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 12/02/2020 02:51 PM Sherri R. Carter, Executive Officer/Clerk of Court, by M. Gonzalez,Deputy Clerk
1 MORAN LAW
Michael F. Moran SB# 121665
2 Lisa Trinh Flint SB# 243468
Philip J. Spinazze SB#325965
3 5 Hutton Centre Drive, Suite 1050
Santa Ana, CA 92707
4 Telephone: (714) 549-0333
Facsimile: (714) 549-0444
5
Attorneys for Plaintiffs, JEFFREY MOR, in and through his Successor-in-Interest, Jeffrey S.
6 Reisbeck, and MARIE MOR, an individual
7
8
SUPERIOR COURT OF THE STATE OF CALIFORNIA
9
COUNTY OF LOS ANGELES [CENTRAL]
10
11 JEFFREY MOR, in and through his Successor- ) CASE NO.: 20STCV12538
in-Interest, Jeffrey S. Reisbeck, and MARIE ) [Assigned for all purposes to the Hon.
12 MOR, an individual, ) Michelle Williams Court, Dept. 74]
)
13 Plaintiffs, )
) PLAINTIFFS’ OPPOSITION TO
14 vs. ) DEFENDANTS’ MOTION FOR
) PROTECTIVE ORDER PRECLUDING
15 MONTROSE SPRINGS SKILLED NURSING ) THE DEPOSITION OF SHLOMO
& WELLNESS CENTER; VERDUGO ) RECHNITZ; REQUEST FOR
16 VALLEY SKILLED NURSING & ) MONETARY SANCTIONS IN THE
WELLNESS CENTRE, LLC dba VERDUGO ) AMOUNT OF $5,250.00;
17 VALLEY SKILLED NURSING & ) DECLARATION OF LISA TRINH
WELLNESS CENTRE; BRIUS ) FLINT, ESQ.
18 MANAGEMENT CO., INC.; ROCKPORT )
ADMINISTRATIVE SERVICES, LLC; ) Date: February 17, 2021
19 SHLOMO RECHNITZ; and DOES 1 through ) Time: 8:30 a.m.
60, inclusive. ) Dept.: 74
20 Defendants. ) Reservation No.: 158358139927
)
21 )
) Complaint filed: March 30, 2020
22 ) Trial Date: November 30, 2020
)
23 )
24
25 Plaintiffs, JEFFREY MOR, in and through his Successor-in-Interest, Jeffrey S.
26 Reisbeck, and MARIE MOR, an individual (collectively referred to as “Plaintiffs”), submit
27 the following opposition to Defendants, MONTROSE SPRINGS SKILLED NURSING &
28 WELLNESS CENTER, VERDUGO VALLEY SKILLED NURSING & WELLNESS
i
PLAINTIFFS’ OPPOSITION TO DEFENDANTS’ MOTION FOR PROTECTIVE ORDER
PRECLUDING THE DEPOSITION OF SHLOMO RECHNITZ; REQUEST FOR MONETARY
SANCTIONS IN THE AMOUNT OF $5,250.00; DECLARATION OF LISA TRINH FLINT, ESQ.
Document Filed Date
December 02, 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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