On March 30, 2020 a
Motion-Secondary
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 10/20/2020 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, )
) MEMORANDUM OF POINTS AND
15 vs. ) AUTHORITIES IN SUPPORT OF
) DEFENDANTS’ MOTION TO COMPEL
16 MONTROSE SPRINGS SKILLED NURSING ) DEPOSITION OF PLAINTIFF MARIE
& WELLNESS CENTER; VERDUGO ) MOR
17 VALLEY SKILLED NURSING & )
WELLNESS CENTRE, LLC dba VERDUGO ) RESERVATION ID: 290320630158
18 VALLEY SKILLED NURSING & ) Date: March 23, 2021
WELLNESS CENTRE; BRIUS ) Time: 8:30 a.m.
19 MANAGEMENT CO., INC.; ROCKPORT ) Dept: 74
ADMINISTRATIVE SERVICES, LLC; )
20 SHLOMO RECHNITZ; and DOES 1 ) Complaint Filed: May 1, 2019
THROUGH 60, inclusive, ) Trial Date: November 30, 2020
21 )
Defendants. )
22
23 MEMORANDUM
24 I. INTRODUCTION
25 Defendants bring this motion as a result of Plaintiffs’ failure to produce Plaintiff Marie
26 Mor for her legally noticed deposition on October 16, 2020. Given the fact that Plaintiffs’
27 Motion for Trial Preference was granted on August 7, 2020, and the trial is scheduled for
28 November 30, 2020, Defendants do not have the luxury of waiting to depose Plaintiff Marie
-1-
Memorandum of Points and Authorities in Support of Defendants’ Motion to Compel Deposition
of Plaintiff Marie Mor
Document Filed Date
October 20, 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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