On March 30, 2022 a
Motion,Ex Parte
was filed
involving a dispute between
Frank Mehwald,
Mary Mehwald,
The Atlantic Tool & Die Company,
and
Albert N Salvatore,
Clifford Croley,
Connick Law, Llc,
Croley, Martell & Assoc Ltd,
Daniel Prugar,
Franklin Hickman,
Hickman And Lowder Co., Lpa Registered Agent Franklin Hickman,
Jennifer Dumm,
John Harrison,
John Kim,
Kim & Associates, Llc,
Marvin Sicherman,
Matthew Gomes,
Michael Mehwald,
Patrick Moore,
Robert E Blackham,
Roetzel & Andress, Lpa A Legal Professional Association,
Thomas Connick,
Weinberg, Wheeler, Hudgins, Gunn & Dial, Llc,
for TORT-MISCELLANEOUS
in the District Court of Cuyahoga County.
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Motion No. 5045079
NAILAH K. BYRD
CUYAHOGA COUNTY CLERK OF COURTS
1200 Ontario Street
Cleveland, Ohio 44113
Court of Common Pleas
MOTION FOR EXTENSION OF TIME
October 28,2022 16:11
By: EDWARD A. PROCTOR 0069877
Confirmation Nbr. 2689653
ATLANTIC TOOL & DIE COMPANY, ET AL. CV 22 961394
vs.
Judge: DAVID T.MATIA
MICHAEL MEH WALD, ET AL.
Pages Filed: 3
Electronically Filed 10/28/2022 16:11 / MOTION / CV 22 961394 / Confirmation Nbr. 2689653 / CLCEJ
IN THE COURT OF COMMON PLEAS
CUYAHOGA COUNTY, OHIO
THE ATLANTIC TOOL & DIE CO., et ) CASE NO.: CV 22 961394
al., )
)
)
Plaintiffs, ) JUDGE: DAVID T. MATIA
)
vs. )
)
MICHAEL MEHWALD, et al., ) MOTION FOR EXTENSION OF TIME TO
) FILE MOTION FOR JUDGMENT ON THE
Defendants. ) PLEADINGS
)
Now come Defendants John Y. Kim, Esq., and Kim & Associates, LLC (the “Kim
Defendants”), by and through undersigned counsel, and hereby respectfully request a brief one-
week continuance of the deadline to file their Motion for Judgment on the Pleadings currently
due October 31, 2022. The Kim Defendants respectfully request a new deadline of November
7, 2022.
Unfortunately, on October 22, 2022, Plaintiffs Counsel tested positive for Covid-19 requiring
his quarantine until Friday, October 28, 2022. This motion is not being proffered for purposes of delay,
but solely in the interests of justice. No party will be prejudiced by the granting of this motion.
For the foregoing reason, counsel for the Kim Defendants respectfully requests this
Honorable Court to continue the deadline for Motions to Dismiss or Motions for Judgment on the
Pleadings for one week until November 7, 2022.
Electronically Filed 10/28/2022 16:11 / MOTION / CV 22 961394 / Confirmation Nbr. 2689653 / CLCEJ
Respectfully submitted,
/s/Edward A. Proctor___________
Edward A. Proctor (0069877)
KIM & ASSOCIATES LLC
4100 Embassy Parkway, Suite 200
Akron, Ohio 44333-1783
Telephone: 330.396.7900
Facsimile: 330.396.7901
Email: eproctor@kimassociateslaw.com
Attorney for the Kim Defendant
Electronically Filed 10/28/2022 16:11 / MOTION / CV 22 961392 I Confirmation Nbr. 2689653 / CLCEJ
CERTIFICATE OF SERVICE
This is to certify that on this 28th day of October 2022, a copy of the foregoing was filed
electronically. Notice of this filing will be sent to all parties by operation of the Court's electronic
filing system.
/s/ Edward A. Proctor_____________
Edward A. Proctor (0069877)
Attorney for Defendants John Y. Kim, Esq.
and Kim & Associates, LLC
Electronically Filed 10/28/2022 16:11 / MOTION / CV 22 961393 / Confirmation Nbr. 2689653 / CLCEJ
Document Filed Date
October 28, 2022
Case Filing Date
March 30, 2022
Category
TORT-MISCELLANEOUS
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Motion No. 5045079 NAILAH K. BYRD CUYAHOGA COUNTY CLERK OF COURTS 1200 Ontario Street Cleveland, Ohio 44113 Court of Common Pleas MOTION FOR EXTENSION OF TIME October 28,2022 16:11 By: EDWARD A. PROCTOR 0069877 Confirmation Nbr. 2689653 ATLANTIC TOOL & DIE COMPANY, ET AL. CV 22 961394 vs. Judge: DAVID T.MATIA MICHAEL MEH WALD, ET AL. Pages Filed: 3 Electronically Filed 10/28/2022 16:11 / MOTION / CV 22 961394 / Confirmation Nbr. 2689653 / CLCEJ IN THE COURT OF COMMON PLEAS CUYAHOGA COUNTY, OHIO THE ATLANTIC TOOL & DIE CO., et ) CASE NO.: CV 22 961394 al., ) ) ) Plaintiffs, ) JUDGE: DAVID T. MATIA ) vs. ) ) MICHAEL MEHWALD, et al., ) MOTION FOR EXTENSION OF TIME TO ) FILE MOTION FOR JUDGMENT ON THE Defendants. ) PLEADINGS ) Now come Defendants John Y. Kim, Esq., and Kim & Associates, LLC (the “Kim Defendants”), by and through undersigned counsel, and hereby respectfully request a brief one- week continuance of the deadline to file their Motion for Judgment on the Pleadings currently due October 31, 2022. The Kim Defendants respectfully request a new deadline of November 7, 2022. Unfortunately, on October 22, 2022, Plaintiffs Counsel tested positive for Covid-19 requiring his quarantine until Friday, October 28, 2022. This motion is not being proffered for purposes of delay, but solely in the interests of justice. No party will be prejudiced by the granting of this motion. For the foregoing reason, counsel for the Kim Defendants respectfully requests this Honorable Court to continue the deadline for Motions to Dismiss or Motions for Judgment on the Pleadings for one week until November 7, 2022. Electronically Filed 10/28/2022 16:11 / MOTION / CV 22 961394 / Confirmation Nbr. 2689653 / CLCEJ Respectfully submitted, /s/Edward A. Proctor___________ Edward A. Proctor (0069877) KIM & ASSOCIATES LLC 4100 Embassy Parkway, Suite 200 Akron, Ohio 44333-1783 Telephone: 330.396.7900 Facsimile: 330.396.7901 Email: eproctor@kimassociateslaw.com Attorney for the Kim Defendant Electronically Filed 10/28/2022 16:11 / MOTION / CV 22 961392 I Confirmation Nbr. 2689653 / CLCEJ CERTIFICATE OF SERVICE This is to certify that on this 28th day of October 2022, a copy of the foregoing was filed electronically. Notice of this filing will be sent to all parties by operation of the Court's electronic filing system. /s/ Edward A. Proctor_____________ Edward A. Proctor (0069877) Attorney for Defendants John Y. Kim, Esq. and Kim & Associates, LLC Electronically Filed 10/28/2022 16:11 / MOTION / CV 22 961393 / Confirmation Nbr. 2689653 / CLCEJ