On February 22, 2023 a
Complaint,Petition
was filed
involving a dispute between
Ruff, Rayniere,
and
Summit County Prosecutor'S Office,
for RELIEF FROM DISABILITY
in the District Court of Summit County.
Preview
CV-2023-02-0602 BAKER ROSS, SUSAN 02/22/2023 11:01:23 AM CMCO Page 1 of 3
IN THE COURT OF COMMON PLEAS
SUMMIT COUNTY OHIO
RAYNIERE D. RUFF ) CASE NO.:
620 Noble Avenue )
Akron, Ohio 44320 ) JUDGE:
)
Plaintiff/Applicant, )
)
SUMMIT COUNTY PROSECUTOR’S ) APPLICATION FOR RELIEF
OFFICE ) FROM WEAPONS DISABILITY
175 S. Main Street ) PURSUANT TO R.C. 2923.14
Akron, Ohio 44308 )
) (ORAL HEARING REQUESTED)
Defendant/Respondent. )
)
Now comes Petitioner/Applicant, Rayniere D. Ruff, by and through counsel, and
respectfully submits this application requesting that this Court relieve the Petitioner/Applicant
from his current disability prohibiting him from possessing a firearm under R.C. 2923.13 and/or
federal law. For the reasons set forth below, this Court should grant him such relief pursuant to
R.C. 2923.14.
BASIS FOR DISABILITY
Pursuant to R.C. 2923.13, Defendant is currently prohibited from possessing a firearm
based upon the following convictions:
1. CR-2016-09-3373. Trafficking In Marijuana-2925.03(A)(C)(3)-F3; Criminal
Forfeiture Specification 1-2911.1417; Criminal Forfeiture Specification 2-2941.1417;
Possession of Marijuana-2925,11(A)(C)(3)-F3. Date of conviction: January 3, 2017.
Sentence: 3 years community control (completed August 2, 2018), forfeit $2,142.00,
forfeit 2013 Dodge Charger.
Sandra Kurt, Summit County Clerk of Courts
CV-2023-02-0602 BAKER ROSS, SUSAN 02/22/2023 11:01:23 AM CMCO Page 2 of 3
2. CR-2016-05-1646-A. Attempted Possession of Marijuana-R.C.
2923.02/2925.11(A)(C)(3)-M1. Date of Conviction: September 12, 2016. Sentence:
1-year community control (completed).
3. CR-2013-08-2207. Carrying Concealed Weapons-R.C. 2923.12(A)(2)-F4. Date of
conviction: January 3, 2014. Sentence: 18 months of community control (completed).
ARGUMENT IN SUPPORT OF RELIEF
A. BECAUSE DEFENDANT SATISFIES ALL STATUTORY CRITERIA HIS SECOND
AMENDMENT RIGHT TO POSSESS A FIREARM SHOULD BE RESTORED
Based upon Petitioner’s prior conviction(s) he is prohibited from possessing a firearm.
R.C. 2923.14 provides statutory authority to relieve an individual of the disability to possess a
firearm. Defendant has completed his sentence(s), and since that time Defendant has
demonstrated that he is a responsible, law-abiding individual who can safely possess a firearm
and is deserving of having his Second Amendment rights restored.
Defendant satisfies all statutory criteria pursuant to R.C. 2923.14 for relief from firearms
disability. Since Defendant’s completion of his sentence(s), Defendant has led a law-abiding life.
Mr. Ruff has not been in trouble with the law since his last case in 2016. He even took the steps
to have his record sealed in this Court in November 2022.
Defendant now lives with his long-time partner and two young children. He loves being
a father. Mr. Ruff is working in real estate and is in the process to get his realtor’s license.
CONCLUSION
Wherefore, based upon the foregoing, the defendant requests that this Honorable Court
issue an order pursuant to R.C. 2923.14 relieving Defendant’s disability to possess a firearm.
Sandra Kurt, Summit County Clerk of Courts
CV-2023-02-0602 BAKER ROSS, SUSAN 02/22/2023 11:01:23 AM CMCO Page 3 of 3
Respectfully Submitted,
/s/ Jensen E. Silvis
Jensen E. Silvis. (0093989)
190 North Union Street, Suite 201
Akron, Ohio 44304
Telephone: (330)696-8231
Fax: (330)348-5209
Email: jensen@jesilvislaw.com
Counsel for Applicant
CERTIFICATE OF SERVICE
The foregoing Motion was sent by regular U.S. mail and/or electronic mail this 22nd day of
February 2023, to the following:
Summit County Prosecutor’s Office
175 S. Main Street
Akron, Ohio 44308
/s/ Jensen E. Silvis
Jensen E. Silvis (0093989)
Sandra Kurt, Summit County Clerk of Courts
Document Filed Date
February 22, 2023
Case Filing Date
February 22, 2023
Category
RELIEF FROM DISABILITY
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CV-2023-02-0602 BAKER ROSS, SUSAN 02/22/2023 11:01:23 AM CMCO Page 1 of 3 IN THE COURT OF COMMON PLEAS SUMMIT COUNTY OHIO RAYNIERE D. RUFF ) CASE NO.: 620 Noble Avenue ) Akron, Ohio 44320 ) JUDGE: ) Plaintiff/Applicant, ) ) SUMMIT COUNTY PROSECUTOR’S ) APPLICATION FOR RELIEF OFFICE ) FROM WEAPONS DISABILITY 175 S. Main Street ) PURSUANT TO R.C. 2923.14 Akron, Ohio 44308 ) ) (ORAL HEARING REQUESTED) Defendant/Respondent. ) ) Now comes Petitioner/Applicant, Rayniere D. Ruff, by and through counsel, and respectfully submits this application requesting that this Court relieve the Petitioner/Applicant from his current disability prohibiting him from possessing a firearm under R.C. 2923.13 and/or federal law. For the reasons set forth below, this Court should grant him such relief pursuant to R.C. 2923.14. BASIS FOR DISABILITY Pursuant to R.C. 2923.13, Defendant is currently prohibited from possessing a firearm based upon the following convictions: 1. CR-2016-09-3373. Trafficking In Marijuana-2925.03(A)(C)(3)-F3; Criminal Forfeiture Specification 1-2911.1417; Criminal Forfeiture Specification 2-2941.1417; Possession of Marijuana-2925,11(A)(C)(3)-F3. Date of conviction: January 3, 2017. Sentence: 3 years community control (completed August 2, 2018), forfeit $2,142.00, forfeit 2013 Dodge Charger. Sandra Kurt, Summit County Clerk of Courts CV-2023-02-0602 BAKER ROSS, SUSAN 02/22/2023 11:01:23 AM CMCO Page 2 of 3 2. CR-2016-05-1646-A. Attempted Possession of Marijuana-R.C. 2923.02/2925.11(A)(C)(3)-M1. Date of Conviction: September 12, 2016. Sentence: 1-year community control (completed). 3. CR-2013-08-2207. Carrying Concealed Weapons-R.C. 2923.12(A)(2)-F4. Date of conviction: January 3, 2014. Sentence: 18 months of community control (completed). ARGUMENT IN SUPPORT OF RELIEF A. BECAUSE DEFENDANT SATISFIES ALL STATUTORY CRITERIA HIS SECOND AMENDMENT RIGHT TO POSSESS A FIREARM SHOULD BE RESTORED Based upon Petitioner’s prior conviction(s) he is prohibited from possessing a firearm. R.C. 2923.14 provides statutory authority to relieve an individual of the disability to possess a firearm. Defendant has completed his sentence(s), and since that time Defendant has demonstrated that he is a responsible, law-abiding individual who can safely possess a firearm and is deserving of having his Second Amendment rights restored. Defendant satisfies all statutory criteria pursuant to R.C. 2923.14 for relief from firearms disability. Since Defendant’s completion of his sentence(s), Defendant has led a law-abiding life. Mr. Ruff has not been in trouble with the law since his last case in 2016. He even took the steps to have his record sealed in this Court in November 2022. Defendant now lives with his long-time partner and two young children. He loves being a father. Mr. Ruff is working in real estate and is in the process to get his realtor’s license. CONCLUSION Wherefore, based upon the foregoing, the defendant requests that this Honorable Court issue an order pursuant to R.C. 2923.14 relieving Defendant’s disability to possess a firearm. Sandra Kurt, Summit County Clerk of Courts CV-2023-02-0602 BAKER ROSS, SUSAN 02/22/2023 11:01:23 AM CMCO Page 3 of 3 Respectfully Submitted, /s/ Jensen E. Silvis Jensen E. Silvis. (0093989) 190 North Union Street, Suite 201 Akron, Ohio 44304 Telephone: (330)696-8231 Fax: (330)348-5209 Email: jensen@jesilvislaw.com Counsel for Applicant CERTIFICATE OF SERVICE The foregoing Motion was sent by regular U.S. mail and/or electronic mail this 22nd day of February 2023, to the following: Summit County Prosecutor’s Office 175 S. Main Street Akron, Ohio 44308 /s/ Jensen E. Silvis Jensen E. Silvis (0093989) Sandra Kurt, Summit County Clerk of Courts