Sandra Martin v. Baj Management, Inc.

I. Introduction

On November 1, 2021, Olive Brown (“Decedent”), by and through her successors in interest Sandra Martin (“Sandra”), Stanley Brown (“Stanley”), Elizabeth Brown (“Elizabeth”) and Charlotte Bland (“Charlotte”); and Sandra, Stanley, Elizabeth and Charlotte, individually (collectively, “Plaintiffs”) brought this action in the Los Angeles Superior Court against Baj Management, Inc., doing business as Prospect Manor (“Prospect Manor” or “Defendant”), and Does 1 through 100. Dkt. 1-1.1 The Complaint advances four causes of action: (i) elder abuse; (ii) willful misconduct; (iii) negligence; and (iv) wrongful death. Dkt. 1-1 ¶¶ 55–78. On December 10, 2021, Defendant removed the action (the “Notice of Removal”) and filed a request for judicial notice (the “Notice of Removal RJN”). Dkts. 1, 3. On February 2, 2022, Defendant filed a motion to dismiss (the “MTD”), and a corresponding request for judicial notice (the “MTD RJN”). Dkts. 18, 19. On April 25, 2022, Plaintiffs filed an opposition to the MTD (the “MTD Opposition”). Dkts. 24, 26. On May 2, 2022, Defendant filed a reply in support of the MTD (the “MTD Reply”). Dkt. 27. On February 3, 2022, Plaintiffs filed a motion to…