On May 16, 2024 a
No Value
was filed
involving a dispute between
Of The Estate Of Annie Jones, Theodore Smothers, Individually And On Behalf,
and
Atlanta Ga Opco Llc Dba Buckhead Center For Nursing & Healing,
Empire Care Centers Llc,
Ensh Consulting Llc,
Ga Nc 14 Holdings Llc,
Ghc By Harborview D B A Ghc By Harborview,
Harborview Health Systems Inc,
Thomas Martens,
for Tort - Medical Malpractice
in the District Court of DeKalb County.
Preview
IN THE SUPERIOR COURT OF DEKALB COUNTY
STATE OF GEORGIA
THEODORE SMOTHERS, §
INDIVIDUALLY §
AND ON BEHALF OF THE ESTATE OF §
ANNIE JONES, §
§
Plaintiff, § CIVIL ACTION NO.
§
v. §
§
ATLANTA GA OPCO LLC d/b/a §
BUCKHEAD CENTER FOR NURSING §
& HEALING; GA 2 HOLDCO LLC; §
ENSH CONSULTING LLC; EMPIRE §
CARE CENTERS LLC; GLENWOOD §
HEALTH CENTER BY HARBORVIEW §
LLC d/b/a GLENWOOD HEALTH §
CENTER BY HARBORVIEW; GA NC §
14 HOLDINGS LLC; HARBORVIEW §
HEALTH SYSTEMS INC; THOMAS §
MARTENS; JOHN DOES (1-5) and ABC §
CORPORATIONS (1-5), §
§
Defendants. §
RULE 5.2 CERTIFICATE OF SERVICE
I hereby certify that I have this date served a copy of the within and foregoing:
• PLAINTIFF’S FIRST CONTINUING INTERROGATORIES OF DOCUMENTS TO
DEFENDANTS.
• PLAINTIFF’S FIRST CONTINUING REQUESTS FOR ADMISSIONS TO
DEFENDANTS.
• PLAINTIFF’S FIRST CONTINUING REQUESTS FOR THE PRODUCTION OF
DOCUMENTS TO DEFENDANTS.
All discovery named within will be served upon defendants via process service to
Defendant’s registered Agents.
Respectfully submitted on this 10th day of May 2024.
/s/: Kimberly Joy Thornton
Kimberly Joy Thornton
Georgia Bar No. 865534
SMITH CLINESMITH LLP
1201 Peachtree Street
Atlanta, GA 30361
jthornton@fightingelderabuse.com
Jacob Runyon
Georgia Bar No. 528373
SMITH CLINESMITH LLP
325 N. St. Paul 29th Floor
Dallas, TX 75201
jacob@fightingelderabuse.com
service@smithclinesmith.com
Tel. 214-953-1900
Fax 214-953-1901
Attorneys for Plaintiff
2
Category
Tort - Medical Malpractice
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IN THE SUPERIOR COURT OF DEKALB COUNTY STATE OF GEORGIA THEODORE SMOTHERS, § INDIVIDUALLY § AND ON BEHALF OF THE ESTATE OF § ANNIE JONES, § § Plaintiff, § CIVIL ACTION NO. § v. § § ATLANTA GA OPCO LLC d/b/a § BUCKHEAD CENTER FOR NURSING § & HEALING; GA 2 HOLDCO LLC; § ENSH CONSULTING LLC; EMPIRE § CARE CENTERS LLC; GLENWOOD § HEALTH CENTER BY HARBORVIEW § LLC d/b/a GLENWOOD HEALTH § CENTER BY HARBORVIEW; GA NC § 14 HOLDINGS LLC; HARBORVIEW § HEALTH SYSTEMS INC; THOMAS § MARTENS; JOHN DOES (1-5) and ABC § CORPORATIONS (1-5), § § Defendants. § RULE 5.2 CERTIFICATE OF SERVICE I hereby certify that I have this date served a copy of the within and foregoing: • PLAINTIFF’S FIRST CONTINUING INTERROGATORIES OF DOCUMENTS TO DEFENDANTS. • PLAINTIFF’S FIRST CONTINUING REQUESTS FOR ADMISSIONS TO DEFENDANTS. • PLAINTIFF’S FIRST CONTINUING REQUESTS FOR THE PRODUCTION OF DOCUMENTS TO DEFENDANTS. All discovery named within will be served upon defendants via process service to Defendant’s registered Agents. Respectfully submitted on this 10th day of May 2024. /s/: Kimberly Joy Thornton Kimberly Joy Thornton Georgia Bar No. 865534 SMITH CLINESMITH LLP 1201 Peachtree Street Atlanta, GA 30361 jthornton@fightingelderabuse.com Jacob Runyon Georgia Bar No. 528373 SMITH CLINESMITH LLP 325 N. St. Paul 29th Floor Dallas, TX 75201 jacob@fightingelderabuse.com service@smithclinesmith.com Tel. 214-953-1900 Fax 214-953-1901 Attorneys for Plaintiff 2