On February 26, 2021 a
MOTION FILED FOR PLAINTIFF(S) ASSUNTA ROSSI PERSONALTY REVOCABLE LIVING TRUST(P1), ASSUNTA ROSSI(P2) and ROBERT V. TRACI(P3) PRO SE 9999999 MOTION TO STAY 03/08/2023 - MOOT - MO
was filed
involving a dispute between
Assunta Rossi,
Assunta Rossi Personalty Revocable Living Trust,
Robert V. Traci,
and
Chicago Title Company, Llc,
David Keehan,
D. J. Keehan,
Gh Holdings Llc,
Online Communications Llc,
Signature Building Concepts Llc,
Westlake Shadow Creek, Llc An Ohio Corporation,
for CONTRACT - REAL ESTATE
in the District Court of Cuyahoga County.
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Motion No. 5070713
NAILAH K. BYRD
CUYAHOGA COUNTY CLERK OF COURTS
1200 Ontario Street
Cleveland, Ohio 44113
Court of Common Pleas
MOTION TO...
March 5,2023 19:17
Confirmation Nbr. 2792529
ASSUNTA ROSSI PERSONALTY REVOCABLE CV 21 944483
LIVING ET AL
vs.
Judge: MAUREEN CLANCY
D.J. KEEHANETAL
Pages Filed: 2
Electronically Filed 03/05/2023 19:17 / MOTION / CV 21 944483 / Confirmation Nbr. 2792529 / BATCH
IN THE COURT OF COMMON PLEAS
CUYAHOGA COUNTY, OHIO
ASSUNTA ROSSI PERSONALTY
REVOCABLE LIVING TRUST, et al
CASE NO.: CV 21 944483
Plaintiffs
JUDGE MAUREEN CLANCY
Vs
D.J.KEEHAN, Individually and MOTION TO STAY
As dba, Westlake
Shadow Creek, LLC, et al
Defendants
Now come the Plaintiffs and move this Court to Stay further proceedings in
this matter while Plaintiffs appeal this Court's Order granting Summary Judgment
on the issues of fraud and alter ego liability and its Order under Rule 54(B) that
“there is no just cause for delay” which were entered on February 10, 2023.
Plaintiffs request that the Trial Date of March 20 be vacated and further
proceedings be halted until the Eighth District Court of Appeals issues a ruling on
said Appeal.
Plaintiffs have filed a Notice of Appeal contemporaneous with this Motion.
The Orders granted by the Court are prejudicial to Plaintiffs and Staying the
proceedings will allow these issues to be clarified by the Court of Appeals. It will
then result in a full trial on all triable issues, avoid the need to perhaps try the
case twice and save potentially wasted time by this Court.
Electronically Filed 03/05/2023 19:17 / MOTION / CV 21 944483 / Confirmation Nbr. 2792529 / BATCH
/s/Robert V. Traci
Robert V. Traci, Esq., Pro Se
Inactive (6734)
29576 Indian Ridge Cove
Westlake, OH 44145
rvt@tracilpa.com
/s/ Assunta Rossi
Assunta Rossi, Esq., Personally
and as Trustee
29576 Indian Ridge Cove
Westlake, Ohio 44145
artrial388@gmail.com
CERTIFICATE OF SERVICE
I certify that a true copy of the foregoing Motion for Continuance was
served on all Defendants by and through their counsel Stephen Hanudel on March
6, 2023, by delivering copies of same by electronic mail.
/s/ Robert V. Traci
Robert V. Traci, Esq., Pro Se
/s/ Assunta Rossi
Assunta Rossi, Esq., Personally
and as Trustee
Electronically Filed 03/05/2023 19:17 / MOTION / CV 21 944483 / Confirmation Nbr. 2792529 / BATCH
Document Filed Date
March 05, 2023
Case Filing Date
February 26, 2021
Category
CONTRACT - REAL ESTATE
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Motion No. 5070713 NAILAH K. BYRD CUYAHOGA COUNTY CLERK OF COURTS 1200 Ontario Street Cleveland, Ohio 44113 Court of Common Pleas MOTION TO... March 5,2023 19:17 Confirmation Nbr. 2792529 ASSUNTA ROSSI PERSONALTY REVOCABLE CV 21 944483 LIVING ET AL vs. Judge: MAUREEN CLANCY D.J. KEEHANETAL Pages Filed: 2 Electronically Filed 03/05/2023 19:17 / MOTION / CV 21 944483 / Confirmation Nbr. 2792529 / BATCH IN THE COURT OF COMMON PLEAS CUYAHOGA COUNTY, OHIO ASSUNTA ROSSI PERSONALTY REVOCABLE LIVING TRUST, et al CASE NO.: CV 21 944483 Plaintiffs JUDGE MAUREEN CLANCY Vs D.J.KEEHAN, Individually and MOTION TO STAY As dba, Westlake Shadow Creek, LLC, et al Defendants Now come the Plaintiffs and move this Court to Stay further proceedings in this matter while Plaintiffs appeal this Court's Order granting Summary Judgment on the issues of fraud and alter ego liability and its Order under Rule 54(B) that “there is no just cause for delay” which were entered on February 10, 2023. Plaintiffs request that the Trial Date of March 20 be vacated and further proceedings be halted until the Eighth District Court of Appeals issues a ruling on said Appeal. Plaintiffs have filed a Notice of Appeal contemporaneous with this Motion. The Orders granted by the Court are prejudicial to Plaintiffs and Staying the proceedings will allow these issues to be clarified by the Court of Appeals. It will then result in a full trial on all triable issues, avoid the need to perhaps try the case twice and save potentially wasted time by this Court. Electronically Filed 03/05/2023 19:17 / MOTION / CV 21 944483 / Confirmation Nbr. 2792529 / BATCH /s/Robert V. Traci Robert V. Traci, Esq., Pro Se Inactive (6734) 29576 Indian Ridge Cove Westlake, OH 44145 rvt@tracilpa.com /s/ Assunta Rossi Assunta Rossi, Esq., Personally and as Trustee 29576 Indian Ridge Cove Westlake, Ohio 44145 artrial388@gmail.com CERTIFICATE OF SERVICE I certify that a true copy of the foregoing Motion for Continuance was served on all Defendants by and through their counsel Stephen Hanudel on March 6, 2023, by delivering copies of same by electronic mail. /s/ Robert V. Traci Robert V. Traci, Esq., Pro Se /s/ Assunta Rossi Assunta Rossi, Esq., Personally and as Trustee Electronically Filed 03/05/2023 19:17 / MOTION / CV 21 944483 / Confirmation Nbr. 2792529 / BATCH