Johnson v. BLC Lexington SNF, LLC et al
| Carrie Johnson |
| HCP, Inc., BKD Twenty One Management Company, Inc., Chad C. White, Brookdale Employee Services - Corporate LLC, Geraldine Gordon-Krupp, Ann Phillips, ARC Richmond Place, Inc., BLC Lexington SNF, LLC, Brookdale Senior Living Communities, Inc., Park Place Investments, LLC, Horizon Bay Management, LLC, Joanne Leskowicz, Brookdale Senior Living, Inc., Mary Sue Patchett, Thomas Smith, BRE Knight SH KY Owner, LLC, Brookdale Employee Services, LLC, American Retirement Corporation, HBP Leaseco Inc., Benita Dickenson, Brookdale Associate Fund, Inc., Bryan Richardson, ARC Therapy Services, LLC, BKD Richmond Place Propco, LLC, George T. Hicks, Emeritus Corporation, ARC Richmond Place Real Estate Holdings, LLC, Lucinda Baier, BKD Personal Assistance Services, LLC, Labeed Diab and Emericare Inc |
| 5:2019cv00064 |
| February 21, 2019 |
| US District Court for the Eastern District of Kentucky |
| Danny C Reeves |
| P.I.: Other |
| 28 U.S.C. § 1441 |
| Plaintiff |
Docket Report
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| Document Text |
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Filing 48
ORDER: 1. Plaintiff Carrie Johnson's motion for leave to file excess pages #45 is GRANTED. The response may not exceed 40 pages; 2. Plaintiff Johnson's motion for jurisdictional discovery #22 is DENIED, as moot; 3. Plaintiff Johnson's motion to stay #47 is DENIED. Signed by Judge Danny C. Reeves on 4/19/2019. (STC)cc: COR
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| NOTICE OF DOCKET MODIFICATION TO Laraclay Parker re #43 Response to Motion. Error: This document was not filed as an attachment to #45 motion for leave to file Excess Pages. Correction: the clerk tendered the Response. An electronically submitted document requiring leave of Court shall be filed as an attachment to the motion and not as a separate entry. No further action required by counsel. cc: COR (STC) |
| Filing 47 MOTION to Stay by Carrie Johnson RENEWED MOTION TO STAY (Attachments: #1 Proposed Order PROPOSED ORDER)(Parker, Laraclay) |
| Filing 46 MOTION for Discovery by Carrie Johnson RENEWED MOTION FOR JURISDICTIONAL DISCOVERY (Attachments: #1 Proposed Order PROPOSED ORDER)(Parker, Laraclay) |
| Filing 45 MOTION for Leave to File Excess Pages by Carrie Johnson MOTION TO FILE RESPONSE IN EXCESS OF PAGE LIMIT (Attachments: #1 Proposed Order Proposed Order)(Parker, Laraclay) |
| Filing 44 RESPONSE to Motion re #33 MOTION to Dismiss for failure to state a claim by Ann Phillips filed by Carrie Johnson. (Attachments: #1 Proposed Order Proposed Order)(Parker, Laraclay) |
| Filing 43 RESPONSE to Motion re #32 MOTION to Dismiss for failure to state a claim by Benita Dickenson , #31 MOTION to Dismiss for Lack of Jurisdiction by ARC Richmond Place, Inc., ARC Therapy Services, LLC, BKD Personal Assistance Services, LLC, BKD Richmond Place Propco, LLC, BKD Twenty One Management Company, Inc., BRE Knight SH KY Owner, LLC, Brookdale, #30 MOTION to Dismiss for Lack of Jurisdiction by Lucinda Baier, Labeed Diab, Geraldine Gordon-Krupp, George T. Hicks, Joanne Leskowicz, Mary Sue Patchett, Bryan Richardson, Thomas Smith, Chad C. White COMBINED RESPONSE filed by Carrie Johnson. (Attachments: #1 Exhibit 1 - Protecting Nursing Home Company Article, #2 Exhibit 2 - Protecting Nursing Home Residents from Attacks on Their Ability to Recover Damages Article, #3 Exhibit 3 - Benita Dickenson Deposition, #4 Exhibit 4 - Stacy Trunecek Deposition, #5 Exhibit 5 - Brookdale Richmond Place Promotional Materials, #6 Exhibit 6 - Medicare Ownershp Information, #7 Exhibit 7 - CMS Technical Users Guide, #8 Exhibit 8 - CMS 671 Form, #9 Exhibit 9 - NPPES FAQ, CMS Center for Program Integrity, #10 Exhibit 10 - National Provider Identifier Database Lookup, #11 Exhibit 11 - Outpatient Rehab and Home Health Form, #12 Exhibit 12 - Brookdale Richmond Place Webpage PDF, #13 Exhibit 13 - PVA Documents, #14 Exhibit 14 - Master Lease Agreement, #15 Exhibit 15 - McKnight's Long Term Care News Article, #16 Exhibit 16 - Proposed Guidance, #17 Exhibit 17 - SOS Documents, #18 Proposed Order Proposed Order)(Parker, Laraclay) Modified on 4/19/2019 (STC). |
| Filing 42 RESPONSE to Motion re #35 MOTION to Dismiss for failure to state a claim by American Retirement Corporation, BLC Lexington SNF, LLC, Brookdale Senior Living Communities, Inc., Brookdale Senior Living, Inc., Benita Dickenson, Ann Phillips filed by Carrie Johnson. (Attachments: #1 Exhibit 1 - AFFIDAVIT OF LARACLAY PARKER, #2 Exhibit 2 - AFFIDAVIT OF CARRIE JOHNSON, #3 Exhibit 3 - CMS FORM 671 2016 EXAMPLE, #4 Proposed Order PROPOSED ORDER)(Parker, Laraclay) |
| Filing 41 RESPONSE to Motion re #28 MOTION to Remand to State Court by Carrie Johnson (Renewed Motion to Remand) filed by ARC Richmond Place, Inc., ARC Therapy Services, LLC, American Retirement Corporation, BKD Personal Assistance Services, LLC, BKD Richmond Place Propco, LLC, BKD Twenty One Management Company, Inc., BLC Lexington SNF, LLC, BRE Knight SH KY Owner, LLC, Lucinda Baier, Brookdale Associate Fund, Inc., Brookdale Employee Services - Corporate LLC, Brookdale Employee Services, LLC, Brookdale Senior Living Communities, Inc., Brookdale Senior Living, Inc., Labeed Diab, Benita Dickenson, Emericare Inc, Emeritus Corporation, Geraldine Gordon-Krupp, George T. Hicks, Horizon Bay Management, LLC, Joanne Leskowicz, Park Place Investments, LLC, Mary Sue Patchett, Ann Phillips, Bryan Richardson, Thomas Smith, Chad C. White. (Attachments: #1 Exhibit A - Plaintiff's Expert Disclosures in Fayette Circuit Court Case Addressing Damages, #2 Exhibit B - California Class Action against Brookdale Senior Living, Inc., #3 Exhibit C - Florida Class Action against Brookdale Senior Living, Inc.)(Cocanougher, Matthew) |
| ***MOTION SUBMITTED TO CHAMBERS of Judge Reeves for review: re #22 MOTION for Discovery by Carrie Johnson MOTION FOR JURISDICTIONAL DISCOVERY (STC) |
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Filing 40
ORDER: granting #34 Motion for Leave to file excess pages. Signed by Judge Danny C. Reeves on 4/1/2019. (STC)cc: COR
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| NOTICE OF DOCKET MODIFICATION TO Matthew Cocanougher re #35 MOTION to Dismiss for failure to state a claim by American Retirement Corporation, BLC Lexington SNF, LLC, Brookdale Senior Living Communities, Inc., Brookdale Senior Living, Inc., Benita Dickenson, Ann Phillips. Error: This document was not filed as an attachment to #34 motion for leave to Exceed Page Limits. Correction: the clerk tendered the Motion to Dismiss. An electronically submitted document requiring leave of Court shall be filed as an attachment to the motion and not as a separate entry. No further action required by counsel. cc: COR (STC) |
| Filing 39 ANSWER to #27 Amended Complaint,,, Counts I through VIII by Brookdale Senior Living, Inc.. (Attachments: #1 Exhibit A - Admission Agreement)(Cocanougher, Matthew) |
| Filing 38 ANSWER to #27 Amended Complaint,,, Counts I through VIII by American Retirement Corporation. (Attachments: #1 Exhibit A - Admission Agreement)(Cocanougher, Matthew) |
| Filing 37 ANSWER to #27 Amended Complaint,,, Counts I through VIII by Brookdale Senior Living Communities, Inc.. (Attachments: #1 Exhibit A- Admission Agreement)(Cocanougher, Matthew) |
| Filing 36 ANSWER to #27 Amended Complaint,,, Counts I through VIII by BLC Lexington SNF, LLC. (Attachments: #1 Exhibit A - Admission Agreement)(Cocanougher, Matthew) |
| Filing 35 MOTION to Dismiss for failure to state a claim by American Retirement Corporation, BLC Lexington SNF, LLC, Brookdale Senior Living Communities, Inc., Brookdale Senior Living, Inc., Benita Dickenson, Ann Phillips (Attachments: #1 Exhibit A - Admission Agreement, #2 Proposed Order)(Cocanougher, Matthew) Modified on 4/1/2019 (STC). Modified on 4/1/2019 (STC). |
| Filing 34 MOTION for Leave by American Retirement Corporation, BLC Lexington SNF, LLC, Brookdale Senior Living Communities, Inc., Brookdale Senior Living, Inc., Benita Dickenson, Ann Phillips to Exceed Page Limits in Local Rule 7.1(d) (Attachments: #1 Proposed Order)(Cocanougher, Matthew) |
| Filing 33 MOTION to Dismiss for failure to state a claim by Ann Phillips (Attachments: #1 Exhibit Puckett v. Salyersville, #2 Proposed Order)(Cocanougher, Matthew) |
| Filing 32 MOTION to Dismiss for failure to state a claim by Benita Dickenson (Attachments: #1 Proposed Order)(Cocanougher, Matthew) |
| Filing 31 MOTION to Dismiss for Lack of Jurisdiction by ARC Richmond Place, Inc., ARC Therapy Services, LLC, BKD Personal Assistance Services, LLC, BKD Richmond Place Propco, LLC, BKD Twenty One Management Company, Inc., BRE Knight SH KY Owner, LLC, Brookdale Associate Fund, Inc., Brookdale Employee Services - Corporate LLC, Brookdale Employee Services, LLC, Emericare Inc, Emeritus Corporation, Horizon Bay Management, LLC, Park Place Investments, LLC (Attachments: #1 Proposed Order)(Cocanougher, Matthew) |
| Filing 30 MOTION to Dismiss for Lack of Jurisdiction by Lucinda Baier, Labeed Diab, Geraldine Gordon-Krupp, George T. Hicks, Joanne Leskowicz, Mary Sue Patchett, Bryan Richardson, Thomas Smith, Chad C. White (Attachments: #1 Proposed Order)(Cocanougher, Matthew) |
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Filing 29
ORDER: Plaintiff Carrie Johnson's first #23 Motion to Remand is DENIED, as moot. Signed by Judge Danny C. Reeves on 3/22/2019. (STC)cc: COR
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| Filing 28 MOTION to Remand to State Court by Carrie Johnson (Renewed Motion to Remand) (Attachments: #1 Memorandum in Support, #2 Exhibit 1 PVA Record of Ann Phillips, #3 Exhibit 2 LinkedIn Profile of Benita Dickenson, #4 Exhibit 3 CMS Form 671s signed by Ms. Dickenson, #5 Proposed Order)(Parker, Laraclay) |
| Filing 27 THIRD AMENDED COMPLAINT against ARC Richmond Place Real Estate Holdings, LLC, ARC Richmond Place, Inc., ARC Therapy Services, LLC, American Retirement Corporation, BKD Personal Assistance Services, LLC, BKD Richmond Place Propco, LLC, BKD Twenty One Management Company, Inc., BLC Lexington SNF, LLC, BRE Knight SH KY Owner, LLC, Lucinda Baier, Brookdale Associate Fund, Inc., Brookdale Employee Services - Corporate LLC, Brookdale Employee Services, LLC, Brookdale Senior Living Communities, Inc., Brookdale Senior Living, Inc., Labeed Diab, Benita Dickenson, Emericare Inc, Emeritus Corporation, Geraldine Gordon-Krupp, HBP Leaseco Inc., HCP, Inc., George T. Hicks, Horizon Bay Management, LLC, Joanne Leskowicz, Park Place Investments, LLC, Mary Sue Patchett, Ann Phillips, Bryan Richardson, Thomas Smith, Chad C. White, filed by Carrie Johnson.(KJR) |
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Filing 26
ORDER: (1) GRANTING pla's #18 Motion to alter or amend & file a Third Amended Complaint: (2) the court's 2/25/19 #17 Order is VACATED in part; the parties dismissed under the Order shall remain in this action; (3) DENYING AS MOOT dfts' #3 #4 #5 #6 #7 #8 #9 #10 #11 #12 #13 Motions to Dismiss; (4) DENYING AS MOOT pla's #24 Motion to Stay. Signed by Judge Danny C. Reeves on 3/15/19. (KJR)cc: COR. Modified text on 3/15/2019 (KJR).
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| Filing 25 RESPONSE to Motion re #11 MOTION to Dismiss for Lack of Jurisdiction by Horizon Bay Management, LLC, #5 MOTION to Dismiss for Lack of Jurisdiction by BKD Personal Assistance Services, LLC, #8 MOTION to Dismiss for Lack of Jurisdiction by Brookdale Employee Services, LLC, MOTION to Dismiss for Lack of Jurisdiction by Brookdale Associate Fund, Inc., #3 MOTION to Dismiss by BLC Lexington SNF, LLC, Brookdale Senior Living Communities, Inc., Brookdale Senior Living, Inc., Benita Dickenson, Ann Phillips, #12 MOTION to Dismiss for Lack of Jurisdiction by Park Place Investments, LLC, #4 MOTION to Dismiss for Lack of Jurisdiction by ARC Richmond Place, Inc., #7 MOTION to Dismiss for Lack of Jurisdiction by Brookdale Employee Services - Corporate LLC, #9 MOTION to Dismiss for Lack of Jurisdiction by Emericare Inc, #13 MOTION to Dismiss for Lack of Jurisdiction by BKD Richmond Place Propco, LLC, #10 MOTION to Dismiss for Lack of Jurisdiction by Emeritus Corporation, #6 MOTION to Dismiss for Lack of Jurisdiction by BKD Twenty One Management Company, Inc. PLAINTIFF'S RESPONSE TO MOTION TO DISMISS filed by Carrie Johnson. (Attachments: #1 Exhibit Exhibit 1 - Affidavit of Laraclay Parker, #2 Exhibit Exhibit 2 - Affidavit of Carrie Johnson, #3 Exhibit Exhibit 3 - Form CMS-671, #4 Proposed Order Proposed Order to Plf's Response to Motion to Dismiss)(Parker, Laraclay) |
| Filing 24 MOTION to Stay by Carrie Johnson Motion to Stay Ruling on Defendants' Motions to Dismiss (Attachments: #1 Proposed Order Proposed Order to Motion to Stay Ruling on Defendants' Motions to Dismiss)(Parker, Laraclay) |
| Filing 23 MOTION to Remand by Carrie Johnson MOTION TO REMAND (Attachments: #1 Memorandum in Support Memorandum of Law in Support of Motion to Remand, #2 Exhibit Exhibit 1 to Memorandum of Law in Support of Motion to Remand - Form CMS-671, #3 Proposed Order Proposed Order to Motion to Remand)(Parker, Laraclay) |
| Filing 22 MOTION for Discovery by Carrie Johnson MOTION FOR JURISDICTIONAL DISCOVERY (Attachments: #1 Memorandum in Support Memorandum of Law in Support of Motion for Jurisdictional Discovery, #2 Proposed Order Proposed Order to Motion for Jurisdictional Discovery)(Parker, Laraclay) |
| Filing 21 RESPONSE to Motion re #11 MOTION to Dismiss for Lack of Jurisdiction by Horizon Bay Management, LLC, #5 MOTION to Dismiss for Lack of Jurisdiction by BKD Personal Assistance Services, LLC, #8 MOTION to Dismiss for Lack of Jurisdiction by Brookdale Employee Services, LLC, MOTION to Dismiss for Lack of Jurisdiction by Brookdale Associate Fund, Inc., #3 MOTION to Dismiss by BLC Lexington SNF, LLC, Brookdale Senior Living Communities, Inc., Brookdale Senior Living, Inc., Benita Dickenson, Ann Phillips, #12 MOTION to Dismiss for Lack of Jurisdiction by Park Place Investments, LLC, #4 MOTION to Dismiss for Lack of Jurisdiction by ARC Richmond Place, Inc., #7 MOTION to Dismiss for Lack of Jurisdiction by Brookdale Employee Services - Corporate LLC, #9 MOTION to Dismiss for Lack of Jurisdiction by Emericare Inc, #13 MOTION to Dismiss for Lack of Jurisdiction by BKD Richmond Place Propco, LLC, #10 MOTION to Dismiss for Lack of Jurisdiction by Emeritus Corporation, #6 MOTION to Dismiss for Lack of Jurisdiction by BKD Twenty One Management Company, Inc. PLAINTIFF'S COMBINED RESPONSE TO DEFENDANTS' MOTIONS TO DISMISS FOR LACK OF JURISDICTION filed by Carrie Johnson. (Attachments: #1 Exhibit Exhibit 1 - Protecting Nursing Home Companies Limiting Liability Through Corporate Restructuring, #2 Exhibit Exhibit 2 - Protecting Nursing Home Residents From Attacks on Their Ability to Recover Damages Excerpts, #3 Exhibit Exhibit 3 - Benita Dickenson Deposition p 42, ll. 6-21, #4 Exhibit Exhibit 4 - Benita Dickenson Deposition p. 31, ll. 15-24; p. 70, ll. 13-17; p. 71, ll. 5-11; p. 301, ll. 8-25; p. 302, l. 1, #5 Exhibit Exhibit 5 - Stacy Trunecek Deposition p. 36, ll. 23-25; p. 37, ll. 1-11; p. 66, ll. 5-17, #6 Exhibit Exhibit 6 - Brookdale Richmond Place Promotional Materials, #7 Exhibit Exhibit 7 - Brookdale Richmond Place Webpage PDF, #8 Exhibit Exhibit 8 - PVA Documents, #9 Exhibit Exhibit 9 - Master Lease Agreement Selected Pages, #10 Exhibit Exhibit 10 - McKnight's Long Term Care News, Treasury Department denies tax benefit to Skilled Care Facilities, #11 Exhibit Exhibit 11 - Proposed Guidance - Prop. Reg. Section 1. 199A-5(c)(2)(i), #12 Exhibit Exhibit 12 - BKD Richmond Place Propoco, LLC and BLC Lexington SNF, LLC SOS Webpage PDF, #13 Exhibit Exhibit 13 - BLC Lexington SNF, LLC SNF Incorporation Documents, #14 Proposed Order Proposed Order)(Parker, Laraclay) |
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Filing 20
ORDER: DENYING pla's #19 Motion to substitute an exhibit. Signed by Judge Danny C. Reeves on 3/11/19. (KJR)cc: COR
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| Filing 19 MOTION to Amend/Correct #18 MOTION to Amend/Correct by Carrie Johnson MOTION TO ALTER OR AMEND AND TO FILE THIRD AMENDED COMPLAINT MOTION for Leave by Carrie Johnson to Substitute Exhibit (Attachments: #1 Memorandum in Support of Motion to Substitute Exhibit, #2 Exhibit Proposed Third Amended Complaint, #3 Proposed Order Granting Motion to Substitute Exhibit)(Parker, Laraclay) |
| NOTICE OF DOCKET MODIFICATION TO Laraclay Parker re #18 MOTION to Amend/Correct by Carrie Johnson MOTION TO ALTER OR AMEND AND TO FILE THIRD AMENDED COMPLAINT. Error: This motion requests 2 forms of relief and only one form of relief was selected; Entry by attorney; Clerk added the motion relief requested. In the future, when filing a motion with multiple reliefs, select a motion relief for each relief requested so all motions will appear on the Judge's motion report. No further action required by counsel. cc: COR (STC) |
| Filing 18 MOTION to Amend/Correct by Carrie Johnson MOTION TO ALTER OR AMEND AND TO FILE THIRD AMENDED COMPLAINT (Attachments: #1 Memorandum in Support Memorandum of Law on Motion to Alter or Amend and to File Third Amended Complaint, #2 Exhibit Exhibit 1 - First Amended Complaint, #3 Exhibit Exhibit 2 - Second Amended Complaint, #4 Exhibit Exhibit 3 - Proposed Third Amended Complaint, #5 Exhibit Exhibit 4 - Complaint, #6 Exhibit Exhibit 5 - State Court Order, #7 Exhibit Exhibit 6 - Chart of Claims, #8 Proposed Order Proposed Order Granting Motion to File Third Amended Complaint, #9 Proposed Order Proposed Order re Listed Defendants to Remain Parties to Action)(Parker, Laraclay). Added MOTION for Leave on 3/7/2019 (STC). |
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Filing 17
ORDER: 1. The twenty-two motions to dismiss filed on November 30, 2018, areDISMISSED, as moot; 2. The motion to stay is DISMISSED, as moot. 3. The motion to compel is DISMISSED, as premature. 4. Defendants BRE Knight SH KY Owner, LLC; ARC Therapy Services, LLC; Brookdale Associate Fund, Inc.; Lucinda Baier; Chad C. White; Mary Sue Patchett; Joanne Leskowicz; George T. Hicks; Labeed Diab; Geraldine Gordon-Krupp; Bryan Richardson; and Thomas Smith are DISMISSED as parties to the case. Signed by Judge Danny C. Reeves on 2/25/2019.(STC)cc: COR Modified on 3/15/2019 (KJR). (VACATED per Court's #26 Order)
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| Filing 16 RESPONSE to Motion re MOTION to Stay by Carrie Johnson filed by George T. Hicks. (Filed in state court and attached herein at #1 )(STC) |
| Filing 14 MOTION to Dismiss for Lack of Jurisdiction by Brookdale Employee Services - Corporate LLC (Filed in state court and attached herein at #1 ). (STC) Modified on 2/22/2019 (STC). |
| RESPONSE to Motion re MOTION to Stay by Carrie Johnson filed by Labeed Diab. (Filed in state court and attached herein at #1 )(STC) |
| RESPONSE to Motion re MOTION to Stay by Carrie Johnson filed by Brookdale Employee Services - Corporate LLC. (Filed in state court and attached herein at #1 )(STC) |
| RESPONSE to Motion re MOTION to Stay by Carrie Johnson filed by Geraldine Gordon-Krupp. (Filed in state court and attached herein at #1 )(STC) |
| RESPONSE to Motion re MOTION to Stay by Carrie Johnson filed by Brookdale Associate Fund, Inc.(Filed in state court and attached herein at #1 )(STC) |
| RESPONSE to Motion re MOTION to Stay by Carrie Johnson filed by Joanne Leskowicz. (Filed in state court and attached herein at #1 )(STC) |
| RESPONSE to Motion re MOTION to Stay by Carrie Johnson filed by ARC Richmond Place, Inc. (Filed in state court and attached herein at #1 )(STC) |
| REPLY to Response to Motion re MOTION to Dismiss for Lack of Jurisdiction by BRE Knight SH KY Owner, LLC filed by BRE Knight SH KY Owner, LLC. (Filed in state court and attached herein at #1 ) (STC) |
| REPLY to Response to Motion re MOTION to Dismiss for Lack of Jurisdiction by BKD Twenty One Management Company, Inc. filed by BKD Twenty One Management Company, Inc. (Filed in state court and attached herein at #1 ) (STC) |
| RESPONSE to Motion re MOTION to Stay by Carrie Johnson filed by Chad C. White. (Filed in state court and attached herein at #1 )(STC) |
| RESPONSE to Motion re MOTION to Stay by Carrie Johnson filed by ARC Therapy Services, LLC. (Filed in state court and attached herein at #1 ) (STC) |
| RESPONSE to Motion re MOTION to Stay by Carrie Johnson filed by BKD Twenty One Management Company, Inc. (Filed in state court and attached herein at #1 )(STC) |
| RESPONSE to Motion re MOTION to Stay by Carrie Johnson filed by BRE Knight SH KY Owner, LLC. (Filed in state court and attached herein at #1 )(STC) |
| RESPONSE to Motion re MOTION to Stay by Carrie Johnson filed by Horizon Bay Management, LLC. (Filed in state court and attached herein at #1 )(STC) |
| RESPONSE to Motion re MOTION to Stay by Carrie Johnson filed by Thomas Smith. (Filed in state court and attached herein at #1 )(STC) |
| RESPONSE to Motion re MOTION to Stay by Carrie Johnson filed by Mary Sue Patchett. (Filed in state court and attached herein at #1 )(STC) |
| RESPONSE to Motion re MOTION to Stay by Carrie Johnson filed by Bryan Richardson. (Filed in state court and attached herein at #1 )(STC) |
| ***MOTION SUBMITTED TO CHAMBERS of Judge Reeves for review: re MOTION to Dismiss by Labeed Diab, MOTION to Dismiss for Lack of Jurisdiction by BKD Twenty One Management Company, Inc., MOTION to Dismiss by Geraldine Gordon-Krupp, MOTION to Dismiss for Lack of Jurisdiction by BKD Personal Assistance Services, LLC, MOTION to Dismiss by Mary Sue Patchett, MOTION to Compel by ARC Richmond Place, Inc., BLC Lexington SNF, LLC, Benita Dickenson, MOTION to Dismiss by Lucinda Baier, MOTION to Dismiss for Lack of Jurisdiction by ARC Therapy Services, LLC, 14 MOTION to Dismiss for Lack of Jurisdiction by Brookdale Employee Services - Corporate LLC, MOTION to Dismiss for Lack of Jurisdiction by Brookdale Employee Services, LLC, MOTION to Dismiss for Lack of Jurisdiction by Emeritus Corporation, MOTION to Dismiss by Bryan Richardson, MOTION to Dismiss for Lack of Jurisdiction by BKD Richmond Place Propco, LLC, MOTION to Dismiss for Lack of Jurisdiction by Horizon Bay Management, LLC, MOTION to Dismiss for Lack of Jurisdiction by Emericare Inc, MOTION to Dismiss by Chad C. White, MOTION to Dismiss by George T. Hicks, MOTION to Dismiss for Lack of Jurisdiction by Park Place Investments, LLC, MOTION to Dismiss by Thomas Smith, MOTION to Stay by Carrie Johnson, MOTION to Dismiss for Lack of Jurisdiction by BRE Knight SH KY Owner, LLC, MOTION to Dismiss for Lack of Jurisdiction by Brookdale Associate Fund, Inc., MOTION to Dismiss for Lack of Jurisdiction by ARC Richmond Place, Inc., MOTION to Dismiss by Joanne Leskowicz (STC) |
| REPLY to Response to Motion re MOTION to Dismiss for Lack of Jurisdiction by BKD Personal Assistance Services, LLC filed by BKD Personal Assistance Services, LLC. (Filed in state court and attached herein at #1 )(STC) |
| RESPONSE to Motion re MOTION to Stay by Carrie Johnson filed by Lucinda Baier. (Filed in state court and attached herein at #1 )(STC) |
| RESPONSE to Motion re MOTION to Stay by Carrie Johnson filed by Emericare Inc. (Filed in state court and attached herein at #1 )(STC) |
| RESPONSE to Motion re MOTION to Stay by Carrie Johnson filed by Benita Dickenson. (Filed in state court and attached herein at #1 )(STC) |
| RESPONSE to Motion re MOTION to Stay by Carrie Johnson filed by Ann Phillips. (Filed in state court and attached herein at #1 )(STC) |
| RESPONSE to Motion re MOTION to Stay by Carrie Johnson filed by BKD Richmond Place Propco, LLC. (Filed in state court and attached herein at #1 )(STC) |
| RESPONSE to Motion re MOTION to Stay by Carrie Johnson filed by Park Place Investments, LLC. (Filed in state court and attached herein at #1 )(STC) |
| RESPONSE to Motion re MOTION to Stay by Carrie Johnson filed by Brookdale Employee Services, LLC. (Filed in state court and attached herein at #1 )(STC) |
| REPLY to Response to Motion re MOTION to Dismiss for Lack of Jurisdiction by ARC Richmond Place, Inc. filed by ARC Richmond Place, Inc.(Filed in state court and attached herein at #1 )(STC) |
| MOTION to Compel by ARC Richmond Place, Inc., BLC Lexington SNF, LLC, Benita Dickenson (Filed in state court and attached herein at #1 ). (STC) |
| MOTION to Dismiss by Bryan Richardson (Filed in state court and attached herein at #1 ). (STC) |
| MOTION to Dismiss for Lack of Jurisdiction by Park Place Investments, LLC (Filed in state court and attached herein at #1 ). (STC) |
| MOTION to Dismiss for Lack of Jurisdiction by Horizon Bay Management, LLC (Filed in state court and attached herein at #1 ). (STC) |
| MOTION to Dismiss for Lack of Jurisdiction by Emeritus Corporation (Filed in state court and attached herein at #1 ). (STC) |
| MOTION to Dismiss by Chad C. White (Filed in state court and attached herein at #1 ). (STC) |
| REPLY to Response to Motion re MOTION to Dismiss for Lack of Jurisdiction by ARC Therapy Services, LLC filed by ARC Therapy Services, LLC. (Filed in state court and attached herein at #1 )(STC) |
| MOTION to Dismiss by Mary Sue Patchett (Filed in state court and attached herein at #1 ). (STC) |
| MOTION to Dismiss by Labeed Diab (Filed in state court and attached herein at #1 ). (STC) |
| MOTION to Dismiss by Joanne Leskowicz (Filed in state court and attached herein at #1 ). (STC) |
| MOTION to Dismiss by Geraldine Gordon-Krupp (Filed in state court and attached herein at #1 ). (STC) |
| MOTION to Dismiss for Lack of Jurisdiction by Emericare Inc (Filed in state court and attached herein at #1 ). (STC) |
| MOTION to Dismiss for Lack of Jurisdiction by Brookdale Employee Services, LLC (Filed in state court and attached herein at #1 ). (STC) |
| ANSWER to Complaint by Brookdale Senior Living, Inc. (Filed in state court and attached herein at #1 ). (STC) |
| MOTION to Dismiss for Lack of Jurisdiction by ARC Richmond Place, Inc. (Filed in state court and attached herein at #1 ). (STC) |
| ANSWER to Complaint by Brookdale Senior Living Communities, Inc. (Filed in state court and attached herein at #1 ). (STC) |
| ANSWER to Complaint by American Retirement Corporation. (Filed in state court and attached herein at #1 ). (STC) |
| ANSWER to Complaint by BLC Lexington SNF, LLC. (Filed in state court and attached herein at #1 ). (STC) |
| MOTION to Dismiss for Lack of Jurisdiction by ARC Therapy Services, LLC (Filed in state court and attached herein at #1 ). (STC) |
| MOTION to Dismiss for Lack of Jurisdiction by BKD Personal Assistance Services, LLC (Filed in state court and attached herein at #1 ). (STC) |
| MOTION to Dismiss for Lack of Jurisdiction by Brookdale Associate Fund, Inc. (Filed in state court and attached herein at #1 ). (STC) |
| MOTION to Dismiss for Lack of Jurisdiction by BRE Knight SH KY Owner, LLC (Filed in state court and attached herein at #1 ). (STC) |
| MOTION to Dismiss for Lack of Jurisdiction by BKD Twenty One Management Company, Inc. (Filed in state court and attached herein at #1 ). (STC) |
| MOTION to Dismiss for Lack of Jurisdiction by BKD Richmond Place Propco, LLC (Filed in state court and attached herein at #1 ). (STC) |
| MOTION to Dismiss by Lucinda Baier (Filed in state court and attached herein at #1 ). (STC) |
| MOTION to Dismiss by George T. Hicks (Filed in state court and attached herein at #1 ). (STC) |
| REPLY to Response to Motion re MOTION to Dismiss for Lack of Jurisdiction by Horizon Bay Management, LLC filed by Horizon Bay Management, LLC. (Filed in state court and attached herein at #1 ) (STC) |
| REPLY to Response to Motion re MOTION to Dismiss for Lack of Jurisdiction by Park Place Investments, LLC filed by Park Place Investments, LLC. (Filed in state court and attached herein at #1 ) (STC) |
| REPLY to Response to Motion re MOTION to Dismiss by Bryan Richardson filed by Bryan Richardson. (Filed in state court and attached herein at #1 ) (STC) |
| REPLY to Response to Motion re MOTION to Dismiss by Thomas Smith filed by Thomas Smith. (Filed in state court and attached herein at #1 ) (STC) |
| MOTION to Dismiss by Thomas Smith (Filed in state court and attached herein at #1 ). (STC) |
| REPLY to Response to Motion re MOTION to Dismiss for Lack of Jurisdiction by Emericare Inc filed by Emericare Inc. (Filed in state court and attached herein at #1 )(STC) |
| REPLY to Response to Motion re MOTION to Dismiss for Lack of Jurisdiction by BKD Richmond Place Propco, LLC filed by BKD Richmond Place Propco, LLC. (Filed in state court and attached herein at #1 ) (STC) |
| REPLY to Response to Motion re MOTION to Dismiss for Lack of Jurisdiction by Brookdale Associate Fund, Inc. filed by Brookdale Associate Fund, Inc. (Filed in state court and attached herein at #1 )(STC) |
| REPLY to Response to Motion re 14 MOTION to Dismiss for Lack of Jurisdiction by Brookdale Employee Services - Corporate LLC filed by Brookdale Employee Services - Corporate LLC. (Filed in state court and attached herein at #1 )(STC) |
| REPLY to Response to Motion re MOTION to Dismiss for Lack of Jurisdiction by Brookdale Employee Services, LLC filed by Brookdale Employee Services, LLC. (Filed in state court and attached herein at #1 )(STC) |
| REPLY to Response to Motion re MOTION to Dismiss by Lucinda Baier filed by Lucinda Baier. (Filed in state court and attached herein at #1 ) (STC) |
| REPLY to Response to Motion re MOTION to Dismiss for Lack of Jurisdiction by Emeritus Corporation filed by Emeritus Corporation. (STC) |
| Conflict Check run. (STC) |
| SECOND AMENDED COMPLAINT against ARC Richmond Place Real Estate Holdings, LLC, ARC Richmond Place, Inc., American Retirement Corporation, BKD Personal Assistance Services, LLC, BKD Richmond Place Propco, LLC, BKD Twenty One Management Company, Inc., BLC Lexington SNF, LLC, Brookdale Employee Services - Corporate LLC, Brookdale Employee Services, LLC, Brookdale Senior Living Communities, Inc., Brookdale Senior Living, Inc., Benita Dickenson, Emericare Inc, Emeritus Corporation, HBP Leaseco Inc., HCP, Inc., Horizon Bay Management, LLC, Park Place Investments, LLC, Ann Phillips, filed by Carrie Johnson.(Filed in state court and attached herein at #1 ). (STC) |
| AMENDED COMPLAINT against ARC Richmond Place, Inc., ARC Therapy Services, LLC, American Retirement Corporation, BKD Personal Assistance Services, LLC, BKD Richmond Place Propco, LLC, BKD Twenty One Management Company, Inc., BLC Lexington SNF, LLC, BRE Knight SH KY Owner, LLC, Lucinda Baier, Brookdale Associate Fund, Inc., Brookdale Employee Services - Corporate LLC, Brookdale Employee Services, LLC, Brookdale Senior Living Communities, Inc., Brookdale Senior Living, Inc., Labeed Diab, Benita Dickenson, Emericare Inc, Emeritus Corporation, Geraldine Gordon-Krupp, George T. Hicks, Horizon Bay Management, LLC, Joanne Leskowicz, Park Place Investments, LLC, Mary Sue Patchett, Ann Phillips, Bryan Richardson, Thomas Smith, Chad C. White, filed by Carrie Johnson.(Filed in state court and attached herein at #1 ). (STC) |
| MOTION to Stay by Carrie Johnson (Filed in state court and attached herein at #1 ). (STC) |
| RESPONSE to Motion re MOTION to Dismiss by Labeed Diab, MOTION to Dismiss for Lack of Jurisdiction by BKD Twenty One Management Company, Inc., MOTION to Dismiss by Geraldine Gordon-Krupp, MOTION to Dismiss for Lack of Jurisdiction by BKD Personal Assistance Services, LLC, MOTION to Dismiss by Mary Sue Patchett, MOTION to Dismiss by Lucinda Baier, MOTION to Dismiss for Lack of Jurisdiction by ARC Therapy Services, LLC, 14 MOTION to Dismiss for Lack of Jurisdiction by Brookdale Employee Services - Corporate LLC, MOTION to Dismiss for Lack of Jurisdiction by Brookdale Employee Services, LLC, MOTION to Dismiss for Lack of Jurisdiction by Emeritus Corporation, MOTION to Dismiss by Bryan Richardson, MOTION to Dismiss for Lack of Jurisdiction by BKD Richmond Place Propco, LLC, MOTION to Dismiss for Lack of Jurisdiction by Horizon Bay Management, LLC, MOTION to Dismiss for Lack of Jurisdiction by Emericare Inc, MOTION to Dismiss by Chad C. White, MOTION to Dismiss by George T. Hicks, MOTION to Dismiss for Lack of Jurisdiction by Park Place Investments, LLC, MOTION to Dismiss by Thomas Smith, MOTION to Dismiss for Lack of Jurisdiction by BRE Knight SH KY Owner, LLC, MOTION to Dismiss for Lack of Jurisdiction by Brookdale Associate Fund, Inc., MOTION to Dismiss for Lack of Jurisdiction by ARC Richmond Place, Inc., MOTION to Dismiss by Joanne Leskowicz filed by Carrie Johnson. (Filed in state court and attached herein at #1 )(STC) |
| REPLY to Response to Motion re MOTION to Dismiss by Mary Sue Patchett filed by Mary Sue Patchett. (Filed in state court and attached herein at #1 ) (STC) |
| REPLY to Response to Motion re MOTION to Dismiss by Chad C. White filed by Chad C. White.(Filed in state court and attached herein at #1 )(STC) |
| REPLY to Response to Motion re MOTION to Dismiss by Labeed Diab filed by Labeed Diab. (Filed in state court and attached herein at #1 ) (STC) |
| REPLY to Response to Motion re MOTION to Dismiss by Joanne Leskowicz filed by Joanne Leskowicz. (Filed in state court and attached herein at #1 ) (STC) |
| REPLY to Response to Motion re MOTION to Dismiss by George T. Hicks filed by George T. Hicks. (Filed in state court and attached herein at #1 ) (STC) |
| REPLY to Response to Motion re MOTION to Dismiss by Geraldine Gordon-Krupp filed by Geraldine Gordon-Krupp. (Filed in state court and attached herein at #1 ) (STC) |
| Filing 13 MOTION to Dismiss for Lack of Jurisdiction by BKD Richmond Place Propco, LLC (Attachments: #1 Proposed Order)(STC) |
| Filing 12 MOTION to Dismiss for Lack of Jurisdiction by Park Place Investments, LLC (Attachments: #1 Proposed Order)(STC) (Main Document 12 replaced on 2/22/2019) (STC). (Attachment 1 replaced on 2/22/2019) (STC). |
| Filing 11 MOTION to Dismiss for Lack of Jurisdiction by Horizon Bay Management, LLC (Attachments: #1 Proposed Order)(STC) |
| Filing 10 MOTION to Dismiss for Lack of Jurisdiction by Emeritus Corporation (Attachments: #1 Proposed Order)(STC) |
| Filing 9 MOTION to Dismiss for Lack of Jurisdiction by Emericare Inc (Attachments: #1 Proposed Order)(STC) |
| Filing 8 MOTION to Dismiss for Lack of Jurisdiction by Brookdale Employee Services, LLC (Attachments: #1 Proposed Order)(STC) |
| Filing 7 MOTION to Dismiss for Lack of Jurisdiction by Brookdale Employee Services - Corporate LLC (Attachments: #1 Proposed Order)(STC) |
| Filing 6 MOTION to Dismiss for Lack of Jurisdiction by BKD Twenty One Management Company, Inc. (Attachments: #1 Proposed Order)(STC) |
| Filing 5 MOTION to Dismiss for Lack of Jurisdiction by BKD Personal Assistance Services, LLC (Attachments: #1 Proposed Order)(STC) |
| Filing 4 MOTION to Dismiss for Lack of Jurisdiction by ARC Richmond Place, Inc. (Attachments: #1 Proposed Order)(STC) Modified text on 2/22/2019 (KJR). |
| Filing 3 MOTION to Dismiss by BLC Lexington SNF, LLC, Brookdale Senior Living Communities, Inc., Brookdale Senior Living, Inc., Benita Dickenson, Ann Phillips (Attachments: #1 Exhibit A Admission Agreement, #2 Proposed Order)(STC) |
| Filing 2 FRCP 7.1 DISCLOSURE STATEMENT by ARC Richmond Place, Inc., American Retirement Corporation, BKD Personal Assistance Services, LLC, BKD Richmond Place Propco, LLC, BKD Twenty One Management Company, Inc., BLC Lexington SNF, LLC, Brookdale Employee Services - Corporate LLC, Brookdale Employee Services, LLC, Brookdale Senior Living Communities, Inc., Brookdale Senior Living, Inc., Emericare Inc, Emeritus Corporation, Horizon Bay Management, LLC, Park Place Investments, LLC identifying Corporate Parent Brookdale Senior Living, Inc. for ARC Richmond Place, Inc., American Retirement Corporation, BKD Personal Assistance Services, LLC, BKD Richmond Place Propco, LLC, BKD Twenty One Management Company, Inc., BLC Lexington SNF, LLC, Brookdale Employee Services - Corporate LLC, Brookdale Employee Services, LLC, Brookdale Senior Living Communities, Inc., Emericare Inc, Emeritus Corporation, Horizon Bay Management, LLC, Park Place Investments, LLC.. (STC) |
| Filing 1 NOTICE OF REMOVAL from Fayette Circuit Court, case number 18-CI-3625. ( Filing fee $400; receipt number 0643-4292318), filed by Brookdale Employee Services - Corporate LLC, Benita Dickenson, BKD Personal Assistance Services, LLC, Horizon Bay Management, LLC, Park Place Investments, LLC, BKD Richmond Place Propco, LLC, American Retirement Corporation, Brookdale Senior Living Communities, Inc., Brookdale Employee Services, LLC, BKD Twenty One Management Company, Inc., Ann Phillips, ARC Richmond Place, Inc., Brookdale Senior Living, Inc., Emeritus Corporation, BLC Lexington SNF, LLC, Emericare Inc. (Attachments: #1 State Court Record, #2 Civil Cover Sheet)(STC) |
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