On July 11, 2014 a
Request,Application
was filed
involving a dispute between
Carter, James,
and
Johnson, Kaye,
for MONEY COMPLAINT
in the District Court of Wayne County.
Preview
Filed on 08/06/2015 at 09:31 AM in Wayne County, Ohio
IN THE WAYNE COUNTY MUNICIPAL COURT, CIVIL DIVISION
WOOSTER, OHIO
JAMES P. CARTER ) Case No. 2014-CV-F-1171
Plaintiff ) Judge VanSickle
v. )
KAYE J. JOHNSON ) REQUEST FOR LEAVE
Defendant y
Now comes Counsel David M. Todaro, respectfully requests this Court grant him leave to
file a response to the Plaintiff's previously filed objection. For cause, Counsel notes that the
Plaintiff never served him with a copy of his objection and as a result, Counsel had no way of
knowing about its filing.
Wherefore, because Counsel has not previously filed a Request for Leave, and does not
request leave here for the purposes of delay, Counsel would respectfully request that he be
permitted to file the attached response.
RESPECTFULLY SUBMITTED,
Z
David M. Todaro, Esq.
126 North Walnut St.
Wooster, Ohio 44691
Phone: (330) 262-2911
Fax: (330) 264-2977
Email: davidmtodaro@aol.com
Counsel for Defendant Kaye JohnsonFiled on 08/06/2015 at 09:31 AM in Wayne County, Ohio
CERTIFICATE OF SERVICE
A copy of the foregoing Request for Leave was served on the Plaintiff James Carter via
‘ot
regular US Mail at 4157 Maidstone Lane, Medina, Ohio 44256 this x day of August, 2015.
ALPE
David M. Todaro, Esq. (0075851)
126 North Walnut St.
Wooster, Ohio 44691
Phone: (330) 262-2911
Fax: (330) 264-2977
Email: davidmtodaro@aol.com
Counsel for Defendant Kaye Johnson
Document Filed Date
August 06, 2015
Case Filing Date
July 11, 2014
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Filed on 08/06/2015 at 09:31 AM in Wayne County, Ohio IN THE WAYNE COUNTY MUNICIPAL COURT, CIVIL DIVISION WOOSTER, OHIO JAMES P. CARTER ) Case No. 2014-CV-F-1171 Plaintiff ) Judge VanSickle v. ) KAYE J. JOHNSON ) REQUEST FOR LEAVE Defendant y Now comes Counsel David M. Todaro, respectfully requests this Court grant him leave to file a response to the Plaintiff's previously filed objection. For cause, Counsel notes that the Plaintiff never served him with a copy of his objection and as a result, Counsel had no way of knowing about its filing. Wherefore, because Counsel has not previously filed a Request for Leave, and does not request leave here for the purposes of delay, Counsel would respectfully request that he be permitted to file the attached response. RESPECTFULLY SUBMITTED, Z David M. Todaro, Esq. 126 North Walnut St. Wooster, Ohio 44691 Phone: (330) 262-2911 Fax: (330) 264-2977 Email: davidmtodaro@aol.com Counsel for Defendant Kaye JohnsonFiled on 08/06/2015 at 09:31 AM in Wayne County, Ohio CERTIFICATE OF SERVICE A copy of the foregoing Request for Leave was served on the Plaintiff James Carter via ‘ot regular US Mail at 4157 Maidstone Lane, Medina, Ohio 44256 this x day of August, 2015. ALPE David M. Todaro, Esq. (0075851) 126 North Walnut St. Wooster, Ohio 44691 Phone: (330) 262-2911 Fax: (330) 264-2977 Email: davidmtodaro@aol.com Counsel for Defendant Kaye Johnson