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 12:51 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
                                           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
                                                                                           ) DEFENDANT’S OPPOSITION TO
                                          16   MONTROSE SPRINGS SKILLED NURSING ) PLAINTIFFS’ MOTION TO COMPEL
                                               & WELLNESS CENTER; VERDUGO                  ) RESPONSE TO REQUEST FOR
                                          17   VALLEY SKILLED NURSING &                    ) PRODUCTION OF DOCUMENTS, SET
                                               WELLNESS CENTRE, LLC dba VERDUGO ) ONE
                                          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

                                          24          I, Heather-Ann T. Young, declare as follows:

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

                                          26   California and am Senior Counsel in the law firm of Gordon Rees Scully Mansukhani, LLP,

                                          27   attorneys for the defendant ROCKPORT ADMINISTRATIVE SERVICES, LLC. I have

                                          28   personal knowledge of the matters contained in this declaration and if called to testify to them
                                                                                                    -1-
                                                  Declaration of Heather-Ann T. Young in Support of Defendant’s Opposition to Plaintiffs’ Motion to Compel
                                                                         Response to Request for Production of Documents, Set One