to Enforce the ...)) Filed by Clerk

Minute Order ( (Final Status Conference)) Filed by Clerk

Opposition ([Plaintiffs'] to Defendants' Motion in Limine No. 5) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Opposition ([Plaintiffs'] to Defendants' Motion in Limine No. 14) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Exhibit List (JOINT) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Opposition ([Plaintiffs'] to Defendants' Motion in Limine No. 16) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Opposition ([Plaintiffs'] to Defendants' Motion in Limine No. 1) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Opposition ([Plaintiffs'] to Defendants' Motion in Limine No. 10) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Notice (Notice of Order to Show Cause re Dismissal) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Notice Re: Continuance of Hearing and Order Filed by Clerk

Certificate of Mailing for ((Court Order re Notice of Settlement) of ) Filed by Clerk

Opposition ([Plaintiffs'] to Defendants' Motion in Limine No. 9) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Minute Order ( (Final Status Conference)) Filed by Clerk

Jury Instructions (JOINT) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Witness List (JOINT) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Minute Order ( (Final Status Conference)) Filed by Clerk

Opposition ([Plaintiffs'] to Defendants' Motion in Limine No. 13) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Minute Order ( (Final Status Conference)) Filed by Clerk

Notice (of Continuance of Plaintiffs' Motion for Attorney's Fees and Costs) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Minute Order ( (Final Status Conference)) Filed by Clerk

Opposition ([Plaintiffs'] to Defendants' Motion in Limine No. 7) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Request for Dismissal Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Ex Parte Application (for an Order to Enforce the Settlement under CCP 664.6 Pursuant to the Executed Release) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Opposition (OPPOSITION TO PLAINTIFFS EX PARTE APPLICATION FOR AN ORDER TO ENFORCE THE SETTLEMENT UNDER CALIFORNIA CODE OF CIVIL PROCEDURE 664.6 PURSUANT TO THE EXECUTED RELEASE) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Opposition ([Plaintiffs]' to Defendants' Motion in Limine No. 17) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Opposition ([Plaintiffs'] to Defendants' Motion in Limine No. 2) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Ex Parte Application (Plaintiffs' Ex Parte Application to be Filed Under Seal Per Court Minute Order dated May 7, 2021) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Declaration (DECLARATION OF I. HOOSHIE BROOMAND IN SUPPORT OF OPPOSITION TO PLAINTIFFS? EX PARTE APPLICATION FOR AN ORDER TO ENFORCE THE SETTLEMENT UNDER CALIFORNIA CODE OF CIVIL PROCEDURE ¿ 664.6 PURSUANT TO THE EXECUTED RELEASE) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Statement of the Case ([PROPOSED] JOINT STATEMENT OF CASE) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Opposition ([Plaintiffs'] to Defendants' Motion in Limine No. 3) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Opposition ([Plaintiffs'] to Defendants' Motion in Limine No. 4) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Notice of Case Management Conference

Proof of Service by Substituted Service

Answer; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent); As to: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Declaration OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANTS? MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION OF SHLOMO RECHNITZ; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Updated -- Order Proposed Order re Ex Parte Application for Order to Advance Plaintiff's Motion for Trial Preference: Filed By: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner),Marie Mor (Petitioner); Result: Granted; Result Date:

Motion to Compel DEPOSITION OF PLAINTIFF MARIE MOR; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent); As to: Marie Mor (Petitioner)

Notice of Ruling; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Opposition to Motion; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Proof of Service by Mail; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); As to: BRIUS MANAGEMENT CO., INC. (Respondent)

Memorandum of Points & Authorities; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Notice and Acknowledgment of Receipt; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); As to: VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent)

Memorandum of Points & Authorities; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Opposition OPPOSITION TO PLAINTIFFS? EX PARTE APPLICATION FOR AN ORDER TO ADVANCE THE DATE OF PLAINTIFFS? MOTION FOR PREFERENCE; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Case Management Statement; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Application And Order For Appointment of Guardian Ad Litem Marie; Signed and Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner); As to: Marie Mor (Petitioner)

Memorandum of Points & Authorities; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Declaration OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANTS? MOTION TO COMPEL PLAINTIFF MARIE MOR?S VERIFIED RESPONSES TO DISCOVERY; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Proof of Service (not Summons and Complaint); Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Motion for Protective Order; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Proof of Service by Mail; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); As to: VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent)

Updated -- Ex Parte Application to Advance Plaintiff's Motion for Trial Preference: Filed By: Marie Mor (Petitioner),Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Result: Granted; Result Date:

Memorandum of Points & Authorities; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Separate Statement; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Motion in Limine NO. 9 TO PRECLUDE ARGUMENT OF ALLEGED ?PROFIT OVER PATIENT CARE? AND PRECLUSION OF FINANCIAL STATEMENTS; DECLARATION OF HEATHER-ANN T. YOUNG; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Declaration DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF EX PARTE APPLICATION FOR SHORTENING TIME TO HEAR DEFENDANTS? MOTION TO COMPEL PLAINTIFF MARIE MOR?S VERIFIED RESPONSES TO DISCOVERY; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Motion to Compel PLAINTIFF MARIE MOR?S VERIFIED RESPONSES TO DISCOVERY; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Motion in Limine NO. 1 TO PRECLUDE REFERENCES TO INVESTIGATIONS OR COMPLAINTS TO CALIFORNIA DEPARTMENT OF PUBLIC HEALTH, STATE OF CALIFORNIA MEDICAL BOARD, THE CALIFORNIA BOARD OF NURSING, OR OTHER STATE AGENCY, INCLUDING CENTERS FOR MEDICARE; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Memorandum of Points & Authorities; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Motion in Limine NO. 10 TO PRECLUDE FROM REFERRING TO PLAINTIFFS OR DECEDENTS AS A VICTIM OR ANY OTHER INFLAMMATORY NOUN; DECLARATION OF HEATHER-ANN T. YOUNG; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Declaration DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF EX PARTE APPLICATION FOR ORDER SHORTENING TIME TO HEAR DEFENDANTS? MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Motion in Limine NO. 15 REQUESTING USE OF ATTACHED JURY QUESTIONNAIRE; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Motion in Limine NO. 13 TO PRECLUDE TESTIMONY RE: MEDICAL TEXT AND PUBLICATIONS; DECLARATION OF HEATHER-ANN T. YOUNG; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Updated -- Application And Order For Appointment of Guardian Ad Litem Marie: Filed By: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner),Marie Mor (Petitioner); Result: Granted; Result Date:

Opposition PLAINTIFFS'OMBINED OPPOSITION TO DEFENDANTS'X PARTE APPLICATIONS FOR AN ORDER SHORTENING TIME FOR THK HEARING ON DEFENDANTS'OTIONS; DECLARATION OF PHILIP J. SPINAZZK IN SUPPORT THEREOF; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Declaration DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF EX PARTE APPLICATION FOR SHORTENING TIME TO HEAR DEFENDANTS? MOTION TO COMPEL FURTHER RESPONSES FROM PLAINTIFF MARIE MOR TO REQUEST FOR ADMISSIONS, SET ONE, NOS. 3 AND 4; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Motion in Limine NO. 17 REQUESTING 48 HOUR ADVANCE NOTICE TO WITNESSES; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Declaration OF HEATHER-ANN T. YOUNG IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES FROM PLAINTIFF MARIE MOR TO REQUEST FOR ADMISSION, SET ONE, NOS. 3 AND 4; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Motion in Limine NO. 5 TO EXCLUDE OR LIMIT AS EVIDENCE PLAINTIFF MARIE MOR?S CLAIM OF LOSS OF INCOME; DECLARATION OF HEATHER-ANN T. YOUNG; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Motion in Limine NO. 12 TO LIMIT EXPERTS TO OPINIONS EXPRESSED AT THEIR DEPOSITIONS; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Motion in Limine NO. 7 TO RESTRICT EXPERT TESTIMONY ON UNSUPPORTED ALLEGATIONS OF UNDERSTAFFING; DECLARATION OF HEATHER-ANN T. YOUNG; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Declaration DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF EX PARTE APPLICATION FOR SHORTENING TIME TO HEAR DEFENDANTS? MOTION TO COMPEL PLAINTIFF MARIE MOR?S RESPONSES TO SPECIAL INTERROGATORIES, SET ONE, NOS. 101 AND 103; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Motion to Compel Deposition of Joshua Kauffman; Filed by: Marie Mor (Petitioner); As to: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Motion to Trifurcate; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Motion in Limine NO. 2 TO PRECLUDE MICHELE MOR FROM TESTIFYING ON BEHALF OF MARIE MOR AS HER GUARDIAN AD LITEM AND ANSWERING HYPOTHETICAL QUESTIONS REGARDING CARE; DECLARATION OF HEATHER-ANN T. YOUNG; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Motion to Compel PLAINTIFF MARIE MOR?S RESPONSES TO SPECIAL INTERROGATORIES, SET ONE, NOS. 101 AND 103; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Motion in Limine NO. 14 TO PRECLUDE EXPERTS FROM OPINING THE DECEDENT?S CARE WAS RECKLESS OR THE LIKE; DECLARATION OF HEATHER-ANN T. YOUNG; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Motion in Limine NO. 4 TO PRECLUDE PLAINTIFFS? EVIDENCE OF INJURIES TO OTHER INDIVIDUALS; DECLARATION OF HEATHER-ANN T. YOUNG; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Motion in Limine NO. 16 REQUESTING PRODUCTION OF DEMONSTRATIVE EVIDENCE; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Declaration OF HEATHER-ANN T. YOUNG IN SUPPORT OF MOTION TO COMPEL PLAINTIFF MARIE MOR?S RESPONSES TO SPECIAL INTERROGATORIES, SET ONE, NOS. 101 AND 103; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Motion to Compel FURTHER RESPONSES FROM PLAINTIFF MARIE MOR TO REQUEST FOR ADMISSION, SET ONE, NOS. 3 AND 4; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Motion in Limine NO. 8 TO PRECLUDE PRIOR LITIGATION DECISIONS RE DEFENDANT; DECLARATION OF HEATHER-ANN T. YOUNG; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Motion in Limine NO. 6 PRECLUDING PLAINTIFFS FROM ASKING WITNESSES ABOUT THEIR OPINIONS AND CONCLUSIONS OF THE LAW; DECLARATION OF HEATHER-ANN T. YOUNG; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Declaration DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF EX PARTE APPLICATION FOR SHORTENING TIME TO HEAR DEFENDANTS? MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION OF SHLOMO RECHNITZ; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Motion in Limine NO. 11 LIMITING NON-RETAINED EXPERT WITNESS TESTIMONY; DECLARATION OF HEATHER-ANN T. YOUNG; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Jury Instructions; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Updated -- Ex Parte Application for Order shortening time to hear Defendants' Motion to Compel Deposition of Plaintiff Marie Mor: Filed By: VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent),SHLOMO RECHNITZ (Respondent),BRIUS MANAGEMENT CO., INC. (Respondent),ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent),Montrose Springs Skilled Nursing & Wellness Center (Respondent); Result: Granted; Result Date:

Exhibit List; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Notice OF TAKING MOTION TO COMPEL PLAINTIFF MARIE MOR?S RESPONSES TO SPECIAL INTERROGATORIES, SET ONE, NOS. 101 AND 103 OFF CALENDAR; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent); As to: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Updated -- Ex Parte Application for Order Shortening Time to Hear Defendants' Motion for Protective Order Precluding the Deposition of Shlomo Rechnitz: Filed By: ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent),VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent),Montrose Springs Skilled Nursing & Wellness Center (Respondent),BRIUS MANAGEMENT CO., INC. (Respondent),SHLOMO RECHNITZ (Respondent); Result: Denied; Result Date: ; As To Parties changed from Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner) to Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Updated -- Ex Parte Application for Order Shortening Time to hear Defendants' Motion to Compel Deposition of Plaintiff Marie Mor: Filed By: ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent),VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent),SHLOMO RECHNITZ (Respondent),Montrose Springs Skilled Nursing & Wellness Center (Respondent),BRIUS MANAGEMENT CO., INC. (Respondent); Result: Denied; Result Date: ; As To Parties changed from Marie Mor (Petitioner), Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner) to Marie Mor (Petitioner), Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Updated -- Ex Parte Application for Order Advancing the Hearing Dates of Plaintiffs Motions to Compel: Filed By: Marie Mor (Petitioner),Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Result: Granted; Result Date:

Updated -- Ex Parte Application for Order Shortening Time to Hear Defendants' Motion to Compel Plaintiff Marie Mor's Responses to Special Interrogatories, Set One, Nos. 101 AND 103: Filed By: SHLOMO RECHNITZ (Respondent),VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent),Montrose Springs Skilled Nursing & Wellness Center (Respondent),BRIUS MANAGEMENT CO., INC. (Respondent),ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); Result: Denied; Result Date: ; As To Parties changed from Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner), Marie Mor (Petitioner) to Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner), Marie Mor (Petitioner)

Declaration DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF EX PARTE APPLICATION FOR ORDER SHORTENING TIME TO HEAR DEFENDANTS? MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Updated -- Ex Parte Application for Order to specifically set hearing date for P's Motion to Compel Deposition: Filed By: Marie Mor (Petitioner); Result: Denied; Result Date: ; As To Parties changed from Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner) to Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Motion in Limine NO. 3 TO EXCLUDE LAY WITNESS OPINION AT TRIAL; DECLARATION OF HEATHER-ANN T. YOUNG; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Motion to Compel Further Discovery Responses; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); As to: SHLOMO RECHNITZ (Respondent)

Motion to Compel Further Discovery Responses; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); As to: ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent)

Updated -- Motion for Protective Order Precluding the Deposition of Steven Stroll: Filed By: BRIUS MANAGEMENT CO., INC. (Respondent),VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent),Montrose Springs Skilled Nursing & Wellness Center (Respondent),ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent),SHLOMO RECHNITZ (Respondent); Result: Granted; Result Date:

Motion to Compel Further Discovery Responses; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); As to: VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent)

Opposition DEFENDANT SHLOMO RECHNITZ?S OPPOSITION TO PLAINTIFF?S MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE; REQUEST FOR MONETARY SANCTIONS IN THE AMOUNT OF $2,500.00; Filed by: SHLOMO RECHNITZ (Respondent)

Separate Statement; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Updated -- Ex Parte Application for Order Shortening time to hear Defendants' Motion to Compel Further Responses from Plaintiff Marie Mor to Request for Admissions, Set One, Nos. 3 and 4: Filed By: VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent),Montrose Springs Skilled Nursing & Wellness Center (Respondent),ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent),BRIUS MANAGEMENT CO., INC. (Respondent),SHLOMO RECHNITZ (Respondent); Result: Denied; Result Date: ; As To Parties changed from Marie Mor (Petitioner), Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner) to Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner), Marie Mor (Petitioner)

Notice OF TAKING MOTION TO COMPEL FURTHER RESPONSES FROM PLAINTIFF MARIE MOR TO REQUEST FOR ADMISSION, SET ONE, NOS. 3 AND 4 OFF CALENDAR; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent); As to: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Updated -- Ex Parte Application for Order Shortening Time to hear Defendants' Motion to Compel Plaintiff Marie Mor's Verified Responses to Discovery: Filed By: Montrose Springs Skilled Nursing & Wellness Center (Respondent),BRIUS MANAGEMENT CO., INC. (Respondent),ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent),VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent),SHLOMO RECHNITZ (Respondent); Result: Denied; Result Date: ; As To Parties changed from Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner), Marie Mor (Petitioner) to Marie Mor (Petitioner), Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Memorandum of Points & Authorities; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Notice DEFENDANTS? NOTICE OF TAKING MOTION TO COMPEL PLAINTIFF MARIE MOR?S VERIFIED RESPONSES TO DISCOVERY OFF CALENDAR; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent); As to: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Trial Brief; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Witness List; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Opposition [Plaintiffs'] to Defendants' Motion in Limine No. 3; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Declaration OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANT?S OPPOSITION TO PLAINTIFF?S MOTION TO COMPEL RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE; Filed by: SHLOMO RECHNITZ (Respondent)

Opposition (P's) to D's App to Continue Trial; Filed by: Marie Mor (Petitioner)

Opposition [Plaintiffs'] to Defendants' Motion in Limine No. 1; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Statement of the Case; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Opposition PLAINTIFFS? OPPOSITION TO DEFENDANTS? MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION OF SHLOMO RECHNITZ; REQUEST FOR MONETARY SANCTIONS IN THE AMOUNT OF $5,250.00; DECLARATION OF LISA TRINH FLINT, ESQ. Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Notice (of Case Management Conference)

Case Management Statement

Answer

Notice (Notice of CMC)

Proof of Service (not Summons and Complaint)

Minute Order ( (Hearing on Ex Parte Application for Order to Advance Plainti...))

Motion for Trial Preference

Ex Parte Application (to Advance Plaintiff's Motion for Trial Preference)

Opposition (OPPOSITION TO PLAINTIFFS? EX PARTE APPLICATION FOR AN ORDER TO ADVANCE THE DATE OF PLAINTIFFS? MOTION FOR PREFERENCE)

Order (re Ex Parte Application for Order to Advance Plaintiff's Motion for Trial Preference)

Notice of Ruling

Case Management Statement

Reply (to Opposition to Plaintiff's Motion for Trial Prefernece Pursuant to C.C.P. Section 36(a); Declaration of Lisa Trinh Flint, Esq.)

Notice of Posting of Jury Fees

Request for Judicial Notice

Declaration (of IHB)

Opposition (to Motion)

Minute Order ( (Case Management Conference; Hearing on Motion for Trial Prefe...))

Motion for Protective Order (Precluding the Deposition of Steven Stroll)

Declaration (OF I. HOOSHIE BROOMAND IN SUPPORT OF DEFENDANTS? MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION OF STEVEN STROLL)

Memorandum of Points & Authorities

Declaration (OF STEVEN STROLL IN SUPPORT OF DEFENDANTS? MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION OF STEVEN STROLL)

Ex Parte Application (for order shortening time to hear Defendants' Motion for Protective Order)

Minute Order ((Hearing on Ex Parte Application FOR ORDER SHORTENING TIME TO ...))

Declaration (DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF EX PARTE APPLICATION FOR ODER SHORTENING TIME TO HEAR DEFENDANTS? MOTION FOR PROTECTIVE ORDER)

Memorandum of Points & Authorities

Memorandum of Points & Authorities

Declaration (OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANTS? MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR)

Application And Order For Appointment of Guardian Ad Litem (Marie)

Motion to Compel (DEPOSITION OF PLAINTIFF MARIE MOR)

Motion in Limine (NO. 5 TO EXCLUDE OR LIMIT AS EVIDENCE PLAINTIFF MARIE MOR?S CLAIM OF LOSS OF INCOME; DECLARATION OF HEATHER-ANN T. YOUNG)

Ex Parte Application (for Order to specifically set hearing date for P's Motion to Compel Deposition)

Motion in Limine (NO. 17 REQUESTING 48 HOUR ADVANCE NOTICE TO WITNESSES)

Motion in Limine (NO. 3 TO EXCLUDE LAY WITNESS OPINION AT TRIAL; DECLARATION OF HEATHER-ANN T. YOUNG)

Motion in Limine (NO. 13 TO PRECLUDE TESTIMONY RE: MEDICAL TEXT AND PUBLICATIONS; DECLARATION OF HEATHER-ANN T. YOUNG)

Motion in Limine (NO. 14 TO PRECLUDE EXPERTS FROM OPINING THE DECEDENT?S CARE WAS RECKLESS OR THE LIKE; DECLARATION OF HEATHER-ANN T. YOUNG)

Motion in Limine (NO. 15 REQUESTING USE OF ATTACHED JURY QUESTIONNAIRE)

Motion in Limine (NO. 12 TO LIMIT EXPERTS TO OPINIONS EXPRESSED AT THEIR DEPOSITIONS)

Motion in Limine (NO. 16 REQUESTING PRODUCTION OF DEMONSTRATIVE EVIDENCE)

Motion in Limine (NO. 10 TO PRECLUDE FROM REFERRING TO PLAINTIFFS OR DECEDENTS AS A VICTIM OR ANY OTHER INFLAMMATORY NOUN; DECLARATION OF HEATHER-ANN T. YOUNG)

Motion in Limine (NO. 11 LIMITING NON-RETAINED EXPERT WITNESS TESTIMONY; DECLARATION OF HEATHER-ANN T. YOUNG)

Minute Order ( (Hearing on Ex Parte Application FOR ORDER TO SPECIFICALLY SET...))

Informal Discovery Conference

Minute Order ( (Hearing on Motion for Protective Order))

Informal Discovery Conference

Minute Order ( (Informal Discovery Conference (IDC); Hearing on Ex Parte Appl...))

Motion to Compel Further Discovery Responses (to Request for Production of Documents, Set One, from Defendant, Rockport Administrative Services, LLC; Request for Monetary Sanctions in the amount of $2,500.00)

Motion to Compel Further Discovery Responses (to Request for Production of Documents, Set One, from Defendant, Shlomo Rechnitz; Request for Monetary Sanctions in the amount of $2,500.00)

Ex Parte Application (for Order Advancing the Hearing Dates of Plaintiffs Motions to Compel)

Declaration (DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF EX PARTE APPLICATION FOR ORDER SHORTENING TIME TO HEAR DEFENDANTS? MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR)

Ex Parte Application (for Order shortening time to hear Defendants' Motion to Compel Deposition of Plaintiff Marie Mor)

Witness List

Statement of the Case

Motion to Compel Further Discovery Responses (to Special Interrogatories, Set One, from Defendant, Verdugo Valley Skilled Nursing & Wellness Centre, LLC dba Montrose Springs Skilled Nursing & Wellness Centre; Request for Monetary Sanctions in the amount of $2,500.00)

Exhibit List

Jury Instructions

Notice (OF TAKING MOTION TO COMPEL PLAINTIFF MARIE MOR?S RESPONSES TO SPECIAL INTERROGATORIES, SET ONE, NOS. 101 AND 103 OFF CALENDAR)

Memorandum of Points & Authorities

Minute Order ( (Hearing on Ex Parte Application Plaintiffs' Ex Parte Applicat...))

Notice (OF TAKING MOTION TO COMPEL FURTHER RESPONSES FROM PLAINTIFF MARIE MOR TO REQUEST FOR ADMISSION, SET ONE, NOS. 3 AND 4 OFF CALENDAR)

Notice (DEFENDANTS? NOTICE OF TAKING MOTION TO COMPEL PLAINTIFF MARIE MOR?S VERIFIED RESPONSES TO DISCOVERY OFF CALENDAR)

Declaration (OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANT?S OPPOSITION TO PLAINTIFF?S MOTION TO COMPEL RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE)

Opposition (DEFENDANT VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC?S OPPOSITION TO PLAINTIFF?S MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET ONE; REQUEST FOR MONETARY SANCTIONS IN THE AMOUNT OF $2,500.00)

Response (DEFENDANT VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC dba MONTROSE SPRINGS?S RESPONSE TO PLAINTIFF JEFFREY MOR?S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET ONE, NOS 32, 63, 70, 71, 120 AN)

Opposition (DEFENDANT ROCKPORT ADMINISTRATIVE SERVICES, LLC?S OPPOSITION TO PLAINTIFF?S MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE; REQUEST FOR MONETARY SANCTIONS IN THE AMOUNT OF $2,500.00)

Opposition (DEFENDANT SHLOMO RECHNITZ?S OPPOSITION TO PLAINTIFF?S MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE; REQUEST FOR MONETARY SANCTIONS IN THE AMOUNT OF $2,500.00)

Response (DEFENDANT SHLOMO RECHNITZ?S RESPONSE TO PLAINTIFF JEFFREY MOR?S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, NOS 9-11 AND 18-20)

Declaration (OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANT?S OPPOSITION TO PLAINTIFF?S MOTION TO COMPEL FURTHER RESPONSES TO SPECIAL INTERROGATORIES, SET ONE)

Request for Judicial Notice

Declaration (DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANT?S OPPOSITION TO PLAINTIFFS? MOTION TO COMPEL RESPONSE TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE)

Response (DEFENDANT ROCKPORT ADMINISTRATIVE SERVICES, LLC?S RESPONSE TO PLAINTIFF JEFFREY MOR?S SEPARATE STATEMENT IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES TO REQUEST FOR PRODUCTION OF DOCUMENTS, SET ONE, NOS 14-15, 21, 46, 49-50 AND 54-62)

Opposition (PLAINTIFFS? OPPOSITION TO DEFENDANTS? MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION OF SHLOMO RECHNITZ; REQUEST FOR MONETARY SANCTIONS IN THE AMOUNT OF $5,250.00; DECLARATION OF LISA TRINH FLINT, ESQ.)

Reply (IN SUPPORT OF DEFENDANTS? MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION OF SHLOMO RECHNITZ)

Opposition (PLAINTIFFS' OPPOSITION TO DEFENDANTS' MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR; DECLARATION OF ALESSANDRA HORII, ESQ.)

Declaration (OF SHLOMO RECHNITZ IN SUPPORT OF DEFENDANTS' REPLY RE: MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION SHLOMO RECHNITZ)

Reply (to Defendant's Opposition to Plaintiff's Motion to Compel Further Responses to Request for Production of Documents, Set One, from Defendant Shlomo Rechnitz)

Reply (to Defendant's Opposition to Plaintiff's Motion to Compel Further Responses to Request for Production of Documents, Set One, from Defendant Rockport Administrative Services, LLC)

Declaration (OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANTS? REPLY TO MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR)

Reply (IN SUPPORT OF DEFENDANTS? MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR)

Reply (Plaintiff's Reply to Defendant's Opposition to Plaintiff's Motion to Compel Further Responses to Special Interrogatories, Set One, from Defendant Verdugo Valley Skilled Nursing & Wellness Centre, LLC)

Minute Order ( (Hearing on Motion for Protective Order; Hearing on Motion to ...))

Certificate of Mailing for ((Hearing on Motion for Protective Order; Hearing on Motion to ...) of 12/15/2020)

Opposition (Plaintiffs' Opposition to Defendants' Ex Parte Application Regarding the Deposition of Genevieve Bautista)

Ex Parte Application (DEFENDANTS? EX PARTE APPLICATION FOR ______________ REGARDING THE DEPOSITION OF GENEVIEVE BAUTISTA; DECLARATION OF HEATHER-ANN T. YOUNG)

Motion to Quash (Deposition Subpoena to Genevieve Bautista)

Minute Order ( (Hearing on Ex Parte Application FOR _______ REGARDING THE DEP...))

Declaration (OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANTS? MOTION TO QUASH DEPOSITION SUBPOENA TO GENEVIEVE BAUTISTA)

Motion for Attorney Fees

Notice of Ruling

Memorandum of Costs (Summary)

Opposition (P's Supplemental Opposition)

Notice (DEFENDANTS? NOTICE OF TAKING MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR OFF CALENDAR)

Ex Parte Application (to Advance Motion to Quash)

Trial Brief

Trial Brief

Minute Order ((Hearing on Ex Parte Application Ex Part Application to Advanc...))

Minute Order ( (Final Status Conference))

Opposition (Plaintiffs' Opposition to Defendants' Motion to Quash Deposition Subpoena to Genevieve Bautista)

Stipulation and Order (to specially set hearing date for Plaintiffs' Motion to Quash Defendants' Deposition Subpoena for personal appearance to Terri Hansen, RN)

Declaration (DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANTS? OPPOSITION TO PLAINTIFFS? MOTION TO QUASH DEFENDANTS? DEPOSITION SUBPOENA FOR PERSONAL APPEARANCE AND AMENDED NOTICE OF TAKING DEPOSITION OF NON-RETAINED EXPERT TERRI HANSEN, RN)

Opposition (DEFENDANTS? OPPOSITION TO PLAINTIFFS? MOTION TO QUASH DEFENDANTS? DEPOSITION SUBPOENA FOR PERSONAL APPEARANCE AND AMENDED NOTICE OF TAKING DEPOSITION OF NON-RETAINED EXPERT TERRI HANSEN, RN)

Ex Parte Application (for Order continuing Final Status Conference and Trial)

Certificate of Mailing for ((Court Order re Advancing Motion to Quash) of 01/19/2021)

Reply (P's Reply to D's Opp)

Minute Order ((Court Order re Advancing Motion to Quash))

Declaration (DECLARATION OF I. HOOSHIE BROOMAND IN SUPPORT OF DEFENDANTS? EX PARTE APPLICATION FOR ORDER CONTINUING FINAL STATUS CONFERENCE AND TRIAL)

Notice (OF ENTRY OF ORDER)

Reply (IN SUPPORT OF DEFENDANTS? MOTION TO QUASH DEPOSITION SUBPOENA TO GENEVIEVE BAUTISTA)

Memorandum of Points & Authorities

Opposition ((P's) to D's App to Continue Trial)

Minute Order ( (Hearing on Motion to Quash Deposition Subpoena to Genevieve B...))

Minute Order ( (Hearing on Ex Parte Application FOR ORDER CONTINUING FINAL ST...))

Witness List (JOINT)

Exhibit List (JOINT)

Jury Instructions (JOINT)

Minute Order ( (Final Status Conference))

Statement of the Case ([PROPOSED] JOINT STATEMENT OF CASE)

Opposition ([Plaintiffs'] to Defendants' Motion in Limine No. 16)

Opposition ([Plaintiffs]' to Defendants' Motion in Limine No. 17)

Opposition ([Plaintiffs'] to Defendants' Motion in Limine No. 1)

Opposition ([Plaintiffs'] to Defendants' Motion in Limine No. 7)

Opposition ([Plaintiffs'] to Defendants' Motion in Limine No. 4)

Opposition ([Plaintiffs'] to Defendants' Motion in Limine No. 5)

Opposition ([Plaintiffs'] to Defendants' Motion in Limine No. 3)

Opposition ([Plaintiffs'] to Defendants' Motion in Limine No. 10)

Opposition ([Plaintiffs'] to Defendants' Motion in Limine No. 2)

Opposition ([Plaintiffs'] to Defendants' Motion in Limine No. 9)

Minute Order ( (Final Status Conference))

Minute Order ( (Final Status Conference))

Notice (of Continuance of Plaintiffs' Motion for Attorney's Fees and Costs)

Opposition ([Plaintiffs'] to Defendants' Motion in Limine No. 13)

Notice Re: Continuance of Hearing and Order

Opposition ([Plaintiffs'] to Defendants' Motion in Limine No. 12)

Minute Order ( (Final Status Conference))

Opposition ([Plaintiffs'] to Defendants' Motion in Limine No. 6)

Minute Order ( (Final Status Conference))

Opposition ([Plaintiffs'] to Defendants' Motion in Limine No. 14)

Minute Order ( (Hearing on Ex Parte Application for an Order to Enforce the ...))

Minute Order ( (Court Order re Notice of Settlement))

Notice of Settlement

Declaration (DECLARATION OF I. HOOSHIE BROOMAND IN SUPPORT OF OPPOSITION TO PLAINTIFFS? EX PARTE APPLICATION FOR AN ORDER TO ENFORCE THE SETTLEMENT UNDER CALIFORNIA CODE OF CIVIL PROCEDURE ¿ 664.6 PURSUANT TO THE EXECUTED RELEASE)

Ex Parte Application (for an Order to Enforce the Settlement under CCP 664.6 Pursuant to the Executed Release)

Opposition (OPPOSITION TO PLAINTIFFS EX PARTE APPLICATION FOR AN ORDER TO ENFORCE THE SETTLEMENT UNDER CALIFORNIA CODE OF CIVIL PROCEDURE 664.6 PURSUANT TO THE EXECUTED RELEASE)

Certificate of Mailing for ((Court Order re Notice of Settlement) of 04/14/2021)

Notice (Notice of Order to Show Cause re Dismissal)

Ex Parte Application (for order shortening time to hear Defendants' Motion for Protective Order) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Ex Parte Application (for Order Shortening Time to hear Defendants' Motion to Compel Plaintiff Marie Mor's Verified Responses to Discovery) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Declaration (DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF EX PARTE APPLICATION FOR SHORTENING TIME TO HEAR DEFENDANTS? MOTION TO COMPEL FURTHER RESPONSES FROM PLAINTIFF MARIE MOR TO REQUEST FOR ADMISSIONS, SET ONE, NOS. 3 AND 4) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Motion in Limine (NO. 16 REQUESTING PRODUCTION OF DEMONSTRATIVE EVIDENCE) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Motion to Compel (DEPOSITION OF PLAINTIFF MARIE MOR) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Summons (on Petition) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Declaration (OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANTS? MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Memorandum of Points & Authorities Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Minute Order ( (Informal Discovery Conference (IDC); Hearing on Ex Parte Appl...)) Filed by Clerk

On the Petition filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck, et al. on , entered Request for Dismissal without prejudice filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck and Marie Mor as to the entire action

Motion to Compel (FURTHER RESPONSES FROM PLAINTIFF MARIE MOR TO REQUEST FOR ADMISSION, SET ONE, NOS. 3 AND 4) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Declaration DECLARATION OF I. HOOSHIE BROOMAND IN SUPPORT OF OPPOSITION TO PLAINTIFFS? EX PARTE APPLICATION FOR AN ORDER TO ENFORCE THE SETTLEMENT UNDER CALIFORNIA CODE OF CIVIL PROCEDURE ¿ 664.6 PURSUANT TO THE EXECUTED RELEASE; Filed by: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent); ROCKPORT ADMINISTRATIVE SERVICES, LLC (Respondent); SHLOMO RECHNITZ (Respondent)

Motion to Trifurcate Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Minute Order ( (Hearing on Ex Parte Application for Order to Advance Plainti...)) Filed by Clerk

Proof of Mailing (Substituted Service) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Declaration (OF I. HOOSHIE BROOMAND IN SUPPORT OF DEFENDANTS? MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION OF STEVEN STROLL) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Minute Order ( (Hearing on Ex Parte Application FOR ORDER SHORTENING TIME TO ...)) Filed by Clerk

Declaration (DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF EX PARTE APPLICATION FOR ORDER SHORTENING TIME TO HEAR DEFENDANTS? MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Proof of Personal Service Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner)

Ex Parte Application for an Order to Enforce the Settlement under CCP 664.6 Pursuant to the Executed Release; Filed by: Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner); As to: Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Minute Order ( (Hearing on Ex Parte Application FOR ORDER TO SPECIFICALLY SET...)) Filed by Clerk

Reply (to Opposition to Plaintiff's Motion for Trial Prefernece Pursuant to C.C.P. Section 36(a); Declaration of Lisa Trinh Flint, Esq.) Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Memorandum of Points & Authorities Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Memorandum of Points & Authorities Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Request for Judicial Notice Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Motion in Limine (NO. 15 REQUESTING USE OF ATTACHED JURY QUESTIONNAIRE) Filed by Montrose Springs Skilled Nursing & Wellness Center (Respondent); VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC (Respondent); BRIUS MANAGEMENT CO., INC. (Respondent) et al.

Proof of Service by Substituted Service Filed by Jeffrey Mor, in and through his Successor-in-Interest, Jeffrey S.Reisbeck (Petitioner); Marie Mor (Petitioner)

Motion to Compel (Deposition of Joshua Kauffman) Filed by Marie Mor (Petitioner)

Memorandum of Points & Authorities

Declaration (OF HEATHER-ANN T. YOUNG IN SUPPORT OF MOTION TO COMPEL FURTHER RESPONSES FROM PLAINTIFF MARIE MOR TO REQUEST FOR ADMISSION, SET ONE, NOS. 3 AND 4)

Declaration (OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANTS? MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION OF SHLOMO RECHNITZ)

Motion to Compel (FURTHER RESPONSES FROM PLAINTIFF MARIE MOR TO REQUEST FOR ADMISSION, SET ONE, NOS. 3 AND 4)

Declaration (OF HEATHER-ANN T. YOUNG IN SUPPORT OF MOTION TO COMPEL PLAINTIFF MARIE MOR?S RESPONSES TO SPECIAL INTERROGATORIES, SET ONE, NOS. 101 AND 103)

Motion for Protective Order

Declaration (OF SHLOMO RECHNITZ IN SUPPORT OF DEFENDANTS? MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION SHLOMO RECHNITZ)

Memorandum of Points & Authorities

Declaration (OF HEATHER-ANN T. YOUNG IN SUPPORT OF DEFENDANTS? MOTION TO COMPEL PLAINTIFF MARIE MOR?S VERIFIED RESPONSES TO DISCOVERY)

Motion to Compel (PLAINTIFF MARIE MOR?S VERIFIED RESPONSES TO DISCOVERY)

Motion to Compel (PLAINTIFF MARIE MOR?S RESPONSES TO SPECIAL INTERROGATORIES, SET ONE, NOS. 101 AND 103)

Declaration (DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF EX PARTE APPLICATION FOR SHORTENING TIME TO HEAR DEFENDANTS? MOTION TO COMPEL FURTHER RESPONSES FROM PLAINTIFF MARIE MOR TO REQUEST FOR ADMISSIONS, SET ONE, NOS. 3 AND 4)

Motion to Trifurcate

Declaration (DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF EX PARTE APPLICATION FOR SHORTENING TIME TO HEAR DEFENDANTS? MOTION TO COMPEL PLAINTIFF MARIE MOR?S RESPONSES TO SPECIAL INTERROGATORIES, SET ONE, NOS. 101 AND 103)

Declaration (DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF EX PARTE APPLICATION FOR SHORTENING TIME TO HEAR DEFENDANTS? MOTION TO COMPEL PLAINTIFF MARIE MOR?S VERIFIED RESPONSES TO DISCOVERY)

Ex Parte Application (for Order Shortening Time to Hear Defendants' Motion to Compel Plaintiff Marie Mor's Responses to Special Interrogatories, Set One, Nos. 101 AND 103)

Ex Parte Application (for Order Shortening Time to Hear Defendants' Motion for Protective Order Precluding the Deposition of Shlomo Rechnitz)

Ex Parte Application (for Order Shortening time to hear Defendants' Motion to Compel Further Responses from Plaintiff Marie Mor to Request for Admissions, Set One, Nos. 3 and 4)

Ex Parte Application (for Order Shortening Time to hear Defendants' Motion to Compel Plaintiff Marie Mor's Verified Responses to Discovery)

Declaration (DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF EX PARTE APPLICATION FOR ORDER SHORTENING TIME TO HEAR DEFENDANTS? MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR)

Declaration (DECLARATION OF HEATHER-ANN T. YOUNG IN SUPPORT OF EX PARTE APPLICATION FOR SHORTENING TIME TO HEAR DEFENDANTS? MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION OF SHLOMO RECHNITZ)

Ex Parte Application (for Order Shortening Time to hear Defendants' Motion to Compel Deposition of Plaintiff Marie Mor)

Minute Order ( (Hearing on Ex Parte Application FOR ORDER SHORTENING TIME TO ...))

Opposition (PLAINTIFFS'OMBINED OPPOSITION TO DEFENDANTS'X PARTE APPLICATIONS FOR AN ORDER SHORTENING TIME FOR THK HEARING ON DEFENDANTS'OTIONS; DECLARATION OF PHILIP J. SPINAZZK IN SUPPORT THEREOF)

Motion in Limine (NO. 9 TO PRECLUDE ARGUMENT OF ALLEGED ?PROFIT OVER PATIENT CARE? AND PRECLUSION OF FINANCIAL STATEMENTS; DECLARATION OF HEATHER-ANN T. YOUNG)

Motion in Limine (NO. 6 PRECLUDING PLAINTIFFS FROM ASKING WITNESSES ABOUT THEIR OPINIONS AND CONCLUSIONS OF THE LAW; DECLARATION OF HEATHER-ANN T. YOUNG)

Motion in Limine (NO. 1 TO PRECLUDE REFERENCES TO INVESTIGATIONS OR COMPLAINTS TO CALIFORNIA DEPARTMENT OF PUBLIC HEALTH, STATE OF CALIFORNIA MEDICAL BOARD, THE CALIFORNIA BOARD OF NURSING, OR OTHER STATE AGENCY, INCLUDING CENTERS FOR MEDICARE)

Motion in Limine (NO. 2 TO PRECLUDE MICHELE MOR FROM TESTIFYING ON BEHALF OF MARIE MOR AS HER GUARDIAN AD LITEM AND ANSWERING HYPOTHETICAL QUESTIONS REGARDING CARE; DECLARATION OF HEATHER-ANN T. YOUNG)

Motion in Limine (NO. 8 TO PRECLUDE PRIOR LITIGATION DECISIONS RE DEFENDANT; DECLARATION OF HEATHER-ANN T. YOUNG)

Motion in Limine (NO. 7 TO RESTRICT EXPERT TESTIMONY ON UNSUPPORTED ALLEGATIONS OF UNDERSTAFFING; DECLARATION OF HEATHER-ANN T. YOUNG)

Motion in Limine (NO. 4 TO PRECLUDE PLAINTIFFS? EVIDENCE OF INJURIES TO OTHER INDIVIDUALS; DECLARATION OF HEATHER-ANN T. YOUNG)

Motion to Compel (Deposition of Joshua Kauffman)

Motion to Quash (Deposition Subpoena)

Ex Parte Application (DEFENDANTS? EX PARTE APPLICATION FOR ORDER CONTINUING FINAL STATUS CONFERENCE AND TRIAL)

Ex Parte Application (Ex Part Application to Advance Motion to Quash)

Notice and Acknowledgment of Receipt

Proof of Service by Mail

Separate Statement

Memorandum of Points & Authorities

Ex Parte Application (Plaintiffs' Ex Parte Application for Order Advancing the Hearing Dates of Plaintiffs Motions to Compel)

Ex Parte Application (EX PARTE APPLICATION FOR ORDER SHORTENING TIME TO HEAR DEFENDANTS? MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR)

Ex Parte Application (EX PARTE APPLICATION FOR ORDER TO SPECIFICALLY SET HEARING DATE FOR P'S MOTION TO COMPEL DEPOSITION)

Minute Order ( (Hearing on Ex Parte Application FOR ORDER SHORTENING TIME TO ...))

Ex Parte Application (EX PARTE APPLICATION FOR ORDER SHORTENING TIME TO HEAR DEFENDANTS? MOTION FOR PROTECTIVE ORDER PRECLUDING THE DEPOSITION OF SHLOMO RECHNITZ)

Ex Parte Application (EX PARTE APPLICATION FOR ORDER SHORTENING TIME TO HEAR DEFENDANTS? MOTION TO COMPEL PLAINTIFF MARIE MOR?S RESPONSES TO SPECIAL INTERROGATORIES, SET ONE, NOS. 101 AND 103)

Ex Parte Application (EX PARTE APPLICATION FOR ORDER SHORTENING TIME TO HEAR DEFENDANTS? MOTION TO COMPEL PLAINTIFF MARIE MOR?S VERIFIED RESPONSES TO DISCOVERY)

Ex Parte Application (EX PARTE APPLICATION FOR ORDER SHORTENING TIME TO HEAR DEFENDANTS? MOTION TO COMPEL FURTHER RESPONSES FROM PLAINTIFF MARIE MOR TO REQUEST FOR ADMISSIONS, SET ONE, NOS. 3 AND 4)

Ex Parte Application (EX PARTE APPLICATION FOR ORDER SHORTENING TIME TO HEAR DEFENDANTS? MOTION TO COMPEL DEPOSITION OF PLAINTIFF MARIE MOR)