Joe Ann Clack v. Silverado Senior Living, Inc.

I. Introduction

On December 15, 2020, Joe Ann Clack (“Plaintiff”), by and through her guardian ad litem Zoanne Clack, brought this action in the Los Angeles Superior Court against the following defendants: Silverado Senior Living, Inc.; Silverado Senior Living Management, Inc.; Subtenant 330 North Hayworth Avenue, LLC (together with the preceding two Defendants, “Silverado” or the “Silverado Defendants”); Loren Shook (“Shook”); Jason Russo (“Russo”) (together with Shook, the “Individual Defendants”) (together with Shook and the Silverado Defendants, “Defendants”); and Does 1 through 25. Dkt. 1 at 39-60 (“Complaint”).1 On May 5, 2021, the action was removed. Dkt. 1 at 1-38. The Complaint advances two causes of action: (i) elder abuse and neglect, and (ii) negligence. Complaint ¶¶ 57-75.

The Clack action has been consolidated for pretrial purposes with the following cases (the “Consolidated Cases”):

1. Albert Sarnoff, et al. v. Silverado Senior Living, Inc., et al., LA CV 21-70; 2. Jakob Khorsandi, et al. v. Silverado Senior Living, Inc., et al., LA CV 21-1503; 3. Catherine Apothaker, et al. v. Silverado Senior Living, Inc., et al., LA CV 21-1509; 4. Anne Palamides v.…