Party Discovery: ASSUNTA ROSSI PERSONALTY REVOCABLE LIVING ET AL vs. D.J. KEEHAN ET AL

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                                NAILAH K. BYRD
                                                  CUYAHOGA COUNTY CLERK OF COURTS
                                                                   1200 Ontario Street
                                                                  Cleveland, Ohio 44113




                                                             Court of Common Pleas


                                                             NOTICE OF DEPOSITION
                                                               November 29,2021 16:35


                                                        By: STEPHEN P. HANUDEL 0083486

                                                              Confirmation Nbr. 2413858



                ASSUNTA ROSSI PERSONALTY REVOCABLE                                        CV 21 944483
                LIVING ET AL

                        vs.
                                                                                 Judge:   MAUREEN CLANCY
                D.J. KEEHANETAL




                                                                    Pages Filed: 2




             Electronically Filed 11/29/202116:35 / NOTICE / CV 21   944483 / Confirmation Nbr. 2413858 / CLCKD
                                                       IN  THE    COURT OF        COMMON         PLEAS
                                                             CUYAHOGA COUNTY,                OHIO


                  ASSUNTA        ROSSI     PERSONALTY                  )         CASE     NO.   CV-21-944483
                  REVOCABLE          LIVING TRUST,          et al       )
                                                                        )
                                             Plaintiffs                )         JUDGE      MAUREEN         CLANCY
                                                                        )
                            v.                                          )
                                                                        )
                  D.J.  KEEHAN                                         )
                                                                        )        NOTICE OF        DEPOSITION
                            and                                         )        OF   PLAINTIFF ASSUNTA               ROSSI
                                                                        )
                  WESTLAKE         SHADOW CREEK,              LLC       )
                                                                        )
                                             Defendants                )


                           Defendants      D.J.  Keehan     and Westlake        Shadow Creek,        LLC,   by and    through

                  undersigned      counsel,    pursuant to     Civ.  R.  30,  hereby give     notice that they will     take the

                  discovery deposition        of Plaintiff Assunta      Rossi,   in both   her personal     capacity and      as
                  Trustee of the Assunta         Rossi    Personalty     Revocable Trust,       upon   oral  examination      on

                  December 8,       2021   at  11:00 AM     at the   office of JK Court Reporting,         13415     Shaker

                  Boulevard,     Suite   12R3,    Cleveland,     Ohio   44120.

                           The   deposition will     be taken    pursuant to the      Ohio   Rules of Civil    Procedure and

                  before a    notary public.     It willbe  recorded     by stenographic and video           means and

                  continue from      day to   day   until completed      and   may be    used    as evidence      in the trial of the

                  above captioned        matter.

                           Pursuant to     Civ.  R.  30(B)(4),    the deponent,      Assunta     Rossi,   is hereby requested

                  to bring the    following documents to the deposition:

                           1.  Copies of all     records of contracts,       invoices,   and   payments      regarding all
                               modifications and/or repairs of the           premises     located    30033    Shadow Creek


             Electronically Filed 11/29/202116:35 / NOTICE / CV 21   944483 / Confirmation Nbr. 2413858 / CLCKD
                                Drive,   Westlake,     Ohio 44145.      (This was     previously requested        in Nos.   6  and   7
                                of Defendants’      Request for Production          of Documents sent July          17,  2021.)

                           2.   If an agreement was         reached    between Assunta         Rossi,   whether in     her
                                personal    capacity or as Trustee of the Assunta             Rossi    Personalty Revocable
                                Trust,  and   Dustin   Messer that resulted        in the dismissal      of Assunta Rossi
                                Personalty Revocable Living            Trust v.  Messer,     Rocky    River Municipal      Court
                                Case    No.  21CVF1007,        then  a  copy of the agreement and           any   payment made
                                pursuant to the     agreement.




                                                                        Respectfully submitted,

                                                                        /s/ Stephen P.      Hanudel____
                                                                        Stephen     P.  Hanudel     (#0083486)
                                                                        Attorney for     Defendants
                                                                        124   Middle Avenue,        Suite  900
                                                                        Elyria,  Ohio 44035
                                                                        Phone:     (440) 328-8973
                                                                        Fax:   (440) 261-4040
                                                                        sph812@gmail.com


                                                         CERTIFICATE          OF SERVICE

                  I certify that a true    copy of the foregoing was delivered to             all parties via the     Court’s
                  electronic filing    system    on  November 29,        2021.


                                                                                 /s/ Stephen P.      Hanudel
                                                                                 Stephen     P.  Hanudel




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             Electronically Filed 11/29/202116:35 / NOTICE / CV 21   944483 / Confirmation Nbr. 2413858 / CLCKD