Case: EEOC v. Royal Wood Care Center

EEOC v. Royal Wood Care Center LLC

EEOC v. Royal Wood Care Center LLC

EEOC v. Royal Wood Care Center LLC

EEOC v. Royal Wood Care Center LLC

EEOC v. Royalwood Care Center LLC

EEOC v. Royalwood Care Center

Carly Knight, Frank Dobbin, Alexandra Kalev

COMPLAINT against Defendants Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Fountain View Inc, Skilled Healthcare LLC, Does 1−10. (Filing fee $ 250 PAID.) Jury Demand, filed by plaintiff U S Equal Employment Opportunity Commission. (jp, ) (Entered: 09/20/2005)

CERTIFICATION AS to Interested Parties filed by Plaintiff U S Equal Employment Opportunity Commission. (jp, ) (Entered: 09/20/2005)

NOTICE TO PARTIES OF ADR PILOT PROGRAM filed.(jp, ) (Entered: 09/20/2005)

FAX number for Attorneys Anna Y Park, Cherry−Marie D Rojas is 213−894−1301. (jp, ) (Entered: 09/20/2005)

20 DAY Summons Issued re Complaint − (Discovery) 1 as to Defendants Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Fountain View Inc, Skilled Healthcare LLC, Does 1−10. (jp, ) (Entered: 09/20/2005)

NOTICE of Change of Attorney Information: Attorney Cherry−Marie D. Rojas will no longer receive service of documents from the Clerks Office for the reason indicated in the G−06 Notice.Cherry−Marie D. Rojas is no longer attorney of record in this case for the reason indicated in the G−06 Notice. Filed by plaintiff U S Equal Employment Opportunity Commission. (pbap, ) (Entered: 12/12/2005)

MINUTES by Judge Audrey B. Collins; It is ordered that plaintiffs counsel show cause in writing not later than 1/15/06 why this action should not be dismissed for lack of prosecution as to defendants Royal Wood Care Center; Fountain View Subacute and Nursing Center; Fountain View; Skilled Healthcare. Court Reporter: n/a. (jag, ) (Entered: 12/19/2005)

WAIVER OF SERVICE Returned Executed filed by plaintiff U S Equal Employment Opportunity Commission. upon defendants Royal Wood Care Center LLC waiver sent by Plaintiff on 12/21/2005, answer due 2/19/2006; Fountain View Subacute and Nuring Center LLC waiver sent by Plaintiff on 12/21/2005, answer due 2/19/2006; Fountain View Inc waiver sent by Plaintiff on 12/21/2005, answer due 2/19/2006; Skilled Healthcare LLC waiver sent by Plaintiff on 12/21/2005, answer due 2/19/2006. Waiver of Service signed by Nikki Wilson, Attorney for defendants. (rrey, ) (Entered: 01/24/2006)

STIPULATION for Extension of Time Within Which to Answer or Respond to Plaintiff's Initial Complaint 1 : IT IS HEREBY STIPULATED, by and between counsel for plaitiff US Equal Employment Opportunity Commission and counsel for defendants, that Defendants shall, pursuant ot US District Court Cnetral District of CA LR 8−3, have up to and including 2/3/2006 to answer and/or otherwise respond to Plaintiff's complaint. This extension is less than 30 days. The parties have also stipulated that in the event the Defendants file a motion to dismiss, the hearing will be set for 3/6/2006 with the following briefing schedule: (See document for further details) filed by Defendants Royal Wood Care Center LLC, Fountain View Inc, Skilled Healthcare LLC. (yl, ) (Entered: 02/06/2006)

NOTICE of Interested Parties filed by Defendants Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Fountain View Inc, Skilled Healthcare LLC. (jag, ) (Entered: 02/06/2006)

MOTION to Dismiss plaintiffs complaint filed by defendants Royal Wood Care Center LLC, Fountain View Inc, Skilled Healthcare LLC. Motion set for hearing on 3/6/2006 at 01:30 PM before Judge Audrey B. Collins. (jag, ) (Entered: 02/09/2006)

NOTICE OF MOTION and MOTION to Dismiss plaintiffs complaint 9 filed by defendants Royal Wood Care Center LLC, Fountain View Inc, Skilled Healthcare LLC. (jag, ) (Entered: 02/09/2006)

REQUEST FOR JUDICIAL NOTICE filed by defendants Royal Wood Care Center LLC, Fountain View Inc, Skilled Healthcare LLC. (jag, ) (Entered: 02/09/2006)

ORDER RE: CONFERENCE: Pretrial Conference pursuant to FRCP 16 and 26; and Local Rule 26; 2) Motions and Ex Parte Application by Judge Audrey B. Collins that this matter is set for a Pretrial/Scheduling Conference on 4/17/2006 at 10:00 AM. The Joint Rule 26 (f) Report shall be file not later than one (1) week before the scheduling conference. A Notice of Settlement Selection Procedure, signed by counsel for both sides, shall be filed no later than 10 days after entry of this Order. (jp, ) (Entered: 02/13/2006)

OPPOSITION to MOTION to Dismiss plaintiffs complaint 9 filed by plaintiff U S Equal Employment Opportunity Commission. (jag, ) (Entered: 02/21/2006)

DECLARATION of DANA C JOHNSON in support of OPPOSITION to MOTION to Dismiss plaintiffs complaint 9 filed by plaintiff U S Equal Employment Opportunity Commission. (jag, ) (Entered: 02/21/2006)

REPLY to OPPOSITION to MOTION to Dismiss plaintiffs complaint 9 filed by defendants Royal Wood Care Center LLC, Fountain View Inc, Skilled Healthcare LLC. (jag, ) (Entered: 03/06/2006)

ORDER by Judge Audrey B. Collins : denying 9 Defendants' Motion to Dismiss.not reported (da, ) (Entered: 03/02/2006)

ANSWER to Complaint − (Discovery) 1 filed by defendants Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Fountain View Inc, Skilled Healthcare LLC.(jag, ) (Entered: 03/14/2006)

JOINT REPORT Rule 26(f) Discovery Plan filed; estimated length of trial 10 days. (jag, ) (Entered: 04/17/2006)

ADR PILOT PROGRAM QUESTIONNAIRE (jag, ) (Entered: 04/12/2006)

ORDER by Judge Audrey B. Collins, case ordered to the Attorney Settlement Officer Panel for an early settlement conference to be completed no later than 7/21/06. Within 10 days, plaintiff shall notify the ADR Program Coordinator of the name of the Attorney Settlement Officer who will conduct the settlement conference. Status Conference set for 8/14/2006 10:00 AM before Judge Audrey B. Collins.(jag, ) (Entered: 04/19/2006)

CIVIL JURY TRIAL ORDER by Judge Audrey B. Collins; Court orders the following dates: Cutoff date for filing motion to join other parties and amending the pleadings is 6/5/2006; Discovery cut−off 3/30/2006; Cutoff date for motions 4/30/2006; Final Pretrial Conference set for 7/23/2007 10:00 AM; Jury Trial set for 8/7/2007 08:30 AM. (see document for details)(jag, ) (Entered: 04/19/2006)

Plaintiff's NOTICE OF MOTION AND MOTION to Amend 1 Complaint − (Discovery), filed by Plaintiff U S Equal Employment Opportunity Commission. Motion set for hearing on 6/26/2006 at 10:00 AM before Judge Audrey B. Collins. Lodged proposed order and 1st amended complaint. (shb, ) (Entered: 06/02/2006)

Plaintiff's MEMORANDUM of points and authorities in Support of MOTION to Amend 1 Complaint − (Discovery) 23 ; Declaration of Sue J Noh filed by Plaintiff U S Equal Employment Opportunity Commission. (shb, ) (Entered: 06/02/2006)

STIPULATION REGARDING SELECTION of Attorney Settlement Officer Filed; Parties stipulate that John Weiss may serve as Attorney Settlement Officer for Settlement Proceedings The Plaintiff obtained the consent of the Attorney Settlement Officer.(lc, ) (Entered: 06/09/2006)

STIPULATION TO EXTEND THE DATE In Which to Hear Plaintiff's Motion to Amend the Complaint and Related Dates by Judge Audrey B. Collins 23 : Good cause appearing therefore, IT IS HEREBY ORDERED that the hearing on Plaintiff's Motion to amend the Complaint currently scheduled for 6/26/2006 be continued to 7/24/2006 at 10:00 AM before Judge Audrey B. Collins. IT IS SO ORDERED.(yl, ) (Entered: 06/20/2006)

DECLARATION of Nikki Wilson in support of Defendants opposition to Plaintiffs motion to Amend the pleadings 1 23 filed by Defendants Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Fountain View Inc, Skilled Healthcare LLC. (ir, ) (Entered: 06/21/2006)

OPPOSITION to Plaintiffs motion to amend the pleadings 1 23 filed by Defendants Royal Wood Care Center LLC, Fountain View Inc, Skilled Healthcare LLC. (ir, ) (Entered: 06/21/2006)

DECLARATION of Cindy Vandran in support of Defendants Opposition to Plaintiffs Motion to amend the pleadings 1 23 filed by Defendants Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Fountain View Inc, Skilled Healthcare LLC. (ir, ) (Entered: 06/21/2006)

REPLY re Plaintiff's MOTION to Amend 1 Complaint − (Discovery) 23 filed by plaintiff U S Equal Employment Opportunity Commission. (shb, ) (Entered: 06/23/2006)

MINUTES OF IN CHAMBERS ORDER held before Judge Audrey B. Collins: GRANTING Plaintiff's MOTION to Amend 1 Complaint − (Discovery), 23 . Plaintiff may file a First Amended Complaint. IT IS SO ORDERED. Court Reporter: Not Present. (shb, ) (Entered: 07/17/2006)

FIRST AMENDED COMPLAINT against Defendant Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Fountain View Inc, Skilled Healthcare LLC amending Complaint − (Discovery), Complaint − (Discovery) 1 ,filed by Plaintiff U S Equal Employment Opportunity Commission (yl, ) (Entered: 08/01/2006)

PLACED IN FILE − NOT USED re (Proposed) Order re EEOC's Motion to Amend Complaint submitted by plaintiff U S Equal Employment Opportunity Commission. (shb, ) (Entered: 07/17/2006)

ORDER AND STIPULATION TO EXTEND TIME TO COMPLETE EARLY SETTLEMENT CONFERENCE AND FOR A CONTINUANCE OF STATUS CONFERENCE by Judge Audrey B. Collins :, Resetting HEARING as to Scheduling Conference, 22 Last date to conduct settlement conference is 10/31/2006. Status Conference reset for 11/13/2006 10:00 AM before Judge Audrey B. Collins.(shb, ) (Entered: 07/21/2006)

NOTICE of Interested Parties filed by Defendants Fountain View Subacute and Nursing Center Inc, Skilled Healthcare Group Inc, Royal Wood Care Center LLC, Fountain View Subacute and Nursing Center LLC, Fountain View Inc, Skilled Healthcare LLC. (pcl, ) (Entered: 09/14/2006)

ANSWER to First Amended Complaint 33 filed by defendants Fountain View Subacute and Nursing Center Inc, Skilled Healthcare Group Inc, Royal Wood Care Center LLC, Fountain View Subacute and Nursing Center LLC, Fountain View Inc, Skilled Healthcare LLC.(pcl, ) (Entered: 09/14/2006)

AMENDED STIPULATION REGARDING SELECTION of Attorney Settlement Officer Filed; Parties stipulate that Michael Wolfram may serve as Attorney Settlement Officer for an early settlement conference. (pcl, ) (Entered: 09/26/2006)

ATTORNEY SETTLEMENT OFFICER PROCEEDING REPORT filed; Settlement Proceedings held on 10/23/06; Settlement Proceedings Outcome: the proceeding was continued;(bp, ) (Entered: 11/09/2006)

NOTICE of Adding New Address to Service List by Nikki L Wilson attorney for Defendants Fountain View Subacute Nursing Center Inc, Skilled Healthcare Group Inc, Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Fountain View Inc, Skilled Healthcare LLC, changing address to 5000 Birch Street, Suite 4800, Newport Beach, CA 92660. Filed by defendant Royalwood Care Center, LLC, Fountain View, Inc., Fountain View Subacute and Nursing Center, LLC, Skilled Healthcare, LLC, Skilled Healthcare Group, Inc., Summit Care Corp., Summit Care−California, Inc. dba Royalwood Care Center, Summit Care Pharmacy nc. (stsh, ) (Entered: 11/08/2006)

MINUTES OF Status Conference held before Judge Audrey B. Collins: Court orders the parties to file a joint Status Report by 2/6/2007 and schedules a further Status Conference hearing for 2/12/2007 at 10:00 AM. Court Reporter: Kathrine Stride. (pcl, ) (Entered: 11/14/2006)

STATUS REPORT filed by Plaintiff U S Equal Employment Opportunity Commission. (lc, ) (Entered: 02/07/2007)

MINUTES OF Status Conference held before Judge Audrey B. Collins: Counsel informs Court of the status of the case.Court Reporter: Katherine Stride. (pcl, ) (Entered: 02/14/2007)

STIPULATION To Extend Discovery Cut−Off and Related Dates AND ORDER by Judge Audrey B. Collins: IT IS ORDERED THAT the Discovery cut−off shall be continued to 6/28/2007; the Motion cut−off shall be continued to Monday, 7/30/2007; the Pretrial Conference shall be continued to 10/22/2007 at 10:00 AM; and Trial shall start on 11/6/2007 at 8:30 AM. (pcl, ) (Entered: 02/22/2007)

JOINT STIPULATION Regarding Plaintiff EEOCs Motion to Compel Production of Documents filed by plaintiff U S Equal Employment Opportunity Commission, and defendants Fountain View Holdings Inc, Fountain View Management Inc, Fountain View Subacute Nursing Center Inc, Fountain View Therapy Services Inc, The Royalwood Convalescent Hospital Inc, Skilled Healthcare Group Inc, Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Fountain View Inc, Skilled Healthcare LLC. (pcl, ) (Entered: 03/13/2007)

DECLARATION of Nikki Wilson in Support of Joint Stipulation Regarding Plaintiff EEOCs Motion to Compel Production of Documents 43 filed by Defendants Fountain View Holdings Inc, Fountain View Management Inc, Fountain View Subacute Nursing Center Inc, Fountain View Therapy Services Inc, The Royalwood Convalescent Hospital Inc, Skilled Healthcare Group Inc, Royal Wood Care Center LLC, Fountain View Subacute and Nursing Center LLC, Fountain View Inc, Skilled Healthcare LLC. (pcl, ) (Entered: 03/13/2007)

DECLARATION of Sue J Noh in Connection with Motion to Compel Documents 43 filed by Plaintiff U S Equal Employment Opportunity Commission. (pcl, ) (Entered:

NOTICE of Association of Counsel associating attorney Laura Karen Sitar on behalf of Defendant Skilled Healthcare LLC. Filed by defendant Skilled Healthcare LLC. (jp) (Entered: 04/04/2007)

STIPULATED PROTECTIVE ORDER by Judge Paul L. Abrams: With regard to personnel information Plaintiff and Defendants agree that, for any document or deposition transcript that either party files with the Court or otherwise discloses to any individual or entity that is not a party to this litigation, the filing or disclosing party shall redact the last name of the employee or former employee, as well as addresses, telephone numbers and dates of birth prior to filing. Defendant may designate non−public financial information ordered to be produced by the Court pursuant to tis 3/13/2007 Order as confidential. IT IS SO ORDERED. (See document for further details.) (pcl, ) (Entered: 03/30/2007)

NOTICE OF MOTION AND MOTION for Contempt, for Monetary Sanctions, and Request to Extend Discovery Cut−Off Date and Related Dates filed by plaintiff U S Equal Employment Opportunity Commission.Motion set for hearing on 7/3/2007 at 10:00 AM before Judge Audrey B. Collins. (ad) (Entered: 06/28/2007)

JOINT STIPULATION Re MOTION for Contempt, for Monetary Sanctions, and Request to Extend Discovery Cut−Off Date and Related Dates 50 filed by Defendants Fountain View Holdings Inc, Fountain View Management Inc, Fountain View Subacute Nursing Center Inc, Fountain View Therapy Services Inc, The Royalwood Convalescent Hospital Inc, Skilled Healthcare Group Inc, Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Fountain View Inc, Skilled Healthcare LLC, Plaintiff U S Equal Employment Opportunity Commission. (ad) (Entered: 06/28/2007)

DECLARATION of Sue J Noh in support of MOTION for Contempt, for Monetary Sanctions, and Request to Extend Discovery Cut−Off Date 50 filed by Plaintiff U S Equal Employment Opportunity Commission. (ad) (Entered: 06/28/2007)

DECLARATION of Nikki Wilson in support of Joint Stipulation Regarding Plaintiff's MOTION for Contempt 50 filed by Defendants Fountain View Holdings Inc, Fountain View Management Inc, Fountain View Subacute Nursing Center Inc, Fountain View Therapy Services Inc, The Royalwood Convalescent Hospital Inc, Skilled Healthcare Group Inc, Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Fountain View Inc, Skilled Healthcare LLC. (ad) (Entered: 06/28/2007)

FAX number for Attorneys Dana C Johnson, Sue J Noh is 213−894−1301. (ad) (Entered: 06/28/2007)

NOTICE OF MOTION AND MOTION to Extend the Discovery Cutoff and Related Dates filed by plaintiff U S Equal Employment Opportunity Commission. Declaration of Dana C Johnson. Declaration of Sue J Noh. Exhibits.Motion set for hearing on 7/2/2007 at 10:00 AM before Judge Audrey B. Collins. Lodged Proposed Order. (ad) (Entered: 06/28/2007)

Defendants' OPPOSITION to EEOC's Motion to extend discovery cutoff and Related Dates; MOTION to Extend Discovery Cut−Off Date to 9/28/2007 50 , MOTION for Order for to Extend the Discovery Cutoff and Related Dates 54 (ear) (Entered: 07/09/2007)

DECLARATION of Nikki Wilson in support of defendants' opposition to EEOC's Motion to Extend Discovery Cutoff and Related Dates; filed by Defendants; MOTION for Order for to Extend the Discovery Cutoff and Related Dates 54 (ear) (Entered: 07/09/2007)

Defendants' supplemental briefing regarding EEOC's Motion for Contempt; MOTION for Contempt against Defendants, MOTION for Sanctions, MOTION to Extend

DECLARATION of Kelly Atkins in support of defendants' supplemental briefing regarding EEOC's Motion for Contempt; filed by Defendants; Supplement(Motion related) 60 (ear) (Entered: 07/09/2007)

DECLARATION of Nikki Wilson in support of defendants' supplemental briefing regarding EEOC's Motion for Contempt; filed by Defendants; Supplement(Motion related) 60 (ear) (Entered: 07/09/2007)

[PROPOSED] ORDER RE: PLAINTIFF EEOC Notice Motion and Motion to Extend the Discovery Cutoff and Related Dates is DENIED by Judge Audrey B. Collins. (jp) (Entered: 06/21/2007)

REPLY re: MOTION to Extend the Discovery Cutoff and Related Dates 54 ; Declaration for Sue J. Noh & Exhibits, filed by Plaintiff U S Equal Employment Opportunity Commission. (yca) (Entered: 07/10/2007)

REQUEST FOR JUDICIAL NOTICE, filed by Defendants Summit Care Corporation, Summit Care−California, Inc dba Royal Wood Care Center, Summit Care Pharmacy, Inc., Fountain View Subacute Nursing Center Inc, Skilled Healthcare Group Inc, Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Fountain View Inc, Skilled Healthcare LLC. (yca) (Entered: 07/12/2007)

ORDER Re Plaintiffs Motion for Contempt, Monetary Sanctions, and Extension of Discovery Cut−Off by Judge Paul L. Abrams: Plaintiffs Motion for Contempt is denied as to plaintiffs request for an order of contempt and for sanctions, but granted as follows: (1) No later than 7/6/2007 defendants shall either (1) produce the contact information already provided in the three bankers boxes of printouts in an electronic format that plaintiff is capable of reading, sorting and manipulating, or (b) pay the costs of plaintiff hiring a service to input into its computer base the three bankers boxes of printouts and convert them into a usable electronic format. (2) No later than 7/9/2007 defendants shall, at their own expense, produce all of the subject personnel files at plaintiffs offices for inspection and copying by plaintiff. The costs of copying shall be borne by plaintiff. (See document for further details.) (pcl) (Entered: 06/28/2007)

EX PARTE APPLICATION for An Order Clarifying and/or Modifying the Courts Order Compelling Production of Personnel files; Memorandum of Points and Authorities; Declarations; Exhibits filed by defendants Royalwood Care Center,LLC, Fountain View, Inc., Fountain View Subacute and Nursing Center, LLC, Skilled Healthcare, LLC, fountain View Subacute and Nursing Center, Inc, Skilled Healthcare Group, Inc, Summit Care Corporation, Summit Care−California, Inc, and Summit Care Pharmacy, Inc. Lodged proposed order. (pcl) (Entered: 07/06/2007)

DECLARATION of Thomas Mackey in support of defendants' EX PARTE APPLICATION for an Order clarifying and/or modifying the court's Order compelling production of personnel files; filed by defendants; EX PARTE APPLICATION for Order 56 (ear) (Entered: 07/18/2007)

DECLARATION of Lori Stewart in Support of EX PARTE APPLICATION for Modification of Order Compelling Production of Personnel Files 56 filed by Defendants Fountain View Subacute Nursing Center Inc, Skilled Healthcare Group Inc, Summit Care Corporation, Summit Care Pharmacy, Inc., Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Fountain View Inc, Movant Summit Care−California, Inc dba Royal Wood Care Center. (pcl) (Entered: 07/23/2007)

ORDER RE EX PARTE APPLICATION for An Order Clarifying and/or Modifying The Courts Order Compelling Production of Personnel files 56 by Judge Paul L. Abrams: Accordingly, defendants application is granted in part as follows: (1) No later than 7/13/2007, defendants shall, at their own expense, produce all of the subject personnel files of their former employees at plaintiffs offices for inspection and copying by plaintiff. (See document for further details.) (2) Defendants shall either copy the subject personnel files of their current employees, or scan the files in PDF format, and deliver the copies or scanned files to plaintiff no later than 20 business days following entry of this order. (See document for further details.) (pcl) (Entered: 07/06/2007)

PLAINTIFF EEOC OPPOSITION to Defendants EX PARTE APPLICATION for An Order Clarifying and/or Modifying the Courts Order Compelling Production of Personnel files 56 and declaration of Dana C. Johnson filed by Plaintiff U S Equal Employment Opportunity Commission. (et) (Entered: 07/18/2007)

PROOF OF PERSONAL SERVICE filed by Defendants Fountain View Subacute Nursing Center Inc, The Royalwood Convalescent Hospital Inc, Skilled Healthcare Group Inc, Summit Care Corporation, Summit Care−California, Inc dba Royal Wood Care Center, Summit Care Pharmacy, Inc., Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Fountain View Inc, Skilled Healthcare LLC, re EX PARTE APPLICATION for Order for Compelling Production of Personnel files 56 served on 07/02/2007. (csa) (Entered: 07/20/2007)

DECLARATION of Dana C. Johnson; filed by plaintiff U.S. Equal Employment Opportunity Commission (ear) (Entered: 07/24/2007)

Defendants' NOTICE of motion for joint stipulation re: defendants' Motion for protective order to prevent the EEOC from sending a mass mailing to thousands of defendants' current and former employees; filed by defendants, Fountain View Subacute Nursing Center Inc, Skilled Healthcare Group Inc, Summit Care Corporation, Summit Care Pharmacy, Inc., Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Fountain View Inc, Skilled Healthcare LLC.; Lodged proposed Order (ear) (Entered: 07/26/2007)

Joint STIPULATION re: defendants' Motion for Protective Order to prevent the EEOC from sending a mass mailing to thousands of defendants' current and former employees; filed by defendants, Fountain View Subacute Nursing Center Inc, Skilled Healthcare Group Inc, Summit Care Corporation, Summit Care Pharmacy, Inc., Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Fountain View Inc, Skilled Healthcare LLC.(ear) (Entered: 07/26/2007)

DECLARATION of Kelly Atkins in support of defendants' motion for protective order to prevent the from EEOC sending a mass mailing to thousands of defendants' current and former employees; filed by defendants Fountain View Subacute Nursing Center Inc, Skilled Healthcare Group Inc, Summit Care Corporation, Summit Care Pharmacy, Inc., Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Skilled Healthcare LLC.; Notice 74 (ear) (Entered: 07/26/2007)

DECLARATION of Nikki Wilson in support of defendants' motion for protective order to prevent the EEOC from sending a mass mailing to thousands of defendants' current and former employees; filed by defendants, Skilled Healthcare Group Inc, Summit Care Corporation, Summit Care Pharmacy, Inc., Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Fountain View Inc, Skilled Healthcare LLC.; Notice 74 (ear) (Entered: 07/27/2007)

NOTICE OF DISCREPANCY AND ORDER: by Judge Fernando M. Olguin, ORDERING Joint Stipulation re Motion for Protective Order submitted by Defendant Fountain View Holdings Inc received on 7/6/2007 is not to be filed but instead rejected. Denial based on: Local Rule 6.1 Written notice of motion lacking.(vdr) (Entered: 07/17/2007)

SUPPLEMENTAL MEMORANDUM Re: Defendants' Motion for Protective Order to Prevent The EEOC from Sending Mass Mailing 75 filed by Plaintiff U S Equal Employment Opportunity Commission. (csa) (Entered: 07/31/2007)

ORDER RE: DISCOVERY MOTION by Judge Fernando M. Olguin for Judge Paul L. Abrams. The court has reviewed defendants' Joint Stipulation Re: Defendants' Motion for Protective Order, filed 7/10/2007. The Motion is untimely. The discovery cut−off was 6/28/2007. The hearing set for 7/31/2007, is hereby vacated. Defendants' Motion

Defendants' EX PARTE APPLICATION for an Order that the EEOC cease and desist its mass mailing and disclose the extent of mailing already initiated; Memorandum of Points and Authorities; Declarations; Exhibits (Local Rules 7−19.1 and 7.3) ([proposed] Order filed concurrently herewith}; filed by defendants Fountain View Subacute Nursing Center Inc, Skilled Healthcare Group Inc, Summit Care Corporation, Summit Care Pharmacy, Inc., Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Fountain View Inc, Skilled Healthcare LLC; Lodged proposed Order(ear) (Entered: 08/01/2007)

SUPPLEMENTAL briefing in support of defendants' Motion for Protective Order to prevent the EEOC from sending a mass mailing to thousands of defendants' current and former employees; filed by defendants, Fountain View Subacute Nursing Center, Inc., Skilled Healthcare Group, Inc., Summit Care Corporation, Summit Care Pharmacy, Inc., Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Fountain View. Inc., Skilled Healthcare LLC. Notice 74 (ear) (Entered: 08/01/2007)

DECLARATION of Thomas G. Mackey in support of defendants' supplemental brief for the motion for protective order to prevent the EEOC from sending a mass mailing to thousands of defendants' current and former employees; filed by defendants Fountain View Holdings Inc, Fountain View Subacute Nursing Center Inc, Skilled Healthcare Group Inc, Summit Care Corporation, Summit Care Pharmacy, Inc., Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Fountain View Inc, Skilled Healthcare LLC; Supplement 80 (ear) (Entered: 08/01/2007)

DECLARATION of Nikki Wilson in support of defendants' supplemental brief for the motion for protective order to prevent the EEOC from sending a mass mailing to thousands of defendants' current and former employees; filed by defendants Fountain View Holdings Inc, Fountain View Subacute Nursing Center Inc, Skilled Healthcare Group Inc, Summit Care Corporation, Summit Care Pharmacy, Inc., Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Fountain View Inc, Skilled Healthcare LLC; Supplement 80 (ear) (Entered: 08/01/2007)

DECLARATION of Thomas G. Mackey in support of defendants' EX PARTE APPLICATION 79 for an Order that the EEOC cease and desist its mass mailing and disclose the extent of mailing already initiated; filed by defendants Fountain View Subacute Nursing Center Inc, Skilled Healthcare Group Inc, Summit Care Corporation, Summit Care Pharmacy, Inc., Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Fountain View Inc, Skilled Healthcare LLC(ear) (Entered: 08/01/2007)

Objection and NOTICE OF MOTION AND MOTION for Review and Reconsideration of Magistrate Judge's Order 68 denying Motion for Protective Order to prevent the EEOC from sending a mass mailing pursuant to Local Rule 72−2.1 [filed concurrently with Memorandum of Points and Authorities; Declarations of Thomas G. Mackey and Nikki L. Wilson; (proposed) Order; Proof of Service] ; filed by defendants Fountain View Subacute Nursing Center Inc, Skilled Healthcare Group Inc, Summit Care Corporation, Summit Care Pharmacy, Inc., Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Fountain View Inc, Skilled Healthcare LLC; Motion set for hearing on 8/20/2007 at 10:00 AM before Judge Audrey B. Collins; Lodged proposed Order (ear) (Entered: 08/07/2007)

MEMORANDUM of Points and Authorities in support of objection and MOTION 90 for Review and Reconsideration of Magistrate Judge's Order 68 denying Motion for Protective Order to prevent the EEOC from sending a mass mailing, pursuant to Local Rule 72−2.1 [filed concurrently with Objection and Notice of Motion; (proposed) Order; Proof of Service]; filed by defendants Fountain View Subacute Nursing Center Inc, Skilled Healthcare Group Inc, Summit Care Corporation, Summit Care Pharmacy, Inc., Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Fountain View Inc, Skilled Healthcare LLC (ear) (Entered: 08/07/2007)

NOTICE OF MOTION AND MOTION for Contempt Due to Defendants' Repeated Failure to Comply with this Court's Orders and for Monetary Sanctions filed by plaintiff U S Equal Employment Opportunity Commission.Motion set for hearing on 8/21/2007 at 10:00 AM before Magistrate Judge Paul L. Abrams. (pcl) (Entered: 08/03/2007)

NOTICE OF MOTION AND MOTION for Modification of Orders Pertaining to the EEOC's Access to and Use of Social Secuirty Numbers and Pay Rates filed by plaintiff U S Equal Employment Opportunity Commission.Motion set for hearing on 8/21/2007 at 10:00 AM before Magistrate Judge Paul L. Abrams. (pcl) (Entered: 08/03/2007)

JOINT STIPULATION Re Second MOTION for Contempt Due to Defendants' Repeated Failure to comply with this Court's Orders and for monetary sanctions 85 filed by Plaintiff U S Equal Employment Opportunity Commission, defendants Fountain View Subacute Nursing Center Inc, Skilled Healthcare Group Inc, Summit Care Corporation, Summit Care Pharmacy, Inc., Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Fountain View Inc, Skilled Healthcare LLC, Movant Summit Care−California, Inc dba Royal Wood Care Center. (ad) Modified on 8/16/2007 (ad, ). (Entered: 08/16/2007)

DECLARATION of Thomas Mackey in support of Joint Stipulation Regarding Plaintiff's MOTION for Contempt 85 filed by Defendants Fountain View Subacute Nursing Center Inc, Skilled Healthcare Group Inc, Summit Care Corporation, Summit Care Pharmacy, Inc., Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Fountain View Inc, Skilled Healthcare LLC, Movant Summit Care−California, Inc dba Royal Wood Care Center. (ad) (Entered: 08/16/2007)

DECLARATION of Sue J Noh in connection with EX PARTE APPLICATION for Order for Shortening Time on (1) Plaintiff EEOC's [Proposed] Second Motion for Contempt Due to Defendants' Repeated Failure to Comply with this Court's Orders and For Monetary Sanctions and (2) Plaintiff EEOC' ;s [Proposed] Motion for Modification re: Orders Pertaining to the EEOC's Access to and Use of Social Security Numbers and Pay Rates 84 filed by Plaintiff U S Equal Employment Opportunity Commission. (ad) (Entered: 08/16/2007)

DECLARATION of Thomas Mackey In Support of Joint Stipulation 110 filed by Defendants.(vdr) (Entered: 08/20/2007)

EX PARTE APPLICATION for Order Shortening Time on Plaintiff EEOC's [Proposed] Motion for Reconsideration of This Court's 6/20/2007 Order Denying EEOC's Motion to Extend the Discovery Cut Off and Related dates filed by plaintiff U S Equal Employment Opportunity Commission. Lodged proposed order; Motion.(pcl) Modified on 8/16/2007 (ad, ). (Entered: 08/03/2007)

DECLARATION of Sue J Noh in connection with EX PARTE APPLICATION for Order Shortening Time on Plaintif EEOC's [Proposed] Motion for Reconsideration of This Court's 6/20/2007 Order Denying EEOC's Motion to Extend the Discovery Cut Off and Related dates 88 filed by Plaintiff U S Equal Employment Opportunity Commission. (ad) (Entered: 08/16/2007)

NOTICE OF MOTION AND MOTION for Reconsideration of 6/20/07 Order denying motion to extend the discovery cutoff and related dates 49 filed by plaintiff U S Equal Employment Opportunity Commission.Motion set for hearing on 8/20/2007 at 10:00 AM before Judge Audrey B. Collins. Memorandum of Points and Authorities; Declaration of Sue J Noh and Exhibits. (ad) (Entered: 08/16/2007)

OPPOSITION to Plaintiff's EX PARTE APPLICATION for Order Shortening Time on Motion for Contempt and Motion for Modification Re Orders as Pertains to Access to Social Security Numbers 84 filed by Defendants Fountain View Subacute Nursing Center Inc, Skilled Healthcare Group Inc, Summit Care Corporation, Summit Care Pharmacy, Inc., Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Fountain View Inc, Skilled Healthcare LLC, Movant Summit Care−California, Inc dba Royal Wood Care Center. (ad) (Entered: 08/16/2007)

DECLARATION of Thomas G Mackey in support of Opposition to Plaintiff's EX PARTE APPLICATION for Order Shortening Time on Motion for Contempt and Motion for Modification Re Orders as Pertains to Access to Social Security Numbers 84 filed by Defendants Fountain View Subacute Nursing Center Inc, Skilled Healthcare Group Inc, Summit Care Corporation, Summit Care Pharmacy, Inc., Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Skilled Healthcare LLC, Movant Summit Care−California, Inc dba Royal Wood Care Center. (ad) (Entered: 08/16/2007)

NOTICE OF MOTION AND MOTION for Summary Judgment, or in the alternative Partial Summary Judgment filed by defendants Fountain View Subacute Nursing Center Inc, Skilled Healthcare Group Inc, Summit Care Corporation, Summit Care−California, Inc dba Royal Wood Care Center, Summit Care Pharmacy, Inc., Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Skilled Healthcare LLC.Motion set for hearing on 8/20/2007 at 10:00 AM before Judge Audrey B. Collins. Lodged Proposed Judgment and Statement of Uncontroverted Facts. (ad) (Entered: 08/16/2007)

DECLARATION of Nikki Wilson in support of MOTION for Summary Judgment, or in the alternative Partial Summary Judgment 99 filed by Defendants Fountain View Subacute Nursing Center Inc, Skilled Healthcare Group Inc, Summit Care Corporation, Summit Care Pharmacy, Inc., Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Skilled Healthcare LLC, Movant Summit Care−California, Inc dba Royal Wood Care Center. (ad) (Entered: 08/16/2007)

DECLARATION of Thomas G Mackey in support of MOTION for Summary Judgment, or in the alternative Partial Summary Judgment 99 filed by Defendants Fountain View Subacute Nursing Center Inc, Skilled Healthcare Group Inc, Summit Care Corporation, Summit Care Pharmacy, Inc., Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Skilled Healthcare LLC, Movant Summit Care−California, Inc dba Royal Wood Care Center. (ad) (Entered: 08/16/2007)

DECLARATION of Rita C Simms in support of MOTION for Summary Judgment, or in the alternative Partial Summary Judgment 99 filed by Defendants Fountain View Subacute Nursing Center Inc, Skilled Healthcare Group Inc, Summit Care Corporation, Summit Care Pharmacy, Inc., Royal Wood Care Center LLC, Fountain View Subacute and Nuring Center LLC, Skilled Healthcare LLC, Movant Summit Care−California, Inc dba Royal Wood Care Center. (ad) (Entered: 08/16/2007)