Julia Rios De Vitela v. Silverscreen Healthcare Inc

I. BACKGROUND

This is a wrongful death case. On June 4, 2021, Plaintiffs filed a complaint in San Bernardino County Superior Court against Defendants Cal-Red Facility, LLC dba Asistencia Villa Rehabilitation & Care Center; Diane Machain; and Does 1-25. (“Complaint,” Dkt. No. 1- 1; “Removal,” Dkt. No. 1.) Plaintiffs’ Complaint alleges elder abuse and neglect, violation of patient rights, negligence, and wrongful death. (Complaint at 1.)

On August 4, 2021, Defendants removed the action to federal court. (Removal.) On September 1, 2021, Plaintiffs filed the Motion. (Motion.) Defendants opposed the Motion on September 27, 2021. (“Opposition,” Dkt. No. 21.) That same day, Defendants filed a Request for Judicial Notice in support of the Opposition (“Request,” Dkt. No. 21.) Plaintiffs replied on September 29, 2021 (“Reply,” Dkt. No. 22.)

II. REQUEST FOR JUDICIAL NOTICE

Defendants request judicial notice of the following documents:

 Plaintiffs’ Complaint for Damages, dated June 4, 2021 (Exhibit 1);  Official acts of the United States Health and Human Services Secretary and his office (Exhibits 2-5, 30, 33-34);  Letter by Robert Charrow, General Counsel for the…