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IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

VENTAS REALTY, LIMITED 

PARTNERSHIP, 

Plaintiff, 

V. 

ALC CVMA, LLC, ALC GGMG, LLC, 

ALC HTIF, LLC, ALC PEDG, LLC, ALC 

TPCG, LLC, ALC TISSC, LLC, ALC 

TSKG, LLC, ALC WRWG, LLC, and 

ASSISTED LIVING CONCEPTS, INC., 

Defendants. 

No.: 12-cv-3107 

Judge Ronald A. Guzman 

Magistrate Judge Sidney I. Schenkier 

VENTAS REALTY, LIMITED PARTNERSHIP'S 

MOTION FOR EXPEDITED DISCOVERY 

Plaintiff Ventas Realty, Limited Partnership ("Ventas"), by its attorneys, respectfully 

moves this Court for leave to conduct limited expedited discovery. As more fully discussed in 

the accompanying memorandum, the requested relief is appropriate under the circumstances. 

WHEREFORE, Plaintiff respectfully requests that this Court grant Plaintiff leave to serve 

the discovery requests attached hereto as Exhibits 1 and 2 and order Defendants to respond to 

Plaintiff's discovery on or before May 22, 2012. Plaintiff further requests that Defendants 

designate one or more officers, directors or managing agents as a deponent on or before May 22, 

2012 and present the designated deponent for a deposition on or before May 25, 2012 to testify 

on the matter designated in Exhibit 3. 

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Dated: May 15, 2012 Respectfully submitted, 

VENTAS REALTY, LIMITED PARTNERSHIP 

By: /s/ Roger H. Stetson 

One of Its Attorneys 

Roger H. Stetson 

John W. Roberts 

Brandon Prosansky 

Rupa Rajagopalan 

BARACK FERRAZZANO KIRSCHBAUM & NAGELBERG LLP 

200 West Madison Street, Suite 3900 

Chicago, Illinois 60606 

Tel: (312) 984-3100 

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CERTIFICATE OF SERVICE 

I, Roger Stetson, an attorney, hereby certify that on May 15, 2012, service of a copy of 

the foregoing Motion for Expedited Discovery was accomplished pursuant to ECF as to Filing 

Users upon the following: 

Leonard S. Shifflett 

Quarles & Brady LLP 

300 North LaSalle Street 

Suite 4000 

Chicago, Illinois 60654 

/s/ Roger Stetson 

Roger Stetson 

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EXHIBIT 1 

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

VENTAS REALTY, LIMITED 

PARTNERSHIP, 

Plaintiff, 

V. 

ALC CVMA, LLC, ALC GGMG, LLC, 

ALC HTIF, LLC, ALC PEDG, LLC, ALC 

TPCG, LLC, ALC TISSC, LLC, ALC 

TSKG, LLC, ALC WRWG, LLC, and 

ASSISTED LIVING CONCEPTS, INC., 

Defendants. 

No.: 12-cv-3107 

Judge Ronald A. Guzman 

Magistrate Judge Sidney I. Schenkier 

PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANTS 

Plaintiff Ventas Realty, Limited Partnership ("Ventas"), by and through its attorneys, 

pursuant to Rule 33 of the Federal Rules of Civil Procedure and this Court's Order granting 

expedited discovery, propounds the following Intenogatories upon Defendants, to be answered 

on or before May 22, 2012. 

DEFINITIONS AND INSTRUCTIONS 

A. "VENTAS" means Plaintiff Ventas Realty, Limited Partnership and its past and 

present officers, directors, members, attorneys, employees, and agents, and anyone affiliated 

with it in any capacity or acting or purporting to act on its behalf. 

B. "ALC" means Assisted Living Concepts, Inc. 

C. "SEC" means United States Securities and Exchange Commission. 

D. "FIRST FORM 8-K" means ALC's Form 8-K filed with the SEC on May 4, 2012. 

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E. "SECOND FORM 8-K" means ALC' s Form 8-K filed with the SEC on May 14, 

2012. 

F. "PERSON" means any natural person, firm, partnership, joint venture, 

comoration, or any juridical person, or any other legal entity. 

G. "DOCUMENTS" means writings, books, records, memoranda, papers, films, 

recordings, accounts, drawings, graphs, charts, photographs, phone records, electronically stored 

information, computer records, electronic mail, electronic files, and other data compilations from 

which information can be obtained. 

H. "COMMUNICATION" means any transmission of information whether face to 

face, by telephone, by telecopy, by letter, by telex, by cable, by facsimile, by electronic mail, by 

electronic means, or by any other means whereby thought, opinions, facts, or other matters are 

transmitted between two or more persons. 

I. "RELATING TO" or "RELATED TO" means, without limitation, discuss, 

describe, reflect, deal with, pertain to, analyze, evaluate, estimate, constitute, study, project, 

assess, record, summarize, criticize, report, comment, or otherwise involve, in whole or in part. 

J. "IDENTIFY" means the following: 

a. For a person, the person' s full name, address, and telephone number; 

b. For a document, the date the document was prepared, the name and 

address of the person who prepared the document, the person to whom the 

document was addressed, the length of the document, and the general 

nature of the document; and 

c. For a communication, the date and time when the communication took 

place, the place where the communication took place, the method by 

which the communication took place, the persons who participated in the 

communication, the persons present during the communication, and the 

information exchanged during the communication. 

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K. The words "AND" as well as "OR" shall be construed disjunctively or 

conjunctively as necessary to bring within the scope of this request all documents or things 

which might otherwise be construed to be outside its scope. 

L. In answering these interrogatories, YOU are required to provide all information 

that is available to YOU, including information in the possession of YOUR attorneys, and not 

merely information known of YOUR own personal knowledge. If YOU cannot answer the 

intenogatory in full, answer to the extent YOU are able to do so, state the reason for YOUR 

inability to answer further, and state the knowledge or information available to YOU concerning 

the unanswered portion. 

M. If YOU claim that any information sought by these intenogatories or requests is 

protected from disclosure by the attorney-client privilege, the work product doctrine, or any 

other privilege, YOU are required to identify such information by subject matter and to state with 

particularity the facts and legal grounds which YOU believe prevent the disclosure of the 

information. 

N. Ventas reserves its right to propound additional intenogatories during the course 

of this litigation. 

INTERROGATORIES 

INTERROGATORY NO. 1: 

State the "possible irregularities" ALC is investigating in connection with the Amended 

and Restated Master Lease Agreement, as stated in the First Form 8-K, and, state all facts and 

identify all documents, communications, and persons with knowledge, relating to such 

inegularities. 

ANSWER: 

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INTERROGATORY NO. 2: 

State the subject matter of the "ongoing internal investigation" referenced in the Second 

Form 8-K, and, state all facts and identify all documents, communications, and persons with 

knowledge, relating to the subject matter of the investigation. 

ANSWER: 

Dated: May 15, 2012 Respectfully submitted, 

VENTAS REALTY, LIMITED PARTNERSHIP 

By: /s/ Roger H. Stetson 

One of Its Attorneys 

Roger H. Stetson 

John W. Roberts 

Brandon Prosansky 

Rupa Rajagopalan 

BARACK FERRAZZANO KIRSCHBAUM & NAGELBERG LLP 

200 West Madison Street, Suite 3900 

Chicago, Illinois 60606 

Tel: (312) 984-3100 

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EXHIBIT 2 

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

VENTAS REALTY, LIMITED 

PARTNERSHIP, 

Plaintiff, 

V. 

ALC CVMA, LLC, ALC GGMG, LLC, 

ALC HTIF, LLC, ALC PEDG, LLC, ALC 

TPCG, LLC, ALC TISSC, LLC, ALC 

TSKG, LLC, ALC WRWG, LLC, and 

ASSISTED LIVING CONCEPTS, INC., 

Defendants. 

No.: 12-cv-3107 

Judge Ronald A. Guzman 

Magistrate Judge Sidney I. Schenkier 

PLAINTIFF'S FIRST SET OF REQUESTS FOR PRODUCTION 

OF DOCUMENTS TO DEFENDANTS 

Plaintiff Ventas Realty, Limited Partnership ("Ventas"), by and through its attorneys, 

pursuant to Rule 34 of the Federal Rules of Civil Procedure and this Court's Order granting 

expedited discovery, hereby requests that Defendants produce all documents requested for 

inspection by Plaintiff at the offices of Barack Fenazzano Kirschbaum & Nagelberg LLP, 200 

West Madison St., Suite 3900, Chicago, Illinois 60606 on or before May 22, 2012. 

DEFINITIONS AND INSTRUCTIONS 

A. "VENTAS" means Plaintiff Ventas Realty, Limited Partnership and its past and 

present officers, directors, members, attorneys, employees, and agents, and anyone affiliated 

with it in any capacity or acting or purporting to act on its behalf. 

B. "ALC" means Assisted Living Concepts, Inc. 

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C. "SEC" means United States Securities and Exchange Commission. 

D. "FIRST FORM 8-K" means ALC' s Form 8-K filed with the SEC on May 4, 2012. 

E. "SECOND FORM 8-K" means ALC' s Form 8-K filed with the SEC on May 14, 

2012. 

F. "DOCUMENTS" means writings, books, records, memoranda, papers, films, 

recordings, accounts, drawings, graphs, charts, photographs, phone records, electronically stored 

information, computer records, electronic mail, electronic files, and other data compilations from 

which information can be obtained. 

G. "RELATING TO" or "RELATED TO" means, without limitation, discuss, 

describe, reflect, deal with, pertain to, analyze, evaluate, estimate, constitute, study, project, 

assess, record, summarize, criticize, report, comment, or otherwise involve, in whole or in part. 

A document "relates" to the subject matter of the request if the subject matter of the document is 

then identified in the request or if the document describes, refers to, serves as a basis for, is 

derived from, is produced as the result of, incomorates, suggests, relies upon, is part of, or in any 

other way logically be connected to the subject matter of the inquiry. 

H. All documents originating in an electronic form are to be produced in their native 

format or otherwise in a format compatible with standard litigation document management 

database software (e.g., Clearwell), with intact metadata fields, OCR images, and appropriate 

conesponding load files to be mutually agreed to by the parties. Defendants reserve their rights 

to request electronic documents in their native format and all electronic documents should be 

preserved in their native format. Documents which exist in hard copy form only may be 

converted to electronic form and produced in the same manner as electronic documents set forth 

above. 

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I. The requested documents include all attachments, envelopes, explanatory notes or 

memoranda, and any other material that accompanied the document(s) requested. If the specific 

document elicited a response, that response is also to be identified and produced. If the 

document was itself a response, the document to which it is responding is also to be identified 

and produced. 

J. Ventas reserves its right to serve additional requests for production of documents 

during the course of this litigation. 

DOCUMENTS REQUESTED 

1. All documents relating to the "possible inegularities" ALC is investigating in 

connection with the Amended and Restated Master Lease Agreement, as stated in the First Fonn 

8-K. 

2. All documents relating to the "ongoing internal investigation" disclosed on page 4 

of the Second Form 8-K. 

3. All documents identified by You in response to Plaintiff's First Set of 

Intenwatories to Defendants. 

Dated: May 15, 2012 Respectfully submitted, 

VENTAS REALTY, LIMITED PARTNERSHIP 

By: /s/ Roger H. Stetson 

One of Its Attorneys 

Roger H. Stetson 

John W. Roberts 

Brandon Prosansky 

Rupa Rajagopalan 

BARACK FERRAZZANO KIRSCHBAUM & NAGELBERG LLP 

200 West Madison Street, Suite 3900 

Chicago, Illinois 60606 

Tel: (312) 984-3100 

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EXHIBIT 3 

IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

VENTAS REALTY, LIMITED 

PARTNERSHIP, 

Plaintiff, 

V. 

ALC CVMA, LLC, ALC GGMG, LLC, 

ALC HTIF, LLC, ALC PEDG, LLC, ALC 

TPCG, LLC, ALC TISSC, LLC, ALC 

TSKG, LLC, and ALC WRWG, LLC, 

Defendants. 

No.: 12-cv-3107 

Judge Ronald A. Guzman 

Magistrate Judge Sidney I. Schenkier 

NOTICE OF DEPOSITION OF ASSISTED LIVING CONCEPTS, INC. 

Please take notice that Plaintiff Ventas Realty, Limited Partnership ("Ventas") will take 

the deposition of Defendant Assisted Living Concepts, Inc. ("ALC") pursuant to Fed. R. Civ. P. 

30(b)(6) at 9:00 a.m. on May 25, 2012. The deposition will take place at the offices of Quarles 

& Brady LLP 411 E. Wisconsin Ave. Milwaukee, WI 53202. Pursuant to Rule 30(b)(6), ALC is 

required to designate one or more persons who shall testify knowledgeably about the subjects 

listed on the attached Exhibit A. The deposition will be recorded by videotape and/or 

stenographic means. 

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Dated: May 15, 2012 Respectfully submitted, 

VENTAS REALTY, LIMITED PARTNERSHIP 

By: /s/ Roger H. Stetson 

One of Its Attorneys 

Roger H. Stetson 

John W. Roberts 

Brandon Prosansky 

Rupa Rajagopalan 

BARACK FERRAZZANO KIRSCHBAUM & NAGELBERG LLP 

200 West Madison Street, Suite 3900 

Chicago, Illinois 60606 

Tel: (312) 984-3100 

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EXHIBIT A 

MATTERS FOR WHICH EXAMITATION IS REQUESTED 

1. The "possible irregularities" ALC is investigating in connection with the Amended 

and Restated Master Lease Agreement between Ventas and the ALC Entities as 

referenced in ALC's May 4, 2012 Form 8-K filing. 

2. The subject(s) of the ongoing internal investigation as referenced in ALC's May 14, 

2012 Fonn 8-K filing. 

3. The activities or conduct of ALC personnel at the Peachtree Estates facility during the 

period of May 3, 2012 through the present. 

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