Ana L. Romero Vs. Emily Oquendo-Maldonado, Et Al

ANSWER, CROSSCLAIM & COUNTERCLAIM $150 DEFENDANT STATE FARM'S AMENDED ANSWER TO THE COMPLAINT, WITH COUNTERCLAIM AND CROSS-CLAIM FOR DECLARATORY JUDGMENT

P1 ANA L. ROMERO'S MOTION FOR CONTINUANCE EARL F GHASTER 0011065. ^F^ MOTION TO CONTINUE MEDIATION HEARING 11/03/2023 - UNKNOWN

DEFENDANT STATE FARM'S MOTION FOR LEAVE TO FILE AMENDED ANSWER, WITH COUNTERCLAIM AND CROSS-CLAIM FOR DECLARATORY JUDGMENT, FILED 09/20/23, IS UNOPPOSED AND GRANTED. AMENDED ANSWER WITH COUNTERCLAIM AND CROSS-CLAIM SHALL BE FILED WITHIN 7 DAYS OF THIS ORDER. RESPONSE(S)/ANSWER(S) DUE BY RULE. IT IS SO ORDERED. NOTICE ISSUED

MOTION FILED FOR D4 STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY PATRICK M ROCHE 0071359 DEFENDANT STATE FARM'S MOTION TO COMPEL CO-DEFENDANT ALBERTO FIGUEROA MALDANADO TO RESPOND TO WRITTEN DISCOVERY 11/29/2023 - UNOPPOSED AND GRANTED

MOTION FILED FOR D4 STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY PATRICK M ROCHE 0071359 STATE FARM'S MOTION FOR LEAVE TO FILE AMENDED ANSWER, WITH COUNTERCLAIM AND CROSS-CLAIM FOR DECLARATORY JUDGMENT 10/05/2023 - UNOPPOSED AND GRANTED

DEFENDANT STATE FARM'S MOTION TO COMPEL DISCOVERY, FILED 11/13/2023, IS UNOPPOSED AND GRANTED. DEFENDANT ALBERTO MALDONADO SHALL RESPOND TO DEFENDANT STATE FARM'S INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANT ALBERTO MALDONADO NO LATER THAN SEVEN (7) DAYS FROM THE DATE OF THIS ORDER. DISCOVERY SHALL BE IN FULL COMPLIANCE WITH CIVIL RULE 26 AND WITHOUT PROMISES TO SUPPLEMENT AND WITHOUT ADVANCING PRIVILEGE OBJECTIONS OTHER THAN WORK PRODUCT, ATTORNEY CLIENT OR PHYSICIAN PATIENT. DEFENDANT IS ON NOTICE THAT FAILURE TO COMPLY WITH THIS ORDER WILL RESULT IN SANCTIONS, INCLUDING BUT NOT LIMITED TO ATTORNEY'S FEES AND/OR ADVERSE JUDGMENT BEING RENDERED AGAINST THE NON-COMPLYING PARTY AND ANY OTHER SANCTIONS AUTHORIZED BY CIV.R. 37. FAILURE OF DEFENDANT ALBERTO MALDONADO TO COMPLY WITH THIS ORDER SHALL BE BROUGHT TO THE COURT'S ATTENTION. IT IS SO ORDERED. NOTICE ISSUED

ANSWER FILED BY DEFENDANT(S) EMILY Y OQUENDO-MALDONADO(D1) and ALBERTO FIGUEROA(D3) ATTORNEY JOSEPHINE V PROKOP 0028383 ANSWER OF DEFENDANTS ALBERTO FIGUEROA AND EMILY OQUENDO-MALDONADO TO DEFENDANT STATE FARM'S CROSS-CLAIM

SUMS COMPLAINT(50490797) SENT BY CERTIFIED MAIL. TO: STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY P. O. BOX 106170 ATLANTA, GA 30348

CASE MANAGEMENT CONFERENCE HELD 07/13/23. ALL PARTIES PRESENT THROUGH COUNSEL. THE FOLLOWING DATES ARE TO APPLY TO THIS MATTER. ALL PAPER DISCOVERY TO BE COMPLETED BY 11/10/23. AFFIRMATIVE EXPERT REPORT DUE BY 11/10/23. REBUTTAL EXPERT REPORT DUE BY 12/11/23. DISPOSITIVE MOTIONS DUE BY 12/18/23. RESPONSES AND REPLIES DUE BY RULE. FINAL PRETRIAL SET FOR 02/29/24 AT 10:00AM. FINAL PRETRIAL STATEMENTS DUE 7 DAYS PRIOR. FPT STATEMENTS SHOULD BE E-MAILED TO THE STAFF ATTORNEY AT ILOVING@CUYAHOGACOUNTY.US. ALL PARTIES, INCLUDING PARTIES WITH ULTIMATE SETTLEMENT AUTHORITY, ARE TO BE PRESENT, IN PERSON. TELEPHONE APPEARANCE IS NOT PERMITTED. TRIAL SET FOR 04/01/24 AT 10:00 AM. AN AGREED UPON SET OF JURY INSTRUCTIONS, INTERROGATORIES, VERDICT FORMS, AND STATEMENT OF THE CASE TO BE READ TO PROSPECTIVE JURORS ARE DUE 7 DAYS PRIOR TO TRIAL. ANY INSTRUCTIONS THAT THE PARTIES CANNOT AGREE UPON SHALL BE SUBMITTED SEPARATELY. COPIES SHALL BE SUBMITTED IN MICROSOFT WORD FORMAT BY EMAIL TO THE STAFF ATTORNEY AT ILOVING@CUYAHOGACOUNTY.US. TRIAL BRIEFS, WITNESS LISTS, AND EXHIBIT LISTS ARE DUE 7 DAYS PRIOR TO TRIAL. EXHIBITS SHALL BE LABELED AND MARKED BEFORE TRIAL. COURTESY COPIES OF EXHIBITS TO BE GIVEN TO THE COURT ON THE DAY OF TRIAL. EACH PARTY SHALL INCLUDE AS ONE OF THEIR EXHIBITS THE CURRICULUM VITAE OF ANY EXPERT(S) THAT MAY BE CALLED TO PRESENT EVIDENCE OR TESTIMONY AT TRIAL FOR THE USE OF COURT. ANY PARTY WISHING TO PROFFER DEPOSITION TESTIMONY (VIDEOTAPE AND WRITTEN) AT TRIAL SHALL FILE A LIST OF ALL DEPOSITION TRANSCRIPTS THAT ARE TO BE UTILIZED AT TRIAL AT LEAST FOURTEEN (14) DAYS BEFORE TRIAL. OBJECTIONS TO TESTIMONIAL DEPOSITIONS THAT REQUIRE RULINGS FROM THE COURT SHALL BE SUBMITTED AT LEAST SEVEN (7) DAYS PRIOR TO TRIAL. COUNSEL PROPOSING TO USE SAID DEPOSITION SHALL FILE A RESPONSE TO THE OBJECTIONS OR INDICATE THEIR AGREEMENT TO DELETE THE PORTION OF THE DEPOSITION FOR WHICH THERE IS AN OBJECTION THREE (3) DAYS BEFORE TRIAL. THE COURT MUST BE PROVIDED WITH A COMPLETE WRITTEN TRANSCRIPT OF THE DISPUTED DEPOSITIONS. FAILURE OF ANY PARTY TO SUBMIT OBJECTIONS SHALL RESULT IN WAIVER OF ALL OBJECTIONS. MOTIONS IN LIMINE MUST BE FILED NO LATER THAN 14 DAYS PRIOR TO TRIAL. ANY BRIEFS IN OPPOSITION TO MOTIONS IN LIMINE ARE DUE 7 DAYS PRIOR TO TRIAL. REPLY BRIEFS IN SUPPORT OF MOTIONS IN LIMINE BY LEAVE OF COURT ONLY. UNTIMELY MOTIONS WILL NOT BE CONSIDERED OR ACCEPTED. ALL PARTIES ARE TO NOTE THAT A PERSON WITH ULTIMATE SETTLEMENT AUTHORITY MUST BE PRESENT, IN PERSON, FOR ALL SET DATES. NO EXCEPTIONS AND NO TELEPHONE APPEARANCE PERMITTED FOR ANY REASON. FAILURE TO APPEAR AT ANY SET DATE WILL RESULT IN JUDGMENT BEING RENDERED OR DISMISSAL WITH PREJUDICE PURSUANT TO CIV. R. 41(B) AS WELL AS POSSIBLE SANCTIONS. IT IS SO ORDERED. NOTICE ISSUED

CAPTIONED CASE IS REFERRED TO THE ADR DEPARTMENT FOR MEDIATION WITH THE COURT MEDIATION. MEDIATION TO TAKE PLACE AFTER 11/01/23 AND BEFORE 12/29/23. NOTICE ISSUED. IT IS SO ORDERED. NOTICE ISSUED

SUMS COMPLAINT(50490796) SENT BY CERTIFIED MAIL. TO: EMILY Y OQUENDO-MALDONADO 1380 E. 13TH STREET #1014 CLEVELAND, OH 44114

CASE FILED: COMPLAINT

SUMS COMPLAINT(50691778) SENT BY REGULAR MAIL SERVICE. TO: EMILY Y OQUENDO-MALDONADO 1380 E. 13TH STREET #1014 CLEVELAND, OH 44114 ANSWER DATE: 06/20/2023

ANSWER FILED BY DEFENDANT(S) EMILY Y OQUENDO-MALDONADO(D1) and ALBERTO FIGUEROA(D3) ATTORNEY JOSEPHINE V PROKOP 0028383 ANSWER OF DEFENDANTS ALBERTO FIGUEROA AND EMILY OQUENDO-MALDONADO

REQUEST FOR SERVICE FILED INSTRUCTIONS FOR SERVICE

STIPULATION FOR LEAVE TO PLEAD & JOURNAL ENTRY

ANSWER FILED BY D4 STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY ATTORNEY PATRICK M ROCHE 0071359 DEFENDANT STATE FARM'S ANSWER TO THE COMPLAINT

DATE 06/12/2023 (NUNC PRO TUNC ENTRY AS OF & FOR 06/12/2023) IN LIGHT OF THE PARTIES' STIPULATED LEAVE TO PLEAD, FILED 06/08/23, THE CASE MGMNT CONFERENCE SET FOR 06/28/2023 AT 01:30 PM IS HEREBY CANCELLED AND RESET FOR 07/13/23 AT 9:00AM. CASE MGMNT CONFERENCE WILL BE CONDUCTED BY PHONE. ALL PARTIES ARE TO CALL THE CONFERENCE CALL NUMBER 1-720-708-1090 AND ENTER ACCESS CODE 7235579# AT THE SCHEDULED DATE AND TIME. COUNSEL FOR PLAINTIFF SHALL INFORM ALL PRO SE PARTIES, IN WRITING, OF THIS DATE AND TIME. THE NOTICE SHALL BE SENT BY ORDINARY MAIL AT LEAST 7 DAYS IN ADVANCE OF THE CMC. FAILURE OF PLAINTIFF'S COUNSEL TO SEND NOTICE WILL RESULT IN THE CMC BEING RESET. COUNSEL FOR ALL PARTIES ARE REQUIRED TO BE FAMILIAR WITH THE UNDERLYING FACTS OF THE CASE. PARTIES NOT REPRESENTED BY COUNSEL SHALL LIKEWISE PARTICIPATE BY PHONE AND ARE REQUIRED TO FILE THEIR TELEPHONE NUMBER, ADDRESS AND EMAIL ADDRESS WITH THIS COURT PRIOR TO THE DATE OF THE CMC. FAILURE OF ANY KIND OF THE AFOREMENTIONED PERSONS TO PARTICIPATE IN THIS PROPERLY SCHEDULED CASE MANAGEMENT CONFERENCE MAY RESULT IN SANCTIONS INCLUDING DISMISSAL OF THE CASE AND/OR JUDGMENT BEING RENDERED. DISCOVERY IS TO START IMMEDIATELY. PARTIES TO BE READY WITH DEMAND AND OFFER OF SETTLEMENT. NOTICE ISSUED. NOTICE ISSUED

IN LIGHT OF THE PARTIES' STIPULATED LEAVE TO PLEAD, FILED 06/08/23, THE CASE MGMNT CONFERENCE SET FOR 06/28/2023 AT 01:30 PM IS HEREBY CANCELLED AND RESET FOR 07/12/23 AT 9:00AM. CASE MGMNT CONFERENCE WILL BE CONDUCTED BY PHONE. ALL PARTIES ARE TO CALL THE CONFERENCE CALL NUMBER 1-720-708-1090 AND ENTER ACCESS CODE 7235579# AT THE SCHEDULED DATE AND TIME. COUNSEL FOR PLAINTIFF SHALL INFORM ALL PRO SE PARTIES, IN WRITING, OF THIS DATE AND TIME. THE NOTICE SHALL BE SENT BY ORDINARY MAIL AT LEAST 7 DAYS IN ADVANCE OF THE CMC. FAILURE OF PLAINTIFF'S COUNSEL TO SEND NOTICE WILL RESULT IN THE CMC BEING RESET. COUNSEL FOR ALL PARTIES ARE REQUIRED TO BE FAMILIAR WITH THE UNDERLYING FACTS OF THE CASE. PARTIES NOT REPRESENTED BY COUNSEL SHALL LIKEWISE PARTICIPATE BY PHONE AND ARE REQUIRED TO FILE THEIR TELEPHONE NUMBER, ADDRESS AND EMAIL ADDRESS WITH THIS COURT PRIOR TO THE DATE OF THE CMC. FAILURE OF ANY KIND OF THE AFOREMENTIONED PERSONS TO PARTICIPATE IN THIS PROPERLY SCHEDULED CASE MANAGEMENT CONFERENCE MAY RESULT IN SANCTIONS INCLUDING DISMISSAL OF THE CASE AND/OR JUDGMENT BEING RENDERED. DISCOVERY IS TO START IMMEDIATELY. PARTIES TO BE READY WITH DEMAND AND OFFER OF SETTLEMENT. NOTICE ISSUED. NOTICE ISSUED

NOTICE OF APPEARANCE, FILED DEFENDANT(S) EMILY Y OQUENDO-MALDONADO(D1) and ALBERTO FIGUEROA(D3) JOSEPHINE V PROKOP 0028383. NOTICE OF APPEARANCE OF COUNSEL

CASE MGMNT CONFERENCE SET FOR 06/28/2023 AT 01:30 PM. COUNSEL FOR PLAINTIFF(S) SHALL INFORM ALL OPPOSING COUNSEL AND/OR PRO SE PARTIES, IN WRITING, OF THIS DATE AND TIME. LEAD COUNSEL FOR ALL PARTIES ARE REQUIRED TO BE PRESENT IN PERSON AND TO BE FAMILIAR WITH THE UNDERLYING FACTS OF THE CASE. PARTIES NOT REPRESENTED BY COUNSEL SHALL LIKEWISE BE PRESENT IN PERSON. FAILURE OF ANY KIND OF THE AFOREMENTIONED PERSONS TO APPEAR AT THIS PROPERLY SCHEDULED CASE MANAGEMENT CONFERENCE MAY RESULT IN SANCTIONS INCLUDING DISMISSAL OF THE CASE AND/OR JUDGMENT BEING RENDERED. DISCOVERY IS TO START IMMEDIATELY. PARTIES TO BE READY WITH DEMAND AND OFFER OF SETTLEMENT. CASE MANAGEMENT CONFERENCES ARE CONDUCTED IN PERSON; TELEPHONE ATTENDANCE IS NOT PERMITTED FOR ANY REASON. DO NOT CALL THE COURT REQUESTING TELEPHONE APPEARANCE. NOTICE ISSUED. NOTICE ISSUED

MOTION FILED FOR D4 STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY PATRICK M ROCHE 0071359 STATE FARM'S MOTION FOR LEAVE TO FILE AMENDED ANSWER, WITH COUNTERCLAIM AND CROSS-CLAIM FOR DECLARATORY JUDGMENT