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 12/07/2020 03:54 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Bolden,Deputy Clerk




                                        I. HOOSHIE BROOMAND (SBN: 210206)
                                        hbroomand@grsm.corn
                                    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

                                   12   JEFFREY MOR, in and through his Successor-                             CASE NO. 20STCV12538
                                        in-Interest, Jeffrey S. Reisbeck, and MARIE
                                   13   MOR, an individual,                                                    Assigned to Judge Melissa Williams Court
                                                                                                               Department 74, all purposes
                                   14                                    Plaintiffs,
                              FT                                                                               DECLARATION OF SHLOMO
             Gordon Rees Sc




                              E 15             vs.                                                             RECHNITZ IN SUPPORT OF
                                                                                                               DEFENDANTS' REPLY RE: MOTION
                                   16   MONTROSE SPRINGS SKILLED NURSING                                       FOR PROTECTIVE ORDER
                                        & WELLNESS CENTER; VERDUGO                                             PRECLUDING THE DEPOSITION
                                   17   VALLEY SKILLED NURSING &                                               SHLOMO RECHNITZ
                                        WELLNESS CENTRE, LLC dba VERDUGO
                                   18   VALLEY SKILLED NURSING &
                                        WELLNESS CENTRE; BRIUS                                                 Date: December 15, 2020
                                   19   MANAGEMENT CO., INC.; ROCKPORT                                         Time: 8:30 a.m.
                                        ADMINISTRATIVE SERVICES, LLC;                                          Dept: 74
                                   20   SHLOMO RECHNITZ; and DOES 1
                                        THROUGH 60, inclusive,                                              Complaint Filed: March 30, 2020
                                   21                                                                     ) Trial Date: January 25, 2021
                                                                         Defendants.                      )
                                   22                                                                     )
                                                                                                          )
                                   23

                                   24          I, Shlomo Rechnitz, declare that:

                                   25          1.        I am the Chief Executive Officer and a shareholder of Brius Management Co.

                                   26   (hereinafter referred to as "Brius"), located in Los Angeles, County. The facts set forth herein

                                   27   are known to me personally, and if called upon to testify, I could and would competently testify

                                   28   thereto.
                                                                                    -1-
                                          Declaration of Shlomo Rechnitz in Support of Defendants' Reply Re: Motion for Protective
                                                             Order Precluding the Deposition of Shlomo Rechnitz