Kohrman Jackson & Krantz P.L.L. Vs. Felicia Carrington

CASE FILED: COMPLAINT

THIS MATTER IS HEREBY REFERRED TO THE MEDIATION DEPARTMENT, WITH MEDIATION TO BE SCHEDULED BETWEEN 10/16/2023 AND 12/15/2023. NOTICE ISSUED

MOTION FILED FOR P1 KOHRMAN JACKSON & KRANTZ P.L.L. AMANDA K. RASBACH YURECHKO 0072458 MOTION TO COMPEL

REQUEST FOR SERVICE FILED REQUEST FOR SERVICE

REQUEST FOR SERVICE FILED REQUEST FOR SERVICE

MOTION FILED FOR P1 KOHRMAN JACKSON & KRANTZ P.L.L. AMANDA K. RASBACH YURECHKO 0072458 PLAINTIFFS MOTION TO CORRECT THE RECORD 02/21/2023 - GRANTED

FOR GOOD CAUSE SHOWN, PLAINTIFFS MOTION TO CORRECT THE RECORD, FILED 02/15/2023, IS GRANTED. THE COURT DIRECTS THE CLERK OF COURT TO CORRECT THE RECORD IN THE WITHIN MATTER TO REFLECT DEFENDANT'S NAME AS FELICIA CARRINGTON AKA FELICIA KELLY. NOTICE ISSUED

CMC BY PHONE SET FOR 02/09/2023 AT 11:30 AM. ALL PARTIES AND/OR COUNSEL SHALL APPEAR. PARTIES SHALL CALL THE CONFERENCE NUMBER (978) 990-5135 AND ENTER ACCESS CODE 4088405# AT THE SCHEDULED TIME. PARTIES SHALL BE PREPARED TO DISCUSS DISCOVERY PROGRESS AND SCHEDULING MATTERS, ETC. PURSUANT TO CIV.R. 4(E), FAILURE TO COMPLETE SERVICE OF THE SUMMONS AND COMPLAINT WITHIN SIX MONTHS AFTER THE FILING OF THE COMPLAINT MAY RESULT IN DISMISSAL WITHOUT PREJUDICE. SERVICE SHALL BE PERFECTED BY 06/13/2023 OR THIS CASE MAY BE DISMISSED FOR FAILURE TO PERFECT SERVICE. NOTICE ISSUED

MOTION FOR DEFAULT JUDGMENT MOTION FOR DEFAULT JUDGMENT

SUMS COMPLAINT(49789604) SENT BY REGULAR MAIL SERVICE. TO: FELICIA CARRINGTON 1282 CLEVELAND HEIGHTS BLVD. CLEVELAND HEIGHTS, OH 44118 ANSWER DATE: 03/14/2023

AFFIDAVIT FILED BY P1 KOHRMAN JACKSON & KRANTZ P.L.L. ATTORNEY AMANDA K. RASBACH YURECHKO 0072458 NON-MILITARY AFFIDAVIT

DEFAULT HEARING SET FOR 04/26/2023 AT 10:00 AM. COUNSEL FOR ALL PARTIES SHALL APPEAR BY PHONE. PARTIES NOT REPRESENTED BY COUNSEL SHALL LIKEWISE APPEAR BY PHONE. ALL PARTICIPANTS SHALL CALL THE CONFERENCE NUMBER (978) 990-5135 AND ENTER ACCESS CODE 4088405# AT THE SCHEDULED TIME. DEFENDANT'S FAILURE TO APPEAR WILL RESULT IN JUDGMENT BEING RENDERED AGAINST DEFENDANT. IN ORDER FOR THE DEFAULT HEARING TO PROCEED, PLAINTIFF MUST PROVIDE TO THE COURT: (1) A PROPOSED JUDGMENT ENTRY; (2) AN AFFIDAVIT SIGNED BY THE PLAINTIFF'S ATTORNEY STATING THAT ACCORDING TO STATUTE AND RULES, SERVICE REQUIREMENTS WERE MET; (3) AN AFFIDAVIT SIGNED BY THE PLAINTIFF'S ATTORNEY STATING THAT A SEARCH HAS BEEN CONDUCTED AND DEFENDANT IS NOT A CURRENT MEMBER OF THE MILITARY; (4) AN AFFIDAVIT SIGNED BY THE PLAINTIFF, OR PLAINTIFF'S REPRESENTATIVE, PROVING DAMAGES; AND (5) PROOF OF ASSIGNMENT OR BILL OF SALE. PLAINTIFF SHALL NOTIFY ALL PARTIES AGAINST WHOM DEFAULT JUDGMENT IS SOUGHT OF THE TIME AND DATE OF THE DEFAULT HEARING BY REGULAR AND CERTIFIED MAIL AT LEAST FOURTEEN (14) DAYS PRIOR TO THE HEARING DATE. PLAINTIFF'S FAILURE TO COMPLY WITH THIS ORDER MAY RESULT IN DISMISSAL OF THE CASE WITHOUT PREJUDICE FOR WANT OF PROSECUTION. NOTICE ISSUED

DEFENDANT FELICIA KELLY IS HEREBY GRANTED LEAVE THROUGH MAY 26, 2023, TO FILE AN ANSWER TO PLAINTIFF'S COMPLAINT. FAILURE TO FILE AN ANSWER MAY RESULT IN DEFAULT JUDGMENT. STATUS CONFERENCE SET FOR 06/07/2023 AT 09:30 AM. COUNSEL FOR ALL PARTIES SHALL APPEAR BY PHONE. PARTIES NOT REPRESENTED BY COUNSEL SHALL LIKEWISE APPEAR BY PHONE. ALL PARTICIPANTS SHALL CALL THE CONFERENCE NUMBER (978) 990-5135 AND ENTER ACCESS CODE 4088405# AT THE SCHEDULED TIME. ALL PARTICIPANTS SHALL BE PREPARED TO DISCUSS THE FACTS OF THE CASE, DISCOVERY PROGRESS, AND SCHEDULING MATTERS. NOTICE ISSUED

CASE MANAGEMENT CONFERENCE (CMC) HELD 02/09/2023 VIA TELEPHONE. PLAINTIFF APPEARED THROUGH COUNSEL. DEFENDANT APPEARED PRO SE. PARTIES DISCUSSED CASE STATUS. BY AGREEMENT OF THE PARTIES, CMC BY PHONE RESET TO 03/20/2023. DEFENDANT IS HEREBY ON NOTICE THAT IN THE ABSENCE OF REPRESENTATION BY COUNSEL, THE COURT WILL ASSUME ANY UNREPRESENTED PARTY WILL BE PROCEEDING TO TRIAL PRO SE. PRO SE LITIGANTS SHALL BE HELD TO THE FOLLOWING STANDARD: "IT IS WELL ESTABLISHED THAT PRO SE LITIGANTS ARE PRESUMED TO HAVE KNOWLEDGE OF THE LAW AND LEGAL PROCEDURES AND THAT THEY ARE HELD TO THE SAME STANDARD AS LITIGANTS WHO ARE REPRESENTED BY COUNSEL." STATE EX REL. FULLER V. MENGEL, 100 OHIO ST.3D 352, 2003-OHIO-6448, ¶ 10 (CITATION OMITTED). IN ADDITION, "PRO SE LITIGANTS ... CANNOT EXPECT NOR DEMAND SPECIAL TREATMENT FROM THE JUDGE WHO IS TO SIT AS IMPARTIAL ARBITER." MALIZIA V. MALIZIA, 9TH DIST. NO. 22565, 2005-OHIO-5186, ¶ 20 (CITATION OMITTED). "[THE] PRO SE LITIGANT IS TO BE TREATED THE SAME AS ONE TRAINED IN THE LAW AS FAR AS THE REQUIREMENT TO FOLLOW PROCEDURAL LAW AND THE ADHERENCE TO COURT RULES." TATE V. OWENS STATE COMMUNITY COLLEGE, 10TH DIST. FRANKLIN NO. 10AP-1201, 2011-OHIO-3452, ¶15 (CITATION OMITTED). CMC BY PHONE SET FOR 03/20/2023 AT 11:30 AM. ALL PARTIES AND/OR COUNSEL SHALL APPEAR. PARTIES SHALL CALL THE CONFERENCE NUMBER (978) 990-5135 AND ENTER ACCESS CODE 4088405# AT THE SCHEDULED TIME. PARTIES SHALL BE PREPARED TO DISCUSS DISCOVERY PROGRESS AND SCHEDULING MATTERS, ETC. NOTICE ISSUED

NOTICE FILED BY P1 KOHRMAN JACKSON & KRANTZ P.L.L. ATTORNEY AMANDA K. RASBACH YURECHKO 0072458 NOTICE OF FILING OF DEFAULT HEARING LETTER

A STATUS CONFERENCE WAS HELD ON 6/7/2023. BY AGREEMENT OF THE PARTIES THE FOLLOWING DATES WERE SET: DISCOVERY CUTOFF: 10/6/2023 PLAINTIFF'S EXPERT DEADLINE: 10/6/2023 DEFENDANT'S EXPERT DEADLINE: 11/10/2023 STATUS CONFERENCE SET FOR 12/12/2023 AT 10:00 AM. COUNSEL FOR ALL PARTIES SHALL APPEAR BY PHONE. PARTIES NOT REPRESENTED BY COUNSEL SHALL LIKEWISE APPEAR BY PHONE. ALL PARTICIPANTS SHALL CALL THE CONFERENCE NUMBER (978) 990-5135 AND ENTER ACCESS CODE 4088405# AT THE SCHEDULED TIME. ALL PARTICIPANTS SHALL BE PREPARED TO DISCUSS THE FACTS OF THE CASE, DISCOVERY PROGRESS, AND SCHEDULING MATTERS. NOTICE ISSUED

ANSWER PRO SE (9999999)

MOTION FOR EXTENSION OF TIME MOTION FOR EXTENSION OF TIME, FILED 09/28/2023, IS GRANTED. PLAINTIFF SHALL HAVE UNTIL 30 DAYS AFTER MEDIATION TO PRODUCE ITS EXPERT REPORT. IT IS SO ORDERED. NOTICE ISSUED

MOTION FOR EXTENSION OF TIME MOTION FOR EXTENSION OF TIME 10/02/2023 - GRANTED

STATUS CONFERENCE SET FOR 11/08/2023 AT 09:30 AM. COUNSEL FOR ALL PARTIES SHALL APPEAR BY PHONE. PARTIES NOT REPRESENTED BY COUNSEL SHALL LIKEWISE APPEAR BY PHONE. ALL PARTICIPANTS SHALL CALL THE CONFERENCE NUMBER (978) 990-5135 AND ENTER ACCESS CODE 4088405# AT THE SCHEDULED TIME. ALL PARTICIPANTS SHALL BE PREPARED TO DISCUSS THE FACTS OF THE CASE, DISCOVERY PROGRESS, AND SCHEDULING MATTERS. NOTICE ISSUED

MOTION FILED FOR P1 KOHRMAN JACKSON & KRANTZ P.L.L. AMANDA K. RASBACH YURECHKO 0072458 AMENDED MOTION TO COMPEL