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 10/20/2020 07:06 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’ NOTICE OF MOTION
                                           15           vs.                                 ) AND MOTION TO COMPEL
                                                                                            ) DEPOSITION OF PLAINTIFF MARIE
                                           16   MONTROSE SPRINGS SKILLED NURSING ) MOR
                                                & WELLNESS CENTER; VERDUGO                  )
                                           17   VALLEY SKILLED NURSING &                    ) RESERVATION ID: 290320630158
                                                WELLNESS CENTRE, LLC dba VERDUGO ) Date: March 23, 2021
                                           18   VALLEY SKILLED NURSING &                    ) Time: 8:30 a.m.
                                                WELLNESS CENTRE; BRIUS                      ) Dept: 74
                                           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                                               )
                                                                                            )
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                                                       TO PLAINTIFFS AND THEIR ATTORNEYS OF RECORD
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                                                       PLEASE TAKE NOTICE that on March 23, 2021, at 8:30 a.m., or as soon thereafter as
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                                                this matter may be heard, in Department 74 of this court, located at 111 North Hill Street, Los
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                                                Angeles, California, 90012, Defendants Montrose Springs Skilled Nursing & Wellness Center,
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                                                                                           -1-
                                                    Defendants’ Notice of Motion and Motion to Compel Deposition of Plaintiff Marie Mor