Preview
Motion No. 5101753
NAILAH K. BYRD
CUYAHOGA COUNTY CLERK OF COURTS
1200 Ontario Street
Cleveland, Ohio 44113
Court of Common Pleas
MOTION FOR EXTENSION OF TIME
July 6,2023 13:41
Confirmation Nbr. 2901483
MELISSA SVIGELJ CV 23 978925
vs.
Judge: NANCY A. FUERST
SUSAN PALMENTERA-WORDELL ET AL
Pages Filed: 10
Electronically Filed 07/06/2023 13:41 / MOTION / CV 23 978925 / Confirmation Nbr. 2901483 / CLDLJ
IN THE COURT OF COMMON PLEAS
CUYAHOGA COUNTY, OHIO
Susan Pafmentera-Wordell Case No.: CV-23-978925
Dr. Paul Worded
Defendants, Judge Nancy A. Fuerst
-vs-
Melissa Svigelj
Plaintiff. DEFENDANTS' REQUEST FOR EXTENSION
FOR UPCOMING TELEPHONE CONF.
SCHEDULED FOR JULY 13, 2023
CONFERENCE DEFENDANTS ARE REFERRING TO IN THIS REQUEST FOR EXTENSION IS CITED IN DOCKET AS
FOLLOWS,
"CMC BY PHONE SET FOR 07/13/2023 AT 10:00 AM. PLAINTIFF'S COUNSEL SHALL INITIATE
CONFERENCE CALL AND CONTACT THE COURT AT 216-443-5963. PARTIES SHALL BE PREPARED
TO DISCUSS DISCOVERY AND SCHEDULING MATTERS.”
Introductory Statement
DEFENDANTS understand and respect that to the benefit of timely court scheduling and the best interest
of county and court employees and officials, as well as the citizenship of the county, extensions on case
timelines are granted only under extreme circumstances and are at the mercy and privilege of the court,
therefore, DEFENDANTS have taken great effort to list and explain the important reasons why this request
has been made. DEFENDANTS’ reasons fall into multiple categories including financial constraints, time
Electronically Filed 07/06/2023 13:41 / MOTION / CV 23 978925 / Confirmation Nbr. 2901483 / CLDLJ
constraints, lack of ability to secure legal representation, and serious and urgent medical issues, as well as
the extensive list of witnesses and multiple categories and volume of evidence the DEFENDANTS intend
to eventually produce in this matter.
DEFENDANTS REQUEST EXTENSION FOR FOLLOWING REASONS:
Financial Circumstances:
1) Despite efforts to do so, including phone and in person meetings with attorneys, DEFENDANTS
have yet to find an attorney willing to take this case. DEFENDANTS’ trusted personal friend and
attorney, Joseph B. Jerome, whom has represented DEFENDANT Susan Palmentera-Wordell in
any and all personal and business matters for almost 30 years sadly and unexpectedly passed
away during the later part of the COVID-19 pandemic, leaving DEFENDANTS without easily
obtainable representation in such a complicated case as this. After conferencing with multiple
attorneys, DEFENDANTS are certain that the political nature of this case is causing issues for
them in securing representation, but they are still trying.
2) DEFENDANTS severely restrained financial circumstances and inability to pay for an attorney
causes them to have to try to find an attorney that will represent them on contingency. Their
severely restrained financial circumstances are affected by various extenuating circumstances
including the following:
a) DEFENDANTS lack of income during most of COVID-19 pandemic (medical complications forced
them to keep their children home for three school years to protect child too young to be
vaccinated who had a heart issue as well another fully disabled child with multiple disabilities)
b) Overall lack of income due to inability for both parents to work full-time and lack of childcare
assistance possible due to special needs child's sometimes extreme symptoms requiring only the
parents to care for him.
c) Parents’ constant battle with school districts in educating their extremely academically gifted and
autistic child and schools not handling child properly often causing child to be out of school and
schooled from home for months at a time even before and after the pandemic.
Electronically Filed 07/06/2023 13:41 / MOTION / CV 23 978925 / Confirmation Nbr. 2901483 / CLDLJ
d) DEFENDANTS’ credit is being seriously damaged by these financial issues as well as student
loan debt of hundreds of thousands of dollars.
e) DEFENDANTS’ credit and extreme symptoms of special needs child’s causing them to be part of
the rising number of “working homeless” families who live in Air B and Bs, hotels, etc. This is such
that the school district the children attend has certified that the children are protected by the
McKinney-Vento Homelessness Assistance Act and manages the children’s enrollment, school
transportation, and academics as such. The extreme costs of these dwellings, which are always
significantly higher than normal housing expenses, have rendered the DEFENDANTS unable to
pay for an attorney despite having income. In addition and worth noting is the fact that the nature
of this case and accusations made by PLAINTIFF are further interfering with the DEFENDANTS’
ability to secure long-term housing for their family.
f) Dr. Paul Wordell’s less than desirable charter schoolteacher’s salary and Susan Palmentera-
Wordell’s low hourly wage and tip wages at her part-time jobs makes financial matters even more
strained.
g) DEFENDANTS’ necessity to secure housing and move often from one Air B and B, hotel, etc.
every few months to another including them being forced to secure and move to and get family
settled into a new dwelling in the next couple of weeks.
h) PLAINTIFF'S recent filing changing the amount of the damages from $6,000 to an unprecedented
and significantly higher amount of $50,000 and the enormity of the personal, social, parental,
familial, and professional damage that the outcome of this case is having and will have for a
lifetime for the DEFENDANTS has made the DEFENDANTS having skilled and knowledgeable
attorney a much more pressing matter than even before. DEFENDANTS beg the court allows
them more time to do so.
i) Please note: DEFENDANTS work hard and have multiple jobs and income streams, and have
consulted with a member of the Legal Aid staff, but due to the nature of this case and
DEFENDANTS income, do not qualify under the Legal Aid guidelines for assistance.
Electronically Filed 07/06/2023 13:41 / MOTION / CV 23 978925 / Confirmation Nbr. 2901483 / CLDLJ
Time Constraints
3) DEFENDANTS have no choice but to work multiple jobs each to provide housing, food, etc. for
their family and work around their disabled child’s need for one of them to always be with him.
DEFENDANT Dr. Paul Wordell works full-time with a contractually required schedule of 7:30 am
to 4:00 pm as a teacher at a dropout-recovery charter high school in the inner-city of Cleveland
that operates 11 months out of the year and is still in session. He also works part-time third shift
at Amazon from 1:45 am to 6:30 am two to three nights per week. Susan Palmentera-Wordell
works part-time as a security officer for the Cleveland Guardians MLB team for every home game
as well as other events scheduled at Progressive Field and at two different restaurants as a
host/busser.
4) DEFENDANTS are not able to afford a vehicle and were recently forced to allow their truck to be
repossessed and auctioned off. DEFENDANTS are reliant on biking, walking, and taking the bus
to get to and from their jobs, adding significant extra time to their work schedules.
5) DEFENDANTS’ 13 year old special needs/gifted child who is also highly academically gifted, is
taking Honors Pre-Calculus, Honors Physics, and is in therapy three days a week, and is still in
session being schooled and treated at home through the summer with class and therapy sessions
scheduled during the week and work done at home requiring the assistance of both
parents/DEFENDANTS.
6) Along with working five jobs between them and caring for a special needs child,
parents/DEFENDANTS have an 11 year old child they lovingly care for as well.
7) DEFENDANTS are currently packing an entire house and will soon be moving to a new dwelling.
Serious and Urgent Medical Issues
8) As noted in prior documents, DEFENDANT Dr. Paul Wordell is 58 years old and has suffered
three cases of COVID-19 with long-term complications of such. This is still on-going and has
included recent Emergency Room visits and follow-up visits of heart-attack like symptoms that
Electronically Filed 07/06/2023 13:41 / MOTION / CV 23 978925 / Confirmation Nbr. 2901483 / CLDLJ
were determined to be caused primarily by stress. He is also still suffering from and being
observed by doctors for mild dementia-like symptoms believed to be attributed to having had
multiple cases of COVID-19 and are exasperated by stress. The latter symptoms will require
extra time to prepare Dr. Paul Wordell for the intense environment that court related questioning
can be as this type of questioning can be difficult for even persons not suffering such symptoms
but can be especially difficult for a witness/DEFENDANT who is.
9) As noted in prior documents, DEFENDANT Susan Palmentera-Wordell is 52 years old and was a
ticket counter/gate agent for DELTA AIR LINES when the COVID-19 pandemic began and
suffered a severe case of COVID-19 in January 2020 that spread to her entire immediate family
including DEFENDANT Dr. Paul Wordell. The “viral load" that Susan Palmentera-Wordell was
exposed to was extremely high due to her job and the fact that DELTA AIR LINES flies more
passengers back and forth to China and Italy (the countries with the two largest and most severe
outbreaks at the start of the pandemic) than any other U.S. airline, and she was dealing very
closely with thousands of these passengers a week. As mentioned in prior documents, Susan
Palmentera-Wordell fell off of a dangerous step in the PLAINTIFF'S home and broke multiple
bones, suffered a concussion, damaged both Achilles tendons, and suffered many other soft
tissue injuries, sprains, etc. This later resulted in the finding of a potentially deadly very large
acute saddle pulmonary embolism that was pressing on her heart, original origin uncertain. There
was later found a partially collapsed lung that is still not inflated, a previous heart-attack, and
other medical complications of COVID and the fall. Because of them being struck with the virus
so early on in the pandemic the family got it again before vaccines were available and then got it
a third time in October of 2022. Despite having been fully vaccinated and boosted by this time,
Susan Palmentera-WordeH's third case was so severe that she was forced to take anti-viral
medication. COVID also caused Susan Palmentera-Wordell to become a diabetic. She has
recently been seen in the ER with potential heart-attack symptoms and has recently had multiple
CT-scans indicating ongoing lung and heart issues. The issues are potentially life threatening and
are exasperated by stress. The conditions have also been recently worsened by the exposure to
the wildfire smoke in downtown Cleveland that she has been exposed to working security for the
Electronically Filed 07/06/2023 13:41 / MOTION / CV 23 978925 / Confirmation Nbr. 2901483 / CLDLJ
Cleveland Guardians. As listed in included documentation, she is currently under the care of
multiple specialists from the Cleveland Clinic and Metro Health Medical Centers for various
issues including hematology, cardiology, pulmonary, orthopedics, and endocrinology and is
scheduled for several tests in July. In addition, a recent CT scan has revealed that she has now
developed a new condition of multiple lung nodules that, because of her prior exposure to dust for
the World Trade Center while working in lower Manhattan after 9/11 puts her in a high risk
category and could require additional medical intervention including Oncology and/or surgical
intervention, which will be determined in July after additional testing.
(If the court deems necessary, more specific medical documentation can be provided to confirm
the above statements, but DEFENDANTS feel that any such documentation should be kept from
prying eyes at this point.)
Gathering and Production of Evidence and Witness List
10) As mentioned in earlier documents and the listing above, the DEFENDANTS acknowledge the
enormity of this case as it related to monetary claims as well as the potential life-long reputation
damage to them. As such, DEFENDANTS intend to produce numerous witnesses who have
relevant testimony, including many who live out of state, some who DEFENDANTS are still trying
to track down the names and contact information for, many who work in jobs of high-importance
including police officers, local government workers, doctors, current and former elected officials,
FBI agents, military personnel, attorneys, clergy, business owners, etc. as well as numerous
every-day folk who witnessed and/or have expertise relevant to this case. In addition,
DEFENDANTS must gather a large amount of documentation and photographs including cell
phone and email records from multiple parties and entities, (some which will have to be
subpoenaed) Freedom of Information Act records, Cuyahoga County Board of Election records,
and many other types of records that will take additional time to request and produce.
Electronically Filed 07/06/2023 13:41 / MOTION / CV 23 978925 / Confirmation Nbr. 2901483 / CLDLJ
In closing, DEFENDANTS recognize and respect that it is the court’s duty to complete cases in a timely
manner and, if an extension is granted, In Closing can only allow a certain amount of time for an
extension. DEFENDANTS do not dare demand of the court how much time the court feels is fair and
appropriate However, DEFENDANTS beg for as much time as the honorable court deems is, so that they
can financially prepare for the costs of subpoenas, witness fees, etc., prepare any and all documentation,
evidence, and witness lists for discovery, and be treated and recover as much as possible for the stressful
nature of any conferences, hearings, trails, etc. of what is sure to be a difficult case.
Closing Statement
DEFENDANTS graciously promise the court that after the potential allotted extension of time, they will
produce whatever witness list, documentation, and evidence for discovery they have been able to gather
and move forward either with an attorney of record, or in self-representation in order to respect the court’s
duty for case progress and completion. DEFENDANTS also graciously promise that they will use any
extension time to medically prepare themselves for the stress of the case proceedings and once the
potential allotted extension of time is over, they will, despite their medical circumstances and to all
possibility, move forward with the case process.
Signe/ /
UJi'icLUM
Sfusan Palmentera-Wordell Date
Dr. Paul Wordell Date
Electronically Filed 07/06/2023 13:41 / MOTION / CV 23 978925 / Confirmation Nbr. 2901483 / CLDLJ
Susan's Appointments
Clinic Apprt Info for CCCPC.docx v P A
References Mailings Review Picture Format
[calibri (Body)
B I U - x2
dl11 -1
xz | A^>
:= v
(U - = = 11= -
v 'a~ v | le
/V p Q
Styles Editing Dictate Editor
Aa - | A" Av
A- # - A - A ~ Lid ~ IT v -
Font 15 Paragraph 15 Styles ft Voice Editor
JUL Lab Visit JUL Procedure JUL
18 LAB LUTHERAN 20 Vascular Medicine 20
2023 Starts at 7:30 AM EDT 2023 Amve by 7:45 AM EDT 2023
Starts at 8:00 AM EDT
Spirometry
Cardtoiogy Molecular imaging Pulmonary Medicine
Arrive by 10:45 AM EDT Arrive by 11:45 AM EDT 2023 Starts at 1:30 PM EDT
EDT
PULM Lab Pulm Lab JUL PULM Lab
Pulmonary Medicine Pulmonary Medicine Pulmonary Medicine
EDT
Pulmonary Medicine
Accessibility: Investigate HFocus SB B s
Electronically Filed 07/06/2023 13:41 / MOTION / CV 23 978925 / Confirmation Nbr. 2901483 / CLDLJ
Susan's Appointments
Q AutoSave (j0 Off) [3 ^3? v O Cleveland Clinic Apprt Info for CCCPC.docx v fl A Susan Palmentera
[ C3 Comments ] [
File Home Insert Draw Design Layout References Mailings Review View Help Picture Format
[calibri (Body)
p ~l »-- V — - lg- v
A/ p
Paste “
b
A "
i y v
- A " Aa
x2
-
/ |A>
A'- A”
s®- - = | 1= V
ii -|zl| IT
Styles
v
/
Editing
v
Dictate
-
Editor
Clipboard N Font rsi Paragraph Styles ISi Voice Editor
n Last 3 Months
MAY Emergency Department
21 Lutheran Emergency Department
2023
View notes
View After Visit Summary®
3 Months Ago
JAN Emergency Department
Q Fairview Hospital Emergency Dept
2023
View notes
o
Page 1 of 1 0 words QJ Text Predictions: Off Accessibility: Investigate Hfocus 80S
Electronically Filed 07/06/2023 13:41 / MOTION / CV 23 978925 / Confirmation Nbr. 2901483 / CLDLJ
Paul's Appointments
MyChart - Appointments and Visits X +
c O ft https://mychart.clevelandclinic.org/Visits Q ☆ *
o paulie loves u
[j MyClevelandClinic | MyChart MyChart
b>Epic
Last 3 Months
MAY Office Visit APR Emergency Department
4 Miguel A Melendez Vitali 20 Lutheran Emergency Department
2023 |nterna| Medicine 2023
View notes View notes
||] View After Visit Summary® View After Visit Summary®
6 Months Ago
DEC Emergency Department e
25 MetroHealth Emergency Medicine
2022
View notes
|§f| View After Visit Summary®
1 Year Ago
Electronically Filed 07/06/2023 13:41 / MOTION / CV 23 978925 / Confirmation Nbr. 2901483 / CLDLJ
Preview
Motion No. 5101753 NAILAH K. BYRD CUYAHOGA COUNTY CLERK OF COURTS 1200 Ontario Street Cleveland, Ohio 44113 Court of Common Pleas MOTION FOR EXTENSION OF TIME July 6,2023 13:41 Confirmation Nbr. 2901483 MELISSA SVIGELJ CV 23 978925 vs. Judge: NANCY A. FUERST SUSAN PALMENTERA-WORDELL ET AL Pages Filed: 10 Electronically Filed 07/06/2023 13:41 / MOTION / CV 23 978925 / Confirmation Nbr. 2901483 / CLDLJ IN THE COURT OF COMMON PLEAS CUYAHOGA COUNTY, OHIO Susan Pafmentera-Wordell Case No.: CV-23-978925 Dr. Paul Worded Defendants, Judge Nancy A. Fuerst -vs- Melissa Svigelj Plaintiff. DEFENDANTS' REQUEST FOR EXTENSION FOR UPCOMING TELEPHONE CONF. SCHEDULED FOR JULY 13, 2023 CONFERENCE DEFENDANTS ARE REFERRING TO IN THIS REQUEST FOR EXTENSION IS CITED IN DOCKET AS FOLLOWS, "CMC BY PHONE SET FOR 07/13/2023 AT 10:00 AM. PLAINTIFF'S COUNSEL SHALL INITIATE CONFERENCE CALL AND CONTACT THE COURT AT 216-443-5963. PARTIES SHALL BE PREPARED TO DISCUSS DISCOVERY AND SCHEDULING MATTERS.” Introductory Statement DEFENDANTS understand and respect that to the benefit of timely court scheduling and the best interest of county and court employees and officials, as well as the citizenship of the county, extensions on case timelines are granted only under extreme circumstances and are at the mercy and privilege of the court, therefore, DEFENDANTS have taken great effort to list and explain the important reasons why this request has been made. DEFENDANTS’ reasons fall into multiple categories including financial constraints, time Electronically Filed 07/06/2023 13:41 / MOTION / CV 23 978925 / Confirmation Nbr. 2901483 / CLDLJ constraints, lack of ability to secure legal representation, and serious and urgent medical issues, as well as the extensive list of witnesses and multiple categories and volume of evidence the DEFENDANTS intend to eventually produce in this matter. DEFENDANTS REQUEST EXTENSION FOR FOLLOWING REASONS: Financial Circumstances: 1) Despite efforts to do so, including phone and in person meetings with attorneys, DEFENDANTS have yet to find an attorney willing to take this case. DEFENDANTS’ trusted personal friend and attorney, Joseph B. Jerome, whom has represented DEFENDANT Susan Palmentera-Wordell in any and all personal and business matters for almost 30 years sadly and unexpectedly passed away during the later part of the COVID-19 pandemic, leaving DEFENDANTS without easily obtainable representation in such a complicated case as this. After conferencing with multiple attorneys, DEFENDANTS are certain that the political nature of this case is causing issues for them in securing representation, but they are still trying. 2) DEFENDANTS severely restrained financial circumstances and inability to pay for an attorney causes them to have to try to find an attorney that will represent them on contingency. Their severely restrained financial circumstances are affected by various extenuating circumstances including the following: a) DEFENDANTS lack of income during most of COVID-19 pandemic (medical complications forced them to keep their children home for three school years to protect child too young to be vaccinated who had a heart issue as well another fully disabled child with multiple disabilities) b) Overall lack of income due to inability for both parents to work full-time and lack of childcare assistance possible due to special needs child's sometimes extreme symptoms requiring only the parents to care for him. c) Parents’ constant battle with school districts in educating their extremely academically gifted and autistic child and schools not handling child properly often causing child to be out of school and schooled from home for months at a time even before and after the pandemic. Electronically Filed 07/06/2023 13:41 / MOTION / CV 23 978925 / Confirmation Nbr. 2901483 / CLDLJ d) DEFENDANTS’ credit is being seriously damaged by these financial issues as well as student loan debt of hundreds of thousands of dollars. e) DEFENDANTS’ credit and extreme symptoms of special needs child’s causing them to be part of the rising number of “working homeless” families who live in Air B and Bs, hotels, etc. This is such that the school district the children attend has certified that the children are protected by the McKinney-Vento Homelessness Assistance Act and manages the children’s enrollment, school transportation, and academics as such. The extreme costs of these dwellings, which are always significantly higher than normal housing expenses, have rendered the DEFENDANTS unable to pay for an attorney despite having income. In addition and worth noting is the fact that the nature of this case and accusations made by PLAINTIFF are further interfering with the DEFENDANTS’ ability to secure long-term housing for their family. f) Dr. Paul Wordell’s less than desirable charter schoolteacher’s salary and Susan Palmentera- Wordell’s low hourly wage and tip wages at her part-time jobs makes financial matters even more strained. g) DEFENDANTS’ necessity to secure housing and move often from one Air B and B, hotel, etc. every few months to another including them being forced to secure and move to and get family settled into a new dwelling in the next couple of weeks. h) PLAINTIFF'S recent filing changing the amount of the damages from $6,000 to an unprecedented and significantly higher amount of $50,000 and the enormity of the personal, social, parental, familial, and professional damage that the outcome of this case is having and will have for a lifetime for the DEFENDANTS has made the DEFENDANTS having skilled and knowledgeable attorney a much more pressing matter than even before. DEFENDANTS beg the court allows them more time to do so. i) Please note: DEFENDANTS work hard and have multiple jobs and income streams, and have consulted with a member of the Legal Aid staff, but due to the nature of this case and DEFENDANTS income, do not qualify under the Legal Aid guidelines for assistance. Electronically Filed 07/06/2023 13:41 / MOTION / CV 23 978925 / Confirmation Nbr. 2901483 / CLDLJ Time Constraints 3) DEFENDANTS have no choice but to work multiple jobs each to provide housing, food, etc. for their family and work around their disabled child’s need for one of them to always be with him. DEFENDANT Dr. Paul Wordell works full-time with a contractually required schedule of 7:30 am to 4:00 pm as a teacher at a dropout-recovery charter high school in the inner-city of Cleveland that operates 11 months out of the year and is still in session. He also works part-time third shift at Amazon from 1:45 am to 6:30 am two to three nights per week. Susan Palmentera-Wordell works part-time as a security officer for the Cleveland Guardians MLB team for every home game as well as other events scheduled at Progressive Field and at two different restaurants as a host/busser. 4) DEFENDANTS are not able to afford a vehicle and were recently forced to allow their truck to be repossessed and auctioned off. DEFENDANTS are reliant on biking, walking, and taking the bus to get to and from their jobs, adding significant extra time to their work schedules. 5) DEFENDANTS’ 13 year old special needs/gifted child who is also highly academically gifted, is taking Honors Pre-Calculus, Honors Physics, and is in therapy three days a week, and is still in session being schooled and treated at home through the summer with class and therapy sessions scheduled during the week and work done at home requiring the assistance of both parents/DEFENDANTS. 6) Along with working five jobs between them and caring for a special needs child, parents/DEFENDANTS have an 11 year old child they lovingly care for as well. 7) DEFENDANTS are currently packing an entire house and will soon be moving to a new dwelling. Serious and Urgent Medical Issues 8) As noted in prior documents, DEFENDANT Dr. Paul Wordell is 58 years old and has suffered three cases of COVID-19 with long-term complications of such. This is still on-going and has included recent Emergency Room visits and follow-up visits of heart-attack like symptoms that Electronically Filed 07/06/2023 13:41 / MOTION / CV 23 978925 / Confirmation Nbr. 2901483 / CLDLJ were determined to be caused primarily by stress. He is also still suffering from and being observed by doctors for mild dementia-like symptoms believed to be attributed to having had multiple cases of COVID-19 and are exasperated by stress. The latter symptoms will require extra time to prepare Dr. Paul Wordell for the intense environment that court related questioning can be as this type of questioning can be difficult for even persons not suffering such symptoms but can be especially difficult for a witness/DEFENDANT who is. 9) As noted in prior documents, DEFENDANT Susan Palmentera-Wordell is 52 years old and was a ticket counter/gate agent for DELTA AIR LINES when the COVID-19 pandemic began and suffered a severe case of COVID-19 in January 2020 that spread to her entire immediate family including DEFENDANT Dr. Paul Wordell. The “viral load" that Susan Palmentera-Wordell was exposed to was extremely high due to her job and the fact that DELTA AIR LINES flies more passengers back and forth to China and Italy (the countries with the two largest and most severe outbreaks at the start of the pandemic) than any other U.S. airline, and she was dealing very closely with thousands of these passengers a week. As mentioned in prior documents, Susan Palmentera-Wordell fell off of a dangerous step in the PLAINTIFF'S home and broke multiple bones, suffered a concussion, damaged both Achilles tendons, and suffered many other soft tissue injuries, sprains, etc. This later resulted in the finding of a potentially deadly very large acute saddle pulmonary embolism that was pressing on her heart, original origin uncertain. There was later found a partially collapsed lung that is still not inflated, a previous heart-attack, and other medical complications of COVID and the fall. Because of them being struck with the virus so early on in the pandemic the family got it again before vaccines were available and then got it a third time in October of 2022. Despite having been fully vaccinated and boosted by this time, Susan Palmentera-WordeH's third case was so severe that she was forced to take anti-viral medication. COVID also caused Susan Palmentera-Wordell to become a diabetic. She has recently been seen in the ER with potential heart-attack symptoms and has recently had multiple CT-scans indicating ongoing lung and heart issues. The issues are potentially life threatening and are exasperated by stress. The conditions have also been recently worsened by the exposure to the wildfire smoke in downtown Cleveland that she has been exposed to working security for the Electronically Filed 07/06/2023 13:41 / MOTION / CV 23 978925 / Confirmation Nbr. 2901483 / CLDLJ Cleveland Guardians. As listed in included documentation, she is currently under the care of multiple specialists from the Cleveland Clinic and Metro Health Medical Centers for various issues including hematology, cardiology, pulmonary, orthopedics, and endocrinology and is scheduled for several tests in July. In addition, a recent CT scan has revealed that she has now developed a new condition of multiple lung nodules that, because of her prior exposure to dust for the World Trade Center while working in lower Manhattan after 9/11 puts her in a high risk category and could require additional medical intervention including Oncology and/or surgical intervention, which will be determined in July after additional testing. (If the court deems necessary, more specific medical documentation can be provided to confirm the above statements, but DEFENDANTS feel that any such documentation should be kept from prying eyes at this point.) Gathering and Production of Evidence and Witness List 10) As mentioned in earlier documents and the listing above, the DEFENDANTS acknowledge the enormity of this case as it related to monetary claims as well as the potential life-long reputation damage to them. As such, DEFENDANTS intend to produce numerous witnesses who have relevant testimony, including many who live out of state, some who DEFENDANTS are still trying to track down the names and contact information for, many who work in jobs of high-importance including police officers, local government workers, doctors, current and former elected officials, FBI agents, military personnel, attorneys, clergy, business owners, etc. as well as numerous every-day folk who witnessed and/or have expertise relevant to this case. In addition, DEFENDANTS must gather a large amount of documentation and photographs including cell phone and email records from multiple parties and entities, (some which will have to be subpoenaed) Freedom of Information Act records, Cuyahoga County Board of Election records, and many other types of records that will take additional time to request and produce. Electronically Filed 07/06/2023 13:41 / MOTION / CV 23 978925 / Confirmation Nbr. 2901483 / CLDLJ In closing, DEFENDANTS recognize and respect that it is the court’s duty to complete cases in a timely manner and, if an extension is granted, In Closing can only allow a certain amount of time for an extension. DEFENDANTS do not dare demand of the court how much time the court feels is fair and appropriate However, DEFENDANTS beg for as much time as the honorable court deems is, so that they can financially prepare for the costs of subpoenas, witness fees, etc., prepare any and all documentation, evidence, and witness lists for discovery, and be treated and recover as much as possible for the stressful nature of any conferences, hearings, trails, etc. of what is sure to be a difficult case. Closing Statement DEFENDANTS graciously promise the court that after the potential allotted extension of time, they will produce whatever witness list, documentation, and evidence for discovery they have been able to gather and move forward either with an attorney of record, or in self-representation in order to respect the court’s duty for case progress and completion. DEFENDANTS also graciously promise that they will use any extension time to medically prepare themselves for the stress of the case proceedings and once the potential allotted extension of time is over, they will, despite their medical circumstances and to all possibility, move forward with the case process. Signe/ / UJi'icLUM Sfusan Palmentera-Wordell Date Dr. Paul Wordell Date Electronically Filed 07/06/2023 13:41 / MOTION / CV 23 978925 / Confirmation Nbr. 2901483 / CLDLJ Susan's Appointments Clinic Apprt Info for CCCPC.docx v P A References Mailings Review Picture Format [calibri (Body) B I U - x2 dl11 -1 xz | A^> := v (U - = = 11= - v 'a~ v | le /V p Q Styles Editing Dictate Editor Aa - | A" Av A- # - A - A ~ Lid ~ IT v - Font 15 Paragraph 15 Styles ft Voice Editor JUL Lab Visit JUL Procedure JUL 18 LAB LUTHERAN 20 Vascular Medicine 20 2023 Starts at 7:30 AM EDT 2023 Amve by 7:45 AM EDT 2023 Starts at 8:00 AM EDT Spirometry Cardtoiogy Molecular imaging Pulmonary Medicine Arrive by 10:45 AM EDT Arrive by 11:45 AM EDT 2023 Starts at 1:30 PM EDT EDT PULM Lab Pulm Lab JUL PULM Lab Pulmonary Medicine Pulmonary Medicine Pulmonary Medicine EDT Pulmonary Medicine Accessibility: Investigate HFocus SB B s Electronically Filed 07/06/2023 13:41 / MOTION / CV 23 978925 / Confirmation Nbr. 2901483 / CLDLJ Susan's Appointments Q AutoSave (j0 Off) [3 ^3? v O Cleveland Clinic Apprt Info for CCCPC.docx v fl A Susan Palmentera [ C3 Comments ] [ File Home Insert Draw Design Layout References Mailings Review View Help Picture Format [calibri (Body) p ~l »-- V — - lg- v A/ p Paste “ b A " i y v - A " Aa x2 - / |A> A'- A” s®- - = | 1= V ii -|zl| IT Styles v / Editing v Dictate - Editor Clipboard N Font rsi Paragraph Styles ISi Voice Editor n Last 3 Months MAY Emergency Department 21 Lutheran Emergency Department 2023 View notes View After Visit Summary® 3 Months Ago JAN Emergency Department Q Fairview Hospital Emergency Dept 2023 View notes o Page 1 of 1 0 words QJ Text Predictions: Off Accessibility: Investigate Hfocus 80S Electronically Filed 07/06/2023 13:41 / MOTION / CV 23 978925 / Confirmation Nbr. 2901483 / CLDLJ Paul's Appointments MyChart - Appointments and Visits X + c O ft https://mychart.clevelandclinic.org/Visits Q ☆ * o paulie loves u [j MyClevelandClinic | MyChart MyChart b>Epic Last 3 Months MAY Office Visit APR Emergency Department 4 Miguel A Melendez Vitali 20 Lutheran Emergency Department 2023 |nterna| Medicine 2023 View notes View notes ||] View After Visit Summary® View After Visit Summary® 6 Months Ago DEC Emergency Department e 25 MetroHealth Emergency Medicine 2022 View notes |§f| View After Visit Summary® 1 Year Ago Electronically Filed 07/06/2023 13:41 / MOTION / CV 23 978925 / Confirmation Nbr. 2901483 / CLDLJ