Select Medical Corporation Comments on Settlement of Qui Tam Lawsuit in Retaliation Against Employees Who Speak Out: Not only did Select Rehabilitation and Reliant Rehab possibly force employees to work unpaid overtime, they may have retaliated when workers complained as well. Moving for summary judgment, Select argues that the elimination of an occupational therapist position was part of a company-wide reduction-in-force, and it retained Rachel Urbanski, the younger occupational therapist, instead of Hartman because Urbanski had superior leadership potential, clinical performance and documentation. Jury trial is scheduled for 4/1/2024 if it gets that far. 30% of employees would recommend working at Select Rehabilitation to a friend and 30% have a positive outlook for the business. An "adverse employment action" is "one which is serious and tangible enough to alter an employee's compensation, terms, conditions, or privileges of employment." Davis contends she resigned after she was switched to PRN status. 1089. De Blouw today by calling (800) 568-8020. Christopher J. DelGaizo, Derek Smith Law Group, PLLC, Philadelphia, PA, for Katherine Hartman. Rather, we are contacting you to determine what your experience has been and if similar to what our client has alleged, and to corroborate facts for this case. In examining the motion, we must draw all reasonable inferences in the nonmovant's favor. Plaintiff Select . Almost 50 employees from 9+ states have joined the lawsuit. BBB File Opened: 8/24/2010. at 16:19-18:3, 66:6-19. Mfeldman@flandgatrialattorneys.com. 2013) (plaintiff was not similarly situated to other employees working in different positions in different departments). After speaking with Serene, Hartman learned that although some staff at the Towne Manor facilities were eliminated or reduced to part-time work, others were retained with a pay cut. Viewing the facts in the light most favorable to Hartman, a reasonable jury could conclude that age discrimination motivated Select's decision to eliminate her position. One of the most powerful tools in this effort is the False Claims Act. (mrgo) (Entered: 04/22/2021), (#29) ORDER by Judge Stanley Blumenfeld, Jr. For further information, visit, Environmental, Social and Governance (ESG), HVAC (Heating, Ventilation and Air-Conditioning), Machine Tools, Metalworking and Metallurgy, Aboriginal, First Nations & Native American. The work of the Program Manager is well known by Select Rehab to work on the weekends handling scheduling and staffing as well as to be always on call for other staff. Even if it's not ethical or appropriate the company still expects it. It may arise where technology or other changes to the industry or workplace enabled the employer to reduce its workforce. Select chose to retain Susan, who is in her late 50s, and reduce Shiney, around age 40, to part-time. Feldman Legal Group provides legal support for people in, This press release was issued through 24-7PressRelease.com. We provide: daily oversight; corporate strategic planning; online and on-site education, training and CEUs for licensure; and our proactive, responsive, hands-on local management is backed by our regional and national support. In making their decision to reduce therapists at each location sometime before the changes went into effect on October 1, 2019, Davis and Serene looked at the needs of each facility. There is no evidence that they perform functions or have responsibilities similar to Hartman. 1999). at 61:22-62:7, 153:16-21; Hartman Dep. 2003). Davis, Bd. As a PRN, Hartman was on a list of temporary staff to call in as needed. 2017) (citing Burlington Indus., Inc. v. Ellerth , 524 U.S. 742, 761, 118 S.Ct. Select Rehabilitation | News & Events Hartman's duties were divided among Urbanski, Macalis and the COTAs. If you would like to know more about the Select Rehabilitation, LLC lawsuit, please contact Attorney Nicholas J. Concurrent treatment is expected everyday and you're repeatedly "talked" to if you don't do it daily. Trial Filings (First Set) Deadline 01/14/2022. 1996) (citation omitted). Davis, Serene's supervisor based in Florida, knew nothing of an offer. at 73:20-74:9. Id. Consequently, there is insufficient information necessary to inform whether the offer was a lateral transfer or a materially different job assignment. "Workers can talk to an employment attorney specialized in wage and hour claims to protect their rights and ensure they get full compensation for their work," says Feldman. Granting Application of Non-Resident Attorney David B. Goroff to Appear Pro Hac Vice on behalf of Defendant Select Rehabilitation, LLC, designating Kristina M. Fernandez Mabrie as local counsel #20 . 3:22-CV-00059 | 2022-01-18, U.S. Courts Of Appeals | Civil Right | Although Select does not conduct formal performance reviews of its therapists, it completes quarterly audits of their documentation to ensure they are meeting standards. There is no evidence of the job title, hours, rate of pay, benefits or any other details. Original Summons NOT returned. Alleged Practices Related to Denial of Overtime Pay. Susan's retention as a full-time occupational therapist at Towne Manor West may militate against an inference of age discrimination. Hartman Dep. at 157:4-5. Whether a transfer or reassignment is an adverse employment action depends on the circumstances of the case. Cision Distribution 888-776-0942 (attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Civil Cover Sheet, # 4 Summons Erik D. Painter, # 5 Summons Paul Vazquez, # 6 Summons Empowerme Rehabilitation Il, Llc)(mckenna, William)', 'Corporate Disclosure Statement By Select Rehabilitation, Llc Identifying Corporate Parent Sri Intermediate Llc For Select Rehabilitation, Llc. REHA-Lise. Discouraged Full Reporting of Hours Worked: The lawsuit also alleges that Select Rehabilitation and Reliant Rehab discouraged reporting of overtime hours and encouraged off the clock work in an attempt to keep employees from complaining and reporting their overtime hours. COMPLAINT against SELECT REHABILITATION, LLC ( Filing fee $ 400 receipt number 0313-14231958. Question: Fair Labor Standards. These questions should be discussed directly with your physical therapist. A: As I've said before, HR"). Select Rehabilitation Reviews - Glassdoor Tr. Eastern District of Pennsylvania | Montgomery County Skilled Nursing By accepting our use of cookies, your data will be aggregated with all other user data. Hartman claims Select's decision was motivated by her age. Hartman claims she was terminated. There are also inconsistencies in Davis's testimony about who was involved in the decision to retain Urbanski over Hartman. Susan's continued employment does not necessarily rule out that Urbanski was chosen to remain over Hartman because of her age. at 54:1-54:23; Def. Working at Select Rehabilitation: 276 Reviews about Pay & Benefits The Lawsuit alleges that McLaughlin (Program Manager-PT), Vanderveen (Program Manager-SLP) and Justin Lembke (PTA) were forced to suffer to work off the clock and without being paid overtime premiums, meaning time and one half their regular rates of pay, for all hours worked in violation of well-settled, indisputable law as per Section 207 of the Fair Labor Standard ACT (FLSA). Davis denied ever telling the staff at Towne Manor East or West that their jobs were safe. The case status is Pending - Other Pending. As a result, Select decided to reduce staff at some of its facilities. Case Details Parties Dockets. To meet its burden in response to Hartman's prima facie case, Select has produced evidence of a legitimate, non-discriminatory reason for Hartman's reduction. You are not alone if you suffered to work without pay working for Select Rehab. PRNs receive no benefits, no health insurance, no routine schedule and no guaranteed minimum hours. Christine McLaughlin, a former Program Manager-PT, Crystal Vanderveen, a current Program Manager -SLP, and Justin Lembke, a former physical therapy assistant (PTA), have filed this FLSA section 216b Collective action (class) overtime wage lawsuit, individually AND on behalf of all present and former Program Managers (PM), Directors of Rehab (DOR), and ALL Therapists and Therapy Assistants (PT, PTA, COTA, OT, and Speech Language Pathologists (SLP), or any other persons performing similar work under alternative job titles, seeking to recover unpaid overtime wages for all hours worked over 40 in each and every workweek over the preceding 3 years up through the date of trial, plus the payment of an equal sum in liquidated damages. Final Pretrial Conference and Hearing on Motions in Limine set for 2/11/2022 11:00 AM before Judge Stanley Blumenfeld Jr. Motion to Amend Pleadings/Add Parties (Hearing Deadline) 6/28/2021. Neither she nor Urbanski had any disciplinary history at Select. They considered each employee's leadership skills, clinical performance and documentation. , 198 F.3d 403, 412 (3d Cir. Select eliminated one of two occupational therapist positions at its Towne Manor East facility as part of a reduction-in-force and terminated Hartman while retaining a significantly younger occupational therapist for the remaining full-time position. We're the nation's trusted leader in contract therapy services. Id. at 9:5-8. Select Medical Corporation and Encore GC Acquisition LLC have agreed to pay $8.4 million to resolve allegations that Select Medical Rehabilitation Services Inc. (SMRS) violated the False Claims Act by knowingly causing 12 skilled nursing facilities (SNFs) in New York and New Jersey to submit false claims to Medicare for rehabilitation therapy services that were not reasonable, Hartman has moved for leave to amend her complaint to add the PHRA claim now that she has exhausted administrative remedies. Access this case on the Florida Middle District Court's Electronic Court Filings (ECF) System. Tr. Willis , 808 F.3d at 64445 (citing Fuentes , 32 F.3d at 765 ). Opsatnik v. Norfolk S. Corp. , 335 F. App'x 220, 223 (3d Cir. When Urbanski started with Select, she split her time between Towne Manor East and another facility, Suburban Woods. , 534 U.S. 506, 511, 122 S.Ct. 's Resp. A Select Rehab executive told McKnight's Long-Term Care News that cursory antitrust and regulatory reviews should be completed by the end of the year, hopefully sooner so the deal can close by . v. Burdine , 450 U.S. 248, 253, 101 S.Ct. At 27 years old, Urbanski, the only similarly situated employee who assumed some of Hartman's duties, was sufficiently younger than Hartman. Final Pretrial Conference and Hearing on Motions in Limine set for 2/11/2022 11:00 AM before Judge Stanley Blumenfeld Jr. Motion to Amend Pleadings/Add Parties (Hearing Deadline) 6/28/2021. (citing Sempier , 45 F.3d at 729 ). 's Mot. Select furloughed Mike, a physical therapist, and Kendra, a PTA, who are both in their thirties. Tr. Select Medical Corporation was the prior parent company of SMRS, while Encore GC Acquisition LLC is the successor-in-interest to SMRS. Id. 's Mot. 2021) (citations omitted); McDonnell Douglas Corp. v. Green , 411 U.S. 792, 802, 93 S.Ct. at 87:3-5, 94:13-14. Dist. Tr. As a result of their rigorous work schedules, PLAINTIFF was from time to time unable to take off-duty meal and rest breaks. Hartman also worked as an occupational therapist at Suburban Woods. This press release was issued through 24-7PressRelease.com. Tr. The United States alleged that SMRS corporate policies and practices encouraged and resulted in the provision of medically unnecessary, unreasonable and unskilled therapy services being provided to patients at the 12 SNFs. She claimed that her search of records of backup Program Managers accessing Casamba, Select's computer software program, showed that Hartman was never granted such access. L'Escale. UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA. (Cabrera, Krista) (Entered: 03/29/2021), (#7) PROOF OF SERVICE filed by Defendant Select Rehabilitation, LLC, re Notice of Assignment to United States Judges(CV-18) - optional html form #5 , Notice to Parties of Court-Directed ADR Program (ADR-8) - optional html form #6 served on 03/23/2021. Hartman Dep. 2006) (citing 10A Charles Alan Wright et al., Fed. at 66:20-22. She was 50 years old. We will hold all health care providers who violate the False Claims Act responsible for their actions., Sticking taxpayers with a hefty bill for unnecessary health care services will never be tolerated, said Special Agent in Charge Scott J. Lampert of the Department of Health and Human Services, Office of the Inspector General (HHS-OIG). Working at Select Rehabilitation: 647 Reviews in US - Indeed at 52:18-21, 63:19, 83:12-84:17. Burdine , 450 U.S. at 256, 101 S.Ct. Prac. Opsatnik , 335 F. App'x at 22223 (internal quotations and citations omitted). A copy of the Complaint can be read here. 's Mot. September 21, 2020. Hartman claims Select's decision was motivated by her age. 2004) (citing Anderson , 297 F.3d at 250 ) (similarly situated employees "work in the same area in approximately the same position"). at 67:14-15. Employees were also allegedly denied second off-duty meal breaks when working ten [10] hour shifts. Though Macalis is an occupational therapist by training, she is the Program Manager who oversaw Hartman and Urbanski. We must also protect the taxpayers by ensuring that Medicare pays only for appropriate services performed for legitimate medical purposes. Tr. Select Rehabilitation offers superior clinical care, innovative approaches, state-of-the-art and proprietary technology, training and education, custom reporting, compliance tracking and monitoring, PDPM expertise and more. Rather, she must also show that the younger employee was similarly situated to her. 25) and the plaintiff's sur-reply (Document No. Select argues Hartman cannot establish the fourth element of the prima facie case. Non-Expert Discovery cut-off 10/8/2021. There is no bright line age difference to satisfy the "sufficiently younger" requirement. Tr. During October 2019, Select Medical and certain of its subsidiaries entered into a settlement agreement with the United States government and the Relators in connection with this qui tam. at 62:13-18. 21) ("Hartman Deposition Transcript"). Tr. Select decided to implement a company-wide reduction-in-force in anticipation of the PDPM system. Her hourly rate is $38. Hartman has produced evidence suggesting that Select's proffered legitimate, non-discriminatory reason for its employment decision is pretext for age discrimination. at 68:15-69:2, 75:18-76:8. Rather the layoffs were due to changing business needs based on, among other things, technological developments such as the predominant use of emails as opposed to faxes, which Operations employees once hand-delivered."). TELL US ABOUT YOUR EXPERIENCE WITH SELECT REHAB. 2:16-cv-03569 (D.N.J.). ), Filed By Select Rehabilitation, Llc. Select Rehabilitation, LLC v. EmpowerMe Rehabilitation Kentucky LLC et al, No. Copyright 2022 The Select Rehab employee class overtime wage information site - All Rights Reserved. P. 56(a). Equal Employment Opportunity Act (EEOA) - 42 USC 2000e JUSTICE FOR WORKERS OF SELECT REHAB - Feldman Legal Group | Facebook As previously discussed, Susan's retention as occupational therapist at Towne Manor West militates against an inference of age discrimination. The affiant must set forth specific facts that reveal a genuine issue of material fact. If you do not agree with these terms, then do not use our website and/or services. Tr. Consultez le profil complet sur LinkedIn et dcouvrez les relations de Anjali, ainsi que des emplois dans des entreprises similaires. at 85:14-20. at 645 (citing Fuentes , 32 F.3d at 764 ). TAMPA, Fla., Oct. 14, 2022 /PRNewswire/ -- Feldman Legal Group is investigating potential claims on behalf of therapists working for Select Rehabilitation and Reliant Rehab. 1995) ) (citations omitted); see also Barber v. CSX Distribution Servs. Contact UNITED STATES ATTORNEY'S OFFICE EASTERN DISTRICT OF PENNSYLVANIA 615 Chestnut Street, Suite 1250 Philadelphia, PA 19106 JENNIFER CRANDALL Media Contact 215-861-8300 at 11:22-12:5; Davis Dep. at 146:17-23. Compl. at 50:6-8; Davis Dep. Urbanski did not recall Select giving its staff any PDPM education. U.S. District Court for the Southern District of Illinois, Illinois bill would criminalize routine discipline as 'parental bullying', Pritzker pushes cash to keep teachers in Illinois schools, Suit alleges home care employees failed to check on woman, who was later found dead, Woman sues construction company after allegedly tripping over debris, July 13: U.S. District Court for the Southern District of Illinois docket for "555 prison condition" cases, U.S. District Court for the Southern District of Illinois: Actions Taken on July 13, U.S. District Court for the Southern District of Illinois: Actions Taken on July 12, July 12: U.S. District Court for the Southern District of Illinois docket for "555 prison condition" cases. Diane Walker, Walker Morton LLP, Chicago, IL, Stanley B. Cheiken, Huntingdon Valley, PA, for Select Rehabilitation, LLC. Nevertheless, the two occupational therapists that were reduced to part-time work through Select's reduction-in-force, Hartman and Shiney, are both members of the protected class, supporting an inference of discrimination. at 146:24-147:4. at 75:11-17. Summary judgment is appropriate "if the movant shows there is no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law." at 112:12-24, 115:10-18, 116:19-117:3. Hartman claims that Serene refused, but offered her a full-time position in Florida. Tr. Working closely with our law enforcement partners, we will tirelessly pursue unscrupulous health care companies to protect patients and federal health care programs.. (mrgo) (Entered: 04/22/2021), Docket(#29) ORDER by Judge Stanley Blumenfeld, Jr. Select Rehabilitation has an overall rating of 2.6 out of 5, based on over 947 reviews left anonymously by employees. Here, as Plaintiffs McLaughlin, Vanderveen, and Lembke explain and contend in the AMENDED Collective Action lawsuit and complaint, if Select Rehab has any reason to know that any employee is working off the clock, or encouraged it, they are legally required to pay all these hours, plus an equal sum in liquidated damages going back a 3 year period. Hartman never received a negative evaluation for her documentation or treatment of patients. Tr. By continuing to use this website, you agree to UniCourts General Disclaimer, Terms of Service, A plaintiff can meet her burden by producing evidence from which a factfinder could conclude that the adverse employment action was more likely than not the result of discrimination. Change the course of yours. Fair pay and good/affordable benefits. The claims resolved by the settlement are allegations only, and there has been no determination of liability. at 50:7-16, 51:1-5; Davis Dep. McLaughlin, Vanderveen and Lembke allege that if they worked overtime hours on the clock they were warned they would be fired, but were simultaneously encouraged and pressured to work all the extra hours to meet productivity requirements and complete all their job duties or be fired. Granting Application of Non-Resident Attorney Robert Smeltzer to Appear Pro Hac Vice on behalf of Defendant Select Rehabilitation, LLC, designating Kristina M. Fernandez Mabrie as local counsel #23 . Tr. R. CIV. Service of the Summons and Complaint were executed upon Jessie Gastelum, Registered Agent for Service of Process in compliance with California Code of Civil Procedure by service on a domestic corporation, unincorporated association, or public entity. Jury Demanded, filed by Plaintiff Nikolay Nisimov. at 78:9-12, 112:15-20; Davis Dep. Tr. They have no schedule and are not guaranteed a number of hours. By pointing to these individuals, Select appears to ignore the "similarly situated" requirement of the reduction-in-force prima facie case. at 136:15-19. Affs. "Present and even former employees can face retaliation by being fired, black listed, or demoted unjustly for reporting behaviors of their employers which violate the FLSA," Feldman says. There is evidence that Hartman and Urbanski were similar. Now a master's degree is required. Overtime pay is required under state law and the federal Fair Labor Standards Act (FLSA). (Attachments: #1 Declaration of Krista Cabrera, #2 Exhibit A - State Court Complaint, #3 Exhibit B - State Court Docket, #4 Declaration of Terry Klonowski) (Attorney Krista M Cabrera added to party SELECT REHABILITATION, LLC(pty:dft))(Cabrera, Krista) (Entered: 03/22/2021), U.S. District Courts | Civil Right | Urbanski Dep. The Centre is part of a particularly dynamic ecosystem, within the second French . Swierkiewicz v. Sorema N.A. It need only show that its decision could have been motivated by the proffered legitimate, non-discriminatory reason. Monaco , 359 F.3d at 305. 22), the defendant's reply (Document No. The law, and 1st AMENDMENT of the US Constitution permits attorneys in FLSA class/collective actions to communicate in this form with the class members (current and former employees) before certification. JUSTICE FOR WORKERS OF SELECT REHAB LLC WHO SUFFERED TO WORK OFF THE CLOCK OVERTIME HOURS WITHOUT BEING PAID AS REQUIRED BY THE FLSA: ATTENTION ALL PROGRAM MANAGERS AND THERAPISTS: https://selectrehabovertimelawsuit.com/ selectrehabovertimelawsuit.com According to Davis, Niketa Patel was the backup Program Manager at Towne Manor East in 2019, and Urbanski became the backup Program Manager in January 2020. (Cabrera, Krista) (Entered: 03/22/2021), (#2) CIVIL COVER SHEET filed by Defendant SELECT REHABILITATION, LLC. Doe v. C.A.R.S. Status Report due by 12/14/2021. (gk) (Entered: 04/20/2021), (#28) ORDER by Judge Stanley Blumenfeld, Jr. /PRNewswire/ -- Feldman Legal Group is investigating potential claims on behalf of therapists working for Select Rehabilitation and Reliant Rehab. Co. v. White , 548 U.S. 53, 71, 126 S.Ct. Was this review helpful? (Cabrera, Krista) (Entered: 03/29/2021), Docket(#7) PROOF OF SERVICE filed by Defendant Select Rehabilitation, LLC, re Notice of Assignment to United States Judges(CV-18) - optional html form #5 , Notice to Parties of Court-Directed ADR Program (ADR-8) - optional html form #6 served on 03/23/2021. MONTEREY, Calif. (PRWEB) September 21, 2020 The San Francisco employment law attorneys at Blumenthal Nordrehaug Bhowmik De Blouw LLP, filed a class action complaint alleging that Select Rehabilitation, LLC, failed to provide accurate wages to employees, among other allegations.The Select Rehabilitation, LLC class action lawsuit, Case No. "With the aid of an employment lawyer, these employees may seek several forms of compensation, including reinstatement, promotion, recovery of lost wages, and punitive damages. at 147:12-21, 149:22-23, 150:15-151:11. Though Macalis was a manager, the PDPM system reduced her administrative burdens, enabling her to conduct more patient treatment. Plaintiff Katherine Hartman, who was born on March 12, 1969, graduated from Temple University with a bachelor of science degree in occupational therapy in 1996. Hartman and Urbanski were the only full-time occupational therapists at Towne Manor East. Davis praised Urbanski's leadership potential, citing her assistance with Select's PDPM education. 4 at 87:23-88:10 ("Davis Deposition Transcript"). Granting Application of Non-Resident Attorney David B. Goroff to Appear Pro Hac Vice on behalf of Defendant Select Rehabilitation, LLC, designating Kristina M. Fernandez Mabrie as local counsel #20 . This docket was last retrieved on March 15, 2022. O'Connor v. Consol. (Cabrera, Krista) (Entered: 03/23/2021), (#6) NOTICE TO PARTIES OF COURT-DIRECTED ADR PROGRAM filed. As full-time occupational therapists at the Towne Manor facilities, they perform similar job functions with similar responsibilities. FED. Id. Jury Trial set for 3/1/2022 08:30 AM before Judge Stanley Blumenfeld Jr. Her nickname among the employees was "Assistant Director of Rehabilitation," though she never held an official title of "director" or "manager.". (lh) (Entered: 03/23/2021), CONFORMED FILED COPY OF PROOF OF SERVICE OF SUMMONS Executed by Plaintiff Nikolay Nisimov, upon Defendant Select Rehabilitation, LLC served on 2/19/2021, answer due 3/12/2021. , 964 F.2d 577, 583 (6th Cir. A more recent docket listing Davis Dep. Although Serene and Macalis observed Hartman and Urbanski in therapy sessions at various times, neither recorded any negative feedback regarding Hartman or Urbanski. Todays settlement reflects our commitment to protect patients and taxpayers by ensuring that the care provided to Medicare beneficiaries is dictated by their individual clinical needs and not by a providers financial interests, said Acting Assistant Attorney General Brian M. Boynton of the Justice Departments Civil Division. Low treatment minutes even if the pt. Additional Information. If any person presents a claim for overtime wages, informally, orally, in writing or by filing a legal claim, the Fair Labor Standards Act prohibits all persons, businesses and employers from taking any retaliatory action, including any adverse employment actions against such claimants, even if the claim for wages is unsuccessful. Reach out to the author: contact and available social following information is listed in the top-right of all news releases. Change lives. Urbanski Dep. Tr. L at 5-9 ("Milks Decl."). 's Mot. Share sensitive information only on official, secure websites. Although Davis testified in detail about purported deficiencies in Hartman's documentation compared to Urbanski's, it is for the jury to compare Urbanski's documentation with Hartman's and decide if Urbanski's was superior and whether the evidence suggests Select's reasons for eliminating Hartman's position are pretextual. (FILED IN LOS ANGELES COUNTY SUPERIOR COURT ON 2/16/2021 SUBMITTED ATTACHED TO NOTICE OF REMOVAL #1 ) (lh) (Entered: 03/23/2021), Docket(#4) PROOF OF SERVICE filed by Defendant SELECT REHABILITATION, LLC, re Notice of Removal (Attorney Civil Case Opening), #1 , Corporate Disclosure Statement #3 , Civil Cover Sheet (CV-71) #2 served on 03/22/2021. Trial Filings (Second Set) Deadline 1/28/2022. Hartman Dep. Her hourly rate was $50 and was later adjusted to $51. The U.S. District Court for the Southern District of Illinois reported the following activities in the suit brought by Select Rehabilitation, LLC against EmpowerMe Rehabilitation IL, LLC, Erik D. Painter and Paul Vazquez on March 9. Copyright 1997-2015, Vocus PRW Holdings, LLC. Case number 3:21-cv-00270 was filed in the U.S. District Court for the Southern District of Illinois on March 9. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia. Hartman does not possess a master's degree because an advanced degree was not required for licensure in 1996. (Cabrera, Krista) (Entered: 03/22/2021), Docket(#1) NOTICE OF REMOVAL from Los Angeles Superior Court, case number 21STCV05917 Receipt No: ACACDC-30960825 - Fee: $402, filed by Defendant SELECT REHABILITATION, LLC. Select's formal letter notifying Hartman of her reduction only states that Hartman will switch to PRN status. J. Ex. The COTA reviewing the documentation with inconsistencies and subjective notes would not know how to properly treat the patient. 2d 547, 558 (E.D. On the other hand, lateral transfers or changes in title absent evidence of a material change in an employee's working conditions generally do not constitute adverse employment actions.

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