On January 01, 2023 a
Party Discovery
was filed
involving a dispute between
Andrew Harbaugh,
and
Emergency Professional Services, Inc. Corporation Service Company, Statutory Agent,
Julie Aljabi,
Southwest General,
Southwest General Health Center Susan Scheutzow, Statutory Agent,
Southwest General Medical Group, Inc. Susan Scheutzow, Statutory Agent,
Tushar Shah Md,
University Hospitals Health System, Inc. Acfb Incorporated, Statutory Agent,
University Hospitals Medical Group, Inc. Acfb Incorporated, Statutory Agent,
for TORT-MEDICAL MALPRACTICE
in the District Court of Cuyahoga County.
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156080779
56080779
IN THE COL RT OF COMMON PLEAS
I" cijyXhoga COUNTY, OHIO
SugTBAUGHM8Ez'?,°^ 23 Case No: CV-23-975038
Plaintiff CLERK OF COURTS Judge: SHIRLEY STRICKLAND SAFFOLD
CUYAHOGA COUNTY
SOUTHWEST GENERAL, ET AL.
Defendant
JOURNAL ENTRY
08/22/23: THE PARTIES DO NOT AGREE AS TO WHICH PARTY HAS THE RIGHT TO LEAD THE DEPOSITIONS OF
DEFENDANT SHAH AND DEFENDANT ALJABI. PLAINTIFF SEEKS CLARIFICATION FROM THE COURT. PLAINTIFF
SEEKS TO CONDUCT DISCOVERY DEPOSITIONS OF TWO INDIVIDUALLY NAMED DEFENDANTS, SHAH AND
ALJABI. PLAINTIFF INITIALLY REQUESTED DEPOSITION DATES FROM DEFENSE COUNSEL. AFTER THE PARTIES
WERE UNABLE TO COORDINATE DATES, PLAINTIFF NOTICED BOTH DEPOSITIONS. PLAINTIFF CONTACTED THE
COURT REQUESTING A STATUS CONFERENCE TO DISCUSS SETTING DEPOSITIONS. AFTER THE STATUS
CONFERENCE AND PURSUANT TO COURT ORDER, THE PARTIES EXCHANGED DATES. THEREAFTER, DEFENDANT
ALJABI NOTICED THE DEPOSITION OF DEFENDANT SHAH AND DEFENDANT SHAH NOTICED THE DEPOSITION OF
DEFENDANT ALJABI.
GIVEN THE RECORD FACTS, IT IS ORDERED, ADJUDGED, AND DECREED THAT:
(1) THE DEPOSITION OF DEFENDANT SHAH SHALL PROCEED ON 08/24/23 AT 10:00AM AT THE LAW OFFICES OF
REMINGER, CO., LPA;
(2) THE DEPOSITION OF DEFENDANT ALJABI SHALL PROCEED ON 08/28/23 AT 10:00AM AT THE LAW OFFICES OF
BONEZZI SWITZER POLITO & PERRY CO. LPA;
(3) THE PARTIES ARE FREE TO CHANGE THE START TIME OR LOCATION OF THE DEPOSITIONS IF THEY ARE ALL
IN AGREEMENT;
(4) PLAINTIFF WILL "TAKE THE LEAD" ON THE DEPOSITIONS OF DEFENDANT SHAH AND DEFENDANT ALJABI.
THIS MEANS THAT PLAINTIFF WILL BE THE FIRST PARTY TO ASK QUESTIONS OF THE DEPONENT; AND
(5) AFTER PLAINTIFF FINISHES QUESTIONING THE DEPONENT, DEFENSE COUNSEL CAN CONDUCT THEIR
EXAMINATION.
PARTIES ARE REMINDED THAT THEY ARE TO WORK COLLABORATIVELY IN RESOLVING ALL DISCOVERY
DISPUTES PRIOR TO REQUESTING COURT INTERVENTION. COUNSEL IS ALSO REMINDED THAT THEY ARE TO
ABIDE BY ALL OHIO CIVIL RULES, LOCAL RULES, AND RULES OF PROFESSIONAL CONDUCT IN THEIR
INTERACTIONS WITH ONE ANOTHER AND THE COURT. THE PARTIES ARE TO CONTACT THE STAFF ATTORNEY AT
216-443-8615 FOR ANY ISSUES THAT ARISE DURING THE ABOVE-REFERENCED DEPOSITIONS. ANY FAILURE TO
COMPLY WITH ANY PART OF THIS ORDER WILL BE APPROPRIATELY SANCTIONED PURSUANT
TO CIV.R. 37, AND MAY RESULT IN THE IMPOSITION OF ANY ONE OR MORE OF THE SANCTIONS, UP TO AND
INCLUDING EVIDENTIARY AND DISPOSITIVE SANCTIONS, ENUMERATED UNDER CTV.R. 37(B)(1)(A) THROUGH (G).
IT IS SO ORDERED.
______
Judge Signature/ \ Date
08/22/2023
MS
Page 1 of 1
Document Filed Date
August 22, 2023
Case Filing Date
January 01, 2023
Category
TORT-MEDICAL MALPRACTICE
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156080779 56080779 IN THE COL RT OF COMMON PLEAS I" cijyXhoga COUNTY, OHIO SugTBAUGHM8Ez'?,°^ 23 Case No: CV-23-975038 Plaintiff CLERK OF COURTS Judge: SHIRLEY STRICKLAND SAFFOLD CUYAHOGA COUNTY SOUTHWEST GENERAL, ET AL. Defendant JOURNAL ENTRY 08/22/23: THE PARTIES DO NOT AGREE AS TO WHICH PARTY HAS THE RIGHT TO LEAD THE DEPOSITIONS OF DEFENDANT SHAH AND DEFENDANT ALJABI. PLAINTIFF SEEKS CLARIFICATION FROM THE COURT. PLAINTIFF SEEKS TO CONDUCT DISCOVERY DEPOSITIONS OF TWO INDIVIDUALLY NAMED DEFENDANTS, SHAH AND ALJABI. PLAINTIFF INITIALLY REQUESTED DEPOSITION DATES FROM DEFENSE COUNSEL. AFTER THE PARTIES WERE UNABLE TO COORDINATE DATES, PLAINTIFF NOTICED BOTH DEPOSITIONS. PLAINTIFF CONTACTED THE COURT REQUESTING A STATUS CONFERENCE TO DISCUSS SETTING DEPOSITIONS. AFTER THE STATUS CONFERENCE AND PURSUANT TO COURT ORDER, THE PARTIES EXCHANGED DATES. THEREAFTER, DEFENDANT ALJABI NOTICED THE DEPOSITION OF DEFENDANT SHAH AND DEFENDANT SHAH NOTICED THE DEPOSITION OF DEFENDANT ALJABI. GIVEN THE RECORD FACTS, IT IS ORDERED, ADJUDGED, AND DECREED THAT: (1) THE DEPOSITION OF DEFENDANT SHAH SHALL PROCEED ON 08/24/23 AT 10:00AM AT THE LAW OFFICES OF REMINGER, CO., LPA; (2) THE DEPOSITION OF DEFENDANT ALJABI SHALL PROCEED ON 08/28/23 AT 10:00AM AT THE LAW OFFICES OF BONEZZI SWITZER POLITO & PERRY CO. LPA; (3) THE PARTIES ARE FREE TO CHANGE THE START TIME OR LOCATION OF THE DEPOSITIONS IF THEY ARE ALL IN AGREEMENT; (4) PLAINTIFF WILL "TAKE THE LEAD" ON THE DEPOSITIONS OF DEFENDANT SHAH AND DEFENDANT ALJABI. THIS MEANS THAT PLAINTIFF WILL BE THE FIRST PARTY TO ASK QUESTIONS OF THE DEPONENT; AND (5) AFTER PLAINTIFF FINISHES QUESTIONING THE DEPONENT, DEFENSE COUNSEL CAN CONDUCT THEIR EXAMINATION. PARTIES ARE REMINDED THAT THEY ARE TO WORK COLLABORATIVELY IN RESOLVING ALL DISCOVERY DISPUTES PRIOR TO REQUESTING COURT INTERVENTION. COUNSEL IS ALSO REMINDED THAT THEY ARE TO ABIDE BY ALL OHIO CIVIL RULES, LOCAL RULES, AND RULES OF PROFESSIONAL CONDUCT IN THEIR INTERACTIONS WITH ONE ANOTHER AND THE COURT. THE PARTIES ARE TO CONTACT THE STAFF ATTORNEY AT 216-443-8615 FOR ANY ISSUES THAT ARISE DURING THE ABOVE-REFERENCED DEPOSITIONS. ANY FAILURE TO COMPLY WITH ANY PART OF THIS ORDER WILL BE APPROPRIATELY SANCTIONED PURSUANT TO CIV.R. 37, AND MAY RESULT IN THE IMPOSITION OF ANY ONE OR MORE OF THE SANCTIONS, UP TO AND INCLUDING EVIDENTIARY AND DISPOSITIVE SANCTIONS, ENUMERATED UNDER CTV.R. 37(B)(1)(A) THROUGH (G). IT IS SO ORDERED. ______ Judge Signature/ \ Date 08/22/2023 MS Page 1 of 1