On March 30, 2020 a
Motion,Ex Parte
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 10/28/2020 02:22 PM Sherri R. Carter, Executive Officer/Clerk of Court, by K. Hung,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, )
) DEFENDANTS’ MOTION IN LIMINE
15 vs. ) NO. 5 TO EXCLUDE OR LIMIT AS
) EVIDENCE PLAINTIFF MARIE MOR’S
16 MONTROSE SPRINGS SKILLED NURSING ) CLAIM OF LOSS OF INCOME;
& WELLNESS CENTER; VERDUGO ) DECLARATION OF HEATHER-ANN T.
17 VALLEY SKILLED NURSING & ) YOUNG
WELLNESS CENTRE, LLC dba VERDUGO )
18 VALLEY SKILLED NURSING & )
WELLNESS CENTRE; BRIUS )
19 MANAGEMENT CO., INC.; ROCKPORT )
ADMINISTRATIVE SERVICES, LLC; ) Complaint Filed: May 1, 2019
20 SHLOMO RECHNITZ; and DOES 1 ) Trial Date: November 30, 2020
THROUGH 60, inclusive, )
21 )
Defendants. )
22 )
)
23
24 PLEASE TAKE NOTICE THAT Defendants hereby move this Court for an order
25 excluding any and all evidence, references to evidence, testimony or argument relating to
26 Plaintiff Marie Mor’s claim of loss of income stemming from either Jeffrey Mor’s social security
27 disability payments or another source.
28 The motion is based upon the ground that any financial loss is speculative. This motion is
-1-
Defendants’ Motion in Limine No. 5 to Exclude or Limit as Evidence Plaintiff Marie Mor’s Claim of Loss of
Income; Declaration of Heather-Ann T. Young
Document Filed Date
October 28, 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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