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 01:11 PM Sherri R. Carter, Executive Officer/Clerk of Court, by A. Miro,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 AND
                                             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 SHLOMO RECHNITZ’S
                                            15           vs.                                 ) RESPONSE TO PLAINTIFF JEFFREY
                                                                                             ) MOR’S SEPARATE STATEMENT IN
                                            16   MONTROSE SPRINGS SKILLED NURSING ) SUPPORT OF MOTION TO COMPEL
                                                 & WELLNESS CENTER; VERDUGO                  ) FURTHER RESPONSES TO REQUEST
                                            17   VALLEY SKILLED NURSING &                    ) FOR PRODUCTION OF DOCUMENTS,
                                                 WELLNESS CENTRE, LLC dba VERDUGO ) SET ONE, NOS 9-11 AND 18-20
                                            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: May 1, 2019
                                            21                                               ) Trial Date: January 25, 2021
                                                                             Defendants.     )
                                            22

                                            23                           RESPONSE TO REQUEST FOR PRODUCTION

                                            24   REQUEST FOR PRODUCTION NO. 9:

                                            25          Produce any and all DOCUMENTS to include correspondence, memorandums, and/or e-

                                            26   mails exchanged between YOU and Defendant, Rockport Administrative Services, LLC relating

                                            27   to any issues regarding neglect at the FACILITY from October 1, 2018 through July 31, 2019.

                                            28   ///
                                                                                                      -1-
                                                   Defendant Shlomo Rechnitz’s Response to Plaintiff Jeffrey Mor’s Separate Statement in Support of Motion to
                                                        Compel Further Responses to Request for Production of Documents, Set One, Nos 9-11 and 18-20