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NAILAH K. BYRD
CUYAHOGA COUNTY CLERK OF COURTS
1200 Ontario Street
Cleveland, Ohio 44113
Court of Common Pleas
OBJECTION...
August 10,2023 17:20
Confirmation Nbr. 2933763
MELISSA SVIGELJ CV 23 978925
vs.
Judge: NANCY A. FUERST
SUSAN PALMENTERA-WORDELL ET AL
Pages Filed: 11
Electronically Filed 08/10/2023 17:20 / OBJECTIONS / CV 23 978925 / Confirmation Nbr. 2933763 / CLDLJ
in the court of common pleas
cuyahoga county , ohio
Melissa Svigelj Case No.: CV-23-978925
Plaintiff, Judge Nancy A. Fuerst
-vs-
Susan Palmentera-Wordell
Dr. Paul Wordell
Defendants.
defendants’ responsive
pleading to plaintiffs’
amended complaint
DEFENDANTS completely understand and respect that the judge must follow procedure and law in the
decision to allow PLAINTIFF to increase her civil claim from the original $6,000. However,
DEFENDANTS ask that the judge consider the following before making a final decision on the increase
to the $50,000 that the PLAINTIFF is demanding.
Post-COVID serious medical conditions exasperated by the stress of this case and the Canadian wildfire
smoke and resulting related issues that have caused both DEFENDANTS during the time of these filings
to require emergency room visits, rest and recuperation, and many tests and doctor’s visits which are still
ongoing. In addition, being forced to move multiple times in part due to the PLAINTIFF’S personal and
Electronically Filed 08/10/2023 17:20 / OBJECTIONS / CV 23 978925 / Confirmation Nbr. 2933763 / CLDLJ
political vendetta, and false and exaggerated legal claims causing severe difficulty in securing housing,
care of their children including a special needs child, as well as both DEFENDANTS being forced to
work multiple jobs to survive economically due to the now increased costs of providing housing for their
family via vacation rentals and hotels,. DEFENDANTS have also struggled with having the time, and
mental and physical stamina to respond to the PLAINTIFF’S bombardment of paperwork and hundreds
of pages of vexatious filings. DEFENDANTS believe these hardships are exactly the PLAINTIFF’S
intent.
After an exhaustive and unfruitful search to find legal representation in this case due to its complicated
and political nature, DEFENDANTS, who are not attorneys, nor have they ever attended law school and
currently work humbly and primarily as a security guard and science teacher, are forced to navigate the
complicated legalities of how and when to respond to filings made by the PLAINTIFF and to best respond
legally and properly in their own defense. It is obvious to DEFENDANTS that the PLAINTIFF, although
not admitting to it on record, is receiving help from attorneys and/or legal organizations in the authoring
of her elaborate filings, and admittedly has a history of these types of filings and lawsuits, while
DEFENDANTS are being honest and forthcoming in admitting that they are not at all experienced in this
area, cannot afford to pay an attorney, earn above the requirements for legal aid, and are acting completely
on their own behalf in Pro-Se manner.
Not fully understanding the law, which DEFENDANTS understand does not withstand the Pro-Se
requirement of this case, DEFENDANTS wholeheartedly believed that filing a response to the
PLAINTIFF’S request to have the amount of her suit changed from an already challenged amount of
Electronically Filed 08/10/2023 17:20 / OBJECTIONS / CV 23 978925 / Confirmation Nbr. 2933763 / CLDLJ
$6,000 to the amount of $50,000 would be deemed unnecessary and bombard the court with
documentation that contained redundant and already submitted information the judge was aware of,
feeling confident that judge has reviewed the hundreds upon hundreds of pages of documents the
PLAINTIFF filed and the few dozen pages of documents the DEFENDANTS filed.
DEFENDANTS are not looking for pity or special treatment from the court or judge. But the
DEFENDANTS are asking that the potential true nature and intention of the PLAINTIFF be considered
as decisions are made throughout the filings and proceedings in this case.
DEFENDANTS have already expressed in previous documentation submitted to the court that they find
the PLAINTIFF’S original claim of $6,000 in damages to her property to include a wide spectrum ranging
from accusations, lies, innuendos, and staged photographs on one end and moving to the center of the
spectrum being that of normal wear and tear, already admitted very minor damage (that may or may not
be something that falls under the legal description of normal wear and tear) that the DEFENDANTS
voluntarily and openly disclosed well before vacating the property. In addition, DEFENDANTS worked
diligently to correct these issues, even hiring assistance in a few matters. DEFENDANTS offered to show
these in a walk through which the DEFENDANTS asked for and voluntarily scheduled. But it never took
place because the PLAINTIFF’S son whom she appointed to do the walk through of the home refused to
take a COVID test upon arrival as politely and understandably requested by the DEFENDANTS. He did
not even show up for the walk through.
Electronically Filed 08/10/2023 17:20 / OBJECTIONS / CV 23 978925 / Confirmation Nbr. 2933763 / CLDLJ
Also in the center of the spectrum is the fact that the DEFENDANTS offered to pay for anything fair and
legally required after vacating, if needed. The opposite end of the spectrum, which the DEFENDANTS
have been merciful in describing in previous filings, now warrant a more specific description because of
PLAINTIFF’S enormous increase in the dollar amount of her accusations. This includes what the
DEFENDANTS believe they can prove is malicious, salacious, self-serving, false information, staged
photographs, and suggestiveness by the PLAINTIFF in order to instill fear in, intimidate, and bully the
DEFENDANTS into paying money so to salvage their personal and professional reputations and their
ability to secure housing for their family that may constitute the PLAINTIFF committing criminal level
extortion, blackmail, fraud, coercion, etc. under Ohio criminal and civil laws covering these matters.
DEFENDANTS further believe their Constitutional rights have been violated in this matter and that the
PLAINTIFF has committed federal level crimes.
Although DEFENDANTS are not requesting nor would they expect the Cuyahoga County civil court
division to involve themselves in any way in a potential criminal version of this matter, DEFENDANTS
want to be respectful and courteous and feel that it is important for them to inform the judge that said
DEFENDANTS reserve the legal right and may consider separately requesting a criminal inquiry into the
actions of the PLAINTIFF in the future. DEFENDANTS want to be clear that, currently, they have faith
in the integrity and professionalism of the civil courts, judges, or magistrates regarding this case, despite
its complicated and political nature.
DEFENDANTS believe that after they moved into the PLAINTIFF’S house and DEFENDANT Susan
Palmentera-Wordell innocently allowed both the PLAINTIFF and her son (who has an investigative
Electronically Filed 08/10/2023 17:20 / OBJECTIONS / CV 23 978925 / Confirmation Nbr. 2933763 / CLDLJ
background and career as well as unsuccessful runs for political office in the Northeast, Ohio area multiple
times) to become friends with her on Facebook, the PLAINTIFF and her son became offended, irritated,
and opinionated about Mrs. Palmentera-Wordell’s interactions on social media and envious of her wide
and diverse range of political and professional friends, acquaintances, and contacts. Although Mrs.
Palmentera-Wordell takes careful concern to not engage in the discussion of political matters on social
media, anyone viewing her social media pages during the course of the time she lived in that house,(which
was from January 2021 to July 2023 and during the most politically charged time in our country in
decades,) could clearly see that the violence and hate in all directions occurring in the severely racially
charged political and social climate was concerning to Mrs. Palmentera-Wordell as someone with three
college degrees including a B.A. Homeland Security with a minor in Terrorists and Terrorism, an M.S.
National Security with a minor in International Relations, and M.A. Political Science with a minor in
American Government and a concentration in the U.S. Presidency, as well as an accredited certification
in Joint Military Warfare from American Military University.
Anyone could see that she is close friends and acquaintances with hundreds of people including those
involved in fighting for civil rights and against racial profiling as well as law enforcement and first
responders including military personnel and leadership, police officers, police chiefs, detectives,
corrections officers, sheriff’s deputies, firefighters, arson investigators, paramedics, and Sheriffs from all
over the country, but especially in the Cleveland area and that Mrs. Palmentera-Wordell sometimes shares
posts in support of law enforcement and first responders, which in this day and age makes people with
extreme views like the PLAINTIFF jump to irrational and unsubstantiated claims and conclusions — that
being supportive of law enforcement and first responders means a person is a racist.
Electronically Filed 08/10/2023 17:20 / OBJECTIONS / CV 23 978925 / Confirmation Nbr. 2933763 / CLDLJ
DEFENDANTS also believe that the same bird’s-eye view the PLAINTIFF and her son had into
DEFENDANTS social media contacts, posts, shares, and alike gave the knowledge of her thousands of
political and professional title holders and personal contacts spanning the globe of various races, religions,
political party affiliations, professions, and much more. DEFENDANTS believe that the PLAINTIFF
recognized the potential for the possibility that Mrs. Palmentera-Wordell has political aspirations, that she
absolutely knew that a book written by Mrs. Palmentera-Wordell based on her true life story was in the
works, and the PLAINTIFF pretended to be Susan Palmentera-Wordell’s friend while she set out a plan
to destroy Susan Palmentera-Wordell’s and Dr. Paul Wordell’s reputation in any way she could.
DEFENDANTS believe that a major turning point in the relationship between the PLAINTIFF and them
was at the time that Mrs. Palmentera-Wordell posted on Facebook in support of close friends - both
respected Cleveland police officers and homicide detectives in the city of Cleveland. Mrs. Palmentera-
Wordell deduced and subtly and politely expressed support for, as information was released via media
outlets, assuming that her friends took leadership roles in searching and finding of evidence, including the
gun, that led to the eventual apprehension and conviction of a teenage boy and several young adults in the
brutal ambush and murder of Detective James Skernivitz (a former Cleveland Central Catholic high school
classmate of both Mrs. Palmentera-Wordell and many Cleveland police officers and detectives) and
civilian police informant Scott Dingess, an acquaintance and friend of many people in Cleveland.
Electronically Filed 08/10/2023 17:20 / OBJECTIONS / CV 23 978925 / Confirmation Nbr. 2933763 / CLDLJ
DEFENDANTS believe that the PLAINTIFF was also highly irritated and offended by Mrs.
Palmentera-Wordell’s frequent postings about God, the Virgin Mary, Catholic patron saints, angels, and
requests and offering of prayers, some of which is evident in the PLAINTIFF’S original complaint.
DEFENDANTS also believe that via listening-in devices and cameras inside and outside the home, the
PLAINTIFF not only listened in on and viewed theirs and their children’s personal lives, conversations,
of the DEFENDANTS’ and their children, but then shared personal, financial, familial, academic,
medical, and professional information about them, etc. and encouraged others to do so as well.
DEFENDANTS also believes that PLAINTIFF is attempting to use the manipulation of the honorable
courts, judges, and magistrates to carry-out her personal, professional, and political vendetta in hopes that
PLAINTIFF’S own personal and political relationships, views and voting record, as well as those of
decision makers in the case will further her efforts to destroy the reputation of the DEFENDANTS.
DEFENDANTS believe that the actions, words, and filings of the PLAINTIFF are driven by her political
and social agenda she is commonly and publicly known for throughout the country, is published for and
does speeches about in many public forums, etc. and that she will continue to use her bullying and attention
seeking tactics of this case to advance herself in those arenas. DEFENDANTS have many reasons to
believe this including the fact mentioned in earlier filings that the PLAINTIFF sent the DEFENDANTS
an email that included a publicly available manifesto of sorts authored by the PLAINTIFF that had a
knife dripping with blood on the cover, as well as her bragging and bullying the DEFENDANTS with her
and her son’s personal and professional relationships with elected, appointed, etc. officials.
Electronically Filed 08/10/2023 17:20 / OBJECTIONS / CV 23 978925 / Confirmation Nbr. 2933763 / CLDLJ
DEFENDANTS also believe that the PLAINTIFF’S original filing was out of retaliation and an attempt
to intimidate, bully, and coerce the DEFENDANTS into being fearful of filing a civil or insurance claim
against the PLAINTIFF after DEFENDANT Susan Palmentera-Wordell fell off a faulty and dangerous
step in the home resulting in multiple serious injuries, and potentially leading to her almost dying. Despite
the DEFENDANTS being kind and open regarding the eventual diagnosis of Mrs. Palmentera-Wordell’s
post-COVID medical conditions that may or may not be related to the fall, the PLAINTIFF 'refused to
acknowledge that the faulty step in her home contributed to the fall. In addition, PLAINTIFF became
angry and combative toward DEFENDANTS for kindly and professionally pointing out both mild and
serious safety and fire hazards (based on their experience living there as well as their vast professional
safety and scientific education, experience, and knowledge) in and around PLAINTIFF’S home and
property, some of which the DEFENDANTS, for the safety of their children, pets, and themselves, and
out of a favor to the PLAINTIFF repaired and/ or cleaned up themselves . When the DEFENDANTS
gave the PLAINTIFF the proper 30 day notice required in the lease, they kindly advised again that she
have the matters fixed before inviting other vacation renters or tenants onto the property to avoid risking
someone getting hurt (especially children) and/or filing suit against her.
DEFENDANTS ask that the court acknowledge that a large portion of the PLAINTIFF’S request for an
increase in the monetary portion of her filing are based on her own overt actions to include the following:
PLAINTIFF is attempting to refurnish and refurbish her house on the DEFENDANT’S “dime”.
PLAINTIFF is the person who originally filed this case and only when she was not able to convince the
DEFENDANTS with her tactics to hand over money and/ or file what they deemed to be a fraudulent and
Electronically Filed 08/10/2023 17:20 / OBJECTIONS / CV 23 978925 / Confirmation Nbr. 2933763 / CLDLJ
irrelevant claim against their renter’s insurance policy and things did not go her way in Berea court, she
incurred and retaliated with additional expenses and now wants the DEFENDANTS to cover those
expenses.
Based on these facts, recognitions, and opinions, the DEFENDANTS ask that the honorable judge
reconsider said decision and disallow what they deem as the PLAINTIFF’S cleverly crafted, yet absurd,
exaggerated add-ons she is asking for that do not represent the true condition the house or the
PLAINTIFF’S request for the increase of the dollar amount of the suit going from $6,000 to $50,000,
and stay the amount of the original filing of $6,000 for the purpose of fair, legally viable, and timely
proceedings in this case, by allowing DEFENDANTS to focus on that amount and defend against it at
trial.
*DEFENDANTS also request that the honorable judge recognize that DEFENDANTS are caught in a
vicious and precarious cycle trying to be patient in this matter and concise in their descriptions and filings,
but the PLAINTIFF is making that difficult with her numerous extensively worded submissions and
descriptions that are themselves tactics to defame, libel, and slander the DEFENDANTS as they are
permanent and in public court record. Examples of this are the continuous use of the words “unsanitary”
and “filth” in filings, as well as gaslighted accusations by the PLAINTIFF about the DEFENDANTS’
responses to the court that the PLAINTIFF claims are “vexatious,” when in actuality the
DEFENDANTS, although feeling apologetic to the honorable court and judge for the length of this and
previous filings authored by them, have no choice but to respond in such a way to defend their reputation,
Electronically Filed 08/10/2023 17:20 / OBJECTIONS / CV 23 978925 / Confirmation Nbr. 2933763 / CLDLJ
finances, right to housing for their family and are learning through commands from the court and review
of Ohio civil law that they are also legally required to do so, or judgments will be rendered against them.
Once such matter that DEFENDANTS feel is important to address is the repeated statement the
PLAINTIFF continues to make in multiple submissions to the court that the DEFENDANTS “refused
service of documents on September 13th, 2022, and thus delayed this case.” This is completely false and
can easily be proven. The PLAINTIFF had those documents delivered to a hotel address in Florida that
she drudged up on her own in her obsession to follow and intimidate the DEFENDANTS, and the
DEFENDENTS were not there and had already long returned to Ohio at that time. No notification about
the documents was made to the DEFENDANTS from anyone at the Florida hotel address. The
PLAINTIFF is and has been aware of this. However, this is another tactic by the PLAINTIFF to defame
DEFENDANTS character and is clearly and continuously making this false claim in an attempt to
influence the court and judge into believing that the DEFENDANTS do not respect the law or legal
proceedings, thus the PLAINTIFF is counting on this to influence decisions made by the courts in the
case.
Electronically Filed 08/10/2023 17:20 / OBJECTIONS / CV 23 978925 / Confirmation Nbr. 2933763 / CLDLJ
Electronically Filed 08/10/2023 17:20 / OBJECTIONS / CV 23 978925 / Confirmation Nbr. 2933763 / CLDLJ
Preview
NAILAH K. BYRD CUYAHOGA COUNTY CLERK OF COURTS 1200 Ontario Street Cleveland, Ohio 44113 Court of Common Pleas OBJECTION... August 10,2023 17:20 Confirmation Nbr. 2933763 MELISSA SVIGELJ CV 23 978925 vs. Judge: NANCY A. FUERST SUSAN PALMENTERA-WORDELL ET AL Pages Filed: 11 Electronically Filed 08/10/2023 17:20 / OBJECTIONS / CV 23 978925 / Confirmation Nbr. 2933763 / CLDLJ in the court of common pleas cuyahoga county , ohio Melissa Svigelj Case No.: CV-23-978925 Plaintiff, Judge Nancy A. Fuerst -vs- Susan Palmentera-Wordell Dr. Paul Wordell Defendants. defendants’ responsive pleading to plaintiffs’ amended complaint DEFENDANTS completely understand and respect that the judge must follow procedure and law in the decision to allow PLAINTIFF to increase her civil claim from the original $6,000. However, DEFENDANTS ask that the judge consider the following before making a final decision on the increase to the $50,000 that the PLAINTIFF is demanding. Post-COVID serious medical conditions exasperated by the stress of this case and the Canadian wildfire smoke and resulting related issues that have caused both DEFENDANTS during the time of these filings to require emergency room visits, rest and recuperation, and many tests and doctor’s visits which are still ongoing. In addition, being forced to move multiple times in part due to the PLAINTIFF’S personal and Electronically Filed 08/10/2023 17:20 / OBJECTIONS / CV 23 978925 / Confirmation Nbr. 2933763 / CLDLJ political vendetta, and false and exaggerated legal claims causing severe difficulty in securing housing, care of their children including a special needs child, as well as both DEFENDANTS being forced to work multiple jobs to survive economically due to the now increased costs of providing housing for their family via vacation rentals and hotels,. DEFENDANTS have also struggled with having the time, and mental and physical stamina to respond to the PLAINTIFF’S bombardment of paperwork and hundreds of pages of vexatious filings. DEFENDANTS believe these hardships are exactly the PLAINTIFF’S intent. After an exhaustive and unfruitful search to find legal representation in this case due to its complicated and political nature, DEFENDANTS, who are not attorneys, nor have they ever attended law school and currently work humbly and primarily as a security guard and science teacher, are forced to navigate the complicated legalities of how and when to respond to filings made by the PLAINTIFF and to best respond legally and properly in their own defense. It is obvious to DEFENDANTS that the PLAINTIFF, although not admitting to it on record, is receiving help from attorneys and/or legal organizations in the authoring of her elaborate filings, and admittedly has a history of these types of filings and lawsuits, while DEFENDANTS are being honest and forthcoming in admitting that they are not at all experienced in this area, cannot afford to pay an attorney, earn above the requirements for legal aid, and are acting completely on their own behalf in Pro-Se manner. Not fully understanding the law, which DEFENDANTS understand does not withstand the Pro-Se requirement of this case, DEFENDANTS wholeheartedly believed that filing a response to the PLAINTIFF’S request to have the amount of her suit changed from an already challenged amount of Electronically Filed 08/10/2023 17:20 / OBJECTIONS / CV 23 978925 / Confirmation Nbr. 2933763 / CLDLJ $6,000 to the amount of $50,000 would be deemed unnecessary and bombard the court with documentation that contained redundant and already submitted information the judge was aware of, feeling confident that judge has reviewed the hundreds upon hundreds of pages of documents the PLAINTIFF filed and the few dozen pages of documents the DEFENDANTS filed. DEFENDANTS are not looking for pity or special treatment from the court or judge. But the DEFENDANTS are asking that the potential true nature and intention of the PLAINTIFF be considered as decisions are made throughout the filings and proceedings in this case. DEFENDANTS have already expressed in previous documentation submitted to the court that they find the PLAINTIFF’S original claim of $6,000 in damages to her property to include a wide spectrum ranging from accusations, lies, innuendos, and staged photographs on one end and moving to the center of the spectrum being that of normal wear and tear, already admitted very minor damage (that may or may not be something that falls under the legal description of normal wear and tear) that the DEFENDANTS voluntarily and openly disclosed well before vacating the property. In addition, DEFENDANTS worked diligently to correct these issues, even hiring assistance in a few matters. DEFENDANTS offered to show these in a walk through which the DEFENDANTS asked for and voluntarily scheduled. But it never took place because the PLAINTIFF’S son whom she appointed to do the walk through of the home refused to take a COVID test upon arrival as politely and understandably requested by the DEFENDANTS. He did not even show up for the walk through. Electronically Filed 08/10/2023 17:20 / OBJECTIONS / CV 23 978925 / Confirmation Nbr. 2933763 / CLDLJ Also in the center of the spectrum is the fact that the DEFENDANTS offered to pay for anything fair and legally required after vacating, if needed. The opposite end of the spectrum, which the DEFENDANTS have been merciful in describing in previous filings, now warrant a more specific description because of PLAINTIFF’S enormous increase in the dollar amount of her accusations. This includes what the DEFENDANTS believe they can prove is malicious, salacious, self-serving, false information, staged photographs, and suggestiveness by the PLAINTIFF in order to instill fear in, intimidate, and bully the DEFENDANTS into paying money so to salvage their personal and professional reputations and their ability to secure housing for their family that may constitute the PLAINTIFF committing criminal level extortion, blackmail, fraud, coercion, etc. under Ohio criminal and civil laws covering these matters. DEFENDANTS further believe their Constitutional rights have been violated in this matter and that the PLAINTIFF has committed federal level crimes. Although DEFENDANTS are not requesting nor would they expect the Cuyahoga County civil court division to involve themselves in any way in a potential criminal version of this matter, DEFENDANTS want to be respectful and courteous and feel that it is important for them to inform the judge that said DEFENDANTS reserve the legal right and may consider separately requesting a criminal inquiry into the actions of the PLAINTIFF in the future. DEFENDANTS want to be clear that, currently, they have faith in the integrity and professionalism of the civil courts, judges, or magistrates regarding this case, despite its complicated and political nature. DEFENDANTS believe that after they moved into the PLAINTIFF’S house and DEFENDANT Susan Palmentera-Wordell innocently allowed both the PLAINTIFF and her son (who has an investigative Electronically Filed 08/10/2023 17:20 / OBJECTIONS / CV 23 978925 / Confirmation Nbr. 2933763 / CLDLJ background and career as well as unsuccessful runs for political office in the Northeast, Ohio area multiple times) to become friends with her on Facebook, the PLAINTIFF and her son became offended, irritated, and opinionated about Mrs. Palmentera-Wordell’s interactions on social media and envious of her wide and diverse range of political and professional friends, acquaintances, and contacts. Although Mrs. Palmentera-Wordell takes careful concern to not engage in the discussion of political matters on social media, anyone viewing her social media pages during the course of the time she lived in that house,(which was from January 2021 to July 2023 and during the most politically charged time in our country in decades,) could clearly see that the violence and hate in all directions occurring in the severely racially charged political and social climate was concerning to Mrs. Palmentera-Wordell as someone with three college degrees including a B.A. Homeland Security with a minor in Terrorists and Terrorism, an M.S. National Security with a minor in International Relations, and M.A. Political Science with a minor in American Government and a concentration in the U.S. Presidency, as well as an accredited certification in Joint Military Warfare from American Military University. Anyone could see that she is close friends and acquaintances with hundreds of people including those involved in fighting for civil rights and against racial profiling as well as law enforcement and first responders including military personnel and leadership, police officers, police chiefs, detectives, corrections officers, sheriff’s deputies, firefighters, arson investigators, paramedics, and Sheriffs from all over the country, but especially in the Cleveland area and that Mrs. Palmentera-Wordell sometimes shares posts in support of law enforcement and first responders, which in this day and age makes people with extreme views like the PLAINTIFF jump to irrational and unsubstantiated claims and conclusions — that being supportive of law enforcement and first responders means a person is a racist. Electronically Filed 08/10/2023 17:20 / OBJECTIONS / CV 23 978925 / Confirmation Nbr. 2933763 / CLDLJ DEFENDANTS also believe that the same bird’s-eye view the PLAINTIFF and her son had into DEFENDANTS social media contacts, posts, shares, and alike gave the knowledge of her thousands of political and professional title holders and personal contacts spanning the globe of various races, religions, political party affiliations, professions, and much more. DEFENDANTS believe that the PLAINTIFF recognized the potential for the possibility that Mrs. Palmentera-Wordell has political aspirations, that she absolutely knew that a book written by Mrs. Palmentera-Wordell based on her true life story was in the works, and the PLAINTIFF pretended to be Susan Palmentera-Wordell’s friend while she set out a plan to destroy Susan Palmentera-Wordell’s and Dr. Paul Wordell’s reputation in any way she could. DEFENDANTS believe that a major turning point in the relationship between the PLAINTIFF and them was at the time that Mrs. Palmentera-Wordell posted on Facebook in support of close friends - both respected Cleveland police officers and homicide detectives in the city of Cleveland. Mrs. Palmentera- Wordell deduced and subtly and politely expressed support for, as information was released via media outlets, assuming that her friends took leadership roles in searching and finding of evidence, including the gun, that led to the eventual apprehension and conviction of a teenage boy and several young adults in the brutal ambush and murder of Detective James Skernivitz (a former Cleveland Central Catholic high school classmate of both Mrs. Palmentera-Wordell and many Cleveland police officers and detectives) and civilian police informant Scott Dingess, an acquaintance and friend of many people in Cleveland. Electronically Filed 08/10/2023 17:20 / OBJECTIONS / CV 23 978925 / Confirmation Nbr. 2933763 / CLDLJ DEFENDANTS believe that the PLAINTIFF was also highly irritated and offended by Mrs. Palmentera-Wordell’s frequent postings about God, the Virgin Mary, Catholic patron saints, angels, and requests and offering of prayers, some of which is evident in the PLAINTIFF’S original complaint. DEFENDANTS also believe that via listening-in devices and cameras inside and outside the home, the PLAINTIFF not only listened in on and viewed theirs and their children’s personal lives, conversations, of the DEFENDANTS’ and their children, but then shared personal, financial, familial, academic, medical, and professional information about them, etc. and encouraged others to do so as well. DEFENDANTS also believes that PLAINTIFF is attempting to use the manipulation of the honorable courts, judges, and magistrates to carry-out her personal, professional, and political vendetta in hopes that PLAINTIFF’S own personal and political relationships, views and voting record, as well as those of decision makers in the case will further her efforts to destroy the reputation of the DEFENDANTS. DEFENDANTS believe that the actions, words, and filings of the PLAINTIFF are driven by her political and social agenda she is commonly and publicly known for throughout the country, is published for and does speeches about in many public forums, etc. and that she will continue to use her bullying and attention seeking tactics of this case to advance herself in those arenas. DEFENDANTS have many reasons to believe this including the fact mentioned in earlier filings that the PLAINTIFF sent the DEFENDANTS an email that included a publicly available manifesto of sorts authored by the PLAINTIFF that had a knife dripping with blood on the cover, as well as her bragging and bullying the DEFENDANTS with her and her son’s personal and professional relationships with elected, appointed, etc. officials. Electronically Filed 08/10/2023 17:20 / OBJECTIONS / CV 23 978925 / Confirmation Nbr. 2933763 / CLDLJ DEFENDANTS also believe that the PLAINTIFF’S original filing was out of retaliation and an attempt to intimidate, bully, and coerce the DEFENDANTS into being fearful of filing a civil or insurance claim against the PLAINTIFF after DEFENDANT Susan Palmentera-Wordell fell off a faulty and dangerous step in the home resulting in multiple serious injuries, and potentially leading to her almost dying. Despite the DEFENDANTS being kind and open regarding the eventual diagnosis of Mrs. Palmentera-Wordell’s post-COVID medical conditions that may or may not be related to the fall, the PLAINTIFF 'refused to acknowledge that the faulty step in her home contributed to the fall. In addition, PLAINTIFF became angry and combative toward DEFENDANTS for kindly and professionally pointing out both mild and serious safety and fire hazards (based on their experience living there as well as their vast professional safety and scientific education, experience, and knowledge) in and around PLAINTIFF’S home and property, some of which the DEFENDANTS, for the safety of their children, pets, and themselves, and out of a favor to the PLAINTIFF repaired and/ or cleaned up themselves . When the DEFENDANTS gave the PLAINTIFF the proper 30 day notice required in the lease, they kindly advised again that she have the matters fixed before inviting other vacation renters or tenants onto the property to avoid risking someone getting hurt (especially children) and/or filing suit against her. DEFENDANTS ask that the court acknowledge that a large portion of the PLAINTIFF’S request for an increase in the monetary portion of her filing are based on her own overt actions to include the following: PLAINTIFF is attempting to refurnish and refurbish her house on the DEFENDANT’S “dime”. PLAINTIFF is the person who originally filed this case and only when she was not able to convince the DEFENDANTS with her tactics to hand over money and/ or file what they deemed to be a fraudulent and Electronically Filed 08/10/2023 17:20 / OBJECTIONS / CV 23 978925 / Confirmation Nbr. 2933763 / CLDLJ irrelevant claim against their renter’s insurance policy and things did not go her way in Berea court, she incurred and retaliated with additional expenses and now wants the DEFENDANTS to cover those expenses. Based on these facts, recognitions, and opinions, the DEFENDANTS ask that the honorable judge reconsider said decision and disallow what they deem as the PLAINTIFF’S cleverly crafted, yet absurd, exaggerated add-ons she is asking for that do not represent the true condition the house or the PLAINTIFF’S request for the increase of the dollar amount of the suit going from $6,000 to $50,000, and stay the amount of the original filing of $6,000 for the purpose of fair, legally viable, and timely proceedings in this case, by allowing DEFENDANTS to focus on that amount and defend against it at trial. *DEFENDANTS also request that the honorable judge recognize that DEFENDANTS are caught in a vicious and precarious cycle trying to be patient in this matter and concise in their descriptions and filings, but the PLAINTIFF is making that difficult with her numerous extensively worded submissions and descriptions that are themselves tactics to defame, libel, and slander the DEFENDANTS as they are permanent and in public court record. Examples of this are the continuous use of the words “unsanitary” and “filth” in filings, as well as gaslighted accusations by the PLAINTIFF about the DEFENDANTS’ responses to the court that the PLAINTIFF claims are “vexatious,” when in actuality the DEFENDANTS, although feeling apologetic to the honorable court and judge for the length of this and previous filings authored by them, have no choice but to respond in such a way to defend their reputation, Electronically Filed 08/10/2023 17:20 / OBJECTIONS / CV 23 978925 / Confirmation Nbr. 2933763 / CLDLJ finances, right to housing for their family and are learning through commands from the court and review of Ohio civil law that they are also legally required to do so, or judgments will be rendered against them. Once such matter that DEFENDANTS feel is important to address is the repeated statement the PLAINTIFF continues to make in multiple submissions to the court that the DEFENDANTS “refused service of documents on September 13th, 2022, and thus delayed this case.” This is completely false and can easily be proven. The PLAINTIFF had those documents delivered to a hotel address in Florida that she drudged up on her own in her obsession to follow and intimidate the DEFENDANTS, and the DEFENDENTS were not there and had already long returned to Ohio at that time. No notification about the documents was made to the DEFENDANTS from anyone at the Florida hotel address. The PLAINTIFF is and has been aware of this. However, this is another tactic by the PLAINTIFF to defame DEFENDANTS character and is clearly and continuously making this false claim in an attempt to influence the court and judge into believing that the DEFENDANTS do not respect the law or legal proceedings, thus the PLAINTIFF is counting on this to influence decisions made by the courts in the case. Electronically Filed 08/10/2023 17:20 / OBJECTIONS / CV 23 978925 / Confirmation Nbr. 2933763 / CLDLJ Electronically Filed 08/10/2023 17:20 / OBJECTIONS / CV 23 978925 / Confirmation Nbr. 2933763 / CLDLJ