Elizabeth Irwin Vs. Regae Elliemae Dormendo, Et Al.

NOTICE OF SUBSTITUTION OF COUNSEL FILED NOTICE OF SUBSTITUTION OF COUNSEL OF PROGRESSIVE DIRECT INSURANCE COMPANY

DEFENDANT REGAE E. DORMENDO'S MOTION TO CONSOLIDATE, FILED 09/14/2023, IS UNOPPOSED, IS WELL TAKEN, AND IS HEREBY GRANTED. NOTICE ISSUED

THE PARTIES' JOINT MOTION TO CONTINUE SCHEDULING ORDER, FILED 11/06/2023, IS GRANTED TO THE EXTENT SPECIFIED IN THIS ORDER. THE COURT IS AMENABLE TO ADJUSTING THE LITIGATION SCHEDULE. THE NEW SCHEDULE FOR DISCOVERY AND MEDIATION WILL BE AS FOLLOWS: FACT DISCOVERY TO BE COMPLETED BY 12/29/2023. PLAINTIFF'S EXPERT REPORT DUE 01/31/2024. DEFENDANTS' EXPERT REPORTS DUE 03/13/2024. THE PREVIOUS MEDIATION REFERRAL IS VACATED AND REPLACED BY THE WITHIN REFERRAL: THIS CASE IS TO BE MEDIATED IN JANUARY OR FEBRUARY, 2024. A PRETRIAL CONFERENCE TO ESTABLISH NEW FINAL PRETRIAL AND TRIAL DATES IS SCHEDULED AS FOLLOWS: PRETRIAL SET FOR 01/05/2024 AT 09:00 AM. THE PRETRIAL CONFERENCE WILL BE CONDUCTED BY VIDEO. PLEASE LOG IN TO THE CONFERENCE AT THE SPECIFIED TIME BY VISITING HTTPS://ZOOM.US/JOIN AND ENTERING THE FOLLOWING MEETING CREDENTIALS: MEETING ID: 880 4763 5108 PASSCODE: 832313 THE URL BELOW SHOULD PROVIDE ONE-CLICK ACCESS TO THE CONFERENCE, BUT PLEASE RELY ON THE MEETING ID AND PASSCODE ABOVE IF THE URL PROMPTS YOU FOR AN ID OR PASSCODE, OR RETURNS AN ERROR: HTTPS://US02WEB.ZOOM.US/J/88047635108?PWD=MHRXQ3BBMU9MBK9LUTJODXFRWUZCUT09 TO DISCOURAGE ABUSE, ALL COUNSEL AND OTHER INDIVIDUALS PARTICIPATING MUST HAVE AN ACCOUNT WITH THE ZOOM VIDEO CONFERENCING SERVICE (HTTPS://ZOOM.US/). A PAID ZOOM ACCOUNT IS NOT REQUIRED; THE FREE TIER IS SUFFICIENT. PRIOR TO THE EVENT, PLEASE DOWNLOAD ZOOM TO A COMPUTER OR MOBILE DEVICE WITH A CAMERA, MICROPHONE, AND SPEAKERS. NEXT, ENSURE INTERNET BROWSER POP-UP BLOCKERS ARE DISABLED FOR ZOOM. FINALLY, CHECK THE CAMERA, MICROPHONE, AND SPEAKERS ON YOUR DEVICE TO MAKE SURE THEY ARE WORKING. ANY PARTY WHO FAILS TO PARTICIPATE IN THE PRETRIAL CONFERENCE WILL BE DEEMED TO HAVE ACCEPTED ANY SCHEDULING ORDER ESTABLISHED BY THE COURT. NOTICE ISSUED

CASE NO. CV-23-974350 AND CASE NO. CV-23-974402 WERE CONSOLIDATED BY ENTRY DATED 10/03/2023. ABSENT FURTHER ENTRY BY THE COURT, THE LITIGATION SCHEDULE MEMORIALIZED 03/31/2023 IN CASE NO. CV-23-974350 WILL GOVERN ALL PROCEEDINGS IN THESE CONSOLIDATED CASES. NOTICE ISSUED

MOTION TO CONSOLIDATE FILED MOTION TO CONSOLIDATE 10/03/2023 - UNOPPOSED AND GRANTED

D4 REGAE ELLIEMAE DORMENDO'S MOTION FOR CONTINUANCE SARAH L. BUNCE 0080816. ^F^ JOINT MOTION TO CONTINUE SCHEDULING ORDER 11/08/2023 - GRANTED IN PART

MOTION FILED FOR D4 REGAE ELLIEMAE DORMENDO SARAH L. BUNCE 0080816 DEFENDANT REGAE DORMENDO'S MOTION TO COMPEL DISCOVERY RESPONSES

SUMS CROSS-COMPLNT(51470739) SENT BY CERTIFIED MAIL. TO: SULEIKA COLON 1369 BEACH PARKWAY APT 4 LAKEWOOD, OH 44107-0000

CASE FILED: COMPLAINT

SUMS COMPLAINT(49660842) SENT BY CERTIFIED MAIL. TO: REGAE ELLIEMAE DORMENDO 1904 WEST 71ST ST. CLEVELAND, OH 44102

SUMS COMPLAINT(49660840) SENT BY CERTIFIED MAIL. TO: PROGRESSIVE DIRECT INSURANCE COMPANY 603 ALPHA DR., BOX ON11 HIGHLAND HEIGHTS, OH 44143

SUMS COMPLAINT(49660841) SENT BY CERTIFIED MAIL. TO: SULEIKA COLON 8107 GOODMAN AVE. CLEVELAND, OH 44105

NOTICE FILED BY P1 ELIZABETH IRWIN ATTORNEY WILLIAM JACK MEOLA 0022122 NOTICE OF SERVICE OF PLAINTIFF'S INITIAL DISCLOSURES

ANSWER FILED BY D1 PROGRESSIVE DIRECT INSURANCE COMPANY ATTORNEY JOEL S. MCPHERSON 0061978 ANSWER OF PROGRESSIVE DIRECT INSURANCE COMPANY- TO PLAINTIFF'S COMPLAINT

CASE MGMNT CONFERENCE HELD ON 03/31/2023. COUNSEL FOR PLAINTIFF AND COUNSEL FOR DEFENDANT PROGRESSIVE PARTICIPATED BY VIDEO CONFERENCE. ALL DISCOVERY TO BE COMPLETED BY 09/30/2023. PLAINTIFF'S EXPERT REPORT DUE 10/31/2023. DEFENDANT'S EXPERT REPORT DUE 12/15/2023. CASE REFERRED TO COURT MEDIATION ON 03/31/2023. MEDIATION TO BE CONDUCTED IN OCTOBER OR NOVEMBER, 2023. COUNSEL ARE TO PROMPTLY CONTACT THE MEDIATION DEPARTMENT TO SECURE A FIRM DATE FOR MEDIATION. FINAL PRETRIAL SET FOR 01/18/2024 AT 11:00 AM. ALL PARTIES AND CHOSEN REPRESENTATIVES MUST BE PRESENT WITH FULL, FINAL, AND IMMEDIATE SETTLEMENT AUTHORITY. IF THE REAL PARTY IN INTEREST IS AN INSURANCE COMPANY, CORPORATION, COMMON CARRIER, OR OTHER ENTITY, THEN THE CHOSEN REPRESENTATIVE MUST BE THE PERSON WITH FULL, FINAL, AND IMMEDIATE AUTHORITY TO NEGOTIATE AND ENTER INTO A BINDING SETTLEMENT AGREEMENT AS TO ALL CLAIMS. A GOVERNMENTAL ENTITY SHALL SEND A REPRESENTATIVE AUTHORIZED TO ACT ON ITS BEHALF. PARTIES ARE EXPECTED TO NEGOTIATE IN GOOD FAITH. FAILURE TO DO SO MAY RESULT IN SANCTIONS. THE PARTIES ARE FURTHER DIRECTED TO SUBMIT PRETRIAL STATEMENTS AT LEAST SEVEN (7) DAYS IN ADVANCE OF THE FINAL PRETRIAL. THE PRETRIAL STATEMENTS SHALL SET FORTH THE FOLLOWING: (1) STATEMENT OF FACTS AND LEGAL ISSUES; (2) STATEMENT OF REAL FACTUAL AND LEGAL ISSUES IN DISPUTE; (3) STIPULATIONS; (4) LIST OF NON-EXPERT TRIAL WITNESSES WITH A BRIEF SUMMARY OF EXPECTED TESTIMONY; (5) LIST OF EXPERT TRIAL WITNESSES WITH REPORTS ATTACHED; (6) SPECIAL LEGAL PROBLEMS ANTICIPATED; (7) ESTIMATED LENGTH OF TRIAL; (8) PRETRIAL MOTIONS CONTEMPLATED. ON SOME OCCASIONS THE COURT'S SCHEDULE MAY PREVENT THE JUDGE FROM CONDUCTING THE FINAL PRETRIAL CONFERENCE IN PERSON. IF THE ATTORNEYS BELIEVE IT IS ABSOLUTELY NECESSARY THAT THE JUDGE CONDUCT THE FINAL PRETRIAL IN PERSON, THE PARTIES ARE DIRECTED TO CONTACT THE JUDICIAL STAFF ATTORNEY AT LEAST SEVENTY-TWO (72) HOURS IN ADVANCE TO MAKE SUCH A REQUEST. IN ANY INSTANCE WHERE THE JUDGE HAS A CONFLICT, THE COURT WILL RESET THE FINAL PRETRIAL IN ORDER TO ALLOW THE JUDGE TO PRESIDE IN PERSON. JURY TRIAL SET FOR 02/20/2024 AT 09:30 AM. ANY MOTION TO CONTINUE THE TRIAL DATE SHALL BE MADE IN WRITING AND CAPTIONED "MOTION TO CONTINUE THE TRIAL DATE." IF ALL PARTIES OR CERTAIN PARTIES AGREE TO THE MOTION TO CONTINUE THE TRIAL DATE, SUCH AGREEMENT SHALL BE REFLECTED IN THE CAPTION. THE COURT WILL NOT RULE ON AMBIGUOUSLY TITLED MOTIONS WHICH ARE, IN EFFECT, MOTIONS FOR A CONTINUANCE (E.G., A MOTION TO RESET CASE MANAGEMENT SCHEDULE). ANY MOTION FILED WHICH DOES NOT FULFILL THE CRITERIA ABOVE WILL BE SUMMARILY DENIED OR STRICKEN. THE PARTIES ARE FURTHER DIRECTED TO FAMILIARIZE THEMSELVES WITH THE COURT'S STANDING ORDER ON LITIGATION PREFERENCES, AVAILABLE AS OF THIS WRITING AT HTTPS://CP.CUYAHOGACOUNTY.US/COURT-RESOURCES/JUDGES/JUDGE-DEENA-R-CALABRESE. THE PARTIES ARE EXPECTED TO REVIEW THE STANDING ORDER REGULARLY FOR UPDATES. THE STANDING ORDER APPLIES UNLESS SPECIFICALLY SUPERSEDED BY JOURNAL ENTRY. NOTICE ISSUED

NOTICE FILED BY P1 ELIZABETH IRWIN ATTORNEY WILLIAM JACK MEOLA 0022122 NOTICE OF SERVICE OF PLAINTIFF'S DISCOVERY REQUESTS

ANSWER FILED BY D4 REGAE ELLIEMAE DORMENDO ATTORNEY SARAH L. BUNCE 0080816 DEFENDANT REGAE E. DORMENDO'S ANSWER TO DEFENDANT PROGRESSIVE DIRECT INSURANCE COMPANY'S CROSS-CLAIM

ANSWER FILED BY D4 REGAE ELLIEMAE DORMENDO ATTORNEY SARAH L. BUNCE 0080816 DEFENDANT REGAE E. DORMENDO'S ) ANSWER AND AFFIRMATIVE DEFENSES TO PLAINTIFF'S COMPLAINT

SUMS CROSS-COMPLNT(50589599) SENT BY CERTIFIED MAIL. TO: SULEIKA COLON 8107 GOODMAN AVE. CLEVELAND, OH 44105

SUMS CROSS-COMPLNT(50338886) SENT BY CERTIFIED MAIL. TO: REGAE ELLIEMAE DORMENDO 1904 WEST 71ST ST. CLEVELAND, OH 44102

CASE MGMNT CONFERENCE SET FOR 03/31/2023 AT 09:00 AM. PLEASE NOTE THAT THIS ORDER SPECIFICALLY REFERENCES CIVIL RULE 26 AS AMENDED EFFECTIVE JULY 2020, IN PARTICULAR THE REQUIREMENT THAT THE PARTIES FILE A WRITTEN DISCOVERY PLAN. THE CMC WILL BE CONDUCTED AS A VIDEO CONFERENCE. PLEASE LOG IN TO THE CONFERENCE AT THE SPECIFIED TIME BY VISITING HTTPS://ZOOM.US/JOIN AND ENTERING THE FOLLOWING MEETING CREDENTIALS: MEETING ID: 822 0710 6963 PASSCODE: 371400 THE URL BELOW SHOULD PROVIDE ONE-CLICK ACCESS TO THE CONFERENCE, BUT PLEASE RELY ON THE MEETING ID AND PASSCODE ABOVE IF THE URL PROMPTS YOU FOR AN ID OR PASSCODE, OR RETURNS AN ERROR: HTTPS://US02WEB.ZOOM.US/J/82207106963?PWD=MTK0Q2F0EWPNU2FHT2SXQJDPAJNADZ09 TO DISCOURAGE ABUSE, ALL COUNSEL AND OTHER INDIVIDUALS PARTICIPATING MUST HAVE AN ACCOUNT WITH THE ZOOM VIDEO CONFERENCING SERVICE (HTTPS://ZOOM.US/). A PAID ZOOM ACCOUNT IS NOT REQUIRED; THE FREE TIER IS SUFFICIENT. PRIOR TO THE EVENT, PLEASE DOWNLOAD ZOOM TO A COMPUTER OR MOBILE DEVICE WITH A CAMERA, MICROPHONE, AND SPEAKERS. NEXT, ENSURE INTERNET BROWSER POP-UP BLOCKERS ARE DISABLED FOR ZOOM. FINALLY, CHECK THE CAMERA, MICROPHONE, AND SPEAKERS ON YOUR DEVICE TO MAKE SURE THEY ARE WORKING. IN ADVANCE OF THE CONFERENCE, COUNSEL AND UNREPRESENTED PARTIES SHALL CONFER IN ACCORDANCE WITH OHIO R. CIV. P. 26(F)(1)-(2), AND SHALL THEREAFTER FILE A DISCOVERY PLAN IN ACCORDANCE WITH OHIO R. CIV. P. 26(F)(3). THE WRITTEN RULE 26(F) DISCOVERY PLAN SHALL BE FILED NO LATER THAN THREE BUSINESS DAYS PRIOR TO THE CASE MANAGEMENT CONFERENCE. DURING THE CASE MANAGEMENT CONFERENCE, SERVICE ISSUES, DISCOVERY PROGRESS AND SCHEDULE, AMOUNT IN CONTROVERSY, EXCHANGE OF EXPERT REPORTS, DATE FOR FINAL PRETRIAL CONFERENCE, REFERRAL TO ARBITRATION, ETC., SHALL BE RESOLVED AND INCLUDED IN A BINDING DECREE AND ORDER FORMALIZED. ALL COUNSEL PARTICIPATING SHALL HAVE FULL AUTHORITY TO ENTER INTO A BINDING CASE MANAGEMENT ORDER. THE PARTIES SHOULD NOT WAIT FOR THE CMC BEFORE BEGINNING TO CONDUCT DISCOVERY. EXCEPT IN COMPLEX CASES, TRIAL WILL BE SCHEDULED 7 TO 9 MONTHS OUT, WITH FINAL PRETRIALS AND/OR SETTLEMENT CONFERENCES SCHEDULED FROM 2 TO 6 WEEKS PRIOR TO TRIAL. ANY PARTY WHO FAILS TO PARTICIPATE IN THE CMC WILL BE DEEMED TO HAVE ACCEPTED THE SCHEDULING ORDER ESTABLISHED BY THE COURT. NOTICE ISSUED

NOTICE FILED BY P1 ELIZABETH IRWIN ATTORNEY WILLIAM JACK MEOLA 0022122 PARTIES' PROPOSED DISCOVERY PLAN PURSUANT TO CIVIL RULE 26(F)

NOTICE FILED BY P1 ELIZABETH IRWIN ATTORNEY WILLIAM JACK MEOLA 0022122 NOTICE OF SERVICE OF PLAINTIFF'S DISCOVERY REQUESTS TO DEFENDANT, PROGRESSIVE DIRECT INSURANCE COMPANY

SUMS COMPLAINT(50244355) SENT BY CERTIFIED MAIL. TO: SULEIKA COLON 8107 GOODMAN AVE. CLEVELAND, OH 44105

REQUEST FOR SERVICE FILED INSTRUCTIONS FOR SERVICE

MOTION TO CONSOLIDATE FILED MOTION TO CONSOLIDATE