On August 02, 2021 a
Order
was filed
involving a dispute between
and
for OTHER CIVIL
in the District Court of Franklin County.
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Franklin County Ohio Clerk of Courts of the Common Pleas- 2022 Nov 10 4:10 PM-21CV004885
0G158 - L8
IN THE COURT OF COMMON PLEAS
FRANKLIN COUNTY, OHIO
1415 SOUTHSIDE PROPERTIES, LLC,
Case No. 21 CV 4885
Plaintiff
Judge Hawkins
-vs-
ERIE INSURANCE EXCHANGE,
Defendant
PLAINTIFF 1415 SOUTHSIDE PROPERTIES, LLC’S UNOPPOSED MOTION TO
EXTEND TIME TO RESPOND TO DEFENDANT’S “MOTION FOR
RECONSIDERATION OF COURT’S AUGUST 19, 2022 ORDER AND ENTRY [AND]
SUMMARY JUDGMENT ON ALL PLAINTIFF’S CLAIMS”
Plaintiff 1415 Southside Properties, LLC, by and through counsel, respectfully moves
this Court for an extension of time to respond to Defendant’s “Motion for Reconsideration of
Court’s August 9, 2022 Order and Entry [and] Summary Judgment on All Plaintiff's Claims.”
Plaintiff’ s response would otherwise be due November 10, 2022. Plaintiff requests that the
deadline for responding to Defendant’s Motion be extended for 22 days, up to and including
December 2, 2022. Plaintiff requests this extension because certain counsel for Plaintiff has
been out of the country, and other counsel has been working on two appellate briefs, which were
due on November 9, 2022. Those briefs have been overwhelming time commitments for
counsel, who has been unable to dedicate the time necessary to prepare the opposition to this
motion. Therefore, counsel for Plaintiff respectfully requests until December 2, 2022 to do so.
Counsel for Plaintiff contacted Counsel for Defendant requesting the extension of time,
and the extension is unopposed.
This extension will not alter the case schedule because a trial date has not yet been set.
The discovery deadline is set for January 11, 2023, the dispositive motions deadline is January
Franklin County Ohio Clerk of Courts of the Common Pleas- 2022 Nov 10 4:10 PM-21CV004885
0G158 - L8
17, 2023, and the final pretrial conference is January 26, 2023. Additionally, the parties are set to
mediate on December 12, 2022.
A proposed order is being submitted herewith.
Respectfully submitted,
/s/ Geoffrey J. Moul
Geoffrey J. Moul (0070663)
Murray Murphy Moul + Basil LLP
1114 Dublin Road
Columbus, OH 43215
Telephone: 614.488.0400
Facsimile: 614.488.0401
Email: moul@mmmb.com
Counsel for Plaintiff 1415 Southside
Properties, LLC
CERTIFICATE OF SERVICE
Thereby certify that on November 10, 2022, I electronically filed the foregoing with the
Clerk of the Court by using the e-Filing system, which will send a notice of electronic filing to
the following:
Gordon D. Arnold Bartholomew T. Freeze
FREUND, FREEZE & ARNOLD FREUND, FREEZE & ARNOLD
1800 Fifth Third Center 65 East State Street, Suite 800
1S. Main St. Columbus, OH 43215
Dayton, OH 45402-2017 bfreeze@ffalaw.com
garnold@ffalaw.com
/s/ Geoffrey J. Moul
Geoffrey J. Moul
Document Filed Date
November 10, 2022
Case Filing Date
August 02, 2021
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Franklin County Ohio Clerk of Courts of the Common Pleas- 2022 Nov 10 4:10 PM-21CV004885 0G158 - L8 IN THE COURT OF COMMON PLEAS FRANKLIN COUNTY, OHIO 1415 SOUTHSIDE PROPERTIES, LLC, Case No. 21 CV 4885 Plaintiff Judge Hawkins -vs- ERIE INSURANCE EXCHANGE, Defendant PLAINTIFF 1415 SOUTHSIDE PROPERTIES, LLC’S UNOPPOSED MOTION TO EXTEND TIME TO RESPOND TO DEFENDANT’S “MOTION FOR RECONSIDERATION OF COURT’S AUGUST 19, 2022 ORDER AND ENTRY [AND] SUMMARY JUDGMENT ON ALL PLAINTIFF’S CLAIMS” Plaintiff 1415 Southside Properties, LLC, by and through counsel, respectfully moves this Court for an extension of time to respond to Defendant’s “Motion for Reconsideration of Court’s August 9, 2022 Order and Entry [and] Summary Judgment on All Plaintiff's Claims.” Plaintiff’ s response would otherwise be due November 10, 2022. Plaintiff requests that the deadline for responding to Defendant’s Motion be extended for 22 days, up to and including December 2, 2022. Plaintiff requests this extension because certain counsel for Plaintiff has been out of the country, and other counsel has been working on two appellate briefs, which were due on November 9, 2022. Those briefs have been overwhelming time commitments for counsel, who has been unable to dedicate the time necessary to prepare the opposition to this motion. Therefore, counsel for Plaintiff respectfully requests until December 2, 2022 to do so. Counsel for Plaintiff contacted Counsel for Defendant requesting the extension of time, and the extension is unopposed. This extension will not alter the case schedule because a trial date has not yet been set. The discovery deadline is set for January 11, 2023, the dispositive motions deadline is January Franklin County Ohio Clerk of Courts of the Common Pleas- 2022 Nov 10 4:10 PM-21CV004885 0G158 - L8 17, 2023, and the final pretrial conference is January 26, 2023. Additionally, the parties are set to mediate on December 12, 2022. A proposed order is being submitted herewith. Respectfully submitted, /s/ Geoffrey J. Moul Geoffrey J. Moul (0070663) Murray Murphy Moul + Basil LLP 1114 Dublin Road Columbus, OH 43215 Telephone: 614.488.0400 Facsimile: 614.488.0401 Email: moul@mmmb.com Counsel for Plaintiff 1415 Southside Properties, LLC CERTIFICATE OF SERVICE Thereby certify that on November 10, 2022, I electronically filed the foregoing with the Clerk of the Court by using the e-Filing system, which will send a notice of electronic filing to the following: Gordon D. Arnold Bartholomew T. Freeze FREUND, FREEZE & ARNOLD FREUND, FREEZE & ARNOLD 1800 Fifth Third Center 65 East State Street, Suite 800 1S. Main St. Columbus, OH 43215 Dayton, OH 45402-2017 bfreeze@ffalaw.com garnold@ffalaw.com /s/ Geoffrey J. Moul Geoffrey J. Moul