On March 15, 2019 a
Order
was filed
for FORECLOSURES
in the District Court of Franklin County.
Preview
Franklin County Ohio Clerk of Courts of the Common Pleas- 2019 Sep 30 4:02 PM-19CV002260
OE862 - S3
KDW# 383050
IN THE COURT OF COMMON PLEAS
FRANKLIN COUNTY, OHIO
TLOA of Ohio, LLC, Case No. 19 CV 002260 bee
Plaintiff, TAX CERTIFICATE FORECLOSURE
VS. Judge Julie Lynch
Maplewood Properties Inc., et al., MOTION TO CANCEL SHERIFF’S
SALE, VACATE JUDGMENT AND
Defendants. DISMISS COMPLAINT
Plaintiff moves the Court for an Order canceling the Sheriff's Sale scheduled for October
11, 2019, vacating the Judgment rendered May 29, 2019, and dismissing its Complaint, with
prejudice, at Plaintiff's costs. Plaintiff further moves the Court for an Order returning the Order
of Sale without execution. For cause, Plaintiff states that the tax certificates have been
redeemed. Therefore, it is no longer equitable for the Judgment Entry and Foreclosure Decree to
have prospective application and it should be vacated pursuant to Civ.R. 60(B)(4). Moreover,
this motion is made within a reasonable time.
Wherefore, Plaintiff moves the Court for an Order canceling the Sheriff's Sale, vacating
the judgment, and dismissing its Complaint, with prejudice, at Plaintiff's costs.
/S/Christian E. Niklas LG I
Kim M. Hammond (0062572
Christian E. Niklas (0066725 fH
Keith D. Weiner & Associates Co., LPA
75 Public Square, 4th Floor
Cleveland, Ohio 44113
Tel: (21 771-6500
Fax: (216) 771-6540
khammond@weinerlaw.com
niklas@weinerlaw.com
Franklin County Ohio Clerk of Courts of the Common Pleas- 2019 Sep 30 4:02 PM-19CV002260
OE862 - S
CERTIFICATE OF SERVICE
A copy of the foregoing was sent by regular U.S. Mail on September SO , 2019 to the
following:
Maplewood Properties Inc.
P.O. Box 329
Etna, OH 43018
Treasurer of Franklin County
373 South High Street, 17th Floor
Columbus, OH 43215
/S/Christian E. Niklas J
Kim M. Hammond (0062572)
Christian E. Niklas (0066725)
Keith D. Weiner & Associates Co., LPA
75 Public Square, 4th Floor
Cleveland, Ohio 44113
Tel: (216) 771-6500
Fax: (216) 771-6540
khammond@weinerlaw.com
cniklas@weinerlaw.com
2.
Document Filed Date
September 30, 2019
Case Filing Date
March 15, 2019
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Franklin County Ohio Clerk of Courts of the Common Pleas- 2019 Sep 30 4:02 PM-19CV002260 OE862 - S3 KDW# 383050 IN THE COURT OF COMMON PLEAS FRANKLIN COUNTY, OHIO TLOA of Ohio, LLC, Case No. 19 CV 002260 bee Plaintiff, TAX CERTIFICATE FORECLOSURE VS. Judge Julie Lynch Maplewood Properties Inc., et al., MOTION TO CANCEL SHERIFF’S SALE, VACATE JUDGMENT AND Defendants. DISMISS COMPLAINT Plaintiff moves the Court for an Order canceling the Sheriff's Sale scheduled for October 11, 2019, vacating the Judgment rendered May 29, 2019, and dismissing its Complaint, with prejudice, at Plaintiff's costs. Plaintiff further moves the Court for an Order returning the Order of Sale without execution. For cause, Plaintiff states that the tax certificates have been redeemed. Therefore, it is no longer equitable for the Judgment Entry and Foreclosure Decree to have prospective application and it should be vacated pursuant to Civ.R. 60(B)(4). Moreover, this motion is made within a reasonable time. Wherefore, Plaintiff moves the Court for an Order canceling the Sheriff's Sale, vacating the judgment, and dismissing its Complaint, with prejudice, at Plaintiff's costs. /S/Christian E. Niklas LG I Kim M. Hammond (0062572 Christian E. Niklas (0066725 fH Keith D. Weiner & Associates Co., LPA 75 Public Square, 4th Floor Cleveland, Ohio 44113 Tel: (21 771-6500 Fax: (216) 771-6540 khammond@weinerlaw.com niklas@weinerlaw.com Franklin County Ohio Clerk of Courts of the Common Pleas- 2019 Sep 30 4:02 PM-19CV002260 OE862 - S CERTIFICATE OF SERVICE A copy of the foregoing was sent by regular U.S. Mail on September SO , 2019 to the following: Maplewood Properties Inc. P.O. Box 329 Etna, OH 43018 Treasurer of Franklin County 373 South High Street, 17th Floor Columbus, OH 43215 /S/Christian E. Niklas J Kim M. Hammond (0062572) Christian E. Niklas (0066725) Keith D. Weiner & Associates Co., LPA 75 Public Square, 4th Floor Cleveland, Ohio 44113 Tel: (216) 771-6500 Fax: (216) 771-6540 khammond@weinerlaw.com cniklas@weinerlaw.com 2.