Plaintiffs’ Motion Opposing Dismissal in Richter, et al., v. CC Palo Alto, Inc., et al.

In February 2014, a group of residents at a California continuing care retirement community (CCRC) sued the facility operator and its corporate owner to protest lack of transparency in financial practices related to responsibility for entrance fee refunds and the components of the monthly unit fees. The plaintiffs allege that the actions and lack of transparency by the facility and its corporate owner constitute financial abuse of elders as defined in California law.  The defendants filed a motion to dismiss the complaint. This document is the plaintiff's motion opposing the defendant's motion to dismiss . . .