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 12/02/2020 01:04 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,     )
                                                                                                    ) DEFENDANT VERDUGO VALLEY
                                                   15           vs.                                 ) SKILLED NURSING & WELLNESS
                                                                                                    ) CENTRE, LLC’S OPPOSITION TO
                                                   16   MONTROSE SPRINGS SKILLED NURSING ) PLAINTIFF’S MOTION TO COMPEL
                                                        & WELLNESS CENTER; VERDUGO                  ) FURTHER RESPONSES TO SPECIAL
                                                   17   VALLEY SKILLED NURSING &                    ) INTERROGATORIES, SET ONE;
                                                        WELLNESS CENTRE, LLC dba VERDUGO ) REQUEST FOR MONETARY
                                                   18   VALLEY SKILLED NURSING &                    ) SANCTIONS IN THE AMOUNT OF
                                                        WELLNESS CENTRE; BRIUS                      ) $2,500.00
                                                   19   MANAGEMENT CO., INC.; ROCKPORT              )
                                                        ADMINISTRATIVE SERVICES, LLC;               ) Date: December 15, 2020
                                                   20   SHLOMO RECHNITZ; and DOES 1                 ) Time: 8:30 a.m.
                                                        THROUGH 60, inclusive,                      ) Dept.: 74
                                                   21                                               )
                                                                                    Defendants.     ) Complaint Filed: May 1, 2019
                                                   22                                               ) Trial Date: January 25, 2021
                                                                                                    )
                                                   23                                               )
                                                   24

                                                   25          TO PLAINTIFFS AND THEIR COUNSEL OF RECORD:

                                                   26          Defendant Verdugo Valley Skilled Nursing & Wellness Centre LLC, (“Verdugo Valley”)

                                                   27   respectfully submits this Opposition to Plaintiff’s Motion to Compel Further Responses to

                                                   28   Special Interrogatories, Set One and Request for Sanctions.
                                                                                                              -1-
                                                        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