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CV-2023-02-0419 MCLAUGHLIN, KELLY 06/19/2023 14:18:40 PM MTCD Page 1of9
IN THE COURT OF COMMON PLEAS
SUMMIT COUNTY, OHIO
SUNTIYA COLLINS, CASE NO. CV 2023 02 0419
Plaintiff, JUDGE KELLY MCLAUGHLIN
-vs- DEFENDANT BRITTNEY M.
ROWBOTTOM’S
MOTION TO COMPEL
BRITTNEY M. ROWBOTTOM, et al. DI ERY
Defendants.
Now comes Defendant, Brittney M. Rowbottom, by and through undersigned
counsel and pursuant to Ohio Civil Rule 37(A)(3), and hereby moves this Honorable Court
for an Order compelling Plaintiff, Suntiya Collins, to respond to paper discovery requests
propounded to her in the form of Interrogatories and Request for Production of
Documents.
This matter involves a motor vehicle collision that occurred on February 12, 2020
between vehicles driven by Plaintiff and Defendant, Brittney Rowbottom. Plaintiff alleges
to have sustained bodily injury as a result of the collision.
On March 30, 2023, Defendant Rowbottom, through her attorney, served Plaintiff
Suntiya Collins, through her attorney, with Interrogatories and Requests for Production of
Documents under cover letter. (Exhibit A). Counsel for Defendant Rowbottom followed up
on the status of the responses to discovery on May 24, 2023 and June 8, 2023. (Exhibits B
and C). As of the date of this filing, Defendant has not received answers to their discovery
request or any response from Plaintiffs counsel.
Sandra Kurt, Summit County Clerk of Courts
CV-2023-02-0419 MCLAUGHLIN, KELLY 06/19/2023 14:18:40 PM MTCD Page 2 of 9
Civil Rule 37(A)(3)(a) allows a party seeking discovery to move for an Order
compelling an answer where a party fails to answer any Interrogatory or provide
requested documents. Recently, Ohio Rule 37 was amended to add a requirement that the
moving party shall make a reasonable effort to resolve the matter through discussion with
the opposing attorney from whom discovery is sought. However, once a party is ordered to
provide discovery he or she cannot stay mute. The party must satisfy the trial court’s order
to convince the trial court of a good-faith excuse for not complying with said order. Russo v.
Goodyear Tire Rubber Company (1987) 36 Ohio App. 3d 175.
In this case, the initial discovery responses were served on the Plaintiff through
their attorney on March 30, 2023. Defense counsel has made multiple attempts to follow
up on the status of those responses. Plaintiff's counsel has not yet provided any response
to either the discovery requests or defense counsel’s inquiry as to the status. Plaintiffs
failure to respond to this outstanding discovery makes it impossible for the Defendant to
evaluate the strength or weakness of the case, or to evaluate the Plaintiffs alleged injuries.
Defendant respectfully moves this Honorable Court for an Order compelling Plaintiff
to provide answers to interrogatories and produce all records requested in the request for
production of documents within the next fourteen (14) days.
LifAnneM. Markowski,
Anne M. Markowski (0069705)
HANNA CAMPBELL & POWELL LLP
3737 Embassy Parkway/Suite 100
Akron OH 44333
330.670.7601/(fax) 330.670.7456
markowski@hcplaw.net
Attorney for Defendant,
Brittney M. Rowbottom
Sandra Kurt, Summit County Clerk of Courts
CV-2023-02-0419 MCLAUGHLIN, KELLY 06/19/2023 14:18:40 PM MTCD Page 3 of 9
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing has been served by electronic mail, this
19th day of June, 2023, upon:
W. Jack Meola, Esq. (0022122) Attorney for Plaintiff,
KISLING NESTICO & REDICK LLC Suntiya Collins
22 East McKinley Way/Suite A
Poland OH 44514
wjmeola@knrlegal.com
Safe Auto Insurance Company A named Defendant
4 Easton Oval
Columbus, OH 43219
‘sf AnneM. Markowski
Collins/Rowbottom
1291820 (2850-87)
Sandra Kurt, Summit County Clerk of Courts
CV-2023-02-0419 MCLAUGHLIN, KELLY 06/19/2023 14:18:40 PM MTCD Page 4 of 9
HANNA CAMPBELL & POWELL, LLP
March 30, 2023
[fransmittal Via Electronic Mail Only|
Via email: wimeola@knrlegal.com
W. Jack Meola, Esq.
KISLING NESTICO & REDICK LLC
22 East McKinley Way/Suite A
Poland OH 44514
Re: Suntiya Collins v. Brittney M. Rowbottom, et al.
Summit County Case No.: CV 2023 02 0419
Dear Mr. Meola:
Enclosed please find an Answer and Notice of Service which we have today filed with the Clerk
on behalf of the Defendant, Brittney M. Rowbottom, in the above referenced matter. Also
enclosed are Interrogatories and Request for Production of Documents (Word format) directed to
your client.
Should you have any questions, please feel free to contact our office.
Sincerely,
dE ud
Catherine E, Nagy
EXHIBIT
CEN:dgb
Enclosures
<>,
cc: Safe Auto Insurance Company (via regular mail)
Anne M. Markowski, Esq.
Catherine E. Nagy 3737 Embassy Parkway, Suite 100 Akron, Ohio 44333
(P) 330.670.7340 (P) 330.670.7458 agyv@heplaw.net
Licensed to Pr tice in Ohio and Mlinois
www.heplaw.net
Sandra Kurt, Summit County Clerk of Courts
CV-2023-02-0419 MCLAUGHLIN, KELLY 06/19/2023 14:18:40 PM MTCD Page 5 of 9
Deborah Beckley
From: Catherine Nagy
To: wjmeola@knrlegal.com
Ce: Anne Markowski; Catherine Nagy
Subject: Suntiya Collins v. Brittney M. Rowbottom, et al, Summit County Case No.: CV 2023 02
0419
Attachments: Letter to counsel re initial pleadings 3.30.23.pdf; Notice of Appearance.pdf, Notice of
Service.pdf; Answer.pdf; Interrogatories.pdf; Request for Production of Documents.pdf
Counsel,
On behalf of Attorney Catherine E. Nagy, attached please find correspondence, together with its referenced pleadings, in
regard to the above matter.
Sincerely,
Deb Beckley
Deb Beckley
Legal Assistant to Beverly A. Sandacz, Esq. and Catherine E. Nagy, Esq.
Hanna, Campbell & Powell LLP
3737 Embassy Parkway
Suite 100
Akron, OH 44333
DID: 330.670.7631
Fax: 330.670.7454
Email: dbeckley@hcplaw.net
This trans mission may contain confidential and/or privileged information which is intended solely for the use of the intendes
re nt ff you are not an intended recipient, or a person responsible for delivering th transmission to an intended recipient,
e do not disseminate this transmission or take any action in reliance on its contents. If you have received this transmission in
error, please delete this transmission and immediately notify the sender of the error.
Sandra Kurt, Summit County Clerk of Courts
CV-2023-02-0419 MCLAUGHLIN, KELLY 06/19/2023 14:18:40 PM MTCD Page 6 of 9
Anne Markowski
From: Anne Markowski
Sent: Wednesday, May 24, 2023 1:52 PM
To: ‘wimeola@knrlegal.com’; ‘Melody C. Montague (mmontague@knrlegal.com)'
Subject: RE: Collins v. Rowbottom
Jack and Melody,
| am following up to my email last week, May | have additional time to answer discovery?
When can | expect your responses?
It looks like an offer was made back in 2022. The offer was $4,310. Please provide a response to the offer.
Thanks,
Anne
Anne M. Markowski, Esq.
Hanna, Campbell & Powell, LLP
3737 Embassy Parkway, Suite 100
Akron, Ohio 44333
330-670-7601 (Direct Dial)
330-670-7456 (Direct fax)
This email transmission may contain confidential and/or privileged information which is intended solely for the use of
the intended recipient. if you are not an intended recipient, or a person responsible for delivering this transmission to an
intended recipient, please do not disseminate this transmission or take any action in reliance on its contents. If you have
received this transmission in error, please delete this transmission and immediately notify the sender of the error
From: Anne Markowski EXHIBIT
Sent: Friday, May 19, 2023 3:15 PM
To: 'wjmeola@knrlegal.com'; Melody C. Montague (mi
Subject: RE: Collins v. Rowbottom
ague@knrlegal.com)
ague
— hp
jack/Melody,
Piease let me know if we have additional time to answer to answer discovery. They are out to my client and | am just
waiting to get them back.
Also, | see we sent you discovery back in March. Can you let me know the status?
Finally, Cathy Nagy is no longer with our office so please forward all correspondence in this case to my attention going
forward. Thank you,
Anne
Sandra Kurt, Summit County Clerk of Courts
CV-2023-02-0419 MCLAUGHLIN, KELLY 06/19/2023 14:18:40 PM MTCD Page 7 of 9
Anne M. Markowski, Esq.
Hanna, Campbell & Powell, LLP
3737 Embassy Parkway, Suite 100
Akron, Ohio 44333
330-670-7601 (Direct Dial)
330-670-7456 (Direct fax)
This email transmission may contain confidential and/or privileged information which is intended solely for the use of
the intended recipient. if you are not an intended recipient, or a person responsible for delivering this transmission to an
intended recipient, please do not disseminate this transmission or take any action in reliance on its contents. If you have
received this transmission in error, please delete this transmission and immediately notify the sender of the error.
From: Catherine Nagy
Sent: Thursday, May 18, 2023 1:47 PM
To: ‘wjmeola@knrlegal.com'; Melody C. Montague (mmontaque@knrlegal.com)
Cc: Anne Markowski; Cheryl Moses
Subject: Collins v. Rowbottom
Jack/Melody,
Please advise whether we may have an additional 28 day {i.e. to and including June 16) to respond to discovery issued
on Ms. Rowbottom.
Thank you.
Cathy
Catherine E. Nagy, Esq.
Hanna, Campbell & Powell, LLP
3737 Embassy Parkway, Suite 100
Akron, Ohio 44333
DID: (330) 670-7340
Fax: (330) 670-7458
Email: cnagy@hcplaw.net
This transmission may contain confidential and/or privileged information which is intended solely for the use of the intended
recipient(s). If you are not an intended recipient, or a person responsible for delivering this transmission to an intended recipient,
please do not disseminate this transmission or take any action in reliance on its contents. If you have received this transmission in
error, please delete this transmission and immediately notify the sender of the error.
Sandra Kurt, Summit County Clerk of Courts
CV-2023-02-0419 MCLAUGHLIN, KELLY 06/19/2023 14:18:40 PM MTCD Page 8 of 9
HANNA CAMPBELL & POWELL, LLP
June 8, 2023
{fransmittal Via Electronic Mail Only|
Via email: wimeola@knrlegal.com
W. Jack Meola, Esq.
KISLING NESTICO & REDICK LLC
22 East McKinley Way/Suite A
Poland OH 44514
Re: Suntiya Collins v. Brittney M. Rowbottom, et al.
Summit County Case No.: CV 2023 02 0419
Dear Jack:
Please be advised on March 30, 2023 my office forwarded to your attention interrogatories
and request for production of documents to your client. As of the date of this letter I have
not yet received a response. I emailed you last month to ask for the status but again
received no answer. Therefore, if I do not receive your client’s complete responses to
interrogatories and request for production of documents by Friday, June 16, 2023 I will be
filing a motion to compel.
Thank you for your attention to this matter.
Very truly yours,
AnneM. Markowskw
EXHIBIT
c
Anne M. Markwski
—
AMM/pjr
Collins v. Rowbottom
1290643 (2850-087)
Anne M. Markowsi 3737 Embassy Parkway, Suite 100 Akron, Ohio 44333
(P) 330.670.7601 (F) 330.670.7456 amarkowski@hcplaw.net
www.heplaw.net
Sandra Kurt, Summit County Clerk of Courts
CV-2023-02-0419 MCLAUGHLIN, KELLY 06/19/2023 14:18:40 PM MTCD Page 9 of 9
Phyllis Ruffin
From: Phyllis Ruffin
Sent: Thursday, June 8, 2023 10:57 AM
To: ‘wjmeola@knrlegal.com’
Ce: Anne Markowski
Subject: Collins v. Rowbottom, Summit County Case No. CV 2023 02 0419
Attachments: HCPDOCS-#1290643-v1-
Collins_v__Rowbottom_Itr_to_OC_(Meola)_req_answers_to_discovery.docx
_ttr_to_!
Phyllis Ruffin
Legal Assistant
Hanna, Campbell & Powell, LLP
3737 Embassy Parkway
Suite 100
Akron, Ohio 44333
Direct: 330-670-7300
Fax: 330-670-7456
Email: pruffin@hcplaw.net
This transmission may contain confidential and/or privileged information which is intended solely for the use
of the intended recipient(s). If you are not an intended recipient or a person responsible for delivering this
transmission to an intended recipient, please do not disseminate this transmission or take any action in
reliance on its contents. If you have received this transmission is error, please delete this transmission and
immediately notify the sender of the error. 330-670-7300.
Sandra Kurt, Summit County Clerk of Courts
Preview
CV-2023-02-0419 MCLAUGHLIN, KELLY 06/19/2023 14:18:40 PM MTCD Page 1of9 IN THE COURT OF COMMON PLEAS SUMMIT COUNTY, OHIO SUNTIYA COLLINS, CASE NO. CV 2023 02 0419 Plaintiff, JUDGE KELLY MCLAUGHLIN -vs- DEFENDANT BRITTNEY M. ROWBOTTOM’S MOTION TO COMPEL BRITTNEY M. ROWBOTTOM, et al. DI ERY Defendants. Now comes Defendant, Brittney M. Rowbottom, by and through undersigned counsel and pursuant to Ohio Civil Rule 37(A)(3), and hereby moves this Honorable Court for an Order compelling Plaintiff, Suntiya Collins, to respond to paper discovery requests propounded to her in the form of Interrogatories and Request for Production of Documents. This matter involves a motor vehicle collision that occurred on February 12, 2020 between vehicles driven by Plaintiff and Defendant, Brittney Rowbottom. Plaintiff alleges to have sustained bodily injury as a result of the collision. On March 30, 2023, Defendant Rowbottom, through her attorney, served Plaintiff Suntiya Collins, through her attorney, with Interrogatories and Requests for Production of Documents under cover letter. (Exhibit A). Counsel for Defendant Rowbottom followed up on the status of the responses to discovery on May 24, 2023 and June 8, 2023. (Exhibits B and C). As of the date of this filing, Defendant has not received answers to their discovery request or any response from Plaintiffs counsel. Sandra Kurt, Summit County Clerk of Courts CV-2023-02-0419 MCLAUGHLIN, KELLY 06/19/2023 14:18:40 PM MTCD Page 2 of 9 Civil Rule 37(A)(3)(a) allows a party seeking discovery to move for an Order compelling an answer where a party fails to answer any Interrogatory or provide requested documents. Recently, Ohio Rule 37 was amended to add a requirement that the moving party shall make a reasonable effort to resolve the matter through discussion with the opposing attorney from whom discovery is sought. However, once a party is ordered to provide discovery he or she cannot stay mute. The party must satisfy the trial court’s order to convince the trial court of a good-faith excuse for not complying with said order. Russo v. Goodyear Tire Rubber Company (1987) 36 Ohio App. 3d 175. In this case, the initial discovery responses were served on the Plaintiff through their attorney on March 30, 2023. Defense counsel has made multiple attempts to follow up on the status of those responses. Plaintiff's counsel has not yet provided any response to either the discovery requests or defense counsel’s inquiry as to the status. Plaintiffs failure to respond to this outstanding discovery makes it impossible for the Defendant to evaluate the strength or weakness of the case, or to evaluate the Plaintiffs alleged injuries. Defendant respectfully moves this Honorable Court for an Order compelling Plaintiff to provide answers to interrogatories and produce all records requested in the request for production of documents within the next fourteen (14) days. LifAnneM. Markowski, Anne M. Markowski (0069705) HANNA CAMPBELL & POWELL LLP 3737 Embassy Parkway/Suite 100 Akron OH 44333 330.670.7601/(fax) 330.670.7456 markowski@hcplaw.net Attorney for Defendant, Brittney M. Rowbottom Sandra Kurt, Summit County Clerk of Courts CV-2023-02-0419 MCLAUGHLIN, KELLY 06/19/2023 14:18:40 PM MTCD Page 3 of 9 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been served by electronic mail, this 19th day of June, 2023, upon: W. Jack Meola, Esq. (0022122) Attorney for Plaintiff, KISLING NESTICO & REDICK LLC Suntiya Collins 22 East McKinley Way/Suite A Poland OH 44514 wjmeola@knrlegal.com Safe Auto Insurance Company A named Defendant 4 Easton Oval Columbus, OH 43219 ‘sf AnneM. Markowski Collins/Rowbottom 1291820 (2850-87) Sandra Kurt, Summit County Clerk of Courts CV-2023-02-0419 MCLAUGHLIN, KELLY 06/19/2023 14:18:40 PM MTCD Page 4 of 9 HANNA CAMPBELL & POWELL, LLP March 30, 2023 [fransmittal Via Electronic Mail Only| Via email: wimeola@knrlegal.com W. Jack Meola, Esq. KISLING NESTICO & REDICK LLC 22 East McKinley Way/Suite A Poland OH 44514 Re: Suntiya Collins v. Brittney M. Rowbottom, et al. Summit County Case No.: CV 2023 02 0419 Dear Mr. Meola: Enclosed please find an Answer and Notice of Service which we have today filed with the Clerk on behalf of the Defendant, Brittney M. Rowbottom, in the above referenced matter. Also enclosed are Interrogatories and Request for Production of Documents (Word format) directed to your client. Should you have any questions, please feel free to contact our office. Sincerely, dE ud Catherine E, Nagy EXHIBIT CEN:dgb Enclosures <>, cc: Safe Auto Insurance Company (via regular mail) Anne M. Markowski, Esq. Catherine E. Nagy 3737 Embassy Parkway, Suite 100 Akron, Ohio 44333 (P) 330.670.7340 (P) 330.670.7458 agyv@heplaw.net Licensed to Pr tice in Ohio and Mlinois www.heplaw.net Sandra Kurt, Summit County Clerk of Courts CV-2023-02-0419 MCLAUGHLIN, KELLY 06/19/2023 14:18:40 PM MTCD Page 5 of 9 Deborah Beckley From: Catherine Nagy To: wjmeola@knrlegal.com Ce: Anne Markowski; Catherine Nagy Subject: Suntiya Collins v. Brittney M. Rowbottom, et al, Summit County Case No.: CV 2023 02 0419 Attachments: Letter to counsel re initial pleadings 3.30.23.pdf; Notice of Appearance.pdf, Notice of Service.pdf; Answer.pdf; Interrogatories.pdf; Request for Production of Documents.pdf Counsel, On behalf of Attorney Catherine E. Nagy, attached please find correspondence, together with its referenced pleadings, in regard to the above matter. Sincerely, Deb Beckley Deb Beckley Legal Assistant to Beverly A. Sandacz, Esq. and Catherine E. Nagy, Esq. Hanna, Campbell & Powell LLP 3737 Embassy Parkway Suite 100 Akron, OH 44333 DID: 330.670.7631 Fax: 330.670.7454 Email: dbeckley@hcplaw.net This trans mission may contain confidential and/or privileged information which is intended solely for the use of the intendes re nt ff you are not an intended recipient, or a person responsible for delivering th transmission to an intended recipient, e do not disseminate this transmission or take any action in reliance on its contents. If you have received this transmission in error, please delete this transmission and immediately notify the sender of the error. Sandra Kurt, Summit County Clerk of Courts CV-2023-02-0419 MCLAUGHLIN, KELLY 06/19/2023 14:18:40 PM MTCD Page 6 of 9 Anne Markowski From: Anne Markowski Sent: Wednesday, May 24, 2023 1:52 PM To: ‘wimeola@knrlegal.com’; ‘Melody C. Montague (mmontague@knrlegal.com)' Subject: RE: Collins v. Rowbottom Jack and Melody, | am following up to my email last week, May | have additional time to answer discovery? When can | expect your responses? It looks like an offer was made back in 2022. The offer was $4,310. Please provide a response to the offer. Thanks, Anne Anne M. Markowski, Esq. Hanna, Campbell & Powell, LLP 3737 Embassy Parkway, Suite 100 Akron, Ohio 44333 330-670-7601 (Direct Dial) 330-670-7456 (Direct fax) This email transmission may contain confidential and/or privileged information which is intended solely for the use of the intended recipient. if you are not an intended recipient, or a person responsible for delivering this transmission to an intended recipient, please do not disseminate this transmission or take any action in reliance on its contents. If you have received this transmission in error, please delete this transmission and immediately notify the sender of the error From: Anne Markowski EXHIBIT Sent: Friday, May 19, 2023 3:15 PM To: 'wjmeola@knrlegal.com'; Melody C. Montague (mi Subject: RE: Collins v. Rowbottom ague@knrlegal.com) ague — hp jack/Melody, Piease let me know if we have additional time to answer to answer discovery. They are out to my client and | am just waiting to get them back. Also, | see we sent you discovery back in March. Can you let me know the status? Finally, Cathy Nagy is no longer with our office so please forward all correspondence in this case to my attention going forward. Thank you, Anne Sandra Kurt, Summit County Clerk of Courts CV-2023-02-0419 MCLAUGHLIN, KELLY 06/19/2023 14:18:40 PM MTCD Page 7 of 9 Anne M. Markowski, Esq. Hanna, Campbell & Powell, LLP 3737 Embassy Parkway, Suite 100 Akron, Ohio 44333 330-670-7601 (Direct Dial) 330-670-7456 (Direct fax) This email transmission may contain confidential and/or privileged information which is intended solely for the use of the intended recipient. if you are not an intended recipient, or a person responsible for delivering this transmission to an intended recipient, please do not disseminate this transmission or take any action in reliance on its contents. If you have received this transmission in error, please delete this transmission and immediately notify the sender of the error. From: Catherine Nagy Sent: Thursday, May 18, 2023 1:47 PM To: ‘wjmeola@knrlegal.com'; Melody C. Montague (mmontaque@knrlegal.com) Cc: Anne Markowski; Cheryl Moses Subject: Collins v. Rowbottom Jack/Melody, Please advise whether we may have an additional 28 day {i.e. to and including June 16) to respond to discovery issued on Ms. Rowbottom. Thank you. Cathy Catherine E. Nagy, Esq. Hanna, Campbell & Powell, LLP 3737 Embassy Parkway, Suite 100 Akron, Ohio 44333 DID: (330) 670-7340 Fax: (330) 670-7458 Email: cnagy@hcplaw.net This transmission may contain confidential and/or privileged information which is intended solely for the use of the intended recipient(s). If you are not an intended recipient, or a person responsible for delivering this transmission to an intended recipient, please do not disseminate this transmission or take any action in reliance on its contents. If you have received this transmission in error, please delete this transmission and immediately notify the sender of the error. Sandra Kurt, Summit County Clerk of Courts CV-2023-02-0419 MCLAUGHLIN, KELLY 06/19/2023 14:18:40 PM MTCD Page 8 of 9 HANNA CAMPBELL & POWELL, LLP June 8, 2023 {fransmittal Via Electronic Mail Only| Via email: wimeola@knrlegal.com W. Jack Meola, Esq. KISLING NESTICO & REDICK LLC 22 East McKinley Way/Suite A Poland OH 44514 Re: Suntiya Collins v. Brittney M. Rowbottom, et al. Summit County Case No.: CV 2023 02 0419 Dear Jack: Please be advised on March 30, 2023 my office forwarded to your attention interrogatories and request for production of documents to your client. As of the date of this letter I have not yet received a response. I emailed you last month to ask for the status but again received no answer. Therefore, if I do not receive your client’s complete responses to interrogatories and request for production of documents by Friday, June 16, 2023 I will be filing a motion to compel. Thank you for your attention to this matter. Very truly yours, AnneM. Markowskw EXHIBIT c Anne M. Markwski — AMM/pjr Collins v. Rowbottom 1290643 (2850-087) Anne M. Markowsi 3737 Embassy Parkway, Suite 100 Akron, Ohio 44333 (P) 330.670.7601 (F) 330.670.7456 amarkowski@hcplaw.net www.heplaw.net Sandra Kurt, Summit County Clerk of Courts CV-2023-02-0419 MCLAUGHLIN, KELLY 06/19/2023 14:18:40 PM MTCD Page 9 of 9 Phyllis Ruffin From: Phyllis Ruffin Sent: Thursday, June 8, 2023 10:57 AM To: ‘wjmeola@knrlegal.com’ Ce: Anne Markowski Subject: Collins v. Rowbottom, Summit County Case No. CV 2023 02 0419 Attachments: HCPDOCS-#1290643-v1- Collins_v__Rowbottom_Itr_to_OC_(Meola)_req_answers_to_discovery.docx _ttr_to_! Phyllis Ruffin Legal Assistant Hanna, Campbell & Powell, LLP 3737 Embassy Parkway Suite 100 Akron, Ohio 44333 Direct: 330-670-7300 Fax: 330-670-7456 Email: pruffin@hcplaw.net This transmission may contain confidential and/or privileged information which is intended solely for the use of the intended recipient(s). If you are not an intended recipient or a person responsible for delivering this transmission to an intended recipient, please do not disseminate this transmission or take any action in reliance on its contents. If you have received this transmission is error, please delete this transmission and immediately notify the sender of the error. 330-670-7300. Sandra Kurt, Summit County Clerk of Courts