On February 26, 2021 a
Party Discovery
was filed
involving a dispute between
Assunta Rossi,
Assunta Rossi Personalty Revocable Living Trust,
Robert V. Traci,
and
Chicago Title Company, Llc,
David Keehan,
D. J. Keehan,
Gh Holdings Llc,
Online Communications Llc,
Signature Building Concepts Llc,
Westlake Shadow Creek, Llc An Ohio Corporation,
for CONTRACT - REAL ESTATE
in the District Court of Cuyahoga County.
Preview
NAILAH K. BYRD
CUYAHOGA COUNTY CLERK OF COURTS
1200 Ontario Street
Cleveland, Ohio 44113
Court of Common Pleas
NOTICE OF DEPOSITION
May 2,2022 12:39
Confirmation Nbr. 2539467
ASSUNTA ROSSI PERSONALTY REVOCABLE CV 21 944483
LIVING ET AL
vs.
Judge: MAUREEN CLANCY
D.J. KEEHANETAL
Pages Filed: 3
Electronically Filed 05/02/2022 12:39 / NOTICE / CV 21 944483 / Confirmation Nbr. 2539467 / CLLMD
IN THE COURT OF COMMON PLEAS
CUYAHOGA COUNTY, OHIO
ASSUNTA ROSSI PERSONALTY :
REVOCABLE LIVING TRUST, et al :
: CASE NO.: CV 21944483
Plaintiffs
: JUDGE MAUREEN CLANCY
Vs ;
D.J.KEEHAN, Individually and as
DBA Westlake Shadow Creek, LLC, :
et al
Defendants :
AMENDED
NOTICE FOR DEPOSITION DUCES TECUM DIRECTED TO NEW
PARTY DEFENDANT DAVID KEEHAN PURSUANT TO
RULES 30 AND 34
Counsel for New Party Defendant David Keehan shall take notice that the
Plaintiffs will take his deposition pursuant to Rules 30 and 34 on Wednesday,
Friday, May 6, 2022 at 9:30 am at the offices of Veritext, located at 1100 Superior
Avenue, Suite 1820, Cleveland, Ohio 44114.
Said deposition will be taken both by stenographic and video means before a
Notary Public duly authorized by law to administer oaths, and continuing day to
day until completed, at which time and place you are invited to appear and take
such part as shall be fitting and proper.
The areas of inquiry all involve or relate directly and/or indirectly to Unit 35
and/or 30033 Shadow Creek Drive, Westlake, Ohio. Said deposition will also
inquire about the deponent’s knowledge of the corporate structure of GH Holdings,
Electronically Filed 05/02/2022 12:39 / NOTICE / CV 21 944483 / Confirmation Nbr. 2539467 / CLLMD
LLC, Westlake Shadow Creek LLC, Online Communications, Signature Building
Concepts, LLC and a loan obtained by yourself, D.J. Keehan, GH Holdings and/or
Westlake Shadow Creek, LLC from RLR.
NOTICE DUCES TECUM PURSUANT TO RULE 30 AND 34
David Keehan, is requested pursuant to the Ohio Civil Rules 30 and 34, to
produce the following at the time of the deposition:
1. Any and all documents filed with the State of Ohio to set up or organize
GH Holdings, LLC and/or Westlake Shadow Creek, LLC (hereinafter
referred to as WSC and GH) including Articles of Organization,
corporate minutes, and dates of meetings of the shareholders/owners of
GH and/or WSC.
2. Any and all documents between yourself and D.J. Keehan regarding the
operation of GH Holdings and/or Westlake Shadow Creek;
3. Any and all tax forms, such as W-2s, 1099s or K-1s, sent to you related
to WSC and/or GH.
4. Copies of all state and federal tax returns for GH and/or WSC.
5. Verification of each and every charge you paid to, for, or on behalf of
WSC, GH and/or the Plaintiffs.
6. Verification of any and all charges which you paid yourself or through
GH for labor or materials on behalf of WSC.
7. Copies of all documents, including correspondence, loan contracts,
payments, private loans, etc involving yourself and D.J. Keehan with
RLR from 2018 to present related to any loans from RLR that was used
in whole or in part for WSC.
Electronically Filed 05/02/2022 12:39 / NOTICE / CV 21 944483 / Confirmation Nbr. 2539467 / CLLMD
/s/ Robert V. Traci
Robert V. Traci, Esq., Pro Se
Inactive (6734)
29576 Indian Ridge Cove
Westlake, OH 44145
rvt@tracilpa.com
/s/ Assunta Rossi
Assunta Rossi, Esq., Personally
and as Trustee
29576 Indian Ridge Cove
Westlake, Ohio 44145
artrial388@gmail.com
CERTIFICATE OF SERVICE
I certify that a true copy of the foregoing Notice for Deposition of David
Keehan from Plaintiffs was served on all Defendants by and through their counsel
Stephen Hanudel and Denio Leone, on May 2, 2022, by delivering copies of same
by electronic mail.
/s/Robert V. Traci
Robert V. Traci
Electronically Filed 05/02/2022 12:39 / NOTICE / CV 21 944483 / Confirmation Nbr. 2539467 / CLLMD
Preview
NAILAH K. BYRD CUYAHOGA COUNTY CLERK OF COURTS 1200 Ontario Street Cleveland, Ohio 44113 Court of Common Pleas NOTICE OF DEPOSITION May 2,2022 12:39 Confirmation Nbr. 2539467 ASSUNTA ROSSI PERSONALTY REVOCABLE CV 21 944483 LIVING ET AL vs. Judge: MAUREEN CLANCY D.J. KEEHANETAL Pages Filed: 3 Electronically Filed 05/02/2022 12:39 / NOTICE / CV 21 944483 / Confirmation Nbr. 2539467 / CLLMD IN THE COURT OF COMMON PLEAS CUYAHOGA COUNTY, OHIO ASSUNTA ROSSI PERSONALTY : REVOCABLE LIVING TRUST, et al : : CASE NO.: CV 21944483 Plaintiffs : JUDGE MAUREEN CLANCY Vs ; D.J.KEEHAN, Individually and as DBA Westlake Shadow Creek, LLC, : et al Defendants : AMENDED NOTICE FOR DEPOSITION DUCES TECUM DIRECTED TO NEW PARTY DEFENDANT DAVID KEEHAN PURSUANT TO RULES 30 AND 34 Counsel for New Party Defendant David Keehan shall take notice that the Plaintiffs will take his deposition pursuant to Rules 30 and 34 on Wednesday, Friday, May 6, 2022 at 9:30 am at the offices of Veritext, located at 1100 Superior Avenue, Suite 1820, Cleveland, Ohio 44114. Said deposition will be taken both by stenographic and video means before a Notary Public duly authorized by law to administer oaths, and continuing day to day until completed, at which time and place you are invited to appear and take such part as shall be fitting and proper. The areas of inquiry all involve or relate directly and/or indirectly to Unit 35 and/or 30033 Shadow Creek Drive, Westlake, Ohio. Said deposition will also inquire about the deponent’s knowledge of the corporate structure of GH Holdings, Electronically Filed 05/02/2022 12:39 / NOTICE / CV 21 944483 / Confirmation Nbr. 2539467 / CLLMD LLC, Westlake Shadow Creek LLC, Online Communications, Signature Building Concepts, LLC and a loan obtained by yourself, D.J. Keehan, GH Holdings and/or Westlake Shadow Creek, LLC from RLR. NOTICE DUCES TECUM PURSUANT TO RULE 30 AND 34 David Keehan, is requested pursuant to the Ohio Civil Rules 30 and 34, to produce the following at the time of the deposition: 1. Any and all documents filed with the State of Ohio to set up or organize GH Holdings, LLC and/or Westlake Shadow Creek, LLC (hereinafter referred to as WSC and GH) including Articles of Organization, corporate minutes, and dates of meetings of the shareholders/owners of GH and/or WSC. 2. Any and all documents between yourself and D.J. Keehan regarding the operation of GH Holdings and/or Westlake Shadow Creek; 3. Any and all tax forms, such as W-2s, 1099s or K-1s, sent to you related to WSC and/or GH. 4. Copies of all state and federal tax returns for GH and/or WSC. 5. Verification of each and every charge you paid to, for, or on behalf of WSC, GH and/or the Plaintiffs. 6. Verification of any and all charges which you paid yourself or through GH for labor or materials on behalf of WSC. 7. Copies of all documents, including correspondence, loan contracts, payments, private loans, etc involving yourself and D.J. Keehan with RLR from 2018 to present related to any loans from RLR that was used in whole or in part for WSC. Electronically Filed 05/02/2022 12:39 / NOTICE / CV 21 944483 / Confirmation Nbr. 2539467 / CLLMD /s/ Robert V. Traci Robert V. Traci, Esq., Pro Se Inactive (6734) 29576 Indian Ridge Cove Westlake, OH 44145 rvt@tracilpa.com /s/ Assunta Rossi Assunta Rossi, Esq., Personally and as Trustee 29576 Indian Ridge Cove Westlake, Ohio 44145 artrial388@gmail.com CERTIFICATE OF SERVICE I certify that a true copy of the foregoing Notice for Deposition of David Keehan from Plaintiffs was served on all Defendants by and through their counsel Stephen Hanudel and Denio Leone, on May 2, 2022, by delivering copies of same by electronic mail. /s/Robert V. Traci Robert V. Traci Electronically Filed 05/02/2022 12:39 / NOTICE / CV 21 944483 / Confirmation Nbr. 2539467 / CLLMD