Party Discovery: JEFFREY MOR, IN AND THROUGH HIS SUCCESSOR-IN-INTEREST, JEFFREY S.REISBECK, ET AL. VS MONTROSE SPRINGS SKILLED NURSING & WELLNESS CENTER, ET AL.

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                                Electronically FILED by Superior Court of California, County of Los Angeles on 12/29/2020 04:33 PM Sherri R. Carter, Executive Officer/Clerk of Court, by K. Hung,Deputy Clerk




                                            1   I. HOOSHIE BROOMAND (SBN: 210206)
                                                hbroomand@grsm.com
                                            2   HEATHER-ANN T. YOUNG (SBN: 283211)
                                                hyoung@grsm.com
                                            3   GORDON REES SCULLY MANSUKHANI, LLP
                                                3 Parkcenter Drive, Suite 200
                                            4   Sacramento, CA 95825
                                                Telephone: (916) 565-2900
                                            5   Facsimile: (916) 920-4402

                                            6   Attorneys for Defendants
                                                MONTROSE SPRINGS SKILLED NURSING & WELLNESS CENTER;
                                            7   VERDUGO VALLEY SKILLED NURSING & WELLNESS CENTRE, LLC
                                                dba MONTROSE SPRINGS SKILLED NURSING & WELLNESS CENTRE
                                            8   (erroneously sued as Verdugo Valley Skilled Nursing & Wellness Centre, LLC dba Verdugo
                                                Valley Skilled Nursing & Wellness Centre); BRIUS MANAGEMENT CO., INC.;
                                            9   ROCKPORT ADMINISTRATIVE SERVICES, LLC and SHLOMO RECHNITZ

                                           10                               SUPERIOR COURT OF CALIFORNIA

                                           11                                   COUNTY OF LOS ANGELES
      Gordon Rees Scully Mansukhani, LLP
         3 Parkcenter Drive, Suite 200




                                           12   JEFFREY MOR, in and through his Successor- ) CASE NO. 20STCV12538
            Sacramento, CA 95825




                                                in-Interest, Jeffrey S. Reisbeck, and MARIE )
                                           13   MOR, an individual,                         ) Assigned to Judge Melissa Williams Court
                                                                                            ) Department 74, all purposes
                                           14                               Plaintiffs,     )
                                                                                            ) DECLARATION OF HEATHER-ANN T.
                                           15           vs.                                 ) YOUNG IN SUPPORT OF
                                                                                            ) DEFENDANTS’ MOTION TO QUASH
                                           16   MONTROSE SPRINGS SKILLED NURSING ) DEPOSITION SUBPOENA TO
                                                & WELLNESS CENTER; VERDUGO                  ) GENEVIEVE BAUTISTA
                                           17   VALLEY SKILLED NURSING &                    )
                                                WELLNESS CENTRE, LLC dba VERDUGO ) RESERVATION ID: 268759636676
                                           18   VALLEY SKILLED NURSING &                    ) Date: May 20, 2021
                                                WELLNESS CENTRE; BRIUS                      ) Time: 8:30 a.m.
                                           19   MANAGEMENT CO., INC.; ROCKPORT              ) Dept: 74
                                                ADMINISTRATIVE SERVICES, LLC;               )
                                           20   SHLOMO RECHNITZ; and DOES 1                 ) Complaint Filed: March 30, 2020
                                                THROUGH 60, inclusive,                      ) Trial Date: January 25, 2021
                                           21                                               )
                                                                            Defendants.     )
                                           22

                                           23          I, Heather-Ann Young, declare as follows:

                                           24          1.     I am an attorney at law licensed to practice before all courts of the State of

                                           25   California and am senior counsel in the law firm of Gordon Rees Scully Mansukhani, LLP,

                                           26   attorneys for the Defendants Montrose Springs Skilled Nursing & Wellness Center, Verdugo

                                           27   Valley Skilled Nursing & Wellness Centre, LLC dba Montrose Springs Skilled Nursing &

                                           28   Wellness Centre (erroneously sued as Verdugo Valley Skilled Nursing & Wellness Centre, LLC
                                                                                            -1-
                                                 Declaration of Heather-Ann T. Young in Support of Defendants’ Motion to Quash Deposition
                                                                               Subpoena to Genevieve Bautista