Poy Fox Rothschild uw»
2000 Market Steet, 20th For
Phiadeiphis, a 19103-3222
7. 215,299,2000 F: 216.209.2150
BETIL, WEISSER
Dyest te 2153992892
Emil Besson com
November 21, 2018
VIA CERTIFIED MAIL/RETURN RECEIPT REQUESTED
Nicole Brambila Karin Simpson, Esquire
‘The Reading Eagle Pennsylvania Department of Health
345 Penn Street 625 Forster Street
Reading, PA 19603, 825 Health and Welfare Building
Harrisburg, PA 17120-0701
Skyline Healtheare LLC
505 Marlboro Road
Wood-Ridge, NJ 07075
Re: Golden Gate National Senior Care Center v. Nicole Brambila, et al.
Dear Sir/Madam:
‘This firm represents Golden Gate National Senior Care Center, d/b/a Golden Living. Enclosed
for service upon you is a copy of a Petition for Review that Golden Living has filed on this date
with the Commonwealth Court of Pennsylvania.
Sincerely,
Beth L. Weisser
BLW/icj
Enclosure
cc: Kelly Isenberg, Esquire (w/enclosure, via certified mail)
Jacqueline Carolan, Esquire
California Colowado Connecticut Delaware Distict of Cobia ‘Ferd Minas
Minnesota Nevada New Jersey New York Pennsyvania Texas Washington
ACTIVEN?8769711 vL-L/20/18,IN THE COMMONWEALTH COURT OF PENNSYLYANIA.
GOLDEN GATE NATIONAL SENIOR
CARE CENTER, d/b/a GOLDEN :
LIVING,
Petitioner,
¥
NICOLE BRAMBILA AND THE
READING EAGLE,
and
PENNSYLVANIA DEPARTMENT OF
HEALTH,
and
SKYLINE HEALTHCARE, LLC,
Respondents.
PET
JON FOR REVIE’
W
Petitioner, Golden Gate National Senior Care Center, d/b/a Golden Living (“Golden
") hereby submits this Petition for Review of the October 25, 2018 Final Determination
issued by the Pennsylvania Office of Open Records (*OOR") in dn The Matier of Nicole Brambila
and The Reading Eagle v. Pennsylvania Dep't. of Health and Golden Gate National Senior Care,
LLC, d/bia Golden Living and Skyline Healthcare, LLC; Docket No. AP 2018-1208. In support
of this Petition, Golden Living states as follows:
ACTIVESTTS79949.91-L12118TATEME!
OF JURISDICTION
1. This Honorable Court has jurisdiction to hear this case pursuant to 42 PaC.S.A. §
763 and, in accordance with Rule 1511 of the Pennsylvania Rules of Appellate Procedure, as the
Final Determination of the OOR is a final determination by a governmental unit. A copy of the
October 25, 2018 Final Determination is attached to this Petition for Review.
PARTY OR PERSON SEEKING REVIEW
The name of the party seeking review before this Honorable Court is Golden Gate
National Senior Care Center, d/b/a Golden Living,
3. Golden Livi
1 Was a direct interest participant in the underlying proceeding and is
now the Petitioner in connection with this Petition for Review.
4. Nicole Brambila represents herself and the Reading Eagle. Ms. Brambila is a
reporter Who sought to compel the Pennsylvania Department of Health (~DOH") to produce
documents related to Skyline Healtheare LLC's (“Skyline”) li
nsing and certification of several
former Golden Living nursing facil
jes pursuant to the Pennsylvania Right to Know Law.
5. The DOH is represented by Karin Simpson, Esquire.
6. Skyline submitted a request to participate in the underlying proceeding but did not
make a submission on appeal to the OOR, Asa result it is unknown who represents Skyline in
these proceedings.
NAME OF THE GOVERNMENTAL UNIT
7. The name of the governmental unit that made the Final Determination for which
Golden Living is seeking review is the Pennsylvania Office of Open Records.
ACTIVESTTA70049.01-11 2018