On December 13, 2021 a
DISCLOSURE OF WITNESSES - INITITAL WITNESS DISCLOSURE OF WITNESSES Attorney: STAHLER, CLINTON P (0092560)
was filed
involving a dispute between
Delaware County Board Of Commissioners,
and
Heinlen, Daniel L,
Heinlen, Gelene V,
Huntington National Bank,
for (CV) CIVIL COMMON PLEAS
in the District Court of Delaware County.
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IN THE COURT OF COMMON PLEAS, DELAWARE COUNTY, OHIO
Delaware County Board of Commissioners, Case No. 21CVH120557
Plaintiff, Judge James P. Schuck
INITIAL WITNESS DISCLOSURE OF
Daniel L. Heinlen, et al., DEFENDANTS
Defendants.
NOW COME Defendants, Daniel L. Heinlen and Gelene V. Heinlen (hereinafter
“Defendants”) and pursuant to Civ. R. 26(B)(3), Civ. R. 26(B)(7) and the Clerk’s Scheduling Order
filed December 14, 2021, hereby make the following witness disclosures:
I Expert Witnesses Expected to Testify:
A Defendants identify the following expert witnesses expected to testify at trial:
1 Patty Costello
Specialty Valuation Group
425 Metro Place North, 620
Dublin, Ohio 43017
(614) 203-2371
pattycostello@yahoo.com
Ms. Costello is a licensed appraiser in the State of Ohio and has been hired by Defendants to testify
in this case as an expert witness regarding the fair market value of the Subject Property and the part taken
and any damages to the residue, which together constitute the just compensation the Defendants are due
for Plaintiff's taking of their property. Ms. Costello’s opinions will be as set forth in her appraisal report,
which will be provided to Plaintiff upon completion.
CLERK OF COURTS - DELAWARE COUNTY, OH - COMMON PLEAS COURT
21 CV H 12 0557 - SCHUCK, JAMES P.
FILED: 04/26/2022 11:47 AM
2 Defendants reserve the right to supplement this list with any and all
officials from Delaware County who have relevant knowledge and information
pertaining to this lawsuit.
3 Defendants further reserve the right to (1) supplement this list with
additional expert witnesses, if necessary, and (2) call any of Plaintiff's witnesses, as if
upon cross-examination, and (3) call additional expert witnesses on rebuttal, without
prior notification.
I. Lay Witnesses Expected to Testify:
A Defendants identify the following lay witnesses expected to testify at trial:
1 Daniel L. Heinlen
Gelene V. Heinlen
2981 East Powell Road
Lewis Center, Ohio 43035
Mr. and Mrs. Heinlen are the owners of the Subject Property and will testify as to their knowledge
of the history of the Subject Property.
2 Defendants reserve the right to supplement this list with any and all
officials from Delaware County who have relevant knowledge and information
pertaining to this lawsuit.
3 Defendants further reserve the right to (1) supplement this list with
additional lay witnesses, if necessary, and (2) call any of Plaintiff’s witnesses, as if upon
cross-examination, and (3) call additional lay witnesses on rebuttal, without prior
notification.
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Respectfully submitted,
/s/ Clinton P. Stahler
Clinton P. Stahler (0092560)
Stahler@GBSKlaw.com
Aaron E. Kenter (0092264)
Kenter@GBSKlaw.com
Goldman Braunstein Stahler Kenter LLP
500 South Front Street, Suite 1200
Columbus, OH 43215
(614) 229-4566/Telephone
(614) 229-4568/Facsimile
Attorneys for Defendants
Daniel L. Heinlen and Gelene V. Heinlen.
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CERTIFICATE OF SERVICE
Thereby certify that on April 26, 2022, the foregoing was served on the following via
electronic mail or regular mail:
Aric I. Hochstettler
Staff Attorney
Delaware County Board of Commissioners
91 North Sandusky Street, First Floor
P.O. Box 8006
Delaware, OH 43015
AHochstettler@co.delaware.oh.us
Counsel for Plaintiff
Huntington National Bank
Department NC1N04
2351 Morse Road
Columbus, OH 43229
Defendant
/s/ Clinton P. Stahler
Clinton P. Stahler (0092560)
Attorney for Defendants
Daniel L. Heinlen and Gelene V. Heinlen
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Document Filed Date
April 26, 2022
Case Filing Date
December 13, 2021
Category
(CV) CIVIL COMMON PLEAS
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IN THE COURT OF COMMON PLEAS, DELAWARE COUNTY, OHIO Delaware County Board of Commissioners, Case No. 21CVH120557 Plaintiff, Judge James P. Schuck INITIAL WITNESS DISCLOSURE OF Daniel L. Heinlen, et al., DEFENDANTS Defendants. NOW COME Defendants, Daniel L. Heinlen and Gelene V. Heinlen (hereinafter “Defendants”) and pursuant to Civ. R. 26(B)(3), Civ. R. 26(B)(7) and the Clerk’s Scheduling Order filed December 14, 2021, hereby make the following witness disclosures: I Expert Witnesses Expected to Testify: A Defendants identify the following expert witnesses expected to testify at trial: 1 Patty Costello Specialty Valuation Group 425 Metro Place North, 620 Dublin, Ohio 43017 (614) 203-2371 pattycostello@yahoo.com Ms. Costello is a licensed appraiser in the State of Ohio and has been hired by Defendants to testify in this case as an expert witness regarding the fair market value of the Subject Property and the part taken and any damages to the residue, which together constitute the just compensation the Defendants are due for Plaintiff's taking of their property. Ms. Costello’s opinions will be as set forth in her appraisal report, which will be provided to Plaintiff upon completion. CLERK OF COURTS - DELAWARE COUNTY, OH - COMMON PLEAS COURT 21 CV H 12 0557 - SCHUCK, JAMES P. FILED: 04/26/2022 11:47 AM 2 Defendants reserve the right to supplement this list with any and all officials from Delaware County who have relevant knowledge and information pertaining to this lawsuit. 3 Defendants further reserve the right to (1) supplement this list with additional expert witnesses, if necessary, and (2) call any of Plaintiff's witnesses, as if upon cross-examination, and (3) call additional expert witnesses on rebuttal, without prior notification. I. Lay Witnesses Expected to Testify: A Defendants identify the following lay witnesses expected to testify at trial: 1 Daniel L. Heinlen Gelene V. Heinlen 2981 East Powell Road Lewis Center, Ohio 43035 Mr. and Mrs. Heinlen are the owners of the Subject Property and will testify as to their knowledge of the history of the Subject Property. 2 Defendants reserve the right to supplement this list with any and all officials from Delaware County who have relevant knowledge and information pertaining to this lawsuit. 3 Defendants further reserve the right to (1) supplement this list with additional lay witnesses, if necessary, and (2) call any of Plaintiff’s witnesses, as if upon cross-examination, and (3) call additional lay witnesses on rebuttal, without prior notification. 2of4 Respectfully submitted, /s/ Clinton P. Stahler Clinton P. Stahler (0092560) Stahler@GBSKlaw.com Aaron E. Kenter (0092264) Kenter@GBSKlaw.com Goldman Braunstein Stahler Kenter LLP 500 South Front Street, Suite 1200 Columbus, OH 43215 (614) 229-4566/Telephone (614) 229-4568/Facsimile Attorneys for Defendants Daniel L. Heinlen and Gelene V. Heinlen. 3 of 4 CERTIFICATE OF SERVICE Thereby certify that on April 26, 2022, the foregoing was served on the following via electronic mail or regular mail: Aric I. Hochstettler Staff Attorney Delaware County Board of Commissioners 91 North Sandusky Street, First Floor P.O. Box 8006 Delaware, OH 43015 AHochstettler@co.delaware.oh.us Counsel for Plaintiff Huntington National Bank Department NC1N04 2351 Morse Road Columbus, OH 43229 Defendant /s/ Clinton P. Stahler Clinton P. Stahler (0092560) Attorney for Defendants Daniel L. Heinlen and Gelene V. Heinlen 4of4