On December 14, 2020 a
Answer
was filed
involving a dispute between
Reyes, Veronica,
and
Does 1 Through 100, Inclusive,
Does 2 Through 100, Inclusive,
Knolls West Convalescent Hospital,
Knolls West Post Acute Llc,
Knolls West Post Acute, Llc,
Rios, Leila,
Victor Valley Medical Center,
for Medical Malpractice Unlimited
in the District Court of San Bernardino County.
Preview
\y V
(ENDORSED)
CASE ATTACHMENT COVER PAGE
ELECTRONICALLY
FILED
SUPERIOR COURT 0F CALIFORNIA, COUNTY 0F SAN BERNARDINO
STREET ADDREss;247 West Third Street
BY SUPERIOR COURT
MAILING ADDRESS:
OF CALIFORNIA, COUNTY OF
CITY AND zup cope; San Bernardino, CA 92415
San Bernardino
BRANCH NAME:San Bernardino Justice Center
WEBSITEhttp //www. sb—court org
: . on Apr 12, 2021
CLERK OF THE SUPERIOR COURT
Defendant s Answer to Complaint
ATTACHMENT NAME: Answer: Deputy Clerk: Liliana Marisca/
Veronica Reyes vs. Knolls West Assisted Living LLC CASE NUMBER:
CASE NAME:
CIVSB2028140
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Please staple this to your original attachment
/woaynoaoq1n1//:duq
Trent Evans (SBN: 241486)
tevans@sunmarhealthcare.com
Kevin Khachatryan (SBN 3 14410)
kkhachalryan@sunmarhealthcare.com
3050 Saturn Street, Suite 101
Brea, California 92821
Telephone: (714) 577—3880
Facsimile: (714) 577—5312
Attorneys for Defendant,
KNOLLS WEST POST ACUTE, LLC (erroneously sued as KNOLLS WEST CONVALESCENT
HOSPITAL, unknown entity, and KNOLLS WEST POST ACUTE LLC)
SUPERIOR COURT OF THE STATE 0F CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO - CENTRAL DISTRICT
10 VERONICA REYES, an individual; Case N0. CIVSB2028140
VERONICA REYES, successor in interest 0f
DEFENDANT’S ANSWER TO
11 decedent ALICE REYES
COMPLAINT
12 Plaintiff,
Action Filed: December 21, 2020
13
VS- Judge: Hon. Lynn Poncin
Dept: $28
14
KNOLLS WEST CONVALESCENT
HOSPITAL, an unknown entity; KNOLLS I
15 Tnal Datei N/A~
WEST POST ACUTE LLC, a California
16 corporation; LEILA RIOS, an individual, and
DOES 1 through 100 inclusive.
17
Defendants.
18
19
Defendant KNOLLS WEST POST ACUTE, LLC (erroneously sued as KNOLLS WEST
20
CONVALESCENT HOSPITAL, unknown entity, and KNOLLS WEST POST ACUTE LLC) hereby
21
answer Plaintiffs’ Complaint (“Complaint”) as follows:
22
Pursuant to Code of Civil Procedure § 431.30, Defendant denies generally and specifically each
23
in the Complaint. Defendant further denies that Plaintiffs have been damaged in
and every allegation
24
the sum and manner alleged in the Complaint, or any other sum or manner, or at all.
25
FIRST AFFIRMATIVE DEFENSE
26
(Comparative Negligence)
27
At the time and place of the occurrence alleged in the
Complaint, Plaintiffs failed to
1.
28
_ 1 _
DEFENDANT’S ANSWER T0 FIRST AMENDED COMPLAINT
Document Filed Date
April 12, 2021
Case Filing Date
December 14, 2020
Category
Medical Malpractice Unlimited
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