On February 17, 2023 a
MOTION FOR EXTENSION OF TIME EJB V NR PLAINTIFFS APPELLANTS MOTION FOR LEAVE TO FILE ASSIGNMENTS OF ERROR AND BRIEF PDF 04/12/2023 - UNKNOWN - MO
was filed
involving a dispute between
Edward Biesiada,
and
City Of North Royalton Board Of Zoning Appeals Ian Russell, Secretary,
City Of North Royalton Mayor,
for ADMIN. APPEALS OTHER
in the District Court of Cuyahoga County.
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Motion No. 5082685
NAILAH K. BYRD
CUYAHOGA COUNTY CLERK OF COURTS
1200 Ontario Street
Cleveland, Ohio 44113
Court of Common Pleas
MOTION FOR EXTENSION OF TIME
April 11,2023 18:18
Confirmation Nbr. 2827381
EDWARD BIESIADA CV 23 975442
vs.
Judge: SHIRLEY STRICKLAND SAFFOED
CITY OF NORTH ROYALTON MAYOR FT AE
Pages Filed: 2
Electronically Filed 04/11/2023 18:18 / MOTION / CV 23 975442 / Confirmation Nbr. 2827381 /CLJSZ
IN THE COURT OF COMMON PLEAS
CUYAHOGA COUNTY. OHIO
EDWARD BIESIADA CASE NO. CV 23 975442
Plaintiff/Appellant, JUDGE SHIRLEY STRICKLAND
SAFFOLD
vs.
PLAINTIFF’S/APPELLANT’S
CITY OF NORTH ROYALTON
MOTION FOR LEAVE TO FILE
MAYOR, et al.,
ASSIGNMENTS OF ERROR AND
BRIEF
Defendants/Appellees.
NOW COMES Plaintiff/Appellant, Edward Biesiada (referred to herein as
“Plaintiff/Appellant”), and hereby moves this Court for an Order granting said Plaintiff/Appellant
a thirty-five (35) day leave to file his Assignments of Error and Brief until on or before Monday,
May 15, 2023. As grounds for this request, Plaintiff/Appellant states that he is currently in the
heaviest period of tax season and due to three taxpayers’ statute of limitations deadlines on top of
the normal April 18, 2023 federal, state, and city tax return deadlines, along with having to
accompany his 89-year-old mother to her oral surgery appointment on April 18, 2023, and due to
payroll tax filing deadline of April 30, 2023, he cannot adequately prepare the response until on or
before May 15, 2023.
Further the Plaintiff/Appellant states that the drafting of the Assignment of Errors and Brief
is in process and has not been left to stagnate. The granting of this request will not unduly delay
these proceedings or cause prejudice to any party hereto.
Electronically Filed 04/11/2023 18:18 / MOTION / CV 23 975442 / Confirmation Nbr. 2827381 / CLJSZ
WHEREFORE, Plaintiff/Appellant respectfully requests that this Honorable Court grant an
extension of time within to file his Assignment of Error and Brief to on or before May 15, 2023.
Respectfully submitted,
Edward Biesiada______
EDWARD BIESIADA
Plaintiff/Appellant
12733 Patricia Drive
North Royalton, OH 44133
(440) 477-6099
Email: tnsejb@tnsejb.com
PROOF OF SERVICE
A copy of the foregoing Plaintiffs/Appellant’s Motion for Leave to File Assignments of
Error and Brief was served via email and hand-delivery on April 11, 2023, on:
Thomas A. Kelly (OSC#10355)
Law Director
Donna M. Vozar ()SC #0058620)
Assistant Law Director
14600 State Road
North Royalton, OH 44133
tkelly@northroyalton.org
dvozar@northroyalton.org
Attorney for Defendants/Appellees
Edward Biesiada
EDWARD BIESIADA
Plaintiff/Appellant
tnsejb@tnsejb.com
Electronically Filed 04/11/2023 18:18 / MOTION / CV 23 975442 / Confirmation Nbr. 2827381 / CLJSZ
Document Filed Date
April 11, 2023
Case Filing Date
February 17, 2023
Category
ADMIN. APPEALS OTHER
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Motion No. 5082685 NAILAH K. BYRD CUYAHOGA COUNTY CLERK OF COURTS 1200 Ontario Street Cleveland, Ohio 44113 Court of Common Pleas MOTION FOR EXTENSION OF TIME April 11,2023 18:18 Confirmation Nbr. 2827381 EDWARD BIESIADA CV 23 975442 vs. Judge: SHIRLEY STRICKLAND SAFFOED CITY OF NORTH ROYALTON MAYOR FT AE Pages Filed: 2 Electronically Filed 04/11/2023 18:18 / MOTION / CV 23 975442 / Confirmation Nbr. 2827381 /CLJSZ IN THE COURT OF COMMON PLEAS CUYAHOGA COUNTY. OHIO EDWARD BIESIADA CASE NO. CV 23 975442 Plaintiff/Appellant, JUDGE SHIRLEY STRICKLAND SAFFOLD vs. PLAINTIFF’S/APPELLANT’S CITY OF NORTH ROYALTON MOTION FOR LEAVE TO FILE MAYOR, et al., ASSIGNMENTS OF ERROR AND BRIEF Defendants/Appellees. NOW COMES Plaintiff/Appellant, Edward Biesiada (referred to herein as “Plaintiff/Appellant”), and hereby moves this Court for an Order granting said Plaintiff/Appellant a thirty-five (35) day leave to file his Assignments of Error and Brief until on or before Monday, May 15, 2023. As grounds for this request, Plaintiff/Appellant states that he is currently in the heaviest period of tax season and due to three taxpayers’ statute of limitations deadlines on top of the normal April 18, 2023 federal, state, and city tax return deadlines, along with having to accompany his 89-year-old mother to her oral surgery appointment on April 18, 2023, and due to payroll tax filing deadline of April 30, 2023, he cannot adequately prepare the response until on or before May 15, 2023. Further the Plaintiff/Appellant states that the drafting of the Assignment of Errors and Brief is in process and has not been left to stagnate. The granting of this request will not unduly delay these proceedings or cause prejudice to any party hereto. Electronically Filed 04/11/2023 18:18 / MOTION / CV 23 975442 / Confirmation Nbr. 2827381 / CLJSZ WHEREFORE, Plaintiff/Appellant respectfully requests that this Honorable Court grant an extension of time within to file his Assignment of Error and Brief to on or before May 15, 2023. Respectfully submitted, Edward Biesiada______ EDWARD BIESIADA Plaintiff/Appellant 12733 Patricia Drive North Royalton, OH 44133 (440) 477-6099 Email: tnsejb@tnsejb.com PROOF OF SERVICE A copy of the foregoing Plaintiffs/Appellant’s Motion for Leave to File Assignments of Error and Brief was served via email and hand-delivery on April 11, 2023, on: Thomas A. Kelly (OSC#10355) Law Director Donna M. Vozar ()SC #0058620) Assistant Law Director 14600 State Road North Royalton, OH 44133 tkelly@northroyalton.org dvozar@northroyalton.org Attorney for Defendants/Appellees Edward Biesiada EDWARD BIESIADA Plaintiff/Appellant tnsejb@tnsejb.com Electronically Filed 04/11/2023 18:18 / MOTION / CV 23 975442 / Confirmation Nbr. 2827381 / CLJSZ