Order: Manufacturers & Trad Ers Trust Vs Mountain View

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                                MRS-L-000488-23        08/14/2023   Pglof3   Trans ID: LCV20232332453



                                                                            FILED
FOX ROTHSCHILD LLP                                                          AUG 14 2023
Formed in the Commonwealth of Pennsylvania                                                 z, ASS.C.
By: Barry J. Muller, Esq. - NJ Attorney ID No. 016911998            Hon. Stuart A. Minkowitw Jersey
Princeton Pike Corporate Center                                        Superior Court of Ne
                                                                           Judge's Chambers
997 Lenox Drive, Building 3
Lawrenceville, New Jersey 08648-2311
Telephone: (609) 896-3600
Attorneys for Defendant Jack Jaffa &
Third Party Plaintiff, Jace     J Management, LLC
                                                      SUPERIOR COURT OF NEW JERSEY
                                                      MORRIS COUNTY: LAW DIVISION
                                                      Docket No.: MRS-L-488-25


MANUFACTURERS AND TRADERS TRUST
COMPANY,
             Plaintiff,                                                  Civil Action
    v

MOUNTAIN VIEW CARE AND
REHABILITATION CENTER, LLC,
BLOOMSBURG CARE AND
REHABILITATION CENTER, LLC, MOT
EPHRAIM REALTY, LLC, MOT MENASHE
REALTY, LLC, JACK JAFFA, CHAIM
SCHEINBAUM, and LOUIS SCHWARTZ, JR.,
                                                                     CONSENT ORDER
                       Defendants.

JACE J MANAGEMENT, LLC and JACK
JAFFA, individually and derivatively on behalf
of MOUNTAIN VIEW CARE AND
REHABILITATION CENTER, LLC,
BLOOMSBURG CARE AND REHABILITATION
CENTER, LLC, MOT EPHRAIM REALTY, LLC,
and MOT MENASHE REALTY, LLC,

                 Third Party Plaintiffs,
        ¥.

CHAIM SCHEINBAUM, and LOUIS
SCHWARTZ, JR.,

                 Third Party Defendants.




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MRS-L-000488-23       08/14/2023      Pg2of3        Trans ID: LCV20232332453




        THIS MATTER,          being brought before the court by Fox Rothschild LLP, attorneys for

Defendant Jack Jaffa & Third Party Plaintiff, Jace     J Management, LLC (collectively “Jaffa”), and

Charles A. Gruen, Esq., attorney for Defendants, Mountain View Care and Rehabilitation Center,

LLC    (the    “Scranton   Facility”),   Bloomsburg   Care    and    Rehabilitation   Center,   LLC   (the

“Bloomsburg Facility”), MOT Ephraim Realty, LLC & MOT Menashe Realty, LLC (the “MOT

Entities”), and Chaim Scheinbaum (“Scheinbaum”); and the parties having consented to the form

of this Order; and for good cause shown;


        IT IS ON THIS             [f       day of
                                                       fy
                                                      pty     ©   os       :
                                                                                           , 2023, hereby

ORDERED that:

        1        Jaffa’s Motion to Compel Production of Documents is hereby withdrawn without

prejudice;

        2        On or before August 25, 2023, Scheinbaum shall provide Jaffa with copies of

existing business and financial records of the MOT           Entities, the Bloomsburg Facility and the

Scranton Facility, including, but not limited to financial and bookkeeping records, including all

income statements, balance sheets, cost reports, annual and quarterly statements,           12 months of

payroll summaries, CPA reviewed / audited financial statements, Medicare/Medicaid/Government

Receivable account oversight/management documents, names of the EMR and electronic financial

systems, and any and other existing records regarding the activities, affairs, and financial condition

of the MOT Entities, the Bloomsburg Facility and the Scranton Facility, ftom January 31, 2018 to

the current date;

        3        On or before October 15, 2023, Scheinbaum shall provide Jaffa with the 2022

Reviewed Financial Statements of the Bloomsburg Facility and the Scranton Facility;




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MRS-L-000488-23        08/14/2023   Pg3of3    Trans ID: LCV20232332453




          4         Any future business or financial record requests from Jaffa shall be responded to

by Scheinbaum within fifteen (15) days of the request.        if there are any disputes, counsel shall

contact Michael Eisner, Esq. to schedule a conference to try to resolve the dispute prior to filing a

motion.
                                                                         a >)
                                                                                /
                                                                           Lan
                                                         HON. SUART A. MINKOWITZ, A.J.S.C.


The undersigned hereby consent to the form and entry of the foregoing Order.




 CHARLES A. GRUEN LAW OFFICES                                FOX ROTHSCHILD LLP
 Attorneys for Scheinbaum                                    Attorneys for Jaffa




 By:          s/ Charles A. Gruen                            By:___s/ Barry J. Muller
              Charles A. Gruen, Esq.                                Barry J. Muller, Esq.




148315023.1