Barbara A. Jackson, As Personal Representative Vs. Galion Pointe, Inc., Et Al.

MOTION TO DISMISS FILED PARTIAL MOTION TO DISMISS ON BEHALF OF DEFENDANTS, GALION POINTE LLC, JAG HEALTHCARE, DAVID COOLEY, AND JONES GRIFFITHS

MOTION FILED FOR P1 BARBARA A. JACKSON BLAKE A DICKSON 0059329 PLAINTIFF'S MOTION FOR LEAVE TO FILE THE WITHIN SUR REPLY BRIEF INSTANTER

REPLY BRIEF FILED BY DEFENDANT(S) GALION POINTE, INC.(D1), GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 REPLY BRIEF IN SUPPORT OF PARTIAL MOTION TO DISMISS

CMC BY PHONE HELD ON 06/13/2022. ALL COUNSEL PRESENT. FACT DISCOVERY TO BE COMPLETED BY 11/11/2022. PLAINTIFF'S EXPERT REPORT DUE 11/11/2022. DEFENDANT'S EXPERT REPORT DUE 01/09/2023. DISPOSITIVE MOTION TO BE FILED BY 01/16/2023. PARTIES ARE ADVISED THAT COURTESY COPIES OF ALL E-FILED DISPOSITIVE MOTIONS, AND ANY OTHER E-FILED MOTION LONGER THAN 10 PAGES MUST BE DELIVERED IN PERSON OR BY MAIL TO CHAMBERS WITHIN 2 DAYS OF FILING. REPLY BRIEFS MAY BE FILED WITHOUT LEAVE OF COURT. SETTLEMENT CONFERENCE SET FOR 01/26/2023 AT 02:00 PM. ALL PARTIES WITH SETTLEMENT AUTHORITY MUST PARTICIPATE. FINAL PRETRIAL SET FOR 03/30/2023 AT 02:30 PM. ALL PARTIES WITH SETTLEMENT AUTHORITY MUST PARTICIPATE. JURY TRIAL SET FOR 05/01/2023 AT 09:30 AM. MOTIONS IN LIMINE, IF ANY, ARE TO BE FILED AT LEAST 14 DAYS PRIOR TO TRIAL. (COPIES TO BE HAND-DELIVERED TO COURTROOM 17-D.) PARTIES TO EXCHANGE PROPOSED STIPULATIONS 14 DAYS PRIOR TO TRIAL. COUNSEL TO PROVIDE COPIES OF ALL EXHIBITS TO OPPOSING COUNSEL AND TO THE COURT ON THE MORNING OF TRIAL. COUNSEL TO PROVIDE THE COURT WITH PROPOSED JURY INSTRUCTIONS AND WITNESS LISTS ON MORNING OF TRIAL. THE COURT PREFERS JURY INSTRUCTIONS ALSO BE PROVIDED IN WORD FORMAT AND E-MAILED TO STAFF ATTORNEY, CARA KOZYK, AT CAKOZYK@CUYAHOGACOUNTY.US. NOTICE ISSUED

MOTION FILED FOR DEFENDANT(S) GALION POINTE, INC.(D1), GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 MOTION FOR PROTECTIVE ORDER ON BEHALF OF DEFENDANTS, GALION POINTE, INC., GALION POINTE, LLC, JAG HEALTHCARE, DAVID COOLEY, AND JAMES GRIFFITHS

WAIVER OF SERVICE OF SUMMONS RETURNED SIGNED ON 07/14/2022 WAIVER OF THE SERVIUCE OF PLAINTIFF'S COMPLAINT BY JAG HEALTHCARE, INC., JAMES GRIFFITHS, AND DAVID COOLEY PURSUANT TO CIVIL RULE 4.7

MOTION TO DISMISS FILED MOTION TO DISMISS ON BEHALF OF DEFENDANTS, GALION POINTE, LLC, JAG HEALTHCARE, DAVID COOLEY, AND JAMES GRIFFITHS 06/10/2022 - DENIED

MOTION TO TRANSFER VENUE TO THE CRAWFORD COUNTY COURT OF COMMON PLEAS PURSUANT TO CIV R 3D ON BEHALF OF DEFENDANTS GALION JAG COOLEY AND GRIFFITHS, FILED 03/17/2022, IS DENIED. PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO FILE AFFIDAVIT OF MERIT, FILED 02/09/2022, IS GRANTED. THE AFFIDAVIT OF MERIT, FILED ON 06/09/2022, IS DEEMED TIMELY FILED. MOTION TO DISMISS ON BEHALF OF DEFENDANTS, GALION POINTE, LLC, JAG HEALTHCARE, DAVID COOLEY, AND JAMES GRIFFITHS, FILED 05/19/2022, IS DENIED. AT THE CMC, THIS COURT INDICATED THAT THE COURT WOULD STAY ALL DEADLINES, INCLUDING THE TIME TO FILE AN AFFIDAVIT OF MERIT, SOUGHT BY PLAINTIFF, AND THE STAY OF DISCOVERY, SOUGHT BY DEFENDANT, UNTIL THE COURT COULD RULE ON THE MOTION TO TRANSFER VENUE. HAVING DENIED THE MOTION TO TRANSFER VENUE WITHIN THIS ORDER, THIS CASE WILL PROCEED TO A CMC TO SET A TRIAL SCHEDULE. PLAINTIFF'S MOTION TO STRIKE THE MOTION TO DISMISS FILED BY DEFENDANTS, FILED 05/20/2022, IS MOOT. MOTION TO STAY DISCOVERY ON BEHALF OF DEFENDANTS COOLEY GRIFFITHS JAG AND GALION, FILED 03/17/2022, IS MOOT AS THIS COURT DETERMINED THAT PLAINTIFF HAS TIMELY FILED AN AFFIDAVIT OF MERIT. NOTICE ISSUED

BRIEF IN OPPOSITION FILED BY DEFENDANT(S) GALION POINTE, INC.(D1), GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) BRET C PERRY 0073488 BRIEF IN OPPOSITION TO MOTION TO STRIKE ON BEHALF OF DEFENDANTS, GALION POINTE, LLC, JAG HEALTHCARE, DAVID COOLEY, AND JAMES GRIFFITHS

NOTICE FILED BY P1 BARBARA A. JACKSON ATTORNEY PAMELA DIMO 0095371 PLAINTIFF'S NOTICE OF FILING AFFIDAVIT OF MERIT OF CHARLOTTE SHEPPARD, DNP, RN-BC, LHRM, WCC, CNECL

REPLY BRIEF FILED BY DEFENDANT(S) GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) BRET C PERRY 0073488 REPLY BRIEF IN SUPPORT OF MOTION TO TRANSFER VENUE TO THE CRAWFORD COUNTY COURT OF COMMON PLEAS PURSUANT TO CIV.R. 3(D) ON BEHALF OF DEFENDANTS

BRIEF IN OPPOSITION FILED BY P1 BARBARA A. JACKSON PAMELA DIMO 0095371 PLAINTIFF'S BRIEF IN OPPOSITION TO THE MOTION TO STAY DISCOVERY FILED BY THE DEFENDANTS

BRIEF IN OPPOSITION FILED BY P1 BARBARA A. JACKSON BLAKE A DICKSON 0059329 PLAINTIFF'S BRIEF IN OPPOSITION TO THE PARTIAL MOTION TO DISMISS FILED BY THE DEFENDANTS.

REPLY BRIEF FILED BY P1 BARBARA A. JACKSON PAMELA DIMO 0095371 PLAINTIFF'S REPLY BRIEF IN SUPPORT OF HER MOTION TO STRIKE THE MOTION TO DISMISS FILED BY DEFENDANTS

NOTICE FILED BY P1 BARBARA A. JACKSON ATTORNEY PAMELA DIMO 0095371 PLAINTIFF'S NOTICE OF FILING AFFIDAVIT OF MERIT OF MATTHEW LEVY, M.D.

BRIEF IN OPPOSITION FILED BY P1 BARBARA A. JACKSON PAMELA DIMO 0095371 PLAINTIFF'S BRIEF IN OPPOSITION TO DEFENDANTS' MOTION TO CHANGE VENUE

CASE CALLED FOR CMC ON 05/04/2022. THE CMC WAS CONTINUED TO ALLOW FOR A RULING ON THE PENDING MOTION TO TRANSFER VENUE. CMC BY PHONE SET FOR 06/13/2022 AT 02:00 PM. PLAINTIFF'S COUNSEL, OR PLAINTIFF, IF PROCEEDING PRO SE, SHALL INITIATE THE CONFERENCE CALL WITH ALL OTHER PARTIES, AND THEN CONTACT THE COURT'S STAFF ATTORNEY, CARA KOZYK AT 216-443-5595. PLEASE DO NOT APPEAR IN PERSON. NOTICE ISSUED

MOTION TO TRANSFER VENUE, FILED MOTION TO TRANSFER VENUE TO THE CRAWFORD COUNTY COURT OF COMMON PLEAS PURSUANT TO CIV R 3D ON BEHALF OF DEFENDANTS GALION JAG COOLEY AND GRIFFITHS 06/10/2022 - DENIED

MOTION FILED FOR P1 BARBARA A. JACKSON PAMELA DIMO 0095371 PLAINTIFF'S MOTION TO STRIKE THE MOTION TO DISMISS FILED BY DEFENDANTS 06/10/2022 - MOOT

REPLY BRIEF FILED BY DEFENDANT(S) GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) BRET C PERRY 0073488 REPLY BRIEF IN SUPPORT OF THE MOTION TO STAY DISCOVERY ON BEHALF OF DEFENDANTS

SUMS COMPLAINT(46690265) SENT BY CERTIFIED MAIL. TO: DAVID COOLEY 2226 WOOSTER ROAD ROCKY RIVER, OH 44116

ANSWER FILED BY DEFENDANT(S) GALION POINTE, INC.(D1), GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) ATTORNEY BRET C PERRY 0073488 ANSWER TO PLAINTIFF'S COMPLAINT ON BEHALF OF COOLEY GRIFFITHS JAG AND GALION

MOTION FILED FOR DEFENDANT(S) GALION POINTE, INC.(D1), GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) BRET C PERRY 0073488 MOTION TO STAY DISCOVERY ON BEHALF OF DEFENDANTS COOLEY GRIFFITHS JAG AND GALION 06/10/2022 - MOOT

MOTION FOR EXTENSION OF TIME TO FILE AFFIDAVIT OF MERIT 06/10/2022 - GRANTED

SUBPOENA SERVICE RETURN FILED LABCORP, PAMELA DIMO (0095371) RETURN OF SERVICE ON LABCORP

BRIEF IN OPPOSITION FILED BY P1 BARBARA A. JACKSON PAMELA DIMO 0095371 PLAINTIFF'S MOTION FOR LEAVE TO FILE THE WITHIN BRIEF IN OPPOSITION TO DEFENDANTS' MOTION FOR PROTECTIVE ORDER, INSTANTER, AND PLAINTIFF'S MOTION FOR REASONABLE EXPENSES PURSUANT TO CIVIL RULE 37(A)(5)(B)

BRIEF IN OPPOSITION FILED BY DEFENDANT(S) GALION POINTE, INC.(D1), GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 BRIEF IN OPPOSITION TO PLAINTIFF'S MOTION FOR LEAVE TO FILE BRIEF IN OPPOSITION TO DEFENDANTS' MOTION FOR PROTECTIVE ORDER INSTANTER ON BEHALF OF DEFENDANTS

MOTION FILED FOR DEFENDANT(S) GALION POINTE, INC.(D1), GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 MOTION TO COMPEL AND FOR AWARD OF REASONABLE EXPENSES PURSUANT TO CIV.R. 37(A) ON BEHALF OF DEFENDANTS, GALION POINTE, INC., GALION POINTE, LLC, JAG HEALTHCARE, DAVID COOLEY, AND JAMES GRIFFITHS

BRIEF IN OPPOSITION FILED BY P1 BARBARA A. JACKSON PAMELA DIMO 0095371 PLAINTIFF'S BRIEF IN OPPOSITION TO THE MOTION TO COMPEL AND MOTION FOR AWARD OF EXPENSES FILED BY THE DEFENDANTS

SUBPOENA SERVICE RETURN FILED TRIDENT CARE, PAMELA DIMO (0095371) RETURN OF SERVICE ON TRIDENT CARE

REPLY BRIEF FILED BY DEFENDANT(S) GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 REPLY BRIEF IN SUPPORT OF DEFENDANTS' MOTION TO COMPEL ON BEHALF OF DEFENDANTS

REPLY BRIEF FILED BY P1 BARBARA A. JACKSON PAMELA DIMO 0095371 PLAINTIFF'S REPLY IN SUPPORT OF HER MOTION FOR LEAVE TO FILE THE A BRIEF IN OPPOSITION TO THE MOTION FOR PROTECTIVE ORDER FILED BY THE DEFENDANTS, INSTANTER AND PLAINTIFF'S REPLY IN SUPPORT OF HER MOTION FOR REASONABLE EXPENSES PURSUANT TO CIVIL RULE 37(A)(5)(B)

MOTION FOR EXTENSION OF TIME PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO IDENTIFY EXPERTS AND PRODUCE THEIR EXPERT REPORTS UNTIL DECEMBER 27, 2022 AND MOTION TO EXTEND THE DISCOVERY CUT-OFF UNTIL DECEMBER 27, 2022

SUBPOENA SERVICE RETURN FILED BARBARA BULL, BLAKE A DICKSON (0059329) PROOF OF SERVICE OF TRIAL SUBPOENA BULL

BRIEF IN OPPOSITION FILED BY P1 BARBARA A. JACKSON BLAKE A DICKSON 0059329 PLAINTIFF'S BRIEF IN OPPOSITION TO DEFENDANTS' MOTION ASKING THE COURT TO EXCLUDE CRITICISMS OF PLAINTIFF'S EXPERT, CHARLOTTE SHEPPARD, RN

BRIEF IN OPPOSITION FILED BY P1 BARBARA A. JACKSON BLAKE A DICKSON 0059329 PLAINTIFF'S BRIEF IN OPPOSITION TO DEFENDANTS' MOTION IN LIMINE ASKING THE COURT TO PRECLUDE ANY EVIDENCE OF STAFFING

SUBPOENA SERVICE RETURN FILED REGINA WOLFORD, BLAKE A DICKSON (0059329) PROOF OF SERVICE OF TRIAL SUBPOENA WOLFORD

TELEPHONE CONFERENCE HELD 03/30/2023. ALL COUNSEL PRESENT. THE COURT WILL ISSUE RULINGS ON THE PENDING MOTIONS WHEN THEY ALL BECOME RIPE AND WILL SET A DISCOVERY DEADLINE ACCORDINGLY. CASE TO PROCEED WITH THE FOLLOWING DATES: SETTLEMENT CONFERENCE SET FOR 06/20/2023 AT 10:00 AM. ALL PARTIES WITH SETTLEMENT AUTHORITY MUST PARTICIPATE. FINAL PRETRIAL SET FOR 09/21/2023 AT 10:00 AM. ALL PARTIES WITH SETTLEMENT AUTHORITY MUST PARTICIPATE. TRIAL SET FOR 11/06/2023 AT 09:30 AM. MOTIONS IN LIMINE, IF ANY, ARE TO BE FILED AT LEAST 14 DAYS PRIOR TO TRIAL. (COPIES TO BE HAND-DELIVERED TO COURTROOM 17-D.) PARTIES TO EXCHANGE PROPOSED STIPULATIONS 14 DAYS PRIOR TO TRIAL. COUNSEL TO PROVIDE COPIES OF ALL EXHIBITS TO OPPOSING COUNSEL AND TO THE COURT ON THE MORNING OF TRIAL. COUNSEL TO PROVIDE THE COURT WITH PROPOSED JURY INSTRUCTIONS AND WITNESS LISTS ON MORNING OF TRIAL. THE COURT PREFERS JURY INSTRUCTIONS ALSO BE PROVIDED IN WORD FORMAT AND E-MAILED TO STAFF ATTORNEY, CARA KOZYK, AT CAKOZYK@CUYAHOGACOUNTY.US. NOTICE ISSUED

SUBPOENA SERVICE RETURN FILED KIMBERLY BENSON, BLAKE A DICKSON (0059329) PROOF OF SERVICE OF TRIAL SUBPOENA BEAVERS

BRIEF IN OPPOSITION FILED BY DEFENDANT(S) GALION POINTE, INC.(D1), GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 BRIEF IN OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL ON BEHALF OF DEFENDANTS, DAVID COOLEY, JAMES GRIFFITHS, JAG HEALTHCARE, AND GALION POINTE, LLC

MOTION IN LIMINE MOTION IN LIMINE TO EXCLUDE STANDARD OF CARE CRITICISMS WITHOUT A CAUSAL LINK TO THE DECEDENT'S FALL AND/OR DEATH ON BEHALF OF DEFENDANTS, GALION POINTE, LLC, JAG HEALTHCARE, DAVID COOLEY, AND JAMES GRIFFITHS 11/02/2023 - MOOT

REPLY BRIEF FILED BY DEFENDANT(S) GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 REPLY BRIEF IN SUPPORT OF DEFENDANTS' MOTION TO STRIKE PLAINTIFF'S UNTIMELY EXPERT IDENTIFICATION, ON BEHALF OF DEFENDANTS

SUBPOENA SERVICE RETURN FILED KIMBERLY BENSON, BLAKE A DICKSON (0059329) PROOF OF SERVICE OF TRIAL SUBPOENA BENSON

BRIEF IN OPPOSITION FILED BY DEFENDANT(S) GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 BRIEF IN OPPOSITION TO PLAINTIFF'S MOTION IN LIMINE ASKING THE COURT TO ALLOW PLAINTIFF TO PUT ON HER CASE IN CHIEF BEFORE THE DEFENDANTS ARE PERMITTED TO PUT ON THEIR CASE IN CHIEF ON BEHALF OF DEFENDANTS

BRIEF FILED BY DEFENDANT(S) GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 TRIAL BRIEF ON BEHALF OF DEFENDANTS, GALION POINTE, LLC, JAG HEALTHCARE, DAVID COOLEY, AND JAMES GRIFFITHS

MOTION IN LIMINE PLAINTIFF'S MOTION IN LIMINE REGARDING THE ISSUE OF COMPARATIVE NEGLIGENCE 11/02/2023 - MOOT

NOTICE OF SUBSTITUTION OF COUNSEL FILED PLAINTIFF'S NOTICE OF SUBSTITUTION OF COUNSEL

BRIEF IN OPPOSITION FILED BY P1 BARBARA A. JACKSON BLAKE A DICKSON 0059329 PLAINTIFF'S BRIEF IN OPPOSITION TO DEFENDANTS' MOTION TO SHOW CAUSE

SETTLEMENT CONFERENCE HELD ON 11/02/2023. ALL COUNSEL PRESENT. THIS CASE SETTLED AND WILL BE DISMISSED PENDING PROBATE COURT APPROVAL. PARTIES TO SUBMIT A FORMAL DISMISSAL ENTRY. THIS COURT RETAINS JURISDICTION OVER THE SETTLEMENT AGREEMENT. COURT COST ASSESSED TO THE DEFENDANT(S). NOTICE ISSUED

NOTICE OF TRANSCRIPT FILED P1 BARBARA A. JACKSON, BLAKE A DICKSON 0059329 NOTICE OF FILING DEPOSITION TRANSCRIPT OF RHONDA DAVEY

MOTION FILED FOR P1 BARBARA A. JACKSON BLAKE A DICKSON 0059329 PLAINTIFF'S MOTION TO COMPEL. 11/02/2023 - MOOT

NOTICE OF DEPOSITION OF DEFENDANT(S) GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) FILED NOTICE OF VIDEOTAPED DISCOVERY DEPOSITION VIA ZOOM OF PLAINTIFF'S EXPERT CHARLOTTE SHEPPARD, DNP RN-BC LHRM WCC CNECL WITH DUCES TECUM

MOTION IN LIMINE PLAINTIFF'S MOTION IN LIMINE TO PRECLUDE DEFENDANTS FROM DISCUSSING AN IRRELEVANT EVENT 11/02/2023 - MOOT

MOTION IN LIMINE PLAINTIFFS MOTION IN LIMINE TO ALLOW PLAINTIFF TO INTRODUCE CLIMATOLOGICAL OBSERVATION DATA INTO EVIDENCE AT TRIAL 11/02/2023 - MOOT

MOTION IN LIMINE MOTION IN LIMINE TO PRECLUDE ANY NEW EXPERT OPINIONS ON BEHALF OF DEFENDANTS, GALION POINTE, LLC, JAG HEALTHCARE, DAVID COOLEY, AND JAMES GRIFFITHS 11/02/2023 - MOOT

MOTION FILED FOR P1 BARBARA A. JACKSON BLAKE A DICKSON 0059329 PLAINTIFF'S MOTION TO APPOINT ROGER MARTIN AS SPECIAL PROCESS SERVER 11/02/2023 - MOOT

NOTICE OF TRANSCRIPT FILED P1 BARBARA A. JACKSON, BLAKE A DICKSON 0059329 NOTICE OF FILING DEPOSITION TRANSCRIPT OF DEFENDANTS' 30(B)(5) REPRESENTATIVE, DAVID COOLEY

SUBPOENA SERVICE RETURN FILED AMANDA MCADOW, BLAKE A DICKSON (0059329) PROOF OF SERVICE OF TRIAL SUBPOENA MCADOW

MOTION IN LIMINE PLAINTIFF'S MOTION IN LIMINE REGARDING SPECULATION RELATIVE TO THE WANDERGUARD BRACELET WORN BY DECEDENT CLYDE JACKSON. 11/02/2023 - MOOT

NOTICE FILED BY DEFENDANT(S) GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) ATTORNEY CHRISTOPHER F MARS 0091604 NOTICE OF DEMAND FOR DISMISSAL AND INTENTION TO FILE GOOD FAITH MOTION TO DISMISS ON BEHALF OF DEFENDANTS, GALION POINTE, LLC, JAG HEALTHCARE, INC., DAVID COOLEY, AND JAMES GRIFFITH

MOTION IN LIMINE PLAINTIFF'S MOTION IN LIMINE TO EXCLUDE ANY REFERENCE TO COLLATERAL SOURCES 11/02/2023 - MOOT

MOTION FILED FOR P1 BARBARA A. JACKSON BLAKE A DICKSON 0059329 PLAINTIFF'S MOTION TO COMPEL 07/26/2023 - GRANTED AND DENIED IN PART

NOTICE OF DEPOSITION OF DEFENDANT(S) GALION POINTE, INC.(D1), GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) FILED NOTICE OF DEPOSITION OF PLAINTIFF BARBARA JACKSON ON BEHALF OF DEFENDANTS

REPLY BRIEF FILED BY DEFENDANT(S) GALION POINTE, INC.(D1), GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 REPLY BRIEF IN SUPPORT OF MOTION TO DISMISS ON BEHALF OF DEFENDANTS, DAVID COOLEY, JAMES GRIFFITHS, JAG HEALTHCARE, AND GALION POINT, LLC

MOTION FILED FOR DEFENDANT(S) GALION POINTE, INC.(D1), GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 MOTION TO COMPEL AND FOR AWARD OF REASONABLE EXPENSES PURSUANT TO CIV.R. 37(A) ON BEHALF OF DEFENDANTS, GALION POINTE, INC., GALION POINTE, LLC, JAG HEALTHCARE, DAVID COOLEY, AND JAMES GRIFFITHS 07/26/2023 - GRANTED

NOTICE OF DEPOSITION OF DEFENDANT(S) GALION POINTE, INC.(D1), GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) FILED NOTICE OF DEPOSITION OF CRAIG JACKSON ON BEHALF OF DEFENDANTS

MOTION IN LIMINE MOTION IN LIMINE TO PRECLUDE THE INTRODUCTION OR DISCUSSION OF POLICIES AND PROCEDURES AT TRIAL ON BEHALF OF DEFENDANTS, GALION POINTE, LLC, JAG HEALTHCARE, DAVID COOLEY, AND JAMES GRIFFITHS 11/02/2023 - MOOT

MOTION FILED FOR DEFENDANT(S) GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 MOTION TO PERMIT DEFENDANTS TO EXAMINE FACT WITNESSES DURING PLAINTIFF'S CASE-IN-CHIEF PURSUANT TO EVID.R. 611(A) ON BEHALF OF DEFENDANTS, GALION POINTE, LLC, JAG HEALTHCARE, DAVID COOLEY, AND JAMES GRIFFITHS 11/02/2023 - MOOT

BRIEF IN OPPOSITION FILED BY DEFENDANT(S) GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 BRIEF IN OPPOSITION TO PLAINTIFF'S MOTION IN LIMINE TO PRECLUDE DEFENDANTS AND THEIR WITNESSES FROM DISCUSSING AN IRRELEVANT EVENT

BRIEF IN OPPOSITION FILED BY P1 BARBARA A. JACKSON BLAKE A DICKSON 0059329 PLAINTIFF'S BRIEF IN OPPOSITION TO DEFENDANTS' MOTION TO DISMISS AND PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO PRODUCE EXPERT REPORTS

BRIEF IN OPPOSITION FILED BY DEFENDANT(S) GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 BRIEF IN OPPOSITION TO PLAINTIFF'S MOTION IN LIMINE REGARDING SPECULATION RELATIVE TO THE WANDERGUARD BRACELET WORN BY DECEDENT CLYDE JACKSON ON BEHALF OF DEFENDANTS

MOTION IN LIMINE PLAINTIFF'S MOTION IN LIMINE TO PRECLUDE DEFENDANTS AND THEIR WITNESSES FROM COMMENTING ABOUT THE CONDITIONS OF OTHER NURSING HOMES. 11/02/2023 - MOOT

BRIEF IN OPPOSITION FILED BY DEFENDANT(S) GALION POINTE, INC.(D1), GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 BRIEF IN OPPOSITION TO PLAINTIFF'S MOTION IN LIMINE RELATIVE TO DECEDENT CLYDE JACKSON'S MEDICAL RECORDS AND BILLS

MOTION FILED FOR DEFENDANT(S) GALION POINTE, INC.(D1), GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 MOTION TO DISMISS FOR FAILURE TO COMPLY WITH A COURT ORDER ON BEHALF OF DEFENDANTS, DAVID COOLEY, JAMES GRIFFITHS, JAG HEALTHCARE, AND GALION POINTE, LLC 07/26/2023 - DENIED

MOTION FOR EXTENSION OF TIME PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO IDENTIFY EXPERTS AND PRODUCE THEIR EXPERT REPORTS UNTIL DECEMBER 27, 2022 AND MOTION TO EXTEND THE DISCOVERY CUT-OFF UNTIL DECEMBER 27, 2022 07/26/2023 - GRANTED

MOTION IN LIMINE PLAINTIFF'S MOTION IN LIMINE REGARDING REFERENCE TO THE STATE AND FEDERAL LAWS AND REGULATIONS THAT APPLY TO THE CARE OF NURSING HOME RESIDENTS IN A NURSING HOME. 11/02/2023 - MOOT

SUBPOENA SERVICE RETURN FILED JESSICA BEAVERS, BLAKE A DICKSON (0059329) PROOF OF SERVICE OF TRIAL SUBPOENA BEAVERS

BRIEF IN OPPOSITION FILED BY P1 BARBARA A. JACKSON BLAKE A DICKSON 0059329 PLAINTIFF'S BRIEF IN OPPOSITION TO DEFENDANTS' MOTION TO STRIKE PLAINTIFF'S EXPERT WITNESSES.

BRIEF IN OPPOSITION FILED BY DEFENDANT(S) GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 BRIEF IN OPPOSITION TO PLAINTIFF'S MOTION IN LIMINE TO PRECLUDE DEFENDANTS AND THEIR WITNESSES FROM COMMENTING ABOUT THE CONDITIONS OF OTHER NURSING HOMES ON BEHALF OF DEFENDANTS

BRIEF IN OPPOSITION FILED BY DEFENDANT(S) GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 BRIEF IN OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL PERSONNEL FILES ON BEHALF OF DEFENDANTS, GALION POINTE, LLC, JAG HEALTHCARE, INC., DAVID COOLEY, AND JAMES GRIFFITHS

MOTION FILED FOR DEFENDANT(S) GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 MOTION FOR SEPARATION OF WITNESSES PURSUANT TO EVID.R. 615(A)ON BEHALF OF DEFENDANTS, GALION POINTE, LLC, JAG HEALTHCARE, DAVID COOLEY, AND JAMES GRIFFITHS 11/02/2023 - MOOT

MOTION FILED FOR DEFENDANT(S) GALION POINTE, INC.(D1), GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 MOTION TO STRIKE PLAINTIFF'S EXPERT WITNESSES ON BEHALF OF DEFENDANTS, DAVID COOLEY, JAMES GRIFFITHS, JAG HEALTHCARE, AND GALION POINTE, LLC 07/26/2023 - DENIED

MOTION TO DISMISS FILED PARTIAL MOTION TO DISMISS ON BEHALF OF DEFENDANTS, GALION POINTE LLC, JAG HEALTHCARE, DAVID COOLEY, AND JONES GRIFFITHS 05/15/2023 - DENIED

REPLY BRIEF FILED BY P1 BARBARA A. JACKSON BLAKE A DICKSON 0059329 PLAINTIFF'S REPLY BRIEF IN SUPPORT OF PLAINTIFF'S MOTION TO COMPEL

BRIEF IN OPPOSITION FILED BY DEFENDANT(S) GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 BRIEF IN OPPOSITION TO PLAINTIFF'S MOTION IN LIMINE REGARDING REFERENCE TO STATE AND FEDERAL LAWS AND REGULATIONS THAT APPLY TO THE CARE OF NURSING HOME RESIDENTS IN A NURSING HOME ON BEHALF OF DEFENDANTS

SUBPOENA SERVICE RETURN FILED NATALIE BERGER, BLAKE A DICKSON (0059329) PROOF OF SERVICE TRIAL SUBPOENA BERGER

REPLY BRIEF FILED BY DEFENDANT(S) GALION POINTE, INC.(D1), GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 REPLY BRIEF IN SUPPORT OF MOTION TO SHOW CAUSE AND REQUEST FOR HEARING AND SANCTIONS ON BEHALF OF DEFENDANTS, GALION POINTE, LLC, JAG HEALTHCARE, DAVID COOLEY, AND JAMES GRIFFITHS

MOTION FILED FOR DEFENDANT(S) GALION POINTE, INC.(D1), GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 MOTION FOR PROTECTIVE ORDER ON BEHALF OF DEFENDANTS, GALION POINTE, INC., GALION POINTE, LLC, JAG HEALTHCARE, DAVID COOLEY, AND JAMES GRIFFITHS 07/26/2023 - DENIED

REPLY BRIEF FILED BY P1 BARBARA A. JACKSON BLAKE A DICKSON 0059329 PLAINTIFF'S REPLY BRIEF IN SUPPORT OF PLAINTIFF'S MOTION TO COMPEL

BRIEF IN OPPOSITION FILED BY DEFENDANT(S) GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 BRIEF IN OPPOSITION TO PLAINTIFF'S MOTION IN LIMINE TO EXCLUDE ANY REFERENCE TO COLLATERAL SOURCES ON BEHALF OF DEFENDANTS, GALION POINTE, LLC, JAG HEALTHCARE, DAVID COOLEY, AND JAMES GRIFFITHS

MOTION IN LIMINE MOTION IN LIMINE TO PRECLUDE INTRODUCTION OR DISCUSSION OF LITERATURE DURING PLAINTIFF'S CASE IN CHIEF ON BEHALF OF DEFENDANTS, GALION POINTE, LLC, JAG HEALTHCARE, DAVID COOLEY, AND JAMES GRIFFITHS 11/02/2023 - MOOT

MOTION FILED FOR P1 BARBARA A. JACKSON BLAKE A DICKSON 0059329 PLAINTIFF'S MOTION FOR LEAVE TO FILE THE WITHIN SUR REPLY BRIEF INSTANTER 05/15/2023 - GRANTED

SUBPOENA SERVICE RETURN FILED CASSANDRA ROHR, BLAKE A DICKSON (0059329) PROOF OF SERVICE OF TRIAL SUBPOENA ROHR

NOTICE FILED BY DEFENDANT(S) GALION POINTE, INC.(D1), GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) ATTORNEY CHRISTOPHER F MARS 0091604 NOTICE OF FILING AFFIDAVIT OF AMANDA MCADOW, LNHA ON BEHALF OF DEFENDANTS, DAVID COOLEY, JAMES GRIFFITHS, JAG HEALTHCARE, AND GALION POINTE, LLC

MOTION FILED FOR P1 BARBARA A. JACKSON BLAKE A DICKSON 0059329 PLAINTIFF'S MOTION TO COMPEL 07/26/2023 - GRANTED AND DENIED IN PART

BRIEF IN OPPOSITION FILED BY DEFENDANT(S) GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 BRIEF IN OPPOSITION TO PLAINTIFF'S MOTION IN LIMINE REGARDING SPECULATION ON BEHALF OF DEFENDANTS

SUBPOENA SERVICE RETURN FILED DAVID COOLEY, BLAKE A DICKSON (0059329) PROOF OF SERVICE OF TRIAL SUBPOENA

SUBPOENA SERVICE RETURN FILED SHANDYN KEENAN, BLAKE A DICKSON (0059329) PROOF OF SERVICE OF TRIAL SUBPOENA KEENAN

MOTION IN LIMINE MOTION IN LIMINE TO PRECLUDE ANY REFERENCE TO GOVERNMENT INSPECTIONS/SURVEYS ON BEHALF OF DEFENDANTS, GALION POINTE, LLC, JAG HEALTHCARE, DAVID COOLEY, AND JAMES GRIFFITHS 11/02/2023 - MOOT

SUBPOENA SERVICE RETURN FILED PAULA ROSE, BLAKE A DICKSON (0059329) PROOF OF SERVICE OF TRIAL SUBPOENA ROSE

SUBPOENA SERVICE RETURN FILED RHONDA DAVEY, BLAKE A DICKSON (0059329) PROOF OF SERVICE OF TRIAL SUBPOENA

MOTION FOR PROTECTIVE ORDER ON BEHALF OF DEFENDANTS, GALION POINTE, INC., GALION POINTE, LLC, JAG HEALTHCARE, DAVID COOLEY, AND JAMES GRIFFITHS, FILED 08/31/2022, IS DENIED. MOTION TO COMPEL AND FOR AWARD OF REASONABLE EXPENSES PURSUANT TO CIV.R. 37(A) ON BEHALF OF DEFENDANTS, GALION POINTE, INC., GALION POINTE, LLC, JAG HEALTHCARE, DAVID COOLEY, AND JAMES GRIFFITHS, FILED 11/07/2022, IS GRANTED IN PART AND DENIED IN PART. PLAINTIFF SHALL RESPOND TO DEFENDANTS' DISCOVERY REQUESTS WITHIN 30 DAYS OF THIS ORDER. DEFENDANTS' REQUEST FOR AWARD OF REASONABLE EXPENSES UNDER CIV.R. 37(A) IS DENIED. PLAINTIFF'S MOTION FOR EXTENSION OF TIME TO IDENTIFY EXPERTS AND PRODUCE THEIR EXPERT REPORTS UNTIL DECEMBER 27, 2022 AND MOTION TO EXTEND THE DISCOVERY CUT-OFF UNTIL DECEMBER 27, 2022, FILED 11/10/2022, IS GRANTED. THE COURT FINDS THAT PLAINTIFF'S EXPERT REPORTS ARE TIMELY SUBMITTED. MOTION TO DISMISS FOR FAILURE TO COMPLY WITH A COURT ORDER ON BEHALF OF DEFENDANTS, DAVID COOLEY, JAMES GRIFFITHS, JAG HEALTHCARE, AND GALION POINTE, LLC, FILED 01/09/2023, IS DENIED. MOTION TO STRIKE PLAINTIFF'S EXPERT WITNESSES ON BEHALF OF DEFENDANTS, DAVID COOLEY, JAMES GRIFFITHS, JAG HEALTHCARE, AND GALION POINTE, LLC, FILED 01/18/2023, IS DENIED. PLAINTIFF'S MOTION TO COMPEL, FILED 01/19/2023, IS GRANTED AND DENIED IN PART. THE COURT FINDS AS FOLLOWS: 1. GRANTED IN PART. DEFENDANTS SHALL PRODUCE THE DECLARATIONS PAGE(S) TO ALL APPLICABLE INSURANCE POLICIES. 2. DENIED. 3. GRANTED. 4. GRANTED. DEFENDANTS SHALL RESPOND TO PLAINTIFF'S DISCOVERY REQUESTS AS ORDERED ABOVE WITHIN 30 DAYS OF ENTRY OF THIS ORDER. PLAINTIFF'S MOTION TO COMPEL, FILED 03/24/2023, IS GRANTED AND DENIED IN PART. THE COURT FINDS AS FOLLOWS: 1. GRANTED IN PART. DEFENDANTS SHALL PRODUCE AN INDEX OF THE PATIENT CARE POLICIES. PLAINTIFF MAY IDENTIFY THE SPECIFIC POLICIES PLAINTIFF SEEKS TO REVIEW. 2. GRANTED IN PART. DEFENDANTS SHALL PRODUCE REQUESTED GRIEVENCE AND CONCERN FORMS AND MAY REDACT HIPAA-PROTECTED INFORMATION. 3. GRANTED IN PART. DEFENDANTS SHALL PRODUCE INCIDENT REPORTS AND WITNESS STATEMENTS RELATING TO DECEDENT. IF DEFENDANTS WISH WITHOLD A RESPONSIVE DOCUMENTS PURSUANT TO A PRIVILEGE OR WORK PRODUCT DOCTRINE PROTECTION, DEFENDANTS SHALL PRODUCE A LOG WITH SUFFICIENT INFORMATION TO ALLOW PLAINTIFF AND THE COURT TO DETERMINE THE APPLICABILITY OF THE ASSERTED PRIVILEGE OR PROTECTION. 4. DENIED. 5. DENIED. 6. DENIED. 7. GRANTED. DEFENDANTS SHALL PRODUCE THE ABOVE DOCUMENTS OR INFORMATION WITHIN 30 DAYS OF ENTRY OF THIS ORDER. THE PARTIES SHALL TAKE STEPS TO SCHEDULE THE DEPOSITIONS OF THE REQUESTED PERSONS WITHIN FOURTEEN DAYS OF ENTRY OF THIS ORDER AND COMPLETE THE DEPOSITIONS OF SUCH PERSONS WITHIN 45 DAYS OF THIS ORDER. IT IS SO ORDERED. NOTICE ISSUED

MOTION FILED FOR P1 BARBARA A. JACKSON BLAKE A DICKSON 0059329 PLAINTIFF'S MOTION TO SHOW CAUSE 11/02/2023 - MOOT

SUBPOENA SERVICE RETURN FILED CHELSEA LOWE, BLAKE A DICKSON (0059329) PROOF OF SERVICE TRIAL SUBPOENA LOWE

MOTION FILED FOR P1 BARBARA A. JACKSON BLAKE A DICKSON 0059329 PLAINTIFF'S MOTION TO SHOW CAUSE RELATIVE TO OHIOHEALTH MANSFIELD HOSPITAL 11/02/2023 - MOOT

SUBPOENA SERVICE RETURN FILED RICK COCHRAN, BLAKE A DICKSON (0059329) PROOF OF SERVICE OF TRIAL SUBPOENA COCHRAN

MOTION FILED FOR DEFENDANT(S) GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 MOTION TO SHOW CAUSE AND REQUEST FOR HEARING AND SANCTIONS ON BAHALF OF DEFENDANTS, GALION POINTE, LLC, JAG HEALTHCARE, DAVID COOLEY, AND JAMES GRIFFITHS 11/02/2023 - MOOT

MOTION FILED FOR P1 BARBARA A. JACKSON BLAKE A DICKSON 0059329 PLAINTIFF'S MOTION FOR LEAVE TO FILE WITHIN SUR REPLY BRIEF INSTANTER 11/02/2023 - MOOT

SUBPOENA SERVICE RETURN FILED LISA WHITE, BLAKE A DICKSON (0059329) PROOF OF SERVICE OF TRIAL SUBPOENA WHITE

FINAL PRETRIAL HELD ON 09/21/2023. THE PARTIES APPEARED THROUGH COUNSEL OF RECORD. STATUS OF CASE AND PENDING MOTIONS TO SHOW CAUSE DISCUSSED. PLAINTIFF HAS ISSUED SUBPEONAS TO DECEDANT'S MEDICAL PROVIDERS AND WILL TAKE THE NECESSARY STEPS TO ENFORCE THOSE SUBPEONAS. DEFENDANT WILL PRODUCE THE PATIENT CARE POLICIES NOT IN DISPUTE BY OR ON 09/29/2023. THE PARTIES SHALL CONFER RELATING TO THE POLICIES AT ISSUE AND NOTIFY THE COURT'S STAFF ATTORNEY OF THE STATUS OF THOSE DISCUSSIONS BY OR ON 09/29/2023. NOTICE ISSUED

BRIEF IN OPPOSITION FILED BY DEFENDANT(S) GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 BRIEF IN OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL ON BEHALF OF DEFENDANTS, GALION POINTE, LLC, JAG HEALTHCARE, DAVID COOLEY, AND JAMES GRIFFITHS

SETTLEMENT CONFERENCE SET FOR 08/03/2023 AT 01:30 PM. SEVEN DAYS BEFORE THE SETTLEMENT CONFERENCE, EACH PARTY SHALL PROVIDE THE COURT WITH A BRIEF STATEMENT, NO LONGER THAN TWO PAGES, OUTLINING THE CLAIMS TO BE DISCUSSED, THE FACTUAL SUPPORT OF ANY DISPUTES, AND ANY OFFERS OR SETTLEMENT DISCUSSION HAD TO DATE. THE SETTLEMENT CONFERENCE STATEMENTS NEED NOT BE FILED, BUT INSTEAD SENT TO THE STAFF ATTORNEY. NOTICE ISSUED

REPLY BRIEF FILED BY P1 BARBARA A. JACKSON BLAKE A DICKSON 0059329 PLAINTIFF'S REPLY BRIEF IN SUPPORT OF PLAINTIFF'S MOTION TO COMPEL.

PLAINTIFF'S MOTION FOR LEAVE TO FILE THE WITHIN SUR REPLY BRIEF INSTANTER, FILED 07/22/2022, IS GRANTED. MOTION TO DISMISS ON BEHALF OF DEFENDANTS, GALION POINTE LLC, JAG HEALTHCARE, DAVID COOLEY, AND JONES GRIFFITHS, FILED 06/20/2022, IS DENIED. NOTICE ISSUED

BRIEF IN OPPOSITION FILED BY DEFENDANT(S) GALION POINTE, INC.(D1), GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 BRIEF IN OPPOSITION TO PLAINTIFF'S MOTION TO SHOW CAUSE ON BEHALF OF DEFENDANTS, GALION POINTE, LLC, JAG HEALTHCARE, DAVID COOLEY, AND JAMES GRIFFITHS

NOTICE OF DEPOSITION OF DEFENDANT(S) GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) FILED NOTICE OF ZOOM DISCOVERY DEPOSITION OF PLAINTIFF'S EXPERT MATTHEW E LEVY MD WITH DUCES TECUM

MOTION FILED FOR P1 BARBARA A. JACKSON BLAKE A DICKSON 0059329 PLAINTIFF'S MOTION TO SHOW CAUSE RELATIVE TO LOUIS STOKES VA MEDICAL CENTER 11/02/2023 - MOOT

NOTICE FILED BY P1 BARBARA A. JACKSON ATTORNEY BLAKE A DICKSON 0059329 PLAINTIFF'S NOTICE OF VOLUNTARY DISMISSAL WITHOUT PREJUDICE OF DEFENDANT GALION POINTE, INC. ONLY.

NOTICE OF TRANSCRIPT FILED DEFENDANT(S) GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5), CHRISTOPHER F MARS 0091604 NOTICE OF FILING DEPOSITION TRANSCRIPT OF CRAIG JACKSON

NOTICE OF TRANSCRIPT FILED DEFENDANT(S) JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5), BRET C PERRY 0073488 NOTICE OF FILOING DEPOSITION TRANSCRIPT OF PLAINTIFF'S EXPERT, MATTHEW E. LEVY, M.D., ON BEHALF OF DEFENDANTS, DAVID COOLEY, JAMES GRIFFITHS, AND JAG HEALTHCARE

BRIEF FILED BY P1 BARBARA A. JACKSON BLAKE A DICKSON 0059329 PLAINTIFF'S TRIAL BRIEF

MOTION FILED FOR P1 BARBARA A. JACKSON BLAKE A DICKSON 0059329 PLAINTIFF'S MOTION TO SHOW CAUSE RELATIVE TO AVITA HEALTH SYSTEM 11/02/2023 - MOOT

BRIEF IN OPPOSITION FILED BY P1 BARBARA A. JACKSON BLAKE A DICKSON 0059329 PLAINTIFF'S BRIEF IN OPPOSITION TO DEFENDANTS' MOTION ASKING THE COURT TO EXCLUDE CRITICISIMS OF PLAINTIFF'S EXPERT CHARLOTTE SHEPPARD, RN

NOTICE OF TRANSCRIPT FILED DEFENDANT(S) GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5), CHRISTOPHER F MARS 0091604 NOTICE OF FILING DEPOSITION TRANSCRIPT OF BARBARA AND CRAIG JACKSON

BRIEF IN OPPOSITION FILED BY P1 BARBARA A. JACKSON BLAKE A DICKSON 0059329 PLAINTIFF'S BRIEF IN OPPOSITION TO DEFENDANTS' MOTION IN LIMINE ASKING THIS COURT TO PRECLUDE ANY DISCUSSION OF ANY FEDERAL OR STATE REGULATIONS THAT APPLY TO THE CARE OF A NURSING HOME RESIDENT IN A NURSING HOME.

NOTICE OF TRANSCRIPT FILED DEFENDANT(S) JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5), BRET C PERRY 0073488 NOTICE OF FILING DEPOSITION TRANSCRIPT OF PLAINTIFF'S EXPERT CHARLOTTE SHEPPARD DNP RN-BC LHRM WCC ON BEHALF OF DEFENDANTS, DAVID COOLEY, JAMES GRIFFITHS, AND JAG HEALTHCARE

MOTION FILED FOR P1 BARBARA A. JACKSON BLAKE A DICKSON 0059329 PLAINTIFF'S MOTION TO COMPEL PERSONNEL FILES 11/02/2023 - MOOT

REPLY BRIEF FILED BY P1 BARBARA A. JACKSON BLAKE A DICKSON 0059329 PLAINTIFF'S REPLY BRIEF IN SUPPORT OF PLAINTIFF'S MOTION TO COMPEL PERSONNEL FILES

NOTICE OF TRANSCRIPT FILED P1 BARBARA A. JACKSON, BLAKE A DICKSON 0059329 NOTICE OF FILING DEPOSITION TRANSCRIPT OF NATALIE BERGER-

MOTION IN LIMINE PLAINTIFF'S MOTION IN LIMINE ASKING THE COURT TO ALLOW PLAINTIFF TO PUT ON HER CASE IN CHIEF BEFORE THE DEFENDANTS ARE PERMITTED TO PUT ON THEIR CASE IN CHIEF. 11/02/2023 - MOOT

MOTION IN LIMINE MOTION IN LIMINE TO PRECLUDE ANY EVIDENCE OF STAFFING ON BEHALF OF DEFENDANTS, GALION POINTE, LLC, JAG HEALTHCARE, DAVID COOLEY, AND JAMES GRIFFITHS 11/02/2023 - MOOT

MOTION IN LIMINE PLAINTIFF'S MOTION IN LIMINE REGARDING SPECULATION. 11/02/2023 - MOOT

MOTION IN LIMINE PLAINTIFF'S MOTION IN LIMINE RELATIVE TO CLYDE JACKSON'S MEDICAL RECORDS AND BILLS. 11/02/2023 - MOOT

SUBPOENA SERVICE RETURN FILED RUDY MIES, BLAKE A DICKSON (0059329) PROOF OF SERVICE OF TRIAL SUBPOENA MIES

MOTION IN LIMINE MOTION IN LIMINE TO PRECLUDE PLAINTIFF FROM INTRODUCING PERSONNEL FILES ON BEHALF OF DEFENDANTS, GALION POINTE, LLC, JAG HEALTHCARE, DAVID COOLEY, AND JAMES GRIFFITHS 11/02/2023 - MOOT

MOTION IN LIMINE MOTION IN LIMINE TO PRECLUDE INADMISSIBLE EXPERT TESTIMONY ON BEHALF OF DEFENDANTS, GALION POINTE, LLC, JAG HEALTHCARE, DAVID COOLEY, AND JAMES GRIFFITHS 11/02/2023 - MOOT

BRIEF IN OPPOSITION FILED BY P1 BARBARA A. JACKSON BLAKE A DICKSON 0059329 PLAINTIFF'S BRIEF IN OPPOSITION TO DEFENDANTS' MOTION IN LIMINE ASKING THIS COURT TO PRECLUDE THE TESTIMONY OF PLAINITFF'S STANDARD OF CARE EXPERT WITNESS REGARDING THE CONDUCT OF THE DEFENDANTS AND THEIR STAFF.

MOTION IN LIMINE MOTION IN LIMINE TO PRECLUDE INTRODUCTION OR DISCUSSION OF FEDERAL OR STATE REGULATIONS ON BEHALF OF DEFENDANTS, GALION POINTE, LLC, JAG HEALTHCARE, DAVID COOLEY, AND JAMES GRIFFITHS 11/02/2023 - MOOT

SUBPOENA SERVICE RETURN FILED TODD T. HORN, BLAKE A DICKSON (0059329) PROOF OF SERVICE OF TRIAL SUBPOENA

BRIEF IN OPPOSITION FILED BY P1 BARBARA A. JACKSON BLAKE A DICKSON 0059329 PLAINTIFF'S BRIEF IN OPPOSITION TO DEFENDANTS' MOTION IN LIMINE ASKING THE COURT TO PRECLUDE PLAINTIFF FROM INTRODUCING PERSONNEL FILES INTO EVIDENCE AT TRIAL.

BRIEF IN OPPOSITION FILED BY DEFENDANT(S) GALION POINTE, LLC(D2), JAG HEALTHCARE, INC.(D3), DAVID COOLEY(D4) and JAMES GRIFFITHS(D5) CHRISTOPHER F MARS 0091604 BRIEF IN OPPOSITION TO PLAINTIFF'S MOTION TO COMPEL ON BEHALF OF DEFENDANTS

BRIEF IN OPPOSITION FILED BY P1 BARBARA A. JACKSON BLAKE A DICKSON 0059329 PLAINTIFF'S BRIEF IN OPPOSITION TO DEFENDANTS' MOTION IN LIMINE TO PRECLUDE THE INTRODUCTION OR DISCUSSION OF PATIENT CARE POLICIES.

SUBPOENA SERVICE RETURN FILED ERIK SHULL, BLAKE A DICKSON (0059329) PROOF OF SERVICE OF TRIAL SUBPOENA SHULL