BARBARA ROCK-LEWIS BY AND THROUGH HER SUCCESSOR-IN-INTEREST, DAVID CLEAVER, ET AL. VS BERKLEY VALLEY CONVALESCENT HOSPITAL, INC. , ET AL.

Barbara Rock-Lewis by and through her Successor in Interest, David Cleaver, et al. v. Berkley Valley

Convalescent Hospital, Inc. dba Berkley Valley Convalescent Hospital, et al.

(1) DEFENDANT BERKLEY VALLEY CONVALESCENT HOSPITAL, INC. dba BERKLEY VALLEY CONVALESCENT HOSPITAL’S DEMURRER TO PLAINTIFF’S COMPLAINT;

(2) DEFENDANT BERKLEY VALLEY CONVALESCENT HOSPITAL, INC. dba BERKLEY VALLEY CONVALESCENT HOSPITAL’S MOTION TO STRIKE PORTIONS OF PLAINTIFF’S COMPLAINT

MOVING PARTY: (1)-(2) Defendant Berkley Valley Convalescent Hospital, Inc. dba Berkley Valley Convalescent Hospital

RESPONDING PARTY(S): (1)-(2) Plaintiff Barbara Rock-Lewis by and through her successor-in-interest David Cleaver, and Plaintiff David Cleaver, individually

STATEMENT OF MATERIAL FACTS AND/OR PROCEEDINGS:

This is an elder abuse action. Plaintiff Barbara Rock-Lewis’s successor in interest alleges that Defendants comm........