Joan Risner 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 Cal-Red Facility, LLC dba Asistencia Villa Rehabilitation & Care Center; Diane Machain; and Does 1-25. (“Complaint,” Dkt. No. 1-1.)

1 Defendant Silverscreen Healthcare Inc. dba Asistencia Villa Rehabilitation and Care Center was erroneously named in the Complaint as Cal-Red Facility, LLC dba Asistencia Villa Rehabilitation & Care Center. (“Removal,” Dkt. No. 1 at 1-2.) Plaintiffs’ Complaint alleges elder abuse and neglect, violation of patient rights, negligence, and wrongful death. (Id. at 1.)

Defendants removed the action to federal court on August 5, 2021. (“Removal,” Dkt. No. 1.) On September 2, 2021, Plaintiffs filed the Motion. (Motion.) Defendants opposed the Motion on September 27, 2021. (“Opposition,” Dkt. No. 20.) 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’…