On March 30, 2020 a
Party Discovery
was filed
involving a dispute between
Jeffrey Mor In And Through His Successor-In-Interest Jeffrey S.Reisbeck,
Mor Marie,
and
Brius Management Co. Inc.,
Montrose Springs Skilled Nursing & Wellness Center,
Rechnitz Shlomo,
Rockport Administrative Services Llc,
Verdugo Valley Skilled Nursing & Wellness Centre Llc Dba Verdugo Valley Skilled Nursing & Wellness Centre,
for civil
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 12/07/2020 04:06 PM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Bolden,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, )
) REPLY IN SUPPORT OF
15 vs. ) DEFENDANTS’ MOTION TO COMPEL
) DEPOSITION OF PLAINTIFF MARIE
16 MONTROSE SPRINGS SKILLED NURSING ) MOR
& WELLNESS CENTER; VERDUGO )
17 VALLEY SKILLED NURSING & ) Date: December 15, 2020
WELLNESS CENTRE, LLC dba VERDUGO ) Time: 8:30 a.m.
18 VALLEY SKILLED NURSING & ) Dept: 74
WELLNESS CENTRE; BRIUS )
19 MANAGEMENT CO., INC.; ROCKPORT ) Complaint Filed: May 1, 2019
ADMINISTRATIVE SERVICES, LLC; ) Trial Date: January 25, 2021
20 SHLOMO RECHNITZ; and DOES 1 )
THROUGH 60, inclusive, )
21 )
Defendants. )
22
23 Defendants respectfully submit this Reply in Support of the Motions to Compel the
24 Deposition of Plaintiff Marie Mor.
25 I. INTRODUCTION
26 On Monday November 16, 2020, Plaintiffs’ moved ex parte to continue the trial date.
27 During this hearing, defense counsel mentioned the issue with Dr. Sawiris deposition. (Young
28 Decl., ¶2). On Friday November 13, 2020, Plaintiffs’ counsel informed defense counsel that Dr.
-1-
Reply in Support of Defendants’ Motion to Compel Deposition of Plaintiff Marie Mor
Document Filed Date
December 07, 2020
Case Filing Date
March 30, 2020
Status
Request for Dismissal - Before Trial not following ADR or more than 60 days since ADR 05/20/2021
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