EPPS COULSON, LLP

1230 CRENsimw BLvu., Sum; 1230, TDRRANCE, CALIFORNIA, 90501

TEL (213) 929-2390 - FAX {21319192394

Dawn M. Coulson, SBN 154085
dcoulson@eppscoulson.com
Gabriel M. Courey, SBN 304489
gcourey@eppscoulson.com
EPPS COULSON, LLP

1230 Crenshaw Blvd., Ste. 200
Torrance, California 90501

(2l3) 929-2390 - Telephone
(213) 929-2394 Facsimile

Attorneys for Plaintiffs.

Arlene H. Rosales, as Trustee of The Arlene H.
Rosales Living Trust dated February 2, 2012; and
David Ross 11pew-r Ci. em if Califorrii 7'

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SUPERIOR COURT OF THE STATE OF CALIFORNIA

IN AND FOR THE COUNTY OF LOS ANGELES

ARLENE H. ROSALES, AS TRUSTEE OF
THE ARLENE H. ROSALES LIVING
TRUST DATED FEBRUARY 2, 2012; and
DAVID ROSS II, LLC, a California limited
liability company,

Plaintiffs,
vs.

LEGACY HEALTHCARE CENTER, LLC, a
California limited liability company; ROSE
GARDEN SUBACUTE 
REHABILITATION CENTER, LLC a
California limited liability company; DOV E.
JACOBS, an individual; MIRIAM TAUB, an
individual; and DOES 1 through 10, inclusive,

Defendants,

 

 

 

 

I



DECLARATION OF KRISTANA
LIAMKRAJANG, IN SUPPORT OF
APPLICATION FOR EX PARTE ORDER
APPOINTING RECEIVER AND FOR
ORDER TO SHOW CAUSE RE
CONFIRMATION OF APPOINTMENT
AND TEMPORARY RESTRAININ 
ORDER

Case No.:

DECLARATION OF KRISTANA LIAMKRAJANG IN SUPPORT OF APPLICATION FOR EX PARTE ORDER

APPOINTING RECEIVER AND FOR ORDER TO SHOW CAUSE RE CONFIRMATION OF APPOINTMENT



 

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$3

 ?llP tsrisirzna {icinmkrajang
i. Krisianr dce areas follows:
1. I. make this declaration based on my personal knowledge. l?li?called upon to testil'y
to the facts in this declaration. could and would competently do so.
2. I, am employed at the skilled nursing lacility commonly known as "legacy
Cerium" meager at i'x?ortn rait' Oaks .v?itenue. Pasadena. Calilbrnia. 1H it)?

Rosegarden i'lealthcare Center located at 1899 N. Raymond Pasadena Ca. 91 103

3. My job title is Business oiilice Manager
4. My job duties include n'tanages the ?nancial needs ot?the residents
5. I have been working, at facility for around 3 years

6. i did not get a paycheck the last payroll. My paycheck was due over a weelt ago on
Friday. January 24-, 2020.

7. 1 spoke with other employees who also told me that they were not paid.

8. Alter the. missed payday, i noticed some employees did not come back to work.

9. it} am not paid. soon. I wilt have to leave my job and find a new job to pay my bills
and earn a living.

10. ~Vendors who provide necessary healthcare services have been calling for payment
of unpaid bills.
1 l. The residents ol? this facility require readily available skilled nursing care and

supportive care on an extended basis. The residents include the elderly and disabled.

12. The environment oi in} VYOi'lx and the residents stay of admission has been
increasingly chaotic recently.

'13. Residents and employees have expressed deep anxiety about whether the facility is
closing because adequate arrangements l?or relocation of residents have not been made.

12. The way the. current, operator is managing this 'tacility is an accident waiting to

happen.

 It; sudden transit-2r nt?thc residents under these conditions would cause severe

kn

t'tt1-32'tlpti0n in their health and we
11" the ham .0 gn thn'rngit this much disorder any longm there in a big

16.
chance that one ot?thcm wilt he 531'] My 
pt?nnhy rut'jtn't Lanna): tut-ts ot?thc State that the

statements an: nut and con :ct.

 

Date: Feb 2? 2th AM