Sherry Ray Alexander, Etc. Vs. University Hospitals Health System, Et Al.

NOTICE OF DEPOSITION OF P1 SHERRY RAY ALEXANDER FILED NOTICE OF VIDEO DEPOSITION OF TODD ZETS, CRNA

MOTION FILED FOR P1 SHERRY RAY ALEXANDER PAMELA E PANTAGES 0046840 PLAINTIFF'S THIRD MOTION TO COMPEL DISCOVERY AND FOR A TELEPHONE STATUS CONFERENCE TO SET A DISCOVERY RESPONSE DEADLINE

NOTICE OF DEPOSITION OF P1 SHERRY RAY ALEXANDER FILED NOTICE OF VIDEO DEPOSITION OF AMELIA OAKS, R.N.

RECENT EVENT CANCELLATIONS APPEARING ON THE DOCKET WERE ENTERED FOR CALENDAR MAINTENANCE ONLY. THE FINAL PRETRIAL REMAINS SCHEDULED FOR 04/18/2024, AND THE TRIAL OF THESE CONSOLIDATED ACTIONS REMAINS SET FOR 05/13/2024. NOTICE ISSUED

MOTION TO CONSOLIDATE FILED DEFENDANTS SAFE ANESTHESIA GENEVA, LLC AND TODD ZETS, CRNA'S MOTION TO CONSOLIDATE 04/16/2023 - UNOPPOSED AND GRANTED

NOTICE OF DEPOSITION OF P1 SHERRY RAY ALEXANDER FILED NOTICE OF VIDEO DEPOSITION OF MADISON MONROE, R.N.

NOTICE OF DEPOSITION OF P1 SHERRY RAY ALEXANDER FILED NOTICE OF VIDEO DEPOSITION OF ROBERT HUDSON, M.D.

NOTICE OF DEPOSITION OF P1 SHERRY RAY ALEXANDER FILED PLAINTIFF'S NOTICE OF VIDEOTAPED DEPOSITIONS PURSUANT TO CIV. R. 30(B)(5)

PLAINTIFF'S RENEWED MOTION TO COMPEL DISCOVERY AND FOR A TELEPHONE STATUS CONFERENCE TO SET A DISCOVERY RESPONSE DEADLINE, FILED 10/20/2023, IS DENIED AS MOOT. NOTICE ISSUED

NOTICE OF APPEARANCE, FILED P1 SHERRY RAY ALEXANDER WILLIAM S JACOBSON 0006013. NOTICE OF APPEARANCE

NOTICE OF APPEARANCE, FILED D3 SAFE ANESTHESIA GENEVA, LLC EMILY DAVIS 0100237. NOTICE OF APPEARANCE

THE CAPTIONED CASE IS HEREBY TRANSFERRED TO THE DOCKET OF JUDGE DEENA R CALABRESE(357) FOR CONSOLIDATION WITH CASE NO. CV-22-967204. NOTICE ISSUED

SUMS COMPLAINT(50078611) SENT BY CERTIFIED MAIL. TO: TRAVIS M. LANDIS 877 QUEENS GATE WAY WADSWORTH, OH 44281

SUMS COMPLAINT(50078606) SENT BY CERTIFIED MAIL. TO: KYRA MARIE SOURS 6158 HOOVER STREET RAVENNA, OH 44266

NOTICE OF APPEARANCE, FILED D3 SAFE ANESTHESIA GENEVA, LLC RYAN K. RUBIN 0077367. NOTICE OF APPEARANCE

ANSWER FILED BY D3 SAFE ANESTHESIA GENEVA, LLC ATTORNEY RYAN K. RUBIN 0077367 ANSWER OF DEFENDANT, SAFE ANESTHESIA GENEVA, LLC TO PLAINTIFF'S 2023 COMPLAINT

THE PRETRIAL CONFERENCE SCHEDULED FOR 06/09/2023 IS CANCELED DUE TO A COURT CONFLICT. THE PRETRIAL WILL BE RESCHEDULED VIA SEPARATE ENTRY. NOTICE ISSUED

PRETRIAL HELD ON 07/07/2023. COUNSEL FOR ALL PARTIES WHO HAVE APPEARED IN THESE CONSOLIDATED CASES PARTICIPATED BY VIDEO CONFERENCE. THE COURT NOTES THAT ACCORDING TO THE DOCKET, NO APPEARANCES HAVE BEEN MADE BY OR ON BEHALF OF DEFENDANTS ERIC L. BRYAN, ADAM N. WORKMAN, OR AMELIA A. OAKS, AND THAT SAID DEFENDANTS APPEAR TO BE IN DEFAULT. PLAINTIFF IS TO DISMISS CLAIMS AGAINST SAID DEFENDANTS OR FILE MOTIONS FOR DEFAULT JUDGMENT WITHIN 45 DAYS OF THIS ENTRY. FOLLOWING ANY ENTRY OF DEFAULT JUDGMENT, THE COURT WILL DEFER ANY DAMAGES HEARING UNTIL THE CONCLUSION OF THE CASE. DUE TO CONSOLIDATION OF CASES AND FOR GOOD CAUSE SHOWN, THE LITIGATION TIMELINE WILL BE AS FOLLOWS: ALL FACT DISCOVERY, INCLUDING FACT WITNESS DEPOSITIONS, SHALL BE COMPLETED BY 10/20/2023. PLAINTIFF'S EXPERT REPORT(S) DUE 11/01/2023. DEFENDANTS' EXPERT REPORT(S) DUE 01/12/2024. EXPERT DISCOVERY CUTOFF IS 04/26/2024. DISPOSITIVE MOTION TO BE FILED BY 01/16/2024. RESPONSE/REPLY DUE PER OHIO R. CIV. P. 6(C). THE COURT WILL RULE ON ANY PENDING DISPOSITIVE MOTIONS NO LESS THAN THIRTY (30) DAYS PRIOR TO THE SCHEDULED TRIAL DATE. AT THE REQUEST OF ANY PARTY, THE COURT WILL SCHEDULE AND CONDUCT ORAL ARGUMENT ON PENDING MOTIONS FOR SUMMARY JUDGMENT. ANY SUCH REQUEST MUST BE MADE BY SEPARATE MOTION AND NOT, E.G., BY ROTE ADDITION TO A PLEADING CAPTION. CLIENTS MUST BE PRESENT AT ORAL ARGUMENT, WHICH SHALL TAKE PLACE ON THE RECORD IN OPEN COURT. IN THE EVENT THAT PERSONAL ATTENDANCE AT ORAL ARGUMENT WILL CREATE AN UNDUE HARDSHIP OR EXPENSE TO THE CLIENT, THE ATTORNEY REPRESENTING THE CLIENT MAY MOVE THE COURT TO ALLOW THE CLIENT TO APPEAR LIVE VIA VIDEO CONFERENCE. CLIENTS WILL NOT BE PERMITTED TO ATTEND BY TELEPHONE. FINAL PRETRIAL SET FOR 04/18/2024 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; (8) PRETRIAL MOTIONS CONTEMPLATED; (9) LATEST DEMAND/OFFER. 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 05/13/2024 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

ANSWER FILED BY DEFENDANT(S) UNIVERSITY HOSPITALS HEALTH SYSTEM, INC.(D1), UNIVERSITY HOSPITALS MEDICAL GROUP, INC.(D2), KAYLEE ELISE MAREZ(D4), JULIE ANN MILLHOFF(D5), SUZI P. NESTICH(D7), JULIE ANN WELLS(D8), TAMMY L. KEMBLE(D9), SHANI DAWN KISSELL(D10), MATTHEW ALLEN BUSEK(D11), JOANNE BEERS(D14), KYRA MARIE SOURS(D15), JENNIE C. CHAMPNEY(D16), KELSEY IRENE STEEN(D17), MADISON LYN MONROE(D18), ZACHARY R. FRAILEY(D19), TRAVIS M. LANDIS(D20), EMILY JOANN ARUS(D21), REDDY SREENIVAS SINGASHANI(D22), SHARAD PRABHAKANTMANI(D23) and ROBERT D. HUDSON(D24) ATTORNEY MATTHEW TURKALJ 0097974 DEFENDANTS UHHS, UH PORTAGE MED CTR, UHMG, KAYLEE MAREZ, RN, JULIE MILLHOFF, RN, SUZI NESTICH, RN, JULIE WELLS, RT, TAMMY KEMBLE, RCA, SHANI KISSELL, RN, MATTHEW BUSEK, RT, AMELIA OAKS, RN, JOANN BEERS, PCA, KYRA SOURS, RN, JENNIE CHAMPNEY, CN, KELSEY STEEN, RT, MADISON MONROE, RN, ZACHARY FRAILEY, PCNA, TRAVIS LANDIS, PAC, EMILY ARUS, REEDY SINGASHANI, MD, SHARAD MANI, DO, AND ROBERT HUDSON, MD'S ANSWER TO PLAINTIFF'S COMPLAINT

PRETRIAL SET FOR 06/09/2023 AT 11:00 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: 824 9648 0502 PASSCODE: 069994 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/82496480502?PWD=YKZJR2HZOUFVEFHXOFK4UK9UATNUUT09 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. NOTICE ISSUED

NOTICE OF DEPOSITION OF P1 SHERRY RAY ALEXANDER FILED NOTICE OF VIDEO DEPOSITION OF ROBERT HUDSON, M.D.

PLAINTIFF HAVING NOT COMPLIED WITH THE COURT'S 07/10/2023 DIRECTIVE, PLAINTIFF IS TO SHOW CAUSE, IN WRITING, WHY HER CLAIMS AGAINST DEFENDANTS ERIC L. BRYAN, ADAM N. WORKMAN, AND AMELIA A. OAKS SHOULD NOT BE DISMISSED WITHOUT PREJUDICE FOR FAILURE TO PROSECUTE. PLAINTIFF IS TO RESPOND TO THIS SHOW CAUSE ORDER BY THE CLOSE OF BUSINESS FRIDAY, 09/08/2023. FAILURE TO RESPOND WILL RESULT IN THE DISMISSAL OF ALL CLAIMS AGAINST SAID DEFENDANTS WITHOUT FURTHER NOTICE. NOTICE ISSUED

SUMS COMPLAINT(50078605) SENT BY CERTIFIED MAIL. TO: JOANNE BEERS 4091 TAPPER ROAD BARBERTON, OH 44203

SUMS COMPLAINT(50644812) SENT BY CERTIFIED MAIL. TO: EMILY JOANN ARUS 4814 SMITH ROAD RAVENNA, OH 44266

SUMS COMPLAINT(50354196) SENT BY REGULAR MAIL SERVICE. TO: ERIC L. BRYAN 97 MAYFIELD AVENUE AKRON, OH 44313 ANSWER DATE: 05/10/2023

CASE FILED: COMPLAINT

SUMS COMPLAINT(50078612) SENT BY CERTIFIED MAIL. TO: EMILY JOANN ARUS 4814 SMITH ROAD RAVENNA, OH 44266

SUMS COMPLAINT(50718837) SENT BY REGULAR MAIL SERVICE. TO: ADAM N. WORKMAN 120 STOVER COURT WADSWORTH, OH 44281 ANSWER DATE: 06/22/2023

SUMS COMPLAINT(50078614) SENT BY CERTIFIED MAIL. TO: SHARAD PRABHAKANTMANI 9001 PORTAGE POINT DRIVE APT. P107 STREETSBORO, OH 44241

SUMS COMPLAINT(50078596) SENT BY CERTIFIED MAIL. TO: JULIE ANN MILLHOFF 1375 HARTVILLE ROAD ATWATER, OH 44201

SUMS COMPLAINT(50078609) SENT BY CERTIFIED MAIL. TO: MADISON LYN MONROE 780 EAST MAIN STREET RAVENNA, OH 44266

SUMS COMPLAINT(50078603) SENT BY CERTIFIED MAIL. TO: ADAM N. WORKMAN 120 STOVER COURT WADSWORTH, OH 44281

SUMS COMPLAINT(50078597) SENT BY CERTIFIED MAIL. TO: ERIC L. BRYAN 97 MAYFIELD AVENUE AKRON, OH 44313

NOTICE OF DEPOSITION OF P1 SHERRY RAY ALEXANDER FILED NOTICE OF VIDEO DEPOSITION OF AMELIA OAKS, R.N.

SUMS COMPLAINT(50078598) SENT BY CERTIFIED MAIL. TO: SUZI P. NESTICH 6126 RIVERBROOKE DRIVE PANAMA CITY, FL 32404

SUMS COMPLAINT(50078601) SENT BY CERTIFIED MAIL. TO: SHANI DAWN KISSELL 4195 PIONEER TRAIL MANTUA, OH 44255

NOTICE OF SUBSTITUTION OF COUNSEL FILED NOTICE OF SUBSTITUTION AND WITHDRAWAL OF COUNSEL

PURSUANT TO CIV. R. 41(A) PLAINTIFF SHERRY RAY ALEXANDER ADMINISTRATOR OF THE ESTATE OF STEPHANIE ALEXANDER, DECEASED HEREBY VOLUNTARILY DISMISSES ALL CLAIMS AGAINST DEFENDANT KAYLEE ELISE MAREZ RN, JULIE ANN MILLHOFF RN, ERIC L. BRYAN RN, SUZI P. NESTICH RN, JULIE ANN WELLS RT, TAMMY L. KEMBLE RCA, SHANI DAWN KISSELL RN, MATTHEW ALLEN BUSEK RT, ADAM N. WORKMAN RN, AMELIA A. OAKS RN, JOANNE BEERS PCA, KYRA MARIE SOURS RN, JENNIE C. CHAMPNEY CN, KELSEY IRENE STEEN RT, MADISON LYN MONROE RN, ZACHARY R. FRAILEY PCNA, TRAVIS M. LANDIS PAC, EMILY JOANN ARUS ONLY, WITHOUT PREJUDICE. THIS CASE REMAINS PENDING AGAINST ALL OTHER DEFENDANTS. PURSUANT TO CIV.R. 58(B), THE CLERK OF COURTS IS DIRECTED TO SERVE THIS JUDGMENT IN A MANNER PRESCRIBED BY CIV.R. 5(B). THE CLERK MUST INDICATE ON THE DOCKET THE NAMES AND ADDRESSES OF ALL PARTIES, THE METHOD OF SERVICE, AND THE COSTS ASSOCIATED WITH THIS SERVICE. NOTICE ISSUED

NOTICE OF DEPOSITION OF P1 SHERRY RAY ALEXANDER FILED NOTICE OF VIDEO DEPOSITIONS OF TANYA BANERJEE, MD AND BRYAN PACE, DO

NOTICE OF DEPOSITION OF P1 SHERRY RAY ALEXANDER FILED NOTICE OF VIDEOTAPED DEPOSITION OF SHARAD PRABHAKANTMANI, M.D.

NOTICE FILED BY P1 SHERRY RAY ALEXANDER ATTORNEY PAMELA E PANTAGES 0046840 PARTIAL VOLUNTARY DISMISSAL WITHOUT PREJUDICE

PRETRIAL SET FOR 07/07/2023 AT 08:00 AM. THE PRETRIAL CONFERENCE ORIGINALLY SCHEDULED FOR 06/09/2023 IS RESCHEDULED TO THE DATE AND TIME REFERENCED ABOVE. LOGIN CREDENTIALS REMAIN THE SAME AS REFLECTED IN THE COURT'S 05/18/2023 JOURNAL ENTRY, BUT ARE REPEATED BELOW FOR THE CONVENIENCE OF COUNSEL: HTTPS://US02WEB.ZOOM.US/J/82496480502?PWD=YKZJR2HZOUFVEFHXOFK4UK9UATNUUT09 MEETING ID: 824 9648 0502 PASSCODE: 069994 NOTICE ISSUED

MOTION TO CONSOLIDATE FILED DEFENDANTS SAFE ANESTHESIA GENEVA, LLC AND TODD ZETS, CRNA'S MOTION TO CONSOLIDATE