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IN THE SUPERIOR COURT OF DEKALB COUNTY, STATE OF GEORGIA
THEODORE SMOTHERS, INDIVIDUALLY AND ON Case No. 24CV5034
BEHALF OF THE ESTATE OF ANNIE JONES
Plaintiff/Petitioner
vs.
ATLANTA GA OPCO LLC D/B/A BUCKHEAD CENTER AFFIDAVIT OF SERVICE OF
FOR NURSING & HEALING, ET AL. SUMMONS; COMPLAINT; PLAINTIFF’S FIRST
Defendant/Respondent CONTINUING REQUESTS FOR ADMISSIONS TO
DEFENDANT THOMAS MARTENS; PLAINTIFF’S FIRST
CONTINUING REQUESTS FOR THE PRODUCTION OF
DOCUMENTS TO DEFENDANT THOMAS MARTENS:
PLAINTIFF’S FIRST CONTINUING INTERROGATORIES
TO DEFENDANT THOMAS MARTENS; PLAINTIFF’S
FIRST CONTINUING REQUESTS FOR ADMISSIONS TO
DEFENDANT ENSH CONSULTING, LLC; PLAINTIFF’S
FIRST CONTINUING REQUESTS FOR THE
PRODUCTION OF DOCUMENTS TO DEFENDANT ENSH
CONSULTING, LLC; PLAINTIFF’S FIRST CONTINUING
INTERROGATORIES TO DEFENDANT ENSH
CONSULTING, LLC; PLAINTIFF’S FIRST CONTINUING
REQUESTS FOR ADMISSIONS TO DEFENDANT GA NC
14 HOLDINGS, LLC; PLAINTIFF’S FIRST CONTINUING
REQUESTS FOR THE PRODUCTION OF DOCUMENTS
TO DEFENDANT GA NC 14 HOLDINGS, LLC;
PLAINTIFF’S FIRST CONTINUING INTERROGATORIES
TO DEFENDANT GLENWOOD HEALTH CENTER BY GA
NC 14 HOLDINGS, LLC; PLAINTIFF’S FIRST
CONTINUING REQUESTS FOR ADMISSIONS TO
DEFENDANT HARBORVIEW HEALTH SYSTEMS, INC.
PLAINTIFF’S FIRST CONTINUING REQUESTS FOR THE
PRODUCTION OF DOCUMENTS TO DEFENDANT
HARBORVIEW HEALTH SYSTEMS, INC.; PLAINTIFF’S
FIRST CONTINUING INTERROGATORIES TO
DEFENDANT HARBORVIEW HEALTH SYSTEMS, INC.
PLAINTIFF’S FIRST CONTINUING REQUESTS FOR
ADMISSIONS TO DEFENDANT GA 2 HOLDCO, LLC:
PLAINTIFF’S FIRST CONTINUING REQUESTS FOR THE
PRODUCTION OF DOCUMENTS TO DEFENDANT GA 2
HOLDCO, LLC; PLAINTIFF’S FIRST CONTINUING
INTERROGATORIES TO DEFENDANT GA 2 HOLDCO.
LLC; PLAINTIFF’S FIRST CONTINUING REQUESTS FOR
ADMISSIONS TO DEFENDANT EMPIRE CARE
CENTERS, LLC; PLAINTIFF’S FIRST CONTINUING
REQUESTS FOR THE PRODUCTION OF DOCUMENTS
TO DEFENDANT EMPIRE CARE CENTERS, LLC:
PLAINTIFF’S FIRST CONTINUING REQUESTS FOR
ADMISSIONS TO DEFENDANT GLENWOOD HEALTH
CENTER BY HARBORVIEW, LLC d/b/a GLENWOOD
HEALTH CENTER BY HARBORVIEW; PLAINTIFF’S
FIRST CONTINUING INTERROGATORIES TO
DEFENDANT GLENWOOD HEALTH CENTER BY
HARBORVIEW, LLC d/b/a GLENWOOD HEALTH
CENTER BY HARBORVIEW; RULE 5.2 CERTIFICATE OF
SERVICE; PLAINTIFF’S FIRST CONTINUING
Page 1 of2
pe REF: Jones, Annie (GA) Tracking #: 0133567290
nn l I ins
Case No: 24CV5034
Plaintiff/Petitioner: THEODORE SMOTHERS, INDIVIDUALLY AND ON BEHALF OF THE ESTATE OF ANNIE
Defendant/Respondent: ONES
ATLANTA GA OPCO LLC D/B/A BUCKHEAD CENTER FOR NURSING & HEALING, ET AL.
REQUESTS FOR ADMISSIONS TO DEFENDANT
ATLANTA GA OPCO, LLC d/b/a BUCKHEAD CENTER
FOR NURSING & HEALING; PLAINTIFF’S FIRST
CONTINUING REQUESTS FOR THE PRODUCTION OF
DOCUMENTS TO DEFENDANT ATLANTA GA OPCO,
LLC d/b/a BUCKHEAD CENTER FOR NURSING &
HEALING; PLAINTIFF’S FIRST CONTINUING
INTERROGATORIES TO DEFENDANT ATLANTA GA
OPCO, LLC d/b/a BUCKHEAD CENTER FOR NURSING
& HEALING
Received by Michael Harbuck, on the 24th day of May, 2024 at 3:41 PM to be served upon Atlanta GA OP Co LLC
d/b/a Buckhead Center for Nursing & Healing at 5437 Bowman Rd Ste 416, Macon, Bibb County, GA 31210.
On the 25th day of May, 2024 at 9:01 AM, |, Michael Harbuck, SERVED Atlanta GA OP Co LLC d/b/a Buckhead
Center for Nursing & Healing at 5437 Bowman Rd Ste 416, Macon, Bibb County, GA 31210 in the manner indicated
below:
CORPORATE SERVICE, by personally delivering 1 copy(ies) of the above listed documents to the named Corporation.
by serving DeDe Nichols, on behalf of said Corporation.
THE DESCRIPTION OF THE PERSON WITH WHOM THE COPY OF THIS PROCESS WAS LEFT IS AS FOLLOWS:
| delivered the documents to DeDe Nichols who identified themselves as the registered agent with identity
confirmed by subject stating their name. The individual accepted service with direct delivery. The individual
appeared to be a brown-haired white female contact 45-55 years of age, 5'8"-5'10" tall and weighing 140-160 Ibs.
Service Fee Total: $118.75
Per 28 U.S.C. § 1746, | declare under penalty of perjury under the laws of the United States of America that the foregoing
is true and correct.
NAME: M254 Dh loe b N/A 5-2 a4
Michael Harbuck Server ID # Date
Notary Public: Subscribed and sworn before me on this QQ day of Wow, in the year of 20.24
Personally known to me or identified by the following document: ©)
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Page 2 of 2
pee REF: Jones, Annie (GA) Tracking #: 0133567290
i | | il | | | | il
FILED 12/11/2023 1:52 PM CLERK OF SUPERIOR COURT DEKALB COUNTY GEORGIA,
IN THE SUPERIOR COURT OF DEKALB COUNTY
STATE OF GEORGIA
IN RE:
MOTION FOR APPOINTMENT AS CIVIL ACTION FILE NUMBER:
PERMANENT PROCESS SERVER 23MPR1502
PURSUANT TO O.C.G.A. §9-11-4(c)
ORDER APPOINTING PERMANENT PROCESS SERVER
FOR CALENDAR YEAR 2024
The foregoing motion having been read and considered; it is HEREBY ORDERED that
the following individual(s) is/are appointed as a permanent process server pursuant to O.C.G.A.
§9-11-4(c):
Joyce Clemmons Travis Cline Jason Garmon
Michael Harbuck Christopher Todd Horton Elizabeth Irvin
Anthony Jackson Chiquita Jackson Lorenzo Kenerson
Shirley Patricia Kirkland Ericka McMillon Ernesqueshia Parker
Marc Perlson Clark Richardson Michael Rivers
Margaret Ruddock Geoffrey Spellen James Stiggers
This appointment shall be effective until midnight December 31, 2024.
IT IS SO ORDERED 8" day of December, 2023.
Y
ALY RGA MW
rable LaTisha ar Jackson
Chief and Administrative Judge
DeKalb County Superior Court
Stone Mountain Judicial Circuit
Preview
IN THE SUPERIOR COURT OF DEKALB COUNTY, STATE OF GEORGIA THEODORE SMOTHERS, INDIVIDUALLY AND ON Case No. 24CV5034 BEHALF OF THE ESTATE OF ANNIE JONES Plaintiff/Petitioner vs. ATLANTA GA OPCO LLC D/B/A BUCKHEAD CENTER AFFIDAVIT OF SERVICE OF FOR NURSING & HEALING, ET AL. SUMMONS; COMPLAINT; PLAINTIFF’S FIRST Defendant/Respondent CONTINUING REQUESTS FOR ADMISSIONS TO DEFENDANT THOMAS MARTENS; PLAINTIFF’S FIRST CONTINUING REQUESTS FOR THE PRODUCTION OF DOCUMENTS TO DEFENDANT THOMAS MARTENS: PLAINTIFF’S FIRST CONTINUING INTERROGATORIES TO DEFENDANT THOMAS MARTENS; PLAINTIFF’S FIRST CONTINUING REQUESTS FOR ADMISSIONS TO DEFENDANT ENSH CONSULTING, LLC; PLAINTIFF’S FIRST CONTINUING REQUESTS FOR THE PRODUCTION OF DOCUMENTS TO DEFENDANT ENSH CONSULTING, LLC; PLAINTIFF’S FIRST CONTINUING INTERROGATORIES TO DEFENDANT ENSH CONSULTING, LLC; PLAINTIFF’S FIRST CONTINUING REQUESTS FOR ADMISSIONS TO DEFENDANT GA NC 14 HOLDINGS, LLC; PLAINTIFF’S FIRST CONTINUING REQUESTS FOR THE PRODUCTION OF DOCUMENTS TO DEFENDANT GA NC 14 HOLDINGS, LLC; PLAINTIFF’S FIRST CONTINUING INTERROGATORIES TO DEFENDANT GLENWOOD HEALTH CENTER BY GA NC 14 HOLDINGS, LLC; PLAINTIFF’S FIRST CONTINUING REQUESTS FOR ADMISSIONS TO DEFENDANT HARBORVIEW HEALTH SYSTEMS, INC. PLAINTIFF’S FIRST CONTINUING REQUESTS FOR THE PRODUCTION OF DOCUMENTS TO DEFENDANT HARBORVIEW HEALTH SYSTEMS, INC.; PLAINTIFF’S FIRST CONTINUING INTERROGATORIES TO DEFENDANT HARBORVIEW HEALTH SYSTEMS, INC. PLAINTIFF’S FIRST CONTINUING REQUESTS FOR ADMISSIONS TO DEFENDANT GA 2 HOLDCO, LLC: PLAINTIFF’S FIRST CONTINUING REQUESTS FOR THE PRODUCTION OF DOCUMENTS TO DEFENDANT GA 2 HOLDCO, LLC; PLAINTIFF’S FIRST CONTINUING INTERROGATORIES TO DEFENDANT GA 2 HOLDCO. LLC; PLAINTIFF’S FIRST CONTINUING REQUESTS FOR ADMISSIONS TO DEFENDANT EMPIRE CARE CENTERS, LLC; PLAINTIFF’S FIRST CONTINUING REQUESTS FOR THE PRODUCTION OF DOCUMENTS TO DEFENDANT EMPIRE CARE CENTERS, LLC: PLAINTIFF’S FIRST CONTINUING REQUESTS FOR ADMISSIONS TO DEFENDANT GLENWOOD HEALTH CENTER BY HARBORVIEW, LLC d/b/a GLENWOOD HEALTH CENTER BY HARBORVIEW; PLAINTIFF’S FIRST CONTINUING INTERROGATORIES TO DEFENDANT GLENWOOD HEALTH CENTER BY HARBORVIEW, LLC d/b/a GLENWOOD HEALTH CENTER BY HARBORVIEW; RULE 5.2 CERTIFICATE OF SERVICE; PLAINTIFF’S FIRST CONTINUING Page 1 of2 pe REF: Jones, Annie (GA) Tracking #: 0133567290 nn l I ins Case No: 24CV5034 Plaintiff/Petitioner: THEODORE SMOTHERS, INDIVIDUALLY AND ON BEHALF OF THE ESTATE OF ANNIE Defendant/Respondent: ONES ATLANTA GA OPCO LLC D/B/A BUCKHEAD CENTER FOR NURSING & HEALING, ET AL. REQUESTS FOR ADMISSIONS TO DEFENDANT ATLANTA GA OPCO, LLC d/b/a BUCKHEAD CENTER FOR NURSING & HEALING; PLAINTIFF’S FIRST CONTINUING REQUESTS FOR THE PRODUCTION OF DOCUMENTS TO DEFENDANT ATLANTA GA OPCO, LLC d/b/a BUCKHEAD CENTER FOR NURSING & HEALING; PLAINTIFF’S FIRST CONTINUING INTERROGATORIES TO DEFENDANT ATLANTA GA OPCO, LLC d/b/a BUCKHEAD CENTER FOR NURSING & HEALING Received by Michael Harbuck, on the 24th day of May, 2024 at 3:41 PM to be served upon Atlanta GA OP Co LLC d/b/a Buckhead Center for Nursing & Healing at 5437 Bowman Rd Ste 416, Macon, Bibb County, GA 31210. On the 25th day of May, 2024 at 9:01 AM, |, Michael Harbuck, SERVED Atlanta GA OP Co LLC d/b/a Buckhead Center for Nursing & Healing at 5437 Bowman Rd Ste 416, Macon, Bibb County, GA 31210 in the manner indicated below: CORPORATE SERVICE, by personally delivering 1 copy(ies) of the above listed documents to the named Corporation. by serving DeDe Nichols, on behalf of said Corporation. THE DESCRIPTION OF THE PERSON WITH WHOM THE COPY OF THIS PROCESS WAS LEFT IS AS FOLLOWS: | delivered the documents to DeDe Nichols who identified themselves as the registered agent with identity confirmed by subject stating their name. The individual accepted service with direct delivery. The individual appeared to be a brown-haired white female contact 45-55 years of age, 5'8"-5'10" tall and weighing 140-160 Ibs. Service Fee Total: $118.75 Per 28 U.S.C. § 1746, | declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. NAME: M254 Dh loe b N/A 5-2 a4 Michael Harbuck Server ID # Date Notary Public: Subscribed and sworn before me on this QQ day of Wow, in the year of 20.24 Personally known to me or identified by the following document: ©) yitllltegy, BY 44, % S\' A,%, lotary Public (Legal ignature) = SARY Sec aw 3O sr; om” 8z 3a Pye & FOS &. dae aks os 0%" “i On col ys wo Vaaenggast® Page 2 of 2 pee REF: Jones, Annie (GA) Tracking #: 0133567290 i | | il | | | | il FILED 12/11/2023 1:52 PM CLERK OF SUPERIOR COURT DEKALB COUNTY GEORGIA, IN THE SUPERIOR COURT OF DEKALB COUNTY STATE OF GEORGIA IN RE: MOTION FOR APPOINTMENT AS CIVIL ACTION FILE NUMBER: PERMANENT PROCESS SERVER 23MPR1502 PURSUANT TO O.C.G.A. §9-11-4(c) ORDER APPOINTING PERMANENT PROCESS SERVER FOR CALENDAR YEAR 2024 The foregoing motion having been read and considered; it is HEREBY ORDERED that the following individual(s) is/are appointed as a permanent process server pursuant to O.C.G.A. §9-11-4(c): Joyce Clemmons Travis Cline Jason Garmon Michael Harbuck Christopher Todd Horton Elizabeth Irvin Anthony Jackson Chiquita Jackson Lorenzo Kenerson Shirley Patricia Kirkland Ericka McMillon Ernesqueshia Parker Marc Perlson Clark Richardson Michael Rivers Margaret Ruddock Geoffrey Spellen James Stiggers This appointment shall be effective until midnight December 31, 2024. IT IS SO ORDERED 8" day of December, 2023. Y ALY RGA MW rable LaTisha ar Jackson Chief and Administrative Judge DeKalb County Superior Court Stone Mountain Judicial Circuit