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Lorain bounty Cburt Of Comn.n Pleas CERTIFIED COPY Case Docket Sheet cApT,001 w yC L BRUMMER V/S N ON CASE NUMBER: 23CV210663 fiVrIMMORLARterTortS DATE FILED: 11/02/2023 jULIF A LERK OF COURTS JUDGk ORAIN COdiMe D. Chris Cook EN AUG I S A 10: 21 Complaint Parties Plaintiff(s) CLERK OF COURTS WILLIAM F. B. VODREY CUYAHOGA COUNTY CV 24 162.1R9 JOYCE L BRUMMER, P- 1 BRENT L ENGLISH, 35659 GRAFTON EASTERN ROAD LAW OFFICES OF BRENT L ENGLISH GRAFTON, OH 44044 820 W SUPERIOR AVE9TH FL CLEVELAND, OH 441131818 (216) 781-9917 NATHANIEL A BRUMMER, P- 2 BRENT L ENGLISH, 35659 GRAFTON EASTERN ROAD LAW OFFICES OF BRENT L ENGLISH GRAFTON, OH 44044 820 W SUPERIOR AVE9TH FL CLEVELAND, OH 441131818 (216) 781-9917 JOYCE L BRUMMER, P- 3 T',Z cl*te.c Defendant(s) JULIE ANNE NORTON, D- 1 RICHARD A DI LISI, 7473 COLUMBIA ROAD 4125 HIGHLANDER PKWY OLMSTED FALLS, OH 44138 STE 200 RICHFIELD, OH 44286 (234) 400-3369 JOYCE L BRUMMER V/S JULIE ANNE NORTON 23CV210663 Date Filed: 11/02/2023 EntriesEntry Date Type Entry Vol. Page11/02/2023 Receipt #: Processed.11/02/2023 FILING COMPLAINT FILED BY JOYCE L. BRUMMER11/06/2023 SUMMONS W/COPY OF COMPLAINT SENT CERTIFIED MAIL TO: JULIE ANNE NORTON ARTICLE #941472669904221995739202/07/2024 ANSWER ANSWER OF DEFT TO PLTFS COMPLAINT FILED02/20/2024 Journal E THIS CASE IS SET FOR A TELEPHONIC CASE MANAGEMENT 1407 1182 CONFERENCE ON 3/8/24 AT 10:00 A.M.03/11/2024 MAGISTRAT HIS MATTER WAS SCHEDULED FOR A TELEPHONE CASE 409 616 MANAGEMENT CONFERENCE. DUE TO A CONFLICT FOR ONE OF THE ATTYS, THIS MATTER IS RESET TO 3/13/24 AT 9:30 A.M. Printed On: Jul-10-24 10:56AM Page 1 Entrim JOYCE L BRUMMER V/S JULIONE NORTON 23CV210663 (II Date Filed: 11/02/2023 utRTIFIEDEntry pateaWp Entry Vol. Page03/14/2024 (MAGISTRA HIS MATTER WAS RESCHEDULED FOR TELEPHONE STATUS 1409 901 CONF.THE PARTIES ARE ENGAGING IN DISCOVERY AND WILL BEGIN DEPOSITIONS.THIS HEARING IS CONTINUED Tagil;RE/414)24 CLERK OF COURTS BY THE CONSENT OF THE PARTIES TO MAY 15 2024 AT LORAIN COUNTY 9:30AM. (BAB) SEE JR05/15/2024 (MAGIST HIS MATTER WAS SCHEDULED FOR A CASE MANAGEMENT 1413 1140 CONFERENCE. PLNTFF IS GRANTED LEAVE UNTIL 6/14/24 TO FILE HIS AMENDED COMPLAINT. THIS MATTER IS SET FOR FURTHER TELEPHONE CONFERENCE ON 6/19/24 AT :30 P.M.05/20/2024 Journal E COURT, ON ITS OWN MOTION, CONTINUES THE 1413 1438 LEPHONE CONFERENCE THAT IS SET FOR 6/19/24 AT 2:30 P.M. AS THIS IS A COURT HOLIDAY. THIS MATTER S RESET TO 6/26/24 AT 2:00 P.M.06/27/2024 FILING IRST AMENDED COMPLAINT FILED.06/27/2024 MOTION OTION TO TRANSFER THIS CASE TO THE COURT OF OMMON PLEAS OF CUYAHOGA COUNTY OHIO TO CORRECT A VENUE ERROR FILED BY PLTF07/01/2024 (MAGIST HE PLTF'S MOTION TO TRANSFER THIS CASE TO THE 1417 55 OURT OF COMMON PLEAS OF CUYAHOGA COUNTY,OHIO TO ORRECT A VENUE ERROR IS BEFORE THIS COURT.FOR GOOD CAUSE SHOWN,PLTF'S MOTION IS GRANTED.THE CLERK OF COURTS SHALL TRANSFER THE ABOVE-CAPTIONED CASE TO THE CUYAHOGA COUNTY COMMON PLEAS COURT,FORTHWITH. (BAB)07/10/2024 TRANSFER TRANSCRIPT OF DOCKET AND JOURNAL ENTRIES AND ALL ORIGINAL PAPERS SENT CERTIFIED MAIL TO CUYAHOGA COUNTY COURT OF COMMON PLEAS 1200 ONTARIO ST FL 1,CLEVELAND OH 44113 Printed On: Jul-10-24 10:56AM Page 2 of 206/27/2024 13:36 Law Office of Brent L. Engl ish (FAX)216 781 8113 P.002/004I • • FILED Lorain County Common Pleas Court by Fax dated C• IN THE COURT OF COMMON PLE LORATN COUNTY, OHIO JUN 2 7 2024 Tom Orlando, Clerk of Courts JOYCE L. BRUMMER, ) CASE NO.: 2 LEGAL CUSTODIAN AND NEXT FRIEND ) OF CORA PRYOR, a minor, et al., ) JUDGE D. CHRISTOPHER COOK Plaintiffs, ) MAGISTRATE BARBARA ) AQUILLA BUTLER vs. ) MOTION TO TRANSFER THIS CASE JULIE ANNE NORTON, ) TO THE COURT OF COMMON PLEAS ) OF CUYAHOGA COUNTY, OHIO TO Defendant. ) CORRECT A VENUE ERROR Plaintiff, Joyce L. Brummer, legal custodian and next friend of Cora Pryor, a minor child, and plaintiff, Nathaniel Pryor, jointly and severally, respectfully move this Court for an order transferring this case from the Court of Common Pleas of Lorain County, Ohio to the Court of Common Pleas of Cuyahoga County, Ohio because venue is not proper in this Court pursuant to Ohio R. Civ. Proc. 3(A). A memorandum in support is attached. Respectfully submitted, /s/Brent L. English BRENT L. ENGLISH LAW OFFICES OF BRENT L. ENGLISH 820 West Superior Avenue, 9th Floor Cleveland, Ohio 44113-1818 (216) 781-9917 (216) 781-8113 (fax) benglish@englishlaw.eom Sup. Ct. Rog. 0022678 Attorney for Plaintiffs, Joyce L. J3rummer, legal guardian and next friend of Cora Pryor and Nathaniel A. Pryor, a plaintiff in his own right.06/27/2024 13:36Law Office of Brent L. Engl ish (FAX)216 781 8113 P.003/004 • • MEMORANDUM The First Amended Complaint being filed contemporaneously with this motion, alleges that on November 21, 2021, Plaintiff, Nathaniel Pryor was injured in a motor vehicle accident with a North Olmsted, Ohio resident in the City of North Olmsted. The complaint further alleges that a minor, Cora Pryor, a passenger in the motor vehicle being driven by her brother, Nathaniel Pryor, was injured as was her brother. Plaintiffs concede they should have been filed this case in Cuyahoga County Ohio, rather in Lorain County where they live. Civ. R. 3(A) establishes that venue is proper in any county in which (1) the defendant resides; (2) a county in which the defendant conducted activity giving rise to the claim for relief; and (3) a county in which all or part of the claim for relief arose. Civ. R. 3(C)(1) (2) and(6). In each of these factual scenarios, Cuyahoga County, Ohio is the proper venue (the Defendant resides in Cuyahoga County, the motor vehicle accident happened in Cuyahoga County and Cuyahoga County is where the claim for relief arose) While Civ. R. 3(C)(12) allows a plaintiff's place of residence to be a proper venue, this is only there is no available forum in divisions (C)(1) to (C)(10) of this rule." Even if the Defendant waived any objection to venue, the parties have nevertheless agreed that the Court of Common Pleas of Cuyahoga County, being the readily available and correct venue, should hear this case. The issue of venue was raised by Magistrate Barbara Acquilla Butler during a pretrial with the parties' counsel on May 15, 2024. Both counsel agreed that venue was not proper in Lorain County, was proper in Cuyahoga County, and that this case should be transferred. The parties also agree it was logical and rational for. Plaintiffs to be given to leave to amend their complaint (to correct several errors and clarify certain facts) while the case was -2-06/27/2024 13:36Lew Office of Brent L. Engl ish (FAX)216 781 8113 P.004/004 • 410JI pending in Lorain County, Ohio. Both counsel agreed this case with then be transferred to the Court of Common Pleas of Cuyahoga County Ohio. Plaintiffs, Joyce Brummer as legal custodian and next friend of Cora Pryor, a minor, and Nathaniel Pryor, an adult, both represented by the same undersigned counsel, have now filed their First Amended Complaint in this Court, with the consent of the Court and Defendant's counsel, Richard Di Lisi, Esq. Having done so, Plaintiffs now respectfully move this Court to transfer this case to the Court of Common Pleas of Cuyahoga County, Ohio. Respectfully submitted, /s/Brent L. English BRENT L. ENGLISH LAw OFFICES OF BRENT L. ENGLISH Attorney for Plaintiffs, Joyce L. Drummer, legal guardian and next friend of Cora Pryor and Nathaniel A. Pryor, a plaintiff in his own right CERTIFICATE OF SERVICE I hereby certify that a true and complete copy of PLAINTIFFS, JOYCE L BRUMMF,R AND NATHANIEL PRYOR'S MOTION TO TRANSFER THIS CASE To CUYAHOGA COUNTY To CORRECT A VENUE ERROR was served upon Richard A. Di Lisi, Esq., Attorney for Defendant, Julie Anne Norton, 4125 Highlander Pkwy., Suite 200, Richfield, Ohio 44286 on this 26th day of June 2024. /5/Brent L. English BRENT L. ENGLISH LAW OFFICES OF BRENT L. ENGLISH Attorneyfor Plaintiffs, Joyce L. Drummer, legal custodian and next friend of Cora Pryor, a minor and Nathaniel A. Pryor, a plaintiff his own right -3-06/27/2024 13:36Law Office of Brent L. Engl ish (FAX)216 781 8113 P.001/004 • • TO THE LORAIN COUNTY CLERK OF COURT, GENERAL DIVISION: THE ATTACHED DOCUMENT IS BEING OFFERED FOR FILING PURSUANT TO LOCAL R. 3. Sent to fax #: From fax #: 440/328-2416 216/781-8113 Date transmitted: Transmittee phone #: June 27, 2024 216/781-9917 # of Pages, including cover: (NOT TO EXCEED 20 PAGES) 4 CASE NUMBER: 23 CV 210663 CAPTION: Joyce Brummer, et al. v. Julie Norton JUDGE: D. Chris Cook Will original exhibit(s) be filed separately? 0 Yes 0 No (If "yes" box is checked, insert a page describing the exhibit(s) after this cover page.) DESCRIPTION OF DOCUMENT ATTACHED: Motion to Transfer Case to the Court of Common Pleas of Cuyahoga County, Ohio to Correct Venue Error • r • r-vr•-• EN1- -a-- 16, • FILED COl.1141-1' Ob 11 JtJL - l P 3: 7.07. LORAIN COUNTY COURT OF"COMMONPIIAS LORAIN COUNTY, OHIO JOURNAL ENTRY D. CHRIS COOK, JUDGE Barbara Aquilla Butler, MagistrateDate 7/1/24 Case No. 23CV210663JOYCE L BRUMMER BRENT L. ENGLISHPlaintiff Plaintiffs Attorney (216)781-9917 VSJULIE ANNE NORTON RICHARD A. DI LISIDefendant Defendant's Attorney (234)400-3369The Plaintiffs Motion to Transfer this Case to the Court of Common Pleas of CuyahogaCounty, Ohio to Correct a Venue Error is before this Court.For good cause shown, Plaintiffs Motion is GRANTED.The Clerk of Courts shall transfer the above-captioned case to the Cuyahoga CountyCommon Pleas Court, forthwith.IT IS SO ORDERED.No Record.VOL \\-\\1 PAGE Barbara Aquilla butler, Magistratecc: Brent L. English, Esq. Richard A. Di Lisi, Esq. LORAIN COUNTY CLERK OF COURTS 225 Court Street Elyria, OH 44036 CASE NO.:23CV210663 I, THE UNDERSIGNED, CLERK OF THE COMMON PLEAS COURT IN AND FORSAID COUNTY, DO HEREBY CERTIFY THAT THE FOREGOING IS A TRUE TRANSCRIPTOF THE DOCKET AND JOURNAL ENTRIES OF SAID COURT IN THE ABOVE ENTITLEDCAUSE. AND I FURTHER CERTIFY THAT THE PAPERS HEREWITH SENT, NUMBEREDFROM ONE TO ELEVEN INCLUSIVE, ARE ALL THE ORIGINAL PAPERS AND PLEADINGSFILED IN THE CAUSE OF JOYCE L BRUMMER V/S JULIE ANNE NORTON. TOM ORLA CLERK OF THE COUR PLEAS LORAI BY: uty Clerk7/10/2024 111111111111111111111111111111111 11111111111111111111111111111111 • TOM ORLANDO LORAIN COUNTY CLERK OF COURTLast revised: 08/22/2008 225 COURT ST. FIRST FLOOR ELYRIA OHIO, 44035 23 k o3 NOV 0 2 2C23 JUDGE D. CHRIS COOK LORAIN COUNTY COURT OF COMMON PLEAS Civil Case Designation Sheet JOYCE BRUMMER, et at.Plaintiff Case Number (to be completed by Clerk)-v- JULIE A. NORTONDefendant Assigned Judge (to be completed by Clerk)11 RE-FILINGFormer case number and previously assigned JudgeEI REQUEST FOR CONSOLIDATION (must also file motion with Court)List companion case(s)El PROFESSIONAL TORT ❑ ADMINISTRATIVE APPEAL O Medical Malpractice ❑ Civil Service ❑ Dental Malpractice ❑ Motor Vehicle ID Optometric Malpractice ❑ Unemployment ❑ Chiropractic Malpractice ❑ Liquor 0 Legal Malpractice ❑ Taxes ❑ Other Malpractice O Zoning❑ PRODUCTS LIABILITY El OTHER CIVIL E] Personal Injury O Appropriation 0 Wrongful Death ❑ Accounting El Breach of Contract ❑ Cognovitgl OTHER TORT 111 Complex Litigation classification request ID Personal Injury Ej Consumer Sales Act (Rev. Code § 1345) ID Wrongful Death ❑ Declaratory Judgment (related case & Judge) O Vehicle Accident El Miscellaneous 0 Habeas Corpus ❑ InjunctionO WORKERS' COMPENSATION ❑ Mandamus ❑ Non-compliant Employer 111 Replevin ❑ Appeal ❑ Specific Performance O Stalking Civil Protection OrderEl FORECLOSURE O Foreign Judgment ❑ Foreclosure O Arbitration Confirmation E1 Foreclosure - Taxes O Civ. R. 3(F) Notice of Pending Litigation 0 Foreclosure - Mechanic's Lien Permanent parcel no. 11/02/2023 Brent L. EnglishDATE: ATTORNEY/PARTY: 0022678 OHIO SUPREME COURT NUMBER:Last revised: 03/24/2008 • e CIVIL CASE DESIGNATION CATEGORIESPROFESSIONAL TORT — This category is used for cases that involve allegationsof malpractice by a person acting in a professional capacity, such as a doctor,lawyer, or engineer.PRODUCTS LIABILITY — Used for cases that involve alleged responsibility ofthe manufacturer or seller of an article for injury caused to person or property by adefect in or condition of the article sold, or an alleged breach of duty to providesuitable instructions to prevent injury.OTHER TORT — Residual category to be used for those tort cases that cannot beclassified as Professional Tort or Products Liability. Examples would includeautomobile tort cases, as well as tort cases involving air and water transportation. A tort is an injury or wrong committed either against a person or against aperson's property by a party who either did something that he or she was obligatednot to do, or failed to do something that he or she was obligated to do.WORKERS' COMPENSATION — A case reported in this category is one broughtpursuant to OH Rev. Code § 4123.519, which is an appeal of a decision by theIndustrial Commission in any injury or occupational disease case, other than adecision as to extent of disability. This category also includes noncomplianceactions by the state for the recovery of benefits or premiums, as well as mandamusactions arising from claims or awards.FORECLOSURE — Used for cases that involve enforcement of a lien, mortgage,trust deed, or other similar instrument in any method provided by law. Pleaseinclude the permanent parcel number(s) of the subject property on the lineindicated. Attach a separate piece of paper if there are numerous parcels involved.ADMINISTRATIVE APPEAL — This category is used for cases that are appealedfrom a decision of an administrative agency. OTHER CIVIL — Residual category used for civil cases that cannot be identified asbelonging in the other listed classifications. Note on Complex Litigation classification requests: This category is for those extraordinary civil cases that involve novel or complicated issues of law or fact, and that are not likely to be resolved within the time guidelines established for other cases. New cases will not be recorded with this designation upon the initialfiling; instead, these cases will be initialized by the Clerk as "Other Civil". See Sup. R. 42 for more information. • TOM ORLANDO LORAIN COUNTY CLERK OF COURT V 225 COURT ST. FIRST FLOOR ELYRIA OHIO, 44035 ENTERED EZOZ Z 0 AON A.M. JUDGE D. CHRIS COOK IN THE COURT OF COMMON PLEAS LORAIN COUNTY, OHIOJOYCE L. BRUMMER Case No.:35659 Grafton Eastern Road,Grafton, Ohio 44044 JUDGE: and COMPLAINT WITH JURY DEMANDNATHANIEL A. BRUMMER35659 Grafton Eastern RoadGrafton, Ohio 44044 Plaintiffs, v.JULIE ANNE NORTON7473 Columbia RoadOlmsted Falls, Ohio 44138 Defendant. 1. Joyce L. Brummer is the legal custodian and next friend of Nathaniel Pryor andCora Pryor, both of whom were minors at the time of the incident giving rise to this complaint. 2. Nathaniel Pryor is now 18 years of age and is a Plaintiff herein in his own right. 3. On November 2, 2021, Nathaniel Pryor, age 16, was operating a 2009 Jeepbearing Ohio License Plate No. JMF9098 owned by non-party Mark S. Brummer in which hissister, Cora Pryor, age 13, was a passenger. • • 4. Nathaniel Pryor was driving the 2009 Jeep southbound on Great NorthernBoulevard in the City of North Olmsted, Cuyahoga County, Ohio and had a solid green trafficsignal at the intersection near a restaurant called Harry Buffalo. 5. Defendant, Julie Anne Norton was operating a 2015 Mazda northbound on GreatNorthern Boulevard and was making a left turn from Great Northern Boulevard into the HarryBuffalo restaurant. 6. Defendant Julie Anne Norton had a solid green traffic light but did not seeNathaniel Pryor traveling lawfully southbound on Great Northern Boulevard. 7. Julie Anne Norton failed to yield the right-of-way to the vehicle Nathaniel Pryorwas driving as she turned in front of Nathaniel Pryor and caused a motor vehicle collision. 8. Julie Anne Norton was negligent in her operation of the 2015 Mazda owned byher father, non-party Robert S. Norton. 9. As a direct and proximate result of the negligence of Julie Anne Norton, the 2009Jeep being driven by Nathaniel Pryor was severely damaged and was totaled. 10. Julie Anne Norton's insurer — Nationwide — satisfactorily adjusted and paid theproperty damage claim made by Mark S. Brummer, the owner of that vehicle. There is no otherproperty damage claim in this case. 11. As a direct and proximate result of the negligence of Julie Anne Norton, NathanielPryor sustained bodily injuries for which he needed and obtained medical treatment atSouthwest General Health Center in Brunswick Ohio and thereafter obtained outpatient •orthopedic treatment and physical therapy. 12. As a direct and proximate result of the negligence of Julie Anne Norton, CoraPryor sustained bodily injuries for which she needed and obtained medical treatment at -2- • •Southwest General HealthCenter in Brunswick Ohio and thereafter obtained outpatient medicaltreatment. 13. The injuries sustained by Nathaniel Pryor and Cora Pryor were serious and maybe permanent in nature. WHEREFORE, Joyce L. Brummer, legal custodian and next friend of Cora Pryor, andfor and on behalf of Cora Pryor, a minor, demands judgment against Julie Anne Norton forcompensatory damages of more than $25,000.00, together with interest, court costs, and suchother relief as may be warranted or allowed under the law. Furthermore, Joyce L. Brummer, legalcustodian for and next friend of Nathaniel Pryor, while he was a minor, and for and on his behalfand Nathaniel Pryor himself, demand judgment against Julie Anne Norton for compensatorydamages of more than $25,000.00, together with interest, court costs, and such other relief asmay be warranted or allowed under the law. Respectfully submitted, /s/Brent L. English BRENT L. ENGLISH LAW OFFICES OF BRENT L. ENGLISH 820 West Superior Avenue, 9th Floor Cleveland, Ohio 44113-1818 (216) 781-9917 (216) 781-8113 (fax) benglish@englishlaw.com Sup. Ct. Reg. 0022678 Attorneyfor Plaintiffs, Joyce L. Brummer and Nathaniel A. Pryor -3- • • JURY DEMAND Plaintiffs, Joyce L. Brummer and Nathaniel A. Pryor, through their undersigned counselof record, Brent L. English, hereby demand a trial by jury pursuant to Ohio R. Civ. Proc. 38 onall issues triable as of right to a jury. /s/Brent L. English BRENT L. ENGLISH LAW OFFICES OF BRENT L. ENGLISH Attorneyfor Plaintiffs; Joyce L. Brummer and Nathaniel A. Pryor -4- LORAIN OUNTY COURT OF COMMIOIN PLEAS LORAIN COUNTY JUSTICE CENTER 225 COURT STREET ELYRIA, OHIO 44035 JOYCE L BRUMMER CASE NO. 23CV210663 35659 GRAFTON EASTERN ROAD GRAFTON, OH 44044 VS.TO: File Copy SUMMONS ON COMPLAINTYou have been named defendant in a complaint filed in Lorain County Court of Common Pleas byplaintiff(s):JOYCE L BRUMMER35659 GRAFTON EASTERN ROADGRAFTON, OH 44044A copy of the complaint is attached hereto. The name and address of the plaintiffs attorney is:BRENT L ENGLISHLAW OFFICES OF BRENT L ENGLISH820 W SUPERIOR AVE 9TH FLCLEVELAND, OH 441131818You are hereby summoned and required to serve a copy of your answer to the complaint upon theplaintiffs attorney, or upon the plaintiff, if he has no attorney of record, within TWENTY-EIGHT (28) DAYSafter service of this summons on you, exclusive of the day you receive it. Your answer must ALSO befiled with this Court within three (3) days after you serve, (delivered or by mail), a copy of your answer onthe plaintiffs attorney.If you fail to appear and defend, judgment by default will be rendered against you for the relief demandedin the complaint. TOM ORLANDO CLERK OF COURTS OF COM PLEAS LORAIN ;'LINTY, OHI11/6/2023 BY: De uty *23CV210663*Page: 2/7 02.07.2024 13:23:35 • • FILED Lorain County Common Pleas Court by Fax dated FEB 0 ? 2124 Tom Orlando, Clerk of Courts IN tHE COURT OF COMMON PLEAS LORAIN COUNTY, OHIO JOYCE L. BRUMMER, ET AL, CASE NO.: 23 CV 210663 Plaintiffs, JUDGE: D. CHRIS COOK •; vs. ANSWER OF DEFENDANT TO JULIE ANN NORTON, PLAINTIFFS' COMPLAINT Defendant. (Jury Demand Endorsed Hereon) Now comes the Defendant, Julie Ann Norton, by and through counsel, and for her Answer to the Complaintof Plaintiffs Joyce L. Brummer and Nathaniel A. Brummer, states as follows: 1. Defendant dehies for want of knowledge sufficient to form a belief the allegations contained in Paragraph One of Plaintiffs' Complaint. 2. Defendant denies for want of knowledge sufficient to form a belief the allegations contained in Paragraph Two of Plaintiffs' Complaint. 3. -befendant denies for want of knowledge sufficient to form a belief the allegations contained in Paragraph Three of Plaintiffs' Complaint. 4. Defendant dehies for want of knowledge sufficient to form a belief the allegations contained in Paragraph Four of Plaintiffs' Complaint. 5. Defendant dehies the allegations set forth in Paragraph Five of Plaintiffs' Complaint to the extent those allegations pertain to her, and denies the remaining allegations of said Paragraph:for want of knowledge and/or information sufficient to form -1-Page: 3/7 02.07.2024 13:23:35 • a belief as to the truth thereof, except to admit that she was travelling northbound on Great Northern Boulevard. in.a Mazda on or about November 2, 2021. 6. Defendant denies the allegations set forth in Paragraph Six of Plaintiffs' Complaint to the extent those allegations pertain to her, and denies the remaining allegations of said Paragraph for want of knowledge and/or information sufficient to form a belief as to the truth thereof. 7. Defendant denies the allegations contained in Paragraph Seven of Plaintiffs' Complaint. 8. .Defendant denies the allegations contained in Paragraph Eight of Plaintiffs' Complaint. 9. Defendant derAes the allegations contained in Paragraph Nine of Plaintiffs' Complaint. 10. Defendant dehies the allegations set forth in Paragraph Ten of Plaintiffs' Complaint to the extent those allegations pertain to her, and denies the remaining allegations of said Paragraph for want of knowledge and/or information sufficient to form a belief as to the truth thereof. Further responding, Defendant submits that evidence of insurance coverage is irrelevant and inadmissible, and, therefore, any references to Defendant's insurer must tio•sticken from Plaintiffs' Complaint. 11. Defendant denies the allegations contained in Paragraph Eleven of Plaintiffs' Complaint. 12. Defendant denies the allegations contained in Paragraph Twelve of Plaintiffs' Complaint. 13. Defendant denies the allegations set forth in Paragraph Thirteen of Plaintiffs' Complaint to the extent those allegations pertain to her, and denies the -2-Page: 4/7 02.07.2024 13:23:35 • remaining allegations of said Paragraph for want of knowledge and/or information sufficient to form a belief as.to the truth thereof. AFFIRMATIVE DEFENSES 1. Defendant incorporates by reference all admissions, denials, and allegations previously set forth as though fully rewritten. 2. Defendant states that the Plaintiffs' Complaint fails to state a claim upon which relief can be granted, and, therefore, must be dismissed. 3. Defendant states that Plaintiffs' Complaint is barred by the applicable statute of limitations. 4. Venue is not OfoP'er in Lorain County. The accident at issue occurred in Cuyahoga County and the Defendant resides in Cuyahoga County. Therefore, this case must be transferred to Cuyahoga County, Ohio. 5. Plaintiffs' CoMplaint must be dismissed for insufficiency of service. 6. Plaintiffs' COrriplaint must be dismissed for insufficiency of service of process. 7. Plaintiffs' Complaint must be dismissed for lack of jurisdiction: 8. Plaintiffs' Corrrplaint must be dismissed for failure to join necessary and indispensable parties as required by Rules 19 and 19.1 of the Ohio Rules of Civil Procedure. • 9. Evidence of insurance is irrelevant and inadmissible. Therefore, any • .•. references to Defendant's insurer must be stricken from Plaintiffs' Complaint. 10. Defendant asserts that the Plaintiffs are not the real parties in interest to seek recovery for amounts raid for expenses as to some or all of the damage alleged in the Complaint. -3-Page: 5/7 02.07.2024 13:23:35 • 11. Defendant status that any damages or injuries which the Plaintiffs may have suffered were the' YifieCt, proximate and sole result of Plaintiff, Nathaniel Brummer's own negligence and carelessness in the incident alleged in the Complaint and therefore, under the Principles of Comparative Negligence as embodied in the Ohio Revised Code, Plaintiffs' Complaint must be dismissed. In the alternative, should judgment be rendered against this Defendant, a reduction in any award to the Plaintiffs must be made proportionate to his degree of negligence. 12. Defendant aSSiiris the defenses of intervening and/Or superseding causes or both. 13. Defendant states that any damages or injuries Plaintiffs allegedly sustained were proximately caused by the negligence of a third person over whom the Defendant had no control aria no right to control. 14. Plaintiffs were comparatively negligent and/or primarily and/or expressly and/or impliedly assumed the risk of injury in the event that Plaintiff, Nathaniel Brummer, was not utilizingia seat belt and/or Plaintiffs' alleged injuries and damages may have been diminished pursuant to Ohio Revised Code Section 4513.263 due to the failure to utilize a seat belt. 15. Plaintiffs were comparatively negligent and/or primarily and/or expressly and/or impliedly assumed titre risk of injury of the injuries and/or damages alleged in the Complaint. 16. Defendant asserts the right to offer proof in support of additional defenses as may be developed thrOdgn investigation and discovery. -4-Page: 6/7 02.07.2024 13:23:35 • WHEREFORE, having fully answered the Plaintiffs' Complaint, Defendant, Julie Ann Norton, demands that said Complaint be dismissed with prejudice at Plaintiffs' costs. Respectfully submitted, / • ; • • RICHARD A. DI LISI (0042148) Attorney for Defendant, Julie Ann Norton 4125 Highlander Parkway - Suite 200 Richfield, Ohio 44286 Direct Dial: (234) 400-3369 Facsimile: (855) 348-0387 Email: dilisir@nationwide.com JURY DEMAND A trial by jury is demanded on all issues. ( /I • RICHARD A. DILISI (0042148) Attorney for Defendant, Julie Ann NortonPage: 7/7 02.07.2024 13:23:35 • • CERTIFICATE OF SERVICE A copy of the foregoing has been sent postage prepaid by regular U.S. mail and/or electronic mail to the following on this 7th day of February, 2024. Brent L. English Attorney for Plaintiffs 820 West Superior Ave 9►h Floor Cleveland, OH 44113 E: benalisheenalishlaw.com RICHARD A. DILISI (#0042148) Attorney for Defendant, Julie Ann Norton 23-012953Page: 1/7 02.07.2024 13:23:35 • LAW OFFICE ALL A TTORNEYSAND THEIR,:3:wF4Re . RILL-ME EMPLOYEESOF NATIONWIDE® MUTUAL INSURANCE COMPANY NOT A LEGAL PARTNERSHIP OR PROFESSIONAL CORPORATION LAUREL E. LETTS 4125 HIGHLANDER PKWY., SUITE 200 RICHARD A. Dr Liisr MANAGING TRIAL ATTORNEY RICHFIELD, Otno 44286 CHRISTINE GAYNOR ^ ^ ALSO LICENSED IN MI TELEPHONE: (234) 400-3130 SHAWN R. PEARSON o ALSO LICENSED IN IN TOLL FREE: (866) 339-6685 MARIA PLACANICA FACSIMILE: (855) 348-0387 ROBERT B. SUTHERLAND 0 February 7, 2024 7 pages including this letter Via Fax: 440 328-2416 Clerk of Courts Lorain County Court of Corry-non Pleas 225 Court Street Elyria, OH 44035 Re: Brummer, J., et al. v. J, Norton Lorain County Court of Common Pleas Case No 23 CV 210663 Claim No: 585287-GM/ Date of Loss: 11/2/2021 Our File No: 23-012953 Dear Clerk: Please file the encicif.A Defendant's Answer to Plaintiffs' Complaint in the above matter. Please fax file thiSyeading on today's date. Thank you for your cooperation. Very truly yours, /s/ Richard A. DiLisi Richard A. DiLisi Direct Dial No. : (234) 400-3369 EMAIL: DILISIR@nationwide.com RAD:plm Enc. cc: Brent English, Esq. via email COUN1 LORAIN COUNTY COURT OF COMMON-PLE-Ai° P 45 e LORAIN COUNTY, OHIO , JOURNAL ENTRY TOM ORLANDO D. CHRIS COOK, JUDGEDate 2/20/24 Case No. 23CV210663JOYCE L BRUMMER, ET AL. BRENT L ENGLISHPlaintiff Plaintiffs Attorney (216)781-9917 VSJULIE ANNE NORTON, ET AL. RICHARD A DI LISIDefendant Defendant's Attorney (234)400-3369 CASE MANAGEMENT ORDERThis case is set for a telephonic case management conference on March 8, 2024 at mooAM. Counsel for plaintiff(s) shall initiate the telephone conference with opposingcounsel and the court (440-329-5417).It is so ORDERED.No record.voL1961 PAGE Mcc: Counsel of record 1111111111111111111111111111111111111111111111111111111111 LORAIN COUNTY 2024 MAR ! 0 3: 02 LORAIN COUNTY COURT OF COMMON PLEAS LORAIN COUNTY, OHIO TOM ORLANDO JOURNAL ENTRY ZATr ,2.3 D. CHRIS COOK, JUDGE Barbara Aquilla Butler, MagistrateDate 3/8/24 Case No. 23CV210663JOYCE L. BRUMMER, ET AL. BRENT L. ENGLISHPlaintiff
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Aug 08, 2024 |JOAN SYNENBERG |TORT-M.V. ACCIDENT |CV-24-101878
Case
LISA M. MARTIN vs. PROGRESSIVE DIRECT INSURANCE COMPANY, ET AL.
Aug 02, 2024 |ANDREW J. SANTOLI |TORT-M.V. ACCIDENT |CV-24-101572
Case
DONTA ROBINSON vs. MATTHEW UTRATA, ET AL
Jul 31, 2024 |TIMOTHY W. CLARY |TORT-M.V. ACCIDENT |CV-24-101466
Case
MACIE CARMEL ZAHN ET AL. vs. BASSIM SFEIR
Aug 19, 2024 |KELLY ANN GALLAGHER |TORT-M.V. ACCIDENT |CV-24-102384
Case
FATEMA KHALAF vs. ROBERT STURGEON, ET AL
Aug 28, 2024 |DEENA R CALABRESE |TORT-M.V. ACCIDENT |CV-24-102964
Case
MARIAH THOMPSON vs. PROGRESSIVE INSURANCE, ET AL.
Aug 26, 2024 |CASSANDRA COLLIER-WILLIAMS |TORT-M.V. ACCIDENT |CV-24-102794
Case
SHAMONTE ALLEN vs. LISA HUDSON JARRELL, ET AL.
Aug 19, 2024 |DEENA R CALABRESE |TORT-M.V. ACCIDENT |CV-24-102364
Ruling
RODNEY PIMENTEL VS JOSEPHY BARRETT ET AL
Aug 27, 2024 |BC701615
Case Number: BC701615 Hearing Date: August 27, 2024 Dept: 57 The Court is denying the motion of Defendants Joseph Barrett and the Barrett Law Firm ("the Barrett Defendants") for reconsideration of the Court's decision denying in part their motion for summary judgment or summary adjudication on the claims of Plaintiff Rodney Pimentel ("Pimentel") . The Court disagrees with Pimentel's contention that the Barrett Defendants' motion for reconsideration is a renewed motion for summary judgment or summary adjudication that does not comply with requirements of Code of Civil Procedure Section 437c. In the Court's view, the Barrett Defendants' motion for reconsideration was properly filed under Section 1008. In that regard, the Court accepts the Barrett Defendants' contention that they did not have a meaningful opportunity at the hearing on their motion for summary judgment or summary adjudication to present precedent on the mediation privilege, which, according to the Barrett Defendants, renders the Court's decision denying their motion for summary judgment or summary adjudication wrong as a matter of law. The Court reviewed that precedent following the hearing and before issuing its decision -- particularly Wimsatt v. Superior Court (2007) 152 Cal.App.4th 137. The Court concluded that the precedent did not compel the conclusion that the Barrett Defendants were entitled to summary judgment or summary adjudication on Pimentel's claims that the Court left standing. The Court has reviewed that precedent again in connection with the Barrett Defendants' motion for reconsideration. Following the additional review, the Court is adhering to its summary judgment ruling and denying the motion for reconsideration.The Court also is denying the motion of Defendant Todd Wakefield ("Wakefield") for reconsideration of the Court's decision denying his motion for summary judgment or summary adjudication. The Court based that decision on the ground that the declaration that Wakefield submitted in support of his motion for summary judgment or summary adjudication, which was the only evidence that he submitted, failed to comply with the strict requirements of Code of Civil Procedure Section 2015.5. In the Court's view, Wakefield has offered insufficient grounds to warrant reconsideration of the Court's determination that the defects in Wakefield's declaration compelled denial of his motion for summary judgment or summary adjudication.
Ruling
ALEX HOPKINS VS GILBERTO SOTO
Aug 28, 2024 |23CHCV01925
Case Number: 23CHCV01925 Hearing Date: August 28, 2024 Dept: F43 Alex Hopkins vs. Gilberto Soto Trial Date: 4-7-25 MOTION TO COMPEL RESPONSES TO FORM INTERROGATORIES MOVING PARTY: Defendant Gilberto Soto RESPONDING PARTY: No response has been filed. RELIEF REQUESTED Plaintiff Alex Hopkins responses to Defendants Form Interrogatories, as well as sanctions. RULING: Motion is granted. SUMMARY OF ACTION On March 5, 2024, Defendant Gilberto Soto (Defendant) served form interrogatories on Plaintiff Alex Hopkins (Plaintiff). Defendant had not received any responses by May 2, 2024, so Defendants counsel wrote to Plaintiffs counsel that the answers were due. Defendant has not received any answers to the Form Interrogatories. Defendant filed this motion to compel discovery responses to the form interrogatories on July 1, 2024. No opposition has been filed. Defendant also requests sanctions in the amount of $588.00 against Plaintiff. Form Interrogatories The propounding party may move for an order compelling responses and monetary sanctions if a party to whom the interrogatories are directed fails to respond. (CCP §§ 2030.290, 2030.300; Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 404.) Responses to interrogatories are due within thirty days from the date of service of the interrogatories. (CCP §§ 2030.260(a), 2016.050.) The responding party waives any objections to the interrogatories by failing to serve responses in a timely manner. (CCP § 2030.290(a).) Plaintiff has failed to respond to Defendants Form Interrogatories. Defendant has moved for an order compelling Plaintiffs response to these Interrogatories. The Court grants Defendants motion to compel responses to the Form Interrogatories. Sanctions CCP § 2023.030 authorizes the Court to issue sanctions against a party engaging in conduct that is a misuse of the discovery process. Failure to respond to discovery, evasive responses, and objections lacking substantial justification are misuses of the discovery process. (CCP § 2023.010, subd. (d)-(f).) Defendant has requested sanctions in the amount of $588.00 against Plaintiff. The amount was based on Defendants counsel spending 3 hours preparing this motion and attending the hearing on the motion at $175.00 an hour, plus the $60 filing fee. (Opfell Decl., ¶ 6.) The Court grants the sanctions in the full requested amount. Defendants request for sanctions against Plaintiff is granted in the total amount of $588.00. ORDER1 .Defendants motion to compel responses to the form interrogatories is granted. 2. 2. Plaintiff is ordered to serve responses within twenty (20) days. 3. 3. Plaintiff is ordered to pay sanctions in the total amount of $588.00. Plaintiff is ordered to pay these sanctions to Defendants counsel within twenty (20) days. 4. 4. Moving party to give notice.
Ruling
RICHARD HYMAN VS RUSSELL ALEXANDER, M.D.
Aug 27, 2024 |Renee C. Reyna |20STCV23672
Case Number: 20STCV23672 Hearing Date: August 27, 2024 Dept: 29 Hyman v. Alexander 20STCV23672 Defendants Motion to Bifurcate Tentative The motion is DENIED without prejudice. Background On June 23, 2020, Richard Hyman (Plaintiff) filed a complaint against Russel Alexander, M.D. (Defendant) for general negligence and intentional tort for administering morphine without Plaintiffs consent. On November 30, 2020, Plaintiff filed the First Amended Complaint (FAC) against Defendant for professional negligence and medical battery from the sedition session on November 19, 2019. On May 26, 2021, Defendant filed an answer. On July 24, 2024, Defendant filed this motion to bifurcate. No opposition has been filed. Trial is set for January 2, 2025. Legal Standard The court, in furtherance of convenience or to avoid prejudice, or when separate trials will be conducive to expedition and economy, may order a separate trial of any cause of action & or of any separate issue or of any number of causes of action or issues& (Code Civ. Proc., § 1048 (b).) The court has general discretion to order certain issues tried before others when the convenience of witnesses, the ends of justice or the economy and efficiency of handling the litigation would be promoted thereby. (Code Civ. Proc., § 598.) Discussion Defendant moves to bifurcate the issue of punitive damage. (Desal Decl., ¶3.) In cases assigned to the Personal Injury Hub, the case will be tried by a different judge than the one assigned to rule on this motion. The Court finds that because of the close relationship between bifurcation motions and trial management, it is appropriate in this matter for the trial judge to determine whether bifurcation is warranted. A motion to bifurcate is not a motion in limine. (Cal. Rules of Court, rule3.57(c).) Nonetheless, as it relates to management of the trial proceedings, a motion to bifurcate has certain attributes that are similar to motions in limine. And, in cases assigned to the Personal Injury Hub, the trial judge (not the judge in the Personal Injury Hub) rules on all motions in limine. While this bifurcation request is not a motion in limine, the logic of having the trial judge determine it here is similar. The request for bifurcation here is one on which the trial judge should make a discretionary determination based on its role in managing the trial proceedings. Accordingly, the Court orders that the bifurcation briefing be included in the trial binders in Tab B along with any motions in limine filed in the case. If there is any issue with regard to Rule of Court 3.57, Defendant or any other party may direct the trial court to this order (which of course does not impose any obligation on the trial judge with regard to ruling on the motion). Conclusion Based on the foregoing, Defendant Russel Alexander, M.D.s motion to bifurcate is DENIED without prejudice. Moving party to give notice.
Ruling
TIMOTHY AVALOS VS ENOVATIVE GROUP, INC., ET AL.
Aug 27, 2024 |Renee C. Reyna |20STCV30553
Case Number: 20STCV30553 Hearing Date: August 27, 2024 Dept: 29 Avalos v. Enovative Group 20STCV30553 Defendants Motion to Continue Trial Tentative The motion is denied as moot. The relief requested in the motion has already been granted. Moving party to give notice.
Ruling
ARPI BAGHOOMIAN VS RICARDO ARTURO FIERRO, ET AL.
Aug 28, 2024 |Renee C. Reyna |20STCV34257
Case Number: 20STCV34257 Hearing Date: August 28, 2024 Dept: 29 Baghoomian v. Fierro 20STCV34257 Motion to Bifurcate Tentative The motion is DENIED without prejudice. Background This case has a long factual and procedural history, only some of which will be summarized here. According to the Complaint, Plaintiff Arpi Baghoomian (Plaintiff) was seriously injured in an automobile accident on March 17, 2020. The other vehicle was driven by Defendant Ricardo Arturo Fierro (Fierro). On September 9, 2020, Plaintiff filed her Complaint against Fierro, Fletcher Jones Motor Cars, Inc./Audi of Beverly Hills (Audi BH or Defendant), VW Credit, Inc., and Does 1 through 50, asserting claims for negligence and negligent entrustment. On March 3, 2021, Plaintiff named Donald Stephenson (Stephenson) as Doe 1. On May 11, 2021, the Court, at the request of Plaintiff, dismissed all claims against VW Credit, Inc. On January 11, 2022, the Clerk entered Fierros default. On May 4, 2023, the Court granted Stephensons motion for summary judgment. On December 1, 2023, the Court denied Audi BHs motion for summary judgment. On April 24, 2024, Plaintiff amended the complaint to correct the name of Audi BH (the name, as corrected, is Jones BH Acquisitions LLC dba Audi of Beverly Hills). On August 1, 2023, Defendant BH Jones Acquisitions, LLC dba Audi of Beverly Hills filed this motion to bifurcate. On July 24, 2024, Plaintiff filed an opposition to the motion to bifurcate. No reply has been filed. Trial is set for March 17, 2025. Legal Standard The court, in furtherance of convenience or to avoid prejudice, or when separate trials will be conducive to expedition and economy, may order a separate trial of any cause of action & or of any separate issue or of any number of causes of action or issues& (Code Civ. Proc., § 1048 (b).) The court has general discretion to order certain issues tried before others when the convenience of witnesses, the ends of justice or the economy and efficiency of handling the litigation would be promoted thereby. (Code Civ. Proc., § 598.) Discussion Defendant moves to bifurcate liability from damages at trial. (Becker Decl., ¶ 13.) In cases assigned to the Personal Injury Hub, the case will be tried by a different judge than the one assigned to rule on this motion. The Court finds that because of the close relationship between bifurcation motions and trial management, it is appropriate in this matter for the trial judge to determine whether bifurcation is warranted. A motion to bifurcate is not a motion in limine. (Cal. Rules of Court, rule3.57(c).) Nonetheless, as it relates to management of the trial proceedings, a motion to bifurcate has certain attributes that are similar to motions in limine. And, in cases assigned to the Personal Injury Hub, the trial judge (not the judge in the Personal Injury Hub) rules on all motions in limine. While this bifurcation request is not a motion in limine, the logic of having the trial judge determine it here is similar. The request for bifurcation here appears to be one for which the trial judge should make a discretionary determination based on its role in managing the trial proceedings. Accordingly, the Court orders that the bifurcation briefing be included in the trial binders in Tab B along with any motions in limine filed in the case. If there is any issue with regard to Rule of Court 3.57, Defendant or any other party may direct the trial court to this order (which of course does not impose any obligation on the trial judge with regard to ruling on the motion). Conclusion Based on the foregoing, the motion to bifurcate is DENIED without prejudice. Moving party to give notice.
Ruling
HOLLINQUEST vs LAUREL PALMS APARTMENTS
Aug 31, 2024 |CVRI2105114
MOTION TO DEEM ADMITTEDREQUESTS FOR ADMISSION, SETONE AND FOR MONETARYSANCTIONS AGAINST PLAINTIFFHOLLINQUEST VS LAURELCVRI2105114 AMINA HARRELL AND/OR HERPALMS APARTMENTSATTORNEYS, 818 LAW GROUP, LLP;MEMORANDUM OF POINTS ANDAUTHORITIES; DECLARATION OFGARY H. KLEINTentative Ruling: Grant the unopposed motion as prayed.
Ruling
SHEILA MAGANA VS SKIN FIRST SPA, INC
Aug 28, 2024 |22NWCV00971
Case Number: 22NWCV00971 Hearing Date: August 28, 2024 Dept: C MAGANA v. SKIN FIRST SPA, INC. CASE NO.: 22NWCV00971 HEARING: 8/28/24 @ 9:30 A.M. #1 TENTATIVE RULING Defendants counsel, Sanjay Sabarwals motion to be relieved as counsel for Skin First Spa, Inc. is DENIED. Moving Party to give NOTICE. The motion is unopposed as of August 26, 2024. This is a continuation. Defendants counsel, Sanjay Sabarwal, moves to be relieved as counsel for Skin First Spa, Inc. On August 13, 2024, the Court found the attorney declaration demonstrated good cause for withdrawal based on a breakdown in the attorney-client relationship. However, Counsel did not file a Notice of Motion and Motion to Be Relieved as Counsel (MC051), an Order Granting Attorneys Motion to Be Relieved as Counsel (MC-053), and a Declaration in Support of Attorneys Motion to Be Relieved as Counsel (MC-052) on the appropriate forms, as outlined within California Rules of Court, rule 3.1362, subdivisions (a), (c), and (e). (Cal. Rules of Court, rule 3.1362, subd. (a), (c), (e).) Since the last hearing date, Counsel has filed a Motion to be Relieved as Counsel and a Declaration in Support of Attorneys Motion to be Relieved as Counsel, but Counsel has not filed or served a Proposed Order. (Cal. Rules of Court, rule 3.1362(d), (e).) Accordingly, the motion to be relieved as counsel for Skin First Spa, Inc. is DENIED.
Ruling
Melissa Lanctot vs Santa Cruz County
Aug 27, 2024 |23CV02111
23CV02111LANCTOT v. SANTA CRUZ COUNTY CROS-DEFENDANT KRISTI ANDERSON’S MOTION FOR GOOD FAITH SETTLEMENT The motion for good faith settlement is granted. Page 1 of 8 Based on the pleadings, the settlement paid to plaintiff of $100,000 is within thereasonable range of the settling tortfeasor’s proportional share of comparative liability for thealleged damages. (Tech-Bilt, Inc. v. Woodward-Clyde & Associates (1985) 38 Cal.3d 488, 499.) The court finds there is little proportionate fault on the part of settling defendantAnderson. The CHP report notes the collision occurred at approximately 3:15 pm on a clear, dry,sunny day and that the primary crash factor was Damian Lanctot’s violation of Vehicle Code §21460(a) when he was attempting to pass another vehicle (crossing into opposing lane overdouble yellow lines). (Pinelli Declaration, Ex. A.) While County argues that proportionateliability is unclear or disputed, Anderson was not ascribed any fault in the CHP investigation. Further, County’s contention that Lanctot and Anderson do not agree on liability orcausation according to Lanctot’s discovery responses is unsupported by that discovery. Instead,County’s Special Interrogatories did not seek information from Lanctot regarding the CHP report(Shaw Decl. Ex. 3) and Lanctot objected to County’s Requests for Admission regarding the CHPreport, but provided no substantive information indicating she believed Anderson to be at fault(Shaw Decl. Ex. 4).Notice to prevailing parties: Local Rule 2.10.01 requires you to submit a proposed formal orderincorporating, verbatim, the language of any tentative ruling – or attaching and incorporating thetentative by reference - or an order consistent with the announced ruling of the Court, inaccordance with California Rule of Court 3.1312. Such proposed order is required even if theprevailing party submitted a proposed order prior to the hearing (unless the tentative issimply to “grant”). Failure to comply with Local Rule 2.10.01 may result in the imposition ofsanctions following an order to show cause hearing, if a proposed order is not timely filed.
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LISA M. MARTIN vs. PROGRESSIVE DIRECT INSURANCE COMPANY, ET AL.
Aug 02, 2024 |ANDREW J. SANTOLI |TORT-M.V. ACCIDENT |CV-24-101572
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WILLIAM TODTEN vs. IDA CONTROLS, ET AL.
Aug 02, 2024 |KELLY ANN GALLAGHER |TORT-M.V. ACCIDENT |CV-24-101631
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TOMMY MIMS vs. MACK CHARLES PAMPLEY
Aug 16, 2024 |MICHAEL P SHAUGHNESSY |TORT-M.V. ACCIDENT |CV-24-102299
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DAMALI MCGREGOR, ET AL. vs. PROGRESSIVE DIRECT INSURANCE COMPANY, ET AL.
Aug 16, 2024 |JOHN P O |TORT-M.V. ACCIDENT |CV-24-102289
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IRA AGBOU vs. V LINE, LLC, ET AL.
Jul 31, 2024 |WILLIAM F. B. VODREY |TORT-M.V. ACCIDENT |CV-24-101443
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DAMIAN SOKOLOWSKI, ET AL. vs. COREY ALLEN COURTNEY
Aug 08, 2024 |STEVEN E GALL |TORT-M.V. ACCIDENT |CV-24-101927
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ANGELA MAXWELL vs. COUNTRY LANE HOLDINGS, LLC, ET AL.
Aug 14, 2024 |JENNIFER O'DONNELL |TORT-M.V. ACCIDENT |CV-24-102167
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JONATHAN SHUCOFSKY POPA vs. NATALIE WILT, ET AL
Aug 02, 2024 |JOHN P O |TORT-M.V. ACCIDENT |CV-24-101601
