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Alexander F. Giovanniello (CSB # 125562) ELECTRONICALLY FILED
Martin R. BoagS (CSB # 178704) SUPERIOR COURT OF CALIFORNIA
GIOVANNIELLO LAW GROUP COUNTY OF SAN BERNARDINO
One Pointe Drive, Suite 300 SAN BERNARDINO DISTRICT
Brea, Cahforma 92821
10/19/2023 2:33 PM
Ph: (714)364—4000 B_Sh
y- ual_Zh ou, DEPUTY
Fax:(714)364—4001
KOOONONUl-hwwu—t
service@giolawgroup.com
Attorneys for Defendants:
KNOLLS WEST POST ACUTE, LLC
and LEILA RIOS
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SAN BERNARDINO
VERONICA REYES, an individual; Case N0.: CIVSB2028140
VERONICA REYES, successor-in-interest
0f decedent ALICE REYES, COMPENDIUM OF EXHIBITS FILED IN
SUPPORT OF MOTIONS IN LIMINE BY
Plaintiff, DEFENDANTS KNOLLS WEST POST
ACUTE, LLC AND LEILA RIOS
VS.
KNOLLS WEST CONVALESCENT
HOSPITAL, unknown entity; KNOLLS TRIAL: November 6, 2023
WEST POST ACUTE LLC, a California JVVVVVVVVVVVVVVVVVVVV
TIME: 10:00 am.
corporation; LEILA RIOS, an individual; DEPT: S28
and DOES 1 through 100 inclusive,
Defendants.
JUDGE: Hon. Michael Sachs
NNNNNNNNNHHHHHHHHHH
OONONM-PWNHOKOOONONm-PWNHO
Complaint filed December 21, 2020
Trial scheduled November 6, 2023
TO THE COURT, ALL PARTIES AND THEIR ATTORNEYS OF RECORD:
PLEASE TAKE NOTICE THAT KNOLLS WEST POST ACUTE, LLC and LEILA
RIOS (hereinafter referred t0 as “Defendants”) hereby submit the following exhibits in support
of their Motions in Limine as follows:
///
///
1
COMPENDIUM OF EXHIBITS FILED IN SUPPORT OF MOTIONS IN LIMINE BY DEFENDANTS
KNOLLS WEST POST ACUTE, LLC AND LEILA RIOS
EXHIBIT NO. DESCRIPTION OF EXHIBIT
EXHIBIT 1 : Complaint for Damages, filed on December 21, 2020 by Plaintiff
Veronica Reyes, as an individual and as successor in interest t0 Alice
Reyes, Deceased, in San Bernardino County Superior Court Case N0.
KOOONONUl-hwwu—t
CIVSB 2028140;
EXHIBIT 2: Form Interrogatories — General, Set One served 0n Plaintiff Alice Reyes,
by Knolls West 0n July 10, 2023;
EXHIBIT 3: Special Interrogatories, Set One served 0n Plaintiff Alice Reyes, by
Knolls West 0n July 10, 2023;
EXHIBIT 4: Requests for Admissions, Set One served 0n Plaintiff Alice Reyes, by
Knolls West 0n July 10, 2023;
EXHIBIT 5: Requests for Production 0f Documents, Set One served 0n Plaintiff Alice
Reyes, by Knolls West 0n July 10, 2023;
EXHIBIT 6: Form Interrogatories — General, Set One served 0n Plaintiff Veronica
Reyes, by Knolls West 0n July 10, 2023;
EXHIBIT 7: Special Interrogatories, Set One served 0n Plaintiff Veronica Reyes, by
Knolls West 0n July 10, 2023;
EXHIBIT 8: Requests for Admissions, Set One served 0n Plaintiff Veronica Reyes, by
NNNNNNNNNHHHHHHHHHH
Knolls West 0n July 10, 2023;
OONONM-PWNHOKOOONONm-PWNHO
EXHIBIT 9: Requests for Production 0f Documents, Set One served 0n Plaintiff
Veronica Reyes, by Knolls West 0n July 10, 2023;
EXHIBIT 10: Form Interrogatories — General, Set One served 0n Plaintiff Alice Reyes,
by Leila Rios 0n July 10, 2023;
EXHIBIT 1 1 : Special Interrogatories, Set One served 0n Plaintiff Alice Reyes, by Leila
Rios 0n July 10, 2023;
EXHIBIT 12: Requests for Admissions, Set One served 0n Plaintiff Alice Reyes, by
Leila Rios 0n July 10, 2023;
2
COMPENDIUM OF EXHIBITS FILED IN SUPPORT OF MOTIONS IN LIMINE BY DEFENDANTS
KNOLLS WEST POST ACUTE, LLC AND LEILA RIOS
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Alexander F. Giovanniello (CSB # 125562) ELECTRONICALLY FILED Martin R. BoagS (CSB # 178704) SUPERIOR COURT OF CALIFORNIA GIOVANNIELLO LAW GROUP COUNTY OF SAN BERNARDINO One Pointe Drive, Suite 300 SAN BERNARDINO DISTRICT Brea, Cahforma 92821 10/19/2023 2:33 PM Ph: (714)364—4000 B_Sh y- ual_Zh ou, DEPUTY Fax:(714)364—4001 KOOONONUl-hwwu—t service@giolawgroup.com Attorneys for Defendants: KNOLLS WEST POST ACUTE, LLC and LEILA RIOS SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN BERNARDINO VERONICA REYES, an individual; Case N0.: CIVSB2028140 VERONICA REYES, successor-in-interest 0f decedent ALICE REYES, COMPENDIUM OF EXHIBITS FILED IN SUPPORT OF MOTIONS IN LIMINE BY Plaintiff, DEFENDANTS KNOLLS WEST POST ACUTE, LLC AND LEILA RIOS VS. KNOLLS WEST CONVALESCENT HOSPITAL, unknown entity; KNOLLS TRIAL: November 6, 2023 WEST POST ACUTE LLC, a California JVVVVVVVVVVVVVVVVVVVV TIME: 10:00 am. corporation; LEILA RIOS, an individual; DEPT: S28 and DOES 1 through 100 inclusive, Defendants. JUDGE: Hon. Michael Sachs NNNNNNNNNHHHHHHHHHH OONONM-PWNHOKOOONONm-PWNHO Complaint filed December 21, 2020 Trial scheduled November 6, 2023 TO THE COURT, ALL PARTIES AND THEIR ATTORNEYS OF RECORD: PLEASE TAKE NOTICE THAT KNOLLS WEST POST ACUTE, LLC and LEILA RIOS (hereinafter referred t0 as “Defendants”) hereby submit the following exhibits in support of their Motions in Limine as follows: /// /// 1 COMPENDIUM OF EXHIBITS FILED IN SUPPORT OF MOTIONS IN LIMINE BY DEFENDANTS KNOLLS WEST POST ACUTE, LLC AND LEILA RIOS EXHIBIT NO. DESCRIPTION OF EXHIBIT EXHIBIT 1 : Complaint for Damages, filed on December 21, 2020 by Plaintiff Veronica Reyes, as an individual and as successor in interest t0 Alice Reyes, Deceased, in San Bernardino County Superior Court Case N0. KOOONONUl-hwwu—t CIVSB 2028140; EXHIBIT 2: Form Interrogatories — General, Set One served 0n Plaintiff Alice Reyes, by Knolls West 0n July 10, 2023; EXHIBIT 3: Special Interrogatories, Set One served 0n Plaintiff Alice Reyes, by Knolls West 0n July 10, 2023; EXHIBIT 4: Requests for Admissions, Set One served 0n Plaintiff Alice Reyes, by Knolls West 0n July 10, 2023; EXHIBIT 5: Requests for Production 0f Documents, Set One served 0n Plaintiff Alice Reyes, by Knolls West 0n July 10, 2023; EXHIBIT 6: Form Interrogatories — General, Set One served 0n Plaintiff Veronica Reyes, by Knolls West 0n July 10, 2023; EXHIBIT 7: Special Interrogatories, Set One served 0n Plaintiff Veronica Reyes, by Knolls West 0n July 10, 2023; EXHIBIT 8: Requests for Admissions, Set One served 0n Plaintiff Veronica Reyes, by NNNNNNNNNHHHHHHHHHH Knolls West 0n July 10, 2023; OONONM-PWNHOKOOONONm-PWNHO EXHIBIT 9: Requests for Production 0f Documents, Set One served 0n Plaintiff Veronica Reyes, by Knolls West 0n July 10, 2023; EXHIBIT 10: Form Interrogatories — General, Set One served 0n Plaintiff Alice Reyes, by Leila Rios 0n July 10, 2023; EXHIBIT 1 1 : Special Interrogatories, Set One served 0n Plaintiff Alice Reyes, by Leila Rios 0n July 10, 2023; EXHIBIT 12: Requests for Admissions, Set One served 0n Plaintiff Alice Reyes, by Leila Rios 0n July 10, 2023; 2 COMPENDIUM OF EXHIBITS FILED IN SUPPORT OF MOTIONS IN LIMINE BY DEFENDANTS KNOLLS WEST POST ACUTE, LLC AND LEILA RIOS