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UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT

LAURA HUDAK,

Executrix of the Estate of William P. Koballa, deceased,

Plaintiff-Appellee,

v.

ELMCROFT OF SAGAMORE HILLS; ELMCROFT BY ECLIPSE SENIOR LIVING; ECLIPSE SENIOR LIVING, INC.; ECLIPSE PORTFOLIO OPERATIONS, LLC; ECLIPSE PORTFOLIO OPERATIONS II, LLC; JAMIE ASHLEY COHEN,

Defendants-Appellants,

and

AL SAGAMORE HILLS OPERATIONS, LLC;
SENIOR CARE OPERATIONS HOLDINGS, LLC,

Defendants.

On Appeal from the United States District Court for the Northern District of Ohio, No. 5:21-cv-00060, Hon. Sara E. Lioi, U.S. District Judge

BRIEF FOR THE CHAMBER OF COMMERCE OF THE UNITED STATES OF AMERICA, OHIO CHAMBER OF COMMERCE, AMERICAN HOSPITAL ASSOCIATION, AMERICAN MEDICAL ASSOCIATION, AND OHIO STATE MEDICAL ASSOCIATION AS AMICI CURIAE IN SUPPORT OF APPELLANTS