On February 23, 2021 a
Court Notice
was filed
involving a dispute between
Nutt, Henry,
Nutt, Kevin,
Nutt, Lola,
Nutt, Tyrone,
Nutt, Vashon,
and
Asfc, Llc,
Aspen Skilled Healthcare, Inc.,
Irwin-Singh, D.O., Crystal,
Saint Agnes Medical Center,
for 23 Unlimited - Other PI/PD/WD
in the District Court of Fresno County.
Preview
Gregory L. Johnson, 177889
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Joanna A. Hutchins, 307058
2 JOHNSON MOORE
100 E. Thousand Oaks Boulevard, Suite 229
3 Thousand Oaks, CA 91360
Telephone: (805) 988-3661 RECEIVED
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Facsimile: (805) 494-4777 9/27/2022 4:08 PM
5 Attorneys for Plaintiffs FRESNO COUNTY SUPERIOR COURT
By: Estela Alvarado, Deputy
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SUPERIOR COURT OF THE STATE OF CALIFORNIA
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COUNTY OF FRESNO
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9 LOLA NUTT, by and through her Successor CASE NO.: 21CECG00531
in Interest, HENRY NUTT; and HENRY
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NUTT, KEVIN NUTT, VASHON NUTT, and [PROPOSED] ORDER GRANTING
11 TYRONE NUTT, individually, PLAINTIFFS’ MOTION FOR LEAVE TO
AMEND COMPLAINT
12 Plaintiffs,
vs. Date: January 4, 2023
13 Time: 3:30 p.m.
Dept.: 503
14 ASFC, LLC dba SIERRA VISTA
HEALTHCARE; ASPEN SKILLED
15 HEALTHCARE, INC; and DOES 1-25,
16 inclusive,
17 Defendants.
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[PROPOSED] ORDER
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IT IS HEREBY ORDERED that Plaintiffs’ Motion Seeking Leave to Amend the
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Complaint and file a Second Amended Complaint is granted.
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Plaintiffs shall file their Second Amended Complaint attached to the Motion as Exhibit A
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within ten (10) days of the signing of this Order.
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Dated: _______________________, 2022
25 ______________________________
Judge of the Superior Court
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[PROPOSED] ORDER GRANTING PLAINTIFFS’ MOTION FOR LEAVE TO AMEND COMPLAINT
1 PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF VENTURA
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I am employed in the County of Ventura, State of California. I am over the age of 18 and not a
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party to the within action. My business address is 100 E. Thousand Oaks Blvd., Suite 229, Thousand Oaks,
4 CA 91360.
5 On September 27, 2022, I served the foregoing document(s) described as: [PROPOSED]
ORDER GRANTING PLAINTIFFS’ MOTION FOR LEAVE TO AMEND COMPLAINT
6 on the interested parties in this action, by placing the original X a true copy thereof enclosed in a
sealed envelope addressed as follows:
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See Attached Service List
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9 (BY FIRST CLASS MAIL) I caused such envelope with postage thereon fully prepaid to be placed
in the United States mail at Thousand Oaks, California. I am "readily familiar" with the firm's practice of
10 collection and processing correspondence for mailing. It is deposited with the U.S. Postal Service on that
same day in the ordinary course of business. I am aware that on motion of the party served, service is
11 presumed invalid if postal cancellation date or postage meter date is more than 1 day after date of deposit
for mailing in affidavit.
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X (BY E-MAIL OR ELECTRONIC TRANSMISSION) I caused to be served by e-mail or
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electronic transmission, the documents to be sent to the persons at the above-listed email addresses.
14 I did not receive, within a reasonable time after the transmission, any electronic message or other
indication that the transmission was unsuccessful. Any period of notice, or any right or duty to do
15 any act or make any response shall be pursuant to Code of Civil Procedure section 1010.6(a)(4)(B).
16 Executed on September 27, 2022, at Thousand Oaks, California.
17 X State) I declare under penalty of perjury under the laws of the State of California that the above
is true and correct.
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___________________________________
21 Marci Bratton
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1 Service List
2 Brett Shoel, Esq. Attorneys for Defendants ASFC, LLC dba
Vanessa Cornejo, Esq. Sierra Vista Healthcare, Aspen Skilled
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LaFollette Johnson Healthcare, Inc., and witness Jason Adiuba,
4 655 University Avenue, Suite 119 LVN
Sacramento, CA 95825-6746
5 Phone: (916) 563-3100
Fax: (916) 565-3704
6 bschoel@ljdfa.com
vcornejo@ljdfa.com
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aeugene@ljdfa.com
8 jkloepfel@ljdfa.com
bmitchell@ljdfa.com
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