On December 03, 2013 a
Motion,Ex Parte
was filed
involving a dispute between
The City Of Wooster, Ohio,
and
Pooler, James N,
for OTHER CIVIL
in the District Court of Wayne County.
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e-filed on 10/28/2014 at 04:40 PM in Wayne County, Ohio
IN THE COURT OF COMMON PLEAS
WAYNE COUNTY, OHIO
THE CITY OF WOOSTER, OHIO : CASE NO. 13-CV-0657
EX REL RICHARD R. BENSON JR.
LAW DIRECTOR : JUDGE SPITLER
Plaintiff, : REQUEST FOR LEAVE TO FILE
: SUPPLEMENTAL
: MEMORANDUM IN SUPPORT OF
vs. : MOTION TO STRIKE
: FRIVOLOUS PLEADING
JAMES N. POOLER : AND FOR SANCTIONS
UNDER O.R.C.§2323.51
Defendant.
Defendant Pooler, by and through Counsel, hereby requests leave to file the
attached Supplemental Memorandum in Support of Motion to Strike Frivolous Pleading
and for Sanctions. Comments by the Law Director and Plaintiff's Counsel at the recent
pretrial hearing in this matter make it necessary that the Defendant be allowed to respond
in order to clarify his position and address those comments.
Respectfully Submitted,
/s/Jason M. Storck
Jason M. Storck (0077071)
Storck Law Office Ltd.
P.O. Box 1023
Wooster, OH 44691
(330) 263-0006 - Phone
(830) 263-0009 - Fax
jasonstorck@storcklawoffice.com
Attorney for DefendantCertificate of Service
| hereby certify that a true and accurate copy of the above, along with all exhibits or
attachments thereto, was served upon the following this 28" day of October, 2014, by
electronic mail, as per Rule 5(B)2(f) of the Ohio Rules of Civil Procedure:
Richard R. Benson Jr.
Director of Law
City of Wooster
538 North Market St.
Wooster, Ohio 44691
Stephen L. Byron,
Darrell A. Clay,
Aimee W. Lane, and
Bozana L. Lundgerg
Walter & Haverfield LLP
The Tower at Erieview
1301 East Ninth Street, Suite 3500
Cleveland, Ohio 44114
/s/Jason M. Storck
Jason M. Storck (0077071)
Document Filed Date
October 28, 2014
Case Filing Date
December 03, 2013
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e-filed on 10/28/2014 at 04:40 PM in Wayne County, Ohio IN THE COURT OF COMMON PLEAS WAYNE COUNTY, OHIO THE CITY OF WOOSTER, OHIO : CASE NO. 13-CV-0657 EX REL RICHARD R. BENSON JR. LAW DIRECTOR : JUDGE SPITLER Plaintiff, : REQUEST FOR LEAVE TO FILE : SUPPLEMENTAL : MEMORANDUM IN SUPPORT OF vs. : MOTION TO STRIKE : FRIVOLOUS PLEADING JAMES N. POOLER : AND FOR SANCTIONS UNDER O.R.C.§2323.51 Defendant. Defendant Pooler, by and through Counsel, hereby requests leave to file the attached Supplemental Memorandum in Support of Motion to Strike Frivolous Pleading and for Sanctions. Comments by the Law Director and Plaintiff's Counsel at the recent pretrial hearing in this matter make it necessary that the Defendant be allowed to respond in order to clarify his position and address those comments. Respectfully Submitted, /s/Jason M. Storck Jason M. Storck (0077071) Storck Law Office Ltd. P.O. Box 1023 Wooster, OH 44691 (330) 263-0006 - Phone (830) 263-0009 - Fax jasonstorck@storcklawoffice.com Attorney for DefendantCertificate of Service | hereby certify that a true and accurate copy of the above, along with all exhibits or attachments thereto, was served upon the following this 28" day of October, 2014, by electronic mail, as per Rule 5(B)2(f) of the Ohio Rules of Civil Procedure: Richard R. Benson Jr. Director of Law City of Wooster 538 North Market St. Wooster, Ohio 44691 Stephen L. Byron, Darrell A. Clay, Aimee W. Lane, and Bozana L. Lundgerg Walter & Haverfield LLP The Tower at Erieview 1301 East Ninth Street, Suite 3500 Cleveland, Ohio 44114 /s/Jason M. Storck Jason M. Storck (0077071)