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CV-2022-11-3991 ROWLANDS, MARY MARGARET 12/30/2022 08:58:56 AM NORE Page 1 of 55
INTHE COURT OF COMMON PLEAS
SUMMIT COUNTY, OHIO
CHRISTAL HEINEY, ) CASE NO. CV-2022-11-3991
Plaintiff, ) JUDGE MARY MARGARET ROWLANDS
vs. ) DI CT TAYLOR COMPANY,
ING,’S 7 NOTICE OF FILING NOTIC
CT TAYLOR COMPANY, INC., et al. ) OF REMOVAL
Defendants. )
PLEASE TAKE NOTICE that on December 30, 2022, Defendant C.T. Taylor Company,
Inc. (“Defendant”) filed a Notice of Removal of this action to the United States District Court for
the Northem District of Ohio, Eastem Division, pursuantto the provisions of 28 U.S.C. §§ 1331,
1441(a), and 1446. A true and comect copy of Defendant’s Notice of Removal is attached hereto
as Exhibit1.
You are further advised
that Defendant, upon filing said Notice of Removal in the Office
of the Clerk of the United States District Court for the Northem District of Ohio, also filed and
served a copy of this Notice to effectuate removal, in accordance with 28 U.S.C. § 1446(d).
Respectfully submitted,
/s/Ann E. Knuth
Ann E. Knuth (0061566)
aknuth@hahnlaw.com
HAHN LOESER & PARKS LLP
200 Public , Suite 2800
Cleveland, Ohio 44114
216.621.0150 - Telephone
216.241.2824 - Facsimile
Attorney for Defendant
C.T. Taylor Company, Inc.
Sandra Kurt, Summit County Clerk of Courts
CV-2022-11-3991 ROWLANDS, MARY MARGARET 12/30/2022 08:58:56 AM NORE Page 2 of 55
CERTIFICATE OF SERVICE
This is to certify that, on December 30, 2022, a true and correct copy of the foregoing
Defendant C.T. Taylor Company, Inc.’s Notice Of Filing Notice Of Removal was served via the
Court's electronic filing system upon:
Daniel S. Dubow
daniel.dubow@spitzlawfirm.com
Kevin A. Buryanek
kevin. buryanek@spitzlawfirm.com
SPITZ LAW FIRM
25825 Science Park Drive, Suite 200
Beachwood, OH 44122
Attomeys for Plaintiff
and via electronic mail and regular United States mail, sufficient postage prepaid, upon the
following parties:
Karen Schippers Matthew Collier
C/o HL Statutory Agent, Inc. C/o HL Statutory Agent, Inc.
200 Public Square, Suite 2800 200 Public Square, Suite 2800
Cleveland, OH 44114 Cleveland, OH 44114
Defendant Defendant
Robert James
C/o HL Statutory Agent, Inc.
200 Public Square, Suite 2800
Cleveland, OH 44114
Defendant
/s/Ann E. Knuth
One of the Attorneys for Defendant
C.T. Taylor Company, Inc.
14281684.2
Sandra Kurt, Summit County Clerk of Courts
CV-2022-11-3991 ROWLANDS, MARY MARGARET 12/30/2022 08:58:56 AM NORE Page 3 of 55
EXHIBIT 1
Sandra Kurt, Summit County Clerk of Courts
CV-2022-11-3991
CRRA
SAR MOPS RF BALI?
PE PEREGM 12/30/22 1NOPS. PagelD #:1 Page 4 of 55
INTHE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF OHIO
EASTERN DIVISION
CHRISTAL HEINEY, ) CASE NO. _ 5:22-cv-2337
Plaintiff, ) JUDGE
vs. ) DEFENDANT C.T. TAYLOR COMPANY,
) INC.’S NOTICE OF REMOVAL
CT TAYLOR COMPANY, INC., et al. )
)
Defendants. )
Pursuant to 28 U.S.C. §§ 1441 and 1446, Defendant C.T. Taylor Company, Inc.
(“Defendant C.T. Taylor’) respectfully submits this Notice of Removal of the above-captioned
case from the Court of Common Pleas for Summit County, Ohio, in which it was commenced, to
the United States District Court for the Northem District of Ohio. A copy of all documents filed
or served in the state court action are attached hereto as ExhibitsA (Instructions for Service), B
(Complaint), C (Summons issued by certified mail to C.T. Taylor Company, Inc.), D (Summons
issued by certified mail to C.T. Taylor Company, Inc.), E (Summons issuedby certified mail to
Karen Schippers), F (Summons issued
by certified mail to Matthew Collier), G (Summons issued
by certified mail to Robert James) and H (case docket). To the knowledge of Defendant C.T.
Taylor, no other motions, pleadings, or papers have been filed in the state court case.
The basis of this removal is 28 U.S.C. § 1331, which provides that the “district courts
shall have original jurisdiction of all civil actions arising under the Constitution, laws, or treaties
of the United States.”
This Notice of Removal is also timely filed pursuant to 28 U.S.C. § 1446(b).
In support of removal, Defendant C.T. Taylor states the following:
Sandra Kurt, Summit County Clerk of Courts
CV-2022-11-3991
CRRA
SMAR MOPS BZ RCI?
PPE REGM 12/30/22 2°BPS. PagelD #: 2 Page 5 of 55
I BACKGROUND
1 On or about November 23, 2022, Plaintiff Christal Heiney (“Plaintiff”) initiated
this case by filing a Complaint in Common Pleas Court for Summit County, Ohio at Docket
Number CV-2022-11-3991.
2. Plaintiff named C.T. Taylor Company, Inc., Karen Schippers, Matthew Collier,
and Robert James as Defendants in the Complaint.
3. Defendant C.T. Taylor was served with the Complaint on December 2, 2022.
4. No Defendant, other than Defendant C.T. Taylor, has been served with the
Complaint.
5. Notice of the filing of this Notice of Removal will be given to all parties and the
Clerk of Courts in accordance with 28 U.S.C. § 1446(d), and this Notice of Removal is being
served per the Certificate of Service.
6. Copies
of all documents filed or served in the state court action, as well as a copy
of the docket sheet in the state court action, are filed contemporaneously
herewith and adopted
herein by reference, as Exhibits A through H. No other pleadings have been received by
Defendant C.T. Taylor or filed in the case.
I REMOVAL IS PROPER BASED ON FEDERAL QUESTION J URISDICTION
7. According to the Complaint, Plaintiff is a resident of Portage County, Ohio.
8. Defendant C.T. Taylor is a corporation incorporated under the laws of the State of
Ohio, with its principal place of business in Summit County, Ohio.
9. Among other claims, Plaintiff seeks relief for disability discrimination in violation
of the Americans with Disabilities Act, 42 U.S.C. § 12101 et seq,, and retaliation in violation of
the Family and Medical Leave Act, 29 U.S.C. § 2601 et seq.
Sandra Kurt, Summit County Clerk of Courts
CV-2022-11-3991
CRRA
SAR MOPS BF BRRCGP2
PEPE REGM 12/30/22 3NOPS. PagelD #: 3 Page 6 of 55
10. The Court has original jurisdiction over these causes of action pursuant to 28
U.S.C. § 1331, because they arise under the federal statute, namely the Americans with
Disabilities Act and the Family and Medical Leave Act.
11. Supplemental jurisdiction is conferred over Plaintiff's state law claims against
Defendant C.T. Taylor under the federal supplemental jurisdiction statute, 28 U.S.C. § 1367,
because the state law claims are so related to Plaintiff's claims for disability discrimination in
violation of the Americans with Disabilities Act and retaliation in violation of the Family and
Medical Leave Act that they form part of the same case or controversy under Article III of the
U.S. Constitution. All claims are related to the termination of Plaintiff's employment with
Defendant C.T. Taylor and the reasons for such termination. Because the state law claims arise
from the same common nucleus of facts and circumstances as the Americans with Disabilities
Act and Family and Medical Leave Act claims, this action against Defendants is properly
removable to this Court.
12. Therefore, removal jurisdiction exists under28 U.S.C. § 1441(a).
13. This Notice of Removal is timely filed with the Court pursuant to 28 U.S.C. §
1446(b), because this notice is filed within 30 days of service upon Defendant C.T. Taylor.
14. Venue may be properly had in this district under28 U.S.C. §§ 1391(b)(1) and (2),
because at least one Defendant resides in this district
and all Defendants are residents of the State
of Ohio, and because a substantial part of the events or omissions allegedly giving rise to the
claim occurred in this district
15. Tn accordance with the time requirements of Federal Rule of Civil Procedure
81,
Defendant C.T. Taylor will timely file a response to the Complaint. Defendant C.T. Taylor does
Sandra Kurt, Summit County Clerk of Courts
CV-2022-11-3991
CRRA
SAR MOPS RF REG?
PPE REGM 12/30/22 ANOPS. PagelD #: 4 Page 7 of 55
not waive, and to the contrary, expressly preserves, any and all rights and defenses it may assert
by motion or otherwise with respect to the action and Complaint.
WHEREFORE, the above-captioned action, pending in the Court of Common Pleas for
Summit County, Ohio, is hereby removed therefrom
to this Court. Defendant C.T. Taylor further
states that this matter should remain in federal district court.
OF COUNSEL: Respectfully submitted,
HAHN LOESER & PARKS LLP /s/ Ann E. Knuth
Ann E. Knuth (0061566)
aknuth@hahnlaw.com
200 Public Suite 2800
Cleveland, Ohio 44114-2316
Phone: 216.621.0150
Fax: 216.241.2824
Attol for Defendant,
C.T. Taylor Company, Inc.
4
Sandra Kurt, Summit County Clerk of Courts
CV-2022-11-3991
CRRA
SAR MORPS BF BRCIP2
PPE REGM 12/30/22 SNOPS. PagelD #:5 Page 8 of 55
CERTIFICATE OF SERVICE
I hereby certify that, on December 30, 2022, a copy of the foregoing Defendant C.T.
Taylor Company, Inc.’s Notice Of Removal was filed with the Clerk of Court via the Court’s
CM/ECF filing system. Notice of this filing will be sent to all parties by operation of the Court’s
electronic filing system and via electronic mail and regular United States mail, sufficient postage
prepaid, upon the following counsel of record and parties:
Daniel S. Dubow Karen Schippers
daniel.dubow@spitzlawfirm.com C/o HL Statutory Agent, Inc.
Kevin A. Buryanek 200 Public Square, Suite 2800
kevin. buryanek@spitzlawfirm.com Cleveland, OH 44114
SPITZ LAW FIRM
25825 Science Park Drive, Suite 200 Defendant
Beachwood, OH 44122
Attorneys for Plaintiff
Matthew Collier
C/o HL Statutory Agent, Inc.
200 Public Square, Suite 2800
Cleveland, OH 44114
Defendant
Robert James
C/o HL Statutory Agent, Inc.
200 Public Square, Suite 2800
Cleveland, OH 44114
Defendant
/s/Ann E. Knuth
One of Attorney for Defendant
C.T. Taylor Company, Inc.
Sandra Kurt, Summit County Clerk of Courts
CV-2022-11-3991
CASE BOSD BESS CA COVERCSHER2 bf 2. PagelD #: 6 Page 9 of 55
JS44_ (Rev. 3/22)
The JS 44 cover sheet and the information contained her in neither replace nor supplement the filing and service of pleadings or other papers as required by la xcept as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS O1 EXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS DEFENDANTS
C.T. Taylor Company, Inc., Karen Schippers,
CHRISTAL HEINEY Matthew Collier, and Robert James
(b) County of Residence of First Listed Plaintiff Portage County of Residence of First Listed Defendant Summit
(EXCEPT U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN ND CONDEMNATION CASE! THE LOCATION OF
‘THE TRACT OF LAND INVOLVED,
(c) Attorneys (Firm Name, Address, and Telephone Number) Attomeys (if Known) Ann E. Knuth (0061566) HAHN LOESER &PARKS
Daniel S. Dubow(0095530) KevinA. B 0099300), SPITZ aknuth@hahnlaw.com, 200 Public Square, Suite 2800
daniel.dubow@spitzlawfirm.com; kevin.buryanek@spitzlawfirm.com, 4Cleveland, Ohio 44114-2316, Phone: 216.621.0150
5825 Science Park Dr., Suite 200, Beachwood, OH 44122, 216-291-4744
II. BASIS OF JURISDICTION (Pace an “x” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (piacean “x” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
Oh U.S. Government Federal Question PTF DE PTF DEF
Plaintiff (US. Government Not a Party) Citizen of This ate Oh Ou Incorporated or Principal Place O4 Oe
of Business In This State
[2 US. Government (4 Diversity Citizen of Another State D2 D2 Incorporated and Principal Place Os Os
Defendant (ndicate Citizenship of Parties in Item I) of Business In Another State
Citizen or Subject of a CO 3 Foreign Nation Oe Oe
Foreign Country
IV. NATURE OF SUIT (Place an “x” in One Box Only) Click here for: Nature of Suit Code Descriptions.
[ CONTRACT. TORTS: FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES,
110 Insurance
120 Marine
130 Miller Act H
PERSONAL INJURY
310 Airplane
315 Airplane Product,
PERSONAL INJURY | ]625 Drug Related Seizure
5 Personal Injury -
Product Liability
of Property 21 USC 881
[1690 other H
422 Appeal 28 USC 158
423 Withdrawal
28 USC 157
Hd
375 False Claims Act
376 Qui Tam (31 USC
3729(a))
140 Negotiable Instrument Liability (1367 Health Care |] 400 State Reapportionment
[150 Recovery of Overpayment [7] 320 Assault, Libel & Pharmaceutical INTELLECTUAL 410 Antitrust
& Enforcement of Judgment] Slander Personal Injury PROPERTY RIGHTS 430 Banks and Banking
B 151 Medicare Act
152 Recovery of Defaulted
|] 330 Federal Employers’
Liability
Product Liability
[1 368 Asbestos Personal
[] 820 Copyrights
d
830 Patent ~
450 Commerce
460 Deportation
Student Loans
(Excludes Veterans)
[21153 Recovery of Overpayment
H
340 Marine
345 Marine Product
Liability
Injury Product
Liability
PERSONAL PROPERTY LABOR
835 Patent Abbreviated
‘New Drug Application
[L] 840 Trademark
470 Racketeer Influenced and
Corrupt Organizations
480 Consumer Credit,
of Veteran’s Benefits
1 160 Stockholders Suits
[J 190 Other Contract
H
350 Motor Vehi
355 Motor Vehi le
Product Liability
B
370 Other Fraud
371 Truth in Lending
[J 380 Other Personal
1710 Fair Labor Standards
‘Act
|_]720 Labor/Management
880 Defend Trade Secrets
Act of 2016
SOCIAL SECURITY
(15 USC 1681 or 1692)
485 Telephone Consumer
Protection Act
H 195 Contract Product Liability |] 360 Other Personal Property Damage Relations 861 HLA (1395ff) 490 Cable/Sat TV
196 Franchise Injury
[] 362 Personal Injury -
Medical Malpractice
[1385 Property Damage
Product Liability R
740 Railway Labor Act
'751 Family and Medical
Leave Act
862 Black Lung (923)
863 DIWC/DIWW (405(g))
864 SSID Title XVI
850 Securities/Commodities
Exchange
|] 890 Other Statutory Actions
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 90 Other Labor Litigation I] 865 RSI (405(2)) [_] 891 Agricultural Acts
[_]210 Land Condemnation [_] 440 Other Civil Rights Habeas Corpus: }791 Employee Retirement 893 Environmental Matters
[_] 220 Foreclosure [| 441 Voting [7 463 Alien Detainee Income Security Act FEDERAL TAX SUITS ] 895 Freedom of Information
;
I] 510 Motions to Vacate
230 Rent Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
H
442 Employment
443 Housing/
Accommodations
Sentence
[_] 530 General
870 Taxes (U.S. Plaintiff
or Defendant)
[) 871 1Rs—Third Party
896 Ai
H tion
899 Administrative Procedure
[_) 290 All Other Real Property [-] 445 Amer. wiDisabilities -[LJ 535 Death Penalty TMMIGRATION 26 USC 7609 ActReview or Appeal of
Employment Other: [462 Naturalization Application| Agency Decision
|] 446 Amer. w/Disabilities 540 Mandamus & Other }465 Other Immigration [_] 950 Constitutionality of
Other 550 Civil Rights Actions State Statutes
[_] 448 Education 555 Prison Condition
560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an “X” in One Box Only)
[! Original [KJ2 Removed from o3 Remanded from of Reinstated or O35 Transferred from. 6 Multidistrict 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
CSG sor BE OE Ego" cite jurisdictional statutes unless diversity)
VI. CAUSE OF ACTION Brief description of cause:
I scrimination in violation of the ADA and retaliation in violation of the FMLA.
VIL. REQUESTED IN (1 CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RUL 23, F.R.Cv.P. $25,000.00 JURY DEMAND: Klves No
VII. RELATED CASE(S)
IF ANY instructions):
UDG DOCKET NUMBER
r T SIGNATURE OF ATTORNEY OF RECORD.
12/30/2022 /s/ Am E.
FOR OFFICE USE ONLY
RECEIPT if AMOUNT APPLYING IEP JUDGE MAG. JUDGE
Sandra Kurt, Summit County Clerk of Courts
CV-2022-11-3991
CAE ASPET ANY USAF RHO 224 OE SHARAM 12/30/22 B°BF2. PagelD #: 7 Page 10 of 55
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF OHIO
I. Civil Categories: (Please check one category only _).
4
xX General Civil
2 Administrative Review/Social Security
3 Habeas Corpus Death Penalty
“If under Title 28, §2255, name the SENTENCING JUDGE.
CASE NUMBER:
Il. RELATED OR REFILED CASES See LR 3.1 which provides in pertinent part: "If an action is filed or removed to this Court
and assigned to a District Judge after which it is discontinued, dismissed or remanded to a State court, and
subsequently refiled, it shall be assigned to the same Judge who received the initial case assignment without regardfor
the place of holding court in which the case was refiled. Counsel or a party without counsel shall be responsible for
bringing such cases to the attention of the Court by responding to the questions included on the Civil Cover Sheet."
This action: is RELATED to another PENDING civil case [_ is a REFILED case was PREVIOUSLY REMANDED
If applicable, please indicate on page 1 in section VIII, the name of the Judge and case number.
I. In accordance with Local Civil Rule 3.8, actions involving counties in the Eastern Division shall be filed at any of the
divisional offices therein. Actions involving counties in the Western Division shall be filed at the Toledo office. For the
purpose of determining the proper division, and for statistical reasons, the following information is requested.
ANSWER ONE PARAGRAPH ONLY. ANSWER PARAGRAPHS 1 THRU 3 IN ORDER. UPON FINDING WHICH
PARAGRAPH APPLIES TO YOUR CASE, ANSWER IT AND STOP.
(1) Resident defendant If the defendant resides in a county within this district, please set forth the name of such
county
COUNTY: Summit
Corporation For the purpose of answering the above, a corporation is deemed to be a resident of that county in
which it has its principal place of business in that district.
(2) Non-Resident defendant, If no defendant is a resident of a county in this district, please set forth the county
wherein the cause of action arose or the event complained of occurred.
COUNTY:
(3) Other Cases. If no defendant is a resident of this district, or if the defendant is a corporation not having a principle
place of business within the district, and the cause of action arose or the event complained of occurred outside
this district, please set forth the county of the plaintiff's residence.
COUNTY
IV. The Counties in the Northern District of Ohio are divided into divisions as shown below. After the county is
determined in Section III, please check the appropriate division.
EASTERN DIVISION
X]| akron (Counties: Carroll, Holmes, Portage, Stark, Summit, Tuscarawas and Wayne)
(Counties: Ashland, Ashtabula, Crawford, Cuyahoga, Geauga,
CLEVELAND Lake, Lorain, Medina and Richland)
YOUNGSTOWN (Counties: Columbiana, Mahoning and Trumbull)
WESTERN DIVISION
TOLEDO (Counties: Allen, Auglaize, Defiance, Erie, Fulton, Hancock, Hardin, Henry,
Huron, Lucas, Marion, Mercer, Ottawa, Paulding, Putnam, Sandusky, Seneca
VanWert, Williams, Wood and Wyandot)
Sandra Kurt, Summit County Clerk of Courts
CV-2022-11-3991
CASAS SUR RSA BGO F024 OS RAY 12/30/22 N°BF3. PagelD #:8 Page 11 of 55
EXHIBIT A
Sandra Kurt, Summit County Clerk of Courts
CV-2022-11-3997
LLM, CARE SAN OPS couny Courter cbminareIeae > PagelD #: 9
iY Civil Division
ya. aA
WAS:<’
QT
Instructions: Complete the following form and file with the Summit County Clerk of Courts - Civil Divsion, located at:
205 South High Street, 1st Floor, Akron, Ohio 44308.
(Case Caption:
CHRISTAL HEINEY
Plaintiff
Case Number
CT TAYLOR COMPANY, INC.
Defendant INSTRUCTIONS FOR SERVICE
To Clerk: You are hereby requestd to make service upon the following by:
FedEx
Certified Mail
Regular Mail
Sheriff Service (Personal)
Sheriff Service (Personal or Residential)
Personal Service Process Server:
Please Serve the following pleadings: TS Complaint
Parties to be served:
Name: CT TAYLOR COMPANY, INC. Name: KAREN SCHIPPERS
Address 5802 Akron-Cleveland Road Address c/o HL Statutory Agent, Inc
Address Address 200 Public Square, Suite 2800
City Hudson State OH Zip 44236 City Cleveland State OH Zip 44114
Name: CT TAYLOR COMPANY, INC. Name: MATTHEW COLLIER
Address c/o HL Statutory Agent, Inc., Statutory Agent Address c/o HL Statutory Agent, Inc.
Address 200 Public Square, Suite 2800 Address 200 Public Square, Suite 2800
City Cleveland State OH Zip 44114 City Cleveland State OH Zip 44114
s/Kevin A. Buryanek 0099300
Attorney for Plaintiff (or pro se litigant) Supreme Ct #
VFormora Rev 1. 20131002-08/17,
Sandra Kurt, Summit County Clerk of Courts
CV-2022-11-3997
CR ee CaS Re Girone er CARMA ie 3: PagelD #: 10
LLM,
iY Civil Division
ya. aA
WAS:<’
QT
Instructions: Complete the following form and file with the Summit County Clerk of Courts - Civil Divsion, located at:
205 South High Street, 1st Floor, Akron, Ohio 44308.
(Case Caption:
CHRISTAL HEINEY
Plaintiff
Case Number
CT TAYLOR COMPANY, INC.
Defendant INSTRUCTIONS FOR SERVICE
To Clerk: You are hereby requestd to make service upon the following by:
FedEx
Certified Mail
Regular Mail
Sheriff Service (Personal)
Sheriff Service (Personal or Residential)
Personal Service Process Server:
Please Serve the following pleadings: TS Complaint
Parties to be served:
Name: ROBERT JAMES Name:
Address c/o HL Statutory Agent, Inc. Address
Address 200 Public Square, Suite 2800 Address
City Cleveland State OH Zip 44114 City State Zip
Name: Name:
Address Address
Address Address
City State Zip City State Zip
s/Kevin A. Buryanek 0099300
Attorney for Plaintiff (or pro se litigant) Supreme Ct #
VFormora Rev 1. 20131002-08/17,
Sandra Kurt, Summit County Clerk of Courts
CV-2022-11-3991
Cage TS BODES DRE rs FH 12/30/22 1'SFS0. PagelD #: 11 Page 4oF55
EXHIBIT B
Sandra Kurt, Summit County Clerk of Courts
CV-2022-11-3991
CaS BPs MORO MARGARET GAN 20R2 ¢8:BH ARAM 5/30/22 2°80. PagelD #: 12 Page 3508295
IN THE COURT OF COMMON PLEAS
SUMMIT COUNTY, OHIO
CHRISTAL HEINEY ) CASE NO.
326 East Central Avenue )
Ravenna, OH 44266 ) JUDGE:
Plaintiff,
Vv. COMPLAINT FOR
DAMAGES AND
CT TAYLOR COMPANY, INC. INJUNCTIVE RELIEF
5802 Akron-Cleveland Road
Hudson, OH 44236 JURY DEMAND ENDORSED
HEREIN
-also serve-
CT TAYLOR COMPANY, INC
c/o HL Statutory Agent, Inc.
Statutory Agent
200 Pu
Preview
CV-2022-11-3991 ROWLANDS, MARY MARGARET 12/30/2022 08:58:56 AM NORE Page 1 of 55 INTHE COURT OF COMMON PLEAS SUMMIT COUNTY, OHIO CHRISTAL HEINEY, ) CASE NO. CV-2022-11-3991 Plaintiff, ) JUDGE MARY MARGARET ROWLANDS vs. ) DI CT TAYLOR COMPANY, ING,’S 7 NOTICE OF FILING NOTIC CT TAYLOR COMPANY, INC., et al. ) OF REMOVAL Defendants. ) PLEASE TAKE NOTICE that on December 30, 2022, Defendant C.T. Taylor Company, Inc. (“Defendant”) filed a Notice of Removal of this action to the United States District Court for the Northem District of Ohio, Eastem Division, pursuantto the provisions of 28 U.S.C. §§ 1331, 1441(a), and 1446. A true and comect copy of Defendant’s Notice of Removal is attached hereto as Exhibit1. You are further advised that Defendant, upon filing said Notice of Removal in the Office of the Clerk of the United States District Court for the Northem District of Ohio, also filed and served a copy of this Notice to effectuate removal, in accordance with 28 U.S.C. § 1446(d). Respectfully submitted, /s/Ann E. Knuth Ann E. Knuth (0061566) aknuth@hahnlaw.com HAHN LOESER & PARKS LLP 200 Public , Suite 2800 Cleveland, Ohio 44114 216.621.0150 - Telephone 216.241.2824 - Facsimile Attorney for Defendant C.T. Taylor Company, Inc. Sandra Kurt, Summit County Clerk of Courts CV-2022-11-3991 ROWLANDS, MARY MARGARET 12/30/2022 08:58:56 AM NORE Page 2 of 55 CERTIFICATE OF SERVICE This is to certify that, on December 30, 2022, a true and correct copy of the foregoing Defendant C.T. Taylor Company, Inc.’s Notice Of Filing Notice Of Removal was served via the Court's electronic filing system upon: Daniel S. Dubow daniel.dubow@spitzlawfirm.com Kevin A. Buryanek kevin. buryanek@spitzlawfirm.com SPITZ LAW FIRM 25825 Science Park Drive, Suite 200 Beachwood, OH 44122 Attomeys for Plaintiff and via electronic mail and regular United States mail, sufficient postage prepaid, upon the following parties: Karen Schippers Matthew Collier C/o HL Statutory Agent, Inc. C/o HL Statutory Agent, Inc. 200 Public Square, Suite 2800 200 Public Square, Suite 2800 Cleveland, OH 44114 Cleveland, OH 44114 Defendant Defendant Robert James C/o HL Statutory Agent, Inc. 200 Public Square, Suite 2800 Cleveland, OH 44114 Defendant /s/Ann E. Knuth One of the Attorneys for Defendant C.T. Taylor Company, Inc. 14281684.2 Sandra Kurt, Summit County Clerk of Courts CV-2022-11-3991 ROWLANDS, MARY MARGARET 12/30/2022 08:58:56 AM NORE Page 3 of 55 EXHIBIT 1 Sandra Kurt, Summit County Clerk of Courts CV-2022-11-3991 CRRA SAR MOPS RF BALI? PE PEREGM 12/30/22 1NOPS. PagelD #:1 Page 4 of 55 INTHE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF OHIO EASTERN DIVISION CHRISTAL HEINEY, ) CASE NO. _ 5:22-cv-2337 Plaintiff, ) JUDGE vs. ) DEFENDANT C.T. TAYLOR COMPANY, ) INC.’S NOTICE OF REMOVAL CT TAYLOR COMPANY, INC., et al. ) ) Defendants. ) Pursuant to 28 U.S.C. §§ 1441 and 1446, Defendant C.T. Taylor Company, Inc. (“Defendant C.T. Taylor’) respectfully submits this Notice of Removal of the above-captioned case from the Court of Common Pleas for Summit County, Ohio, in which it was commenced, to the United States District Court for the Northem District of Ohio. A copy of all documents filed or served in the state court action are attached hereto as ExhibitsA (Instructions for Service), B (Complaint), C (Summons issued by certified mail to C.T. Taylor Company, Inc.), D (Summons issued by certified mail to C.T. Taylor Company, Inc.), E (Summons issuedby certified mail to Karen Schippers), F (Summons issued by certified mail to Matthew Collier), G (Summons issued by certified mail to Robert James) and H (case docket). To the knowledge of Defendant C.T. Taylor, no other motions, pleadings, or papers have been filed in the state court case. The basis of this removal is 28 U.S.C. § 1331, which provides that the “district courts shall have original jurisdiction of all civil actions arising under the Constitution, laws, or treaties of the United States.” This Notice of Removal is also timely filed pursuant to 28 U.S.C. § 1446(b). In support of removal, Defendant C.T. Taylor states the following: Sandra Kurt, Summit County Clerk of Courts CV-2022-11-3991 CRRA SMAR MOPS BZ RCI? PPE REGM 12/30/22 2°BPS. PagelD #: 2 Page 5 of 55 I BACKGROUND 1 On or about November 23, 2022, Plaintiff Christal Heiney (“Plaintiff”) initiated this case by filing a Complaint in Common Pleas Court for Summit County, Ohio at Docket Number CV-2022-11-3991. 2. Plaintiff named C.T. Taylor Company, Inc., Karen Schippers, Matthew Collier, and Robert James as Defendants in the Complaint. 3. Defendant C.T. Taylor was served with the Complaint on December 2, 2022. 4. No Defendant, other than Defendant C.T. Taylor, has been served with the Complaint. 5. Notice of the filing of this Notice of Removal will be given to all parties and the Clerk of Courts in accordance with 28 U.S.C. § 1446(d), and this Notice of Removal is being served per the Certificate of Service. 6. Copies of all documents filed or served in the state court action, as well as a copy of the docket sheet in the state court action, are filed contemporaneously herewith and adopted herein by reference, as Exhibits A through H. No other pleadings have been received by Defendant C.T. Taylor or filed in the case. I REMOVAL IS PROPER BASED ON FEDERAL QUESTION J URISDICTION 7. According to the Complaint, Plaintiff is a resident of Portage County, Ohio. 8. Defendant C.T. Taylor is a corporation incorporated under the laws of the State of Ohio, with its principal place of business in Summit County, Ohio. 9. Among other claims, Plaintiff seeks relief for disability discrimination in violation of the Americans with Disabilities Act, 42 U.S.C. § 12101 et seq,, and retaliation in violation of the Family and Medical Leave Act, 29 U.S.C. § 2601 et seq. Sandra Kurt, Summit County Clerk of Courts CV-2022-11-3991 CRRA SAR MOPS BF BRRCGP2 PEPE REGM 12/30/22 3NOPS. PagelD #: 3 Page 6 of 55 10. The Court has original jurisdiction over these causes of action pursuant to 28 U.S.C. § 1331, because they arise under the federal statute, namely the Americans with Disabilities Act and the Family and Medical Leave Act. 11. Supplemental jurisdiction is conferred over Plaintiff's state law claims against Defendant C.T. Taylor under the federal supplemental jurisdiction statute, 28 U.S.C. § 1367, because the state law claims are so related to Plaintiff's claims for disability discrimination in violation of the Americans with Disabilities Act and retaliation in violation of the Family and Medical Leave Act that they form part of the same case or controversy under Article III of the U.S. Constitution. All claims are related to the termination of Plaintiff's employment with Defendant C.T. Taylor and the reasons for such termination. Because the state law claims arise from the same common nucleus of facts and circumstances as the Americans with Disabilities Act and Family and Medical Leave Act claims, this action against Defendants is properly removable to this Court. 12. Therefore, removal jurisdiction exists under28 U.S.C. § 1441(a). 13. This Notice of Removal is timely filed with the Court pursuant to 28 U.S.C. § 1446(b), because this notice is filed within 30 days of service upon Defendant C.T. Taylor. 14. Venue may be properly had in this district under28 U.S.C. §§ 1391(b)(1) and (2), because at least one Defendant resides in this district and all Defendants are residents of the State of Ohio, and because a substantial part of the events or omissions allegedly giving rise to the claim occurred in this district 15. Tn accordance with the time requirements of Federal Rule of Civil Procedure 81, Defendant C.T. Taylor will timely file a response to the Complaint. Defendant C.T. Taylor does Sandra Kurt, Summit County Clerk of Courts CV-2022-11-3991 CRRA SAR MOPS RF REG? PPE REGM 12/30/22 ANOPS. PagelD #: 4 Page 7 of 55 not waive, and to the contrary, expressly preserves, any and all rights and defenses it may assert by motion or otherwise with respect to the action and Complaint. WHEREFORE, the above-captioned action, pending in the Court of Common Pleas for Summit County, Ohio, is hereby removed therefrom to this Court. Defendant C.T. Taylor further states that this matter should remain in federal district court. OF COUNSEL: Respectfully submitted, HAHN LOESER & PARKS LLP /s/ Ann E. Knuth Ann E. Knuth (0061566) aknuth@hahnlaw.com 200 Public Suite 2800 Cleveland, Ohio 44114-2316 Phone: 216.621.0150 Fax: 216.241.2824 Attol for Defendant, C.T. Taylor Company, Inc. 4 Sandra Kurt, Summit County Clerk of Courts CV-2022-11-3991 CRRA SAR MORPS BF BRCIP2 PPE REGM 12/30/22 SNOPS. PagelD #:5 Page 8 of 55 CERTIFICATE OF SERVICE I hereby certify that, on December 30, 2022, a copy of the foregoing Defendant C.T. Taylor Company, Inc.’s Notice Of Removal was filed with the Clerk of Court via the Court’s CM/ECF filing system. Notice of this filing will be sent to all parties by operation of the Court’s electronic filing system and via electronic mail and regular United States mail, sufficient postage prepaid, upon the following counsel of record and parties: Daniel S. Dubow Karen Schippers daniel.dubow@spitzlawfirm.com C/o HL Statutory Agent, Inc. Kevin A. Buryanek 200 Public Square, Suite 2800 kevin. buryanek@spitzlawfirm.com Cleveland, OH 44114 SPITZ LAW FIRM 25825 Science Park Drive, Suite 200 Defendant Beachwood, OH 44122 Attorneys for Plaintiff Matthew Collier C/o HL Statutory Agent, Inc. 200 Public Square, Suite 2800 Cleveland, OH 44114 Defendant Robert James C/o HL Statutory Agent, Inc. 200 Public Square, Suite 2800 Cleveland, OH 44114 Defendant /s/Ann E. Knuth One of Attorney for Defendant C.T. Taylor Company, Inc. Sandra Kurt, Summit County Clerk of Courts CV-2022-11-3991 CASE BOSD BESS CA COVERCSHER2 bf 2. PagelD #: 6 Page 9 of 55 JS44_ (Rev. 3/22) The JS 44 cover sheet and the information contained her in neither replace nor supplement the filing and service of pleadings or other papers as required by la xcept as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS O1 EXT PAGE OF THIS FORM.) I. (a) PLAINTIFFS DEFENDANTS C.T. Taylor Company, Inc., Karen Schippers, CHRISTAL HEINEY Matthew Collier, and Robert James (b) County of Residence of First Listed Plaintiff Portage County of Residence of First Listed Defendant Summit (EXCEPT U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY) NOTE: IN ND CONDEMNATION CASE! THE LOCATION OF ‘THE TRACT OF LAND INVOLVED, (c) Attorneys (Firm Name, Address, and Telephone Number) Attomeys (if Known) Ann E. Knuth (0061566) HAHN LOESER &PARKS Daniel S. Dubow(0095530) KevinA. B 0099300), SPITZ aknuth@hahnlaw.com, 200 Public Square, Suite 2800 daniel.dubow@spitzlawfirm.com; kevin.buryanek@spitzlawfirm.com, 4Cleveland, Ohio 44114-2316, Phone: 216.621.0150 5825 Science Park Dr., Suite 200, Beachwood, OH 44122, 216-291-4744 II. BASIS OF JURISDICTION (Pace an “x” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (piacean “x” in One Box for Plaintiff (For Diversity Cases Only) and One Box for Defendant) Oh U.S. Government Federal Question PTF DE PTF DEF Plaintiff (US. Government Not a Party) Citizen of This ate Oh Ou Incorporated or Principal Place O4 Oe of Business In This State [2 US. Government (4 Diversity Citizen of Another State D2 D2 Incorporated and Principal Place Os Os Defendant (ndicate Citizenship of Parties in Item I) of Business In Another State Citizen or Subject of a CO 3 Foreign Nation Oe Oe Foreign Country IV. NATURE OF SUIT (Place an “x” in One Box Only) Click here for: Nature of Suit Code Descriptions. [ CONTRACT. TORTS: FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES, 110 Insurance 120 Marine 130 Miller Act H PERSONAL INJURY 310 Airplane 315 Airplane Product, PERSONAL INJURY | ]625 Drug Related Seizure 5 Personal Injury - Product Liability of Property 21 USC 881 [1690 other H 422 Appeal 28 USC 158 423 Withdrawal 28 USC 157 Hd 375 False Claims Act 376 Qui Tam (31 USC 3729(a)) 140 Negotiable Instrument Liability (1367 Health Care |] 400 State Reapportionment [150 Recovery of Overpayment [7] 320 Assault, Libel & Pharmaceutical INTELLECTUAL 410 Antitrust & Enforcement of Judgment] Slander Personal Injury PROPERTY RIGHTS 430 Banks and Banking B 151 Medicare Act 152 Recovery of Defaulted |] 330 Federal Employers’ Liability Product Liability [1 368 Asbestos Personal [] 820 Copyrights d 830 Patent ~ 450 Commerce 460 Deportation Student Loans (Excludes Veterans) [21153 Recovery of Overpayment H 340 Marine 345 Marine Product Liability Injury Product Liability PERSONAL PROPERTY LABOR 835 Patent Abbreviated ‘New Drug Application [L] 840 Trademark 470 Racketeer Influenced and Corrupt Organizations 480 Consumer Credit, of Veteran’s Benefits 1 160 Stockholders Suits [J 190 Other Contract H 350 Motor Vehi 355 Motor Vehi le Product Liability B 370 Other Fraud 371 Truth in Lending [J 380 Other Personal 1710 Fair Labor Standards ‘Act |_]720 Labor/Management 880 Defend Trade Secrets Act of 2016 SOCIAL SECURITY (15 USC 1681 or 1692) 485 Telephone Consumer Protection Act H 195 Contract Product Liability |] 360 Other Personal Property Damage Relations 861 HLA (1395ff) 490 Cable/Sat TV 196 Franchise Injury [] 362 Personal Injury - Medical Malpractice [1385 Property Damage Product Liability R 740 Railway Labor Act '751 Family and Medical Leave Act 862 Black Lung (923) 863 DIWC/DIWW (405(g)) 864 SSID Title XVI 850 Securities/Commodities Exchange |] 890 Other Statutory Actions REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 90 Other Labor Litigation I] 865 RSI (405(2)) [_] 891 Agricultural Acts [_]210 Land Condemnation [_] 440 Other Civil Rights Habeas Corpus: }791 Employee Retirement 893 Environmental Matters [_] 220 Foreclosure [| 441 Voting [7 463 Alien Detainee Income Security Act FEDERAL TAX SUITS ] 895 Freedom of Information ; I] 510 Motions to Vacate 230 Rent Lease & Ejectment 240 Torts to Land 245 Tort Product Liability H 442 Employment 443 Housing/ Accommodations Sentence [_] 530 General 870 Taxes (U.S. Plaintiff or Defendant) [) 871 1Rs—Third Party 896 Ai H tion 899 Administrative Procedure [_) 290 All Other Real Property [-] 445 Amer. wiDisabilities -[LJ 535 Death Penalty TMMIGRATION 26 USC 7609 ActReview or Appeal of Employment Other: [462 Naturalization Application| Agency Decision |] 446 Amer. w/Disabilities 540 Mandamus & Other }465 Other Immigration [_] 950 Constitutionality of Other 550 Civil Rights Actions State Statutes [_] 448 Education 555 Prison Condition 560 Civil Detainee - Conditions of Confinement V. ORIGIN (Place an “X” in One Box Only) [! Original [KJ2 Removed from o3 Remanded from of Reinstated or O35 Transferred from. 6 Multidistrict 8 Multidistrict Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation - (specify) Transfer Direct File CSG sor BE OE Ego" cite jurisdictional statutes unless diversity) VI. CAUSE OF ACTION Brief description of cause: I scrimination in violation of the ADA and retaliation in violation of the FMLA. VIL. REQUESTED IN (1 CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint: COMPLAINT: UNDER RUL 23, F.R.Cv.P. $25,000.00 JURY DEMAND: Klves No VII. RELATED CASE(S) IF ANY instructions): UDG DOCKET NUMBER r T SIGNATURE OF ATTORNEY OF RECORD. 12/30/2022 /s/ Am E. FOR OFFICE USE ONLY RECEIPT if AMOUNT APPLYING IEP JUDGE MAG. JUDGE Sandra Kurt, Summit County Clerk of Courts CV-2022-11-3991 CAE ASPET ANY USAF RHO 224 OE SHARAM 12/30/22 B°BF2. PagelD #: 7 Page 10 of 55 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO I. Civil Categories: (Please check one category only _). 4 xX General Civil 2 Administrative Review/Social Security 3 Habeas Corpus Death Penalty “If under Title 28, §2255, name the SENTENCING JUDGE. CASE NUMBER: Il. RELATED OR REFILED CASES See LR 3.1 which provides in pertinent part: "If an action is filed or removed to this Court and assigned to a District Judge after which it is discontinued, dismissed or remanded to a State court, and subsequently refiled, it shall be assigned to the same Judge who received the initial case assignment without regardfor the place of holding court in which the case was refiled. Counsel or a party without counsel shall be responsible for bringing such cases to the attention of the Court by responding to the questions included on the Civil Cover Sheet." This action: is RELATED to another PENDING civil case [_ is a REFILED case was PREVIOUSLY REMANDED If applicable, please indicate on page 1 in section VIII, the name of the Judge and case number. I. In accordance with Local Civil Rule 3.8, actions involving counties in the Eastern Division shall be filed at any of the divisional offices therein. Actions involving counties in the Western Division shall be filed at the Toledo office. For the purpose of determining the proper division, and for statistical reasons, the following information is requested. ANSWER ONE PARAGRAPH ONLY. ANSWER PARAGRAPHS 1 THRU 3 IN ORDER. UPON FINDING WHICH PARAGRAPH APPLIES TO YOUR CASE, ANSWER IT AND STOP. (1) Resident defendant If the defendant resides in a county within this district, please set forth the name of such county COUNTY: Summit Corporation For the purpose of answering the above, a corporation is deemed to be a resident of that county in which it has its principal place of business in that district. (2) Non-Resident defendant, If no defendant is a resident of a county in this district, please set forth the county wherein the cause of action arose or the event complained of occurred. COUNTY: (3) Other Cases. If no defendant is a resident of this district, or if the defendant is a corporation not having a principle place of business within the district, and the cause of action arose or the event complained of occurred outside this district, please set forth the county of the plaintiff's residence. COUNTY IV. The Counties in the Northern District of Ohio are divided into divisions as shown below. After the county is determined in Section III, please check the appropriate division. EASTERN DIVISION X]| akron (Counties: Carroll, Holmes, Portage, Stark, Summit, Tuscarawas and Wayne) (Counties: Ashland, Ashtabula, Crawford, Cuyahoga, Geauga, CLEVELAND Lake, Lorain, Medina and Richland) YOUNGSTOWN (Counties: Columbiana, Mahoning and Trumbull) WESTERN DIVISION TOLEDO (Counties: Allen, Auglaize, Defiance, Erie, Fulton, Hancock, Hardin, Henry, Huron, Lucas, Marion, Mercer, Ottawa, Paulding, Putnam, Sandusky, Seneca VanWert, Williams, Wood and Wyandot) Sandra Kurt, Summit County Clerk of Courts CV-2022-11-3991 CASAS SUR RSA BGO F024 OS RAY 12/30/22 N°BF3. PagelD #:8 Page 11 of 55 EXHIBIT A Sandra Kurt, Summit County Clerk of Courts CV-2022-11-3997 LLM, CARE SAN OPS couny Courter cbminareIeae > PagelD #: 9 iY Civil Division ya. aA WAS:<’ QT Instructions: Complete the following form and file with the Summit County Clerk of Courts - Civil Divsion, located at: 205 South High Street, 1st Floor, Akron, Ohio 44308. (Case Caption: CHRISTAL HEINEY Plaintiff Case Number CT TAYLOR COMPANY, INC. Defendant INSTRUCTIONS FOR SERVICE To Clerk: You are hereby requestd to make service upon the following by: FedEx Certified Mail Regular Mail Sheriff Service (Personal) Sheriff Service (Personal or Residential) Personal Service Process Server: Please Serve the following pleadings: TS Complaint Parties to be served: Name: CT TAYLOR COMPANY, INC. Name: KAREN SCHIPPERS Address 5802 Akron-Cleveland Road Address c/o HL Statutory Agent, Inc Address Address 200 Public Square, Suite 2800 City Hudson State OH Zip 44236 City Cleveland State OH Zip 44114 Name: CT TAYLOR COMPANY, INC. Name: MATTHEW COLLIER Address c/o HL Statutory Agent, Inc., Statutory Agent Address c/o HL Statutory Agent, Inc. Address 200 Public Square, Suite 2800 Address 200 Public Square, Suite 2800 City Cleveland State OH Zip 44114 City Cleveland State OH Zip 44114 s/Kevin A. Buryanek 0099300 Attorney for Plaintiff (or pro se litigant) Supreme Ct # VFormora Rev 1. 20131002-08/17, Sandra Kurt, Summit County Clerk of Courts CV-2022-11-3997 CR ee CaS Re Girone er CARMA ie 3: PagelD #: 10 LLM, iY Civil Division ya. aA WAS:<’ QT Instructions: Complete the following form and file with the Summit County Clerk of Courts - Civil Divsion, located at: 205 South High Street, 1st Floor, Akron, Ohio 44308. (Case Caption: CHRISTAL HEINEY Plaintiff Case Number CT TAYLOR COMPANY, INC. Defendant INSTRUCTIONS FOR SERVICE To Clerk: You are hereby requestd to make service upon the following by: FedEx Certified Mail Regular Mail Sheriff Service (Personal) Sheriff Service (Personal or Residential) Personal Service Process Server: Please Serve the following pleadings: TS Complaint Parties to be served: Name: ROBERT JAMES Name: Address c/o HL Statutory Agent, Inc. Address Address 200 Public Square, Suite 2800 Address City Cleveland State OH Zip 44114 City State Zip Name: Name: Address Address Address Address City State Zip City State Zip s/Kevin A. Buryanek 0099300 Attorney for Plaintiff (or pro se litigant) Supreme Ct # VFormora Rev 1. 20131002-08/17, Sandra Kurt, Summit County Clerk of Courts CV-2022-11-3991 Cage TS BODES DRE rs FH 12/30/22 1'SFS0. PagelD #: 11 Page 4oF55 EXHIBIT B Sandra Kurt, Summit County Clerk of Courts CV-2022-11-3991 CaS BPs MORO MARGARET GAN 20R2 ¢8:BH ARAM 5/30/22 2°80. PagelD #: 12 Page 3508295 IN THE COURT OF COMMON PLEAS SUMMIT COUNTY, OHIO CHRISTAL HEINEY ) CASE NO. 326 East Central Avenue ) Ravenna, OH 44266 ) JUDGE: Plaintiff, Vv. COMPLAINT FOR DAMAGES AND CT TAYLOR COMPANY, INC. INJUNCTIVE RELIEF 5802 Akron-Cleveland Road Hudson, OH 44236 JURY DEMAND ENDORSED HEREIN -also serve- CT TAYLOR COMPANY, INC c/o HL Statutory Agent, Inc. Statutory Agent 200 Pu