Preview
CV-2020-02-0578 ROWLANDS, MARY MARGARET 08/30/2022 12:05:58 PM MQUH Page 1of9
IN THE COURT OF COMMON PLEAS
CIVIL DIVISION
SUMMIT COUNTY, OHIO
MICHAEL A. RENNE, CASE NO.: CV 2020-02-0578
AS GUARDIAN OF THE ESTATE OF
L.P., AMINOR
Plaintiff
Vv. JUDGE MARY MARGARET
ROWLANDS
SUMMA HEALTH SYSTEMS
Defendant
MOTION TO QUASH
Now comes Summit County Children Services ("SCCS"), by and through counsel, and
pursuant to Civ R 45(C)(3)(b)(d) respectfully moves the Court to quash the records subpoena
served upon SCCS in the within matter.
Plaintiff has subpoenaed from SCCS documentation including agency records, medical
records, educational, school and/or social service records, records pertaining to the child’s
medical coverage, bills for treatment, photographs or videos of the child, court orders regarding
the child’s custody status, and information identifying the name and residential address for all
persons identified who the child has lived with from February 12, 2019.
As Plaintiff is aware, the child was in the Temporary Custody of SCCS when the
biological mother initiated the within lawsuit. The biological mother’s parental rights were
subsequently involuntarily terminated, and the child was placed in the Permanent Custody of
SCCS, pursuant to Summit County Juvenile Court Case No. DN 19-05-458. Permanent Custody
Sandra Kurt, Summit County Clerk of Courts
CV-2020-02-0578 ROWLANDS, MARY MARGARET 08/30/2022 12:05:58 PM MQUH Page 2 of 9
was affirmed on appeal. See In re L.P., 9" Dist. No. 29963, 2021-Ohio-3183. It appears that
biological mother was removed as a plaintiff in the within case, and the plaintiff in this matter is
now the attorney Mr. Renne who was appointed as Guardian of the Estate for the child in
Summit County Probate Court.
SCCS holds Permanent Custody and stands in full /oco parentis to the child. SCCS never
initiated nor consented to the within lawsuit. The Attorney/Guardian ad Litem who was
appointed to represent the best interest of the child in Summit County Juvenile Court did not
initiate or consent to the within lawsuit.
At this time, SCCS is standing neutral because the child’s prospective adoptive parents
are interested in pursuing this lawsuit. The Court may wish to consider staying this matter until
the child has been adopted.
On November 9, 2021, the Summit County Probate Court issued an Order (see attached
Exhibit A, Summit County Probate Court Case No. 2020 GM 00028) that requires specific steps
from SCCS in working with Guardian of the Estate Michael Renne. SCCS has abided by this
Order. SCCS has disclosed to Mr. Renne a list of the medical providers, institutions, and social
services agencies that the child has received services from. SCCS has provided the names of the
individual physicians who work with the child. SCCS has executed and renewed releases as
requested. SCCS has worked with counsel for a mutually agreeable date for the 30 minute “meet
and greet” with the child, which was set for August 9, 2022.
FOSTER PARENT AND/OR PROSPECTIVE ADOPTIVE PARENT IDENTITY:
SCCS strongly urges the Court to quash the subpoena requiring disclosure of the name,
residential address, and contact information for all persons who have lived with the minor child
Sandra Kurt, Summit County Clerk of Courts
CV-2020-02-0578 ROWLANDS, MARY MARGARET 08/30/2022 12:05:58 PM MQUH Page 3 of 9
since February 12, 2019. The individuals with whom the child has resided are foster parents.
Other foster children placed in the home would also fall under this category.
O.R.C. 5101.29(D) states that names, documentation, and other identifying information
regarding a foster caregiver or prospective foster caregiver, when contained in a record held by a
county agency, are not public records for purposes of section 149.43 of the Revised Code. The
Ohio Supreme Court has reiterated this confidentiality where a foster caregiver receives federal
foster care maintenance on behalf of a child. State ex rel. Cincinnati Enquirer v. Jones-Kelly,
118 Ohio St.3d 81, 886 N.E.2d 206 (2008). Additionally, the records maintained by a public
children services agency are confidential per O.R.C. 5153.17.
SCCS has a Policy to maintain the confidentiality of foster parent identity (see attached
Exhibit B). The public purpose behind the agency’s policy as well as the aforementioned legal
authority is to maintain confidentiality and prevent harassment of individuals who opt to undergo
hours of training and open their homes to provide care for abused, neglected and dependent
children. To allow a foster parent’s identifying information to be disclosed, without their
consent, will have a chilling effect upon those who might consider becoming foster parents.
In the within case, the child’s current foster parents do not consent to their personal
identifying information being disclosed in this lawsuit. If and when the child is placed with his
prospective adoptive parents, SCCS shares the concern of maintaining their confidentiality and
privacy.
Furthermore, because the child’s biological mother instituted the within lawsuit prior to
her parental rights being terminated, biological mother is aware of the pending litigation.
Information on the public docket that identifies the child’s foster parent(s) or potential adoptive
parent(s) could jeopardize the safety and privacy of the child and the families. It could even lead
Sandra Kurt, Summit County Clerk of Courts
CV-2020-02-0578 ROWLANDS, MARY MARGARET 08/30/2022 12:05:58 PM MQUH Page 4 of 9
to a placement disruption if the family chooses to put in their notice to terminate the child’s
placement in their home. None of this would be in the child’s best interest.
MEDICAL RECORDS AND BILLS FROM OTHER ENTITIES:
SCCS does not disseminate medical records that the agency might have received from
other entities. SCCS has already executed releases to allow plaintiff to access the records
regarding the minor child L.P. directly from the child’s providers, including the child’s medical
providers as well as school/educational records and any records from other providers. SCCS
renewed the releases as recently as July of 2022. With these executed releases, plaintiffs should
be able to subpoena full and complete medical records and bills directly from the providers.
AGENCY RECORDS:
Insofar as SCCS records are requested, the subpoena should be quashed as it calls for the
disclosure of privileged or otherwise protected confidential information relating to a
child/family, which SCCS is not permitted to divulge absent a court order.
Under Ohio law, written records of investigations relating to children performed by
public children services agencies ("PCSA") are confidential. R.C. 5153.17, O.A.C. 5101:2-33-
21 and R.C. 2151.421 (Records maintained by a PCSA are confidential and may not be
disseminated.) The Ohio Supreme Court has held that investigatory records of child abuse,
neglect and/or dependency are not public records. State ex re Renfro v. Cuyahoga County Dept.
of Human Services, 54 Ohio St3d 25, 560 NE2d 230 (1990). Rather, they are confidential
records that are not subject to disclosure. Jd.
Sandra Kurt, Summit County Clerk of Courts
CV-2020-02-0578 ROWLANDS, MARY MARGARET 08/30/2022 12:05:58 PM MQUH Page 5 of 9
Although the provisions of R.C. 5153.17 and R.C. 2151.421 grant confidentiality to
PCSA records, it has been established that the confidentiality is not absolute. (See, e.g., State ex
rel. Renfro v. Cuyahoga County Dep't of Human Services, id.; Hughes v. Butler County Children
Services Bd., 12" Dist. Butler No. CA2001-07-178, 2002-Ohio-184; Johnson v. Johnson, 134
Ohio App. 3d 579, 583, 731 N.E.2d 1144 (3rd Dist.1999); Sharpe v. Sharpe, 85 Ohio App. 3d
638, 642, 620 N.E.2d 916 (11th Dist.1993).) To gain access to records kept pursuant to R.C.
5153.17, it is necessary for a person “to demonstrate ‘good cause’ that outweighs any need to
keep the records confidential.” Wiley v. Summit County Children Services, 9th Dist. No. 23372,
2007-Ohio-1476, at 410.
The determination as to whether there is “good cause” to disclose records involves two
issues. First, whether disclosure is in the best interests of the child; and second, whether due
process rights are implicated. Swartzentruber v. Orrville Grace Brethren Church, 163 Ohio
App. 3d 96, 2005-Ohio-4264, 836 N.E. 2d 619, at §9; Johnson at 583; 1991 Ohio Atty Gen.Ops.
No. 91-003, at 2-19 to 2-20. In the instant case, Plaintiff has not demonstrated whether good
cause exists to produce the records.
A court may conduct an in-camera review of child abuse reports or records and “has the
inherent power to order disclosure of such reports where: (1) the records or reports are relevant
to the pending action; (2) good cause for such a request has been established by the person
seeking disclosure; and (3) where admission of the records or reports outweighs the
confidentiality considerations set forth in R.C. 5153.17 and R.C. 2151.421(H)(1)."_ See Johnson
at 583; See also Nash v. Cleveland Clinic, 8th Dist. Cuyahoga No. 99128, 2013 Ohio 3618;
Vaughn v. City of Shaker Heights, No. 1:10 CV 609, 2013 WL 3940790 (N.D. Ohio 2013).
Sandra Kurt, Summit County Clerk of Courts
CV-2020-02-0578 ROWLANDS, MARY MARGARET 08/30/2022 12:05:58 PM MQUH Page 6 of 9
The Ohio Attorney General has held that if a PCSA receives a subpoena for confidential
information—issued in conjunction with a criminal and/or civil proceeding—then the PCSA, in
order to preserve the confidentiality prescribed by statute, may file a motion to quash the
subpoena, thereby seeking from the court an in camera review of the PCSA records and a
determination as to whether and to what extent the information may be disclosed. 2007 Ohio
Atty. Gen.Op. No. 2007-025.
WHEREFORE, SCCS requests that the Court quash the records subpoena in its entirety.
Should the Court not quash the subpoena in its entirety, SCCS requests a reasonable amount of
time be permitted for the agency to compile and submit the records to the Court for in camera
review if the Court so orders. SCCS will need time beyond September 8, 2022 to comply. If the
Court deems that the records should be released, then SCCS would further request protective
orders prohibiting their re-release and/or dissemination beyond purposes of the above captioned
case, and for purposes of maintaining the records under seal. SCCS especially urges the Court to
protect the confidentiality of the child’s foster and/or prospective adoptive caregivers.
Respectfully submitted,
_/s/_Catherine P. Van Horne __
Catherine P. Van Horne
Deputy Executive Director/
Chief Legal Counsel
Summit County Children Services
264 S. Arlington Street
Akron, Ohio 44306
330-379-2002
Sup. Ct. No: 0061082
catherine.pomeroy-vanhorne@summitkids.org
Sandra Kurt, Summit County Clerk of Courts
CV-2020-02-0578 ROWLANDS, MARY MARGARET 08/30/2022 12:05:58 PM MQUH Page 7 of 9
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing motion was sent by regular U.S. mail on
the 31st_ day of August, 2022, to the following individuals:
Attorneys for Plaintiff
Lisa Weinstein
Edward Aucoin, Jr.
Grant & Eisenhoffer
30 N. Lasalle St., Suite 2350
Chicago, IL 60602
Pamela Pantages
Nurenberg Paris Heller & McCarthy, LPA
600 Superior Ave. East, Suite 1200
Cleveland, OH 44114
Attorney for Defendant
Gregory Rossi
Hanna Campbell & Powell
3737 Embassy Parkway, Suite 100
Akron, OH 44333
/s/ Catherine P. Van Horne
Catherine P. Van Horne
Chief Legal Counsel
Summit County Children Services
CVH
cc: SCCS, Legal Department
Sandra Kurt, Summit County Clerk of Courts
CV-2020-02-0578 ROWLANDS, MARY MARGARET 08/30/2022 12:05:58 PM MQUH Page 8 of 9
RECEIVED
By sheas at is pi, Nov 16, 2024
ROBATE COURT
COUNTY OF suMMat, OH
NOV 9 2021
NORE MARSH STORMEL
PROBATE COURT OF SUMMIT COUNTY, OHIO JUDGE EL!
ELINORE MARSH STORMER, JUDGE
IN THE MATTER OF GUARDIANSHIP OF LEVI LEON PATTERSON, a minor
Case No. 2020 GM 00028
ORDER
Michael A. Renne, Guardian of the Estate of Levi Leon Patterson, a minor, having filed
a Petition for Access to Minor and Minor's Medical and Education/Social Services Records,
has shown good cause for said Petition and the Court finds that the relief requested therein is in
the best interest of Levi Leon Patterson. The Court grants the Guardian's Petition and orders
Summit County Children Services, as permanent custodian of Levi Patterson, to do the
following:
Allow the experts in the fields of pediatric neurology, physical medicine
and rehabilitation, life care planning and pediatric neuropsychology
retained by Mr. Renne and his counsel in the civil matter to each examine
Levi in order to prepare their reports and/or life care plan;
Disclose to Mr. Renne and his counsel in the civil matter all medical care that
Levi has received since his birth and update that information as Levi receives
additional medical treatment for the pendency of the civil matter;
Disclose to Mr. Renne and his counsel in the civil matter all educational
institutions and social services agencies, including but not limited to Early
Intervention, Help Me Grow, Home Visiting, and Moms and Babies First,
that Levi has received services from since his birth and update that
information as Levi receives additional services for the pendency of the
civil matter;
Execute any medical and/or education/social service authorizations that Mr.
Renne and his counsel in the civil matter submit for Levi's records throughout
the pendency of the civil matter;
Allow defense counsel in the civil matter to have a “meet and greet" not to last
longer than 30 minutes on a date and time agreeable by SCCS;
Allow Mr. Renne and his counsel's videographer to prepare a Day in the Life
video of Levi for use at mediation and/or trial of the civil matter; and
Se Fil
8. Present Levi at trial of the civil matter for a brief introduction to the jury ona
date and ti ho: Mr. Renne an his counsel..
Judge
“
23170995.1
Sandra Kurt, Summit County
CoS Badu A
Clerk of Courts
CV-2020-02-0578 ROWLANDS, MARY MARGARET 08/30/2022 12:05:58 PM MQUH Page 9 of 9
Summit County
CHILDREN SERVICES
Building Families . . Building Futures
[conFrost
ce carghen
rentyt
SUMMIT COUNTY CHILDREN SERVICES
ORC: 5153.17 ORIGINAL: 5/24/07
OAC: N/A REVISIONS: 8/03/18
USC: N/A RELATED FORM(S): N/A
CFR: N/A RELATED PROCEDURE/POLICY(IES): N/A
O Administrative O Legal
O Fiscal O Safety & Security
C1 Human Resources O Social Services - All Departments
0 Information Technology Social Services - Foster & Adoption
All Staff & Bargaining Unit 0 Non-Bargaining 0 Management 0
POLICY:
Summit County Children Services (SCCS) will assure confidentiality of foster caregiver's
identity with the birth family and friends of children placed in the foster home.
PROCEDURE:
SCCS staff will not release the identity of a foster caregiver to the birth family or friends
of a child placed with the foster caregiver without the permission of the foster parent. It
is recommended that the child's caseworker discuss the foster parent's comfort with
release of identity regularly throughout the case as the foster caregiver's decision on the
release of their identity may change as they know the child's family and friends.
Secs
Sandra Kurt, Summit County Clerk abet 0
Preview
CV-2020-02-0578 ROWLANDS, MARY MARGARET 08/30/2022 12:05:58 PM MQUH Page 1of9 IN THE COURT OF COMMON PLEAS CIVIL DIVISION SUMMIT COUNTY, OHIO MICHAEL A. RENNE, CASE NO.: CV 2020-02-0578 AS GUARDIAN OF THE ESTATE OF L.P., AMINOR Plaintiff Vv. JUDGE MARY MARGARET ROWLANDS SUMMA HEALTH SYSTEMS Defendant MOTION TO QUASH Now comes Summit County Children Services ("SCCS"), by and through counsel, and pursuant to Civ R 45(C)(3)(b)(d) respectfully moves the Court to quash the records subpoena served upon SCCS in the within matter. Plaintiff has subpoenaed from SCCS documentation including agency records, medical records, educational, school and/or social service records, records pertaining to the child’s medical coverage, bills for treatment, photographs or videos of the child, court orders regarding the child’s custody status, and information identifying the name and residential address for all persons identified who the child has lived with from February 12, 2019. As Plaintiff is aware, the child was in the Temporary Custody of SCCS when the biological mother initiated the within lawsuit. The biological mother’s parental rights were subsequently involuntarily terminated, and the child was placed in the Permanent Custody of SCCS, pursuant to Summit County Juvenile Court Case No. DN 19-05-458. Permanent Custody Sandra Kurt, Summit County Clerk of Courts CV-2020-02-0578 ROWLANDS, MARY MARGARET 08/30/2022 12:05:58 PM MQUH Page 2 of 9 was affirmed on appeal. See In re L.P., 9" Dist. No. 29963, 2021-Ohio-3183. It appears that biological mother was removed as a plaintiff in the within case, and the plaintiff in this matter is now the attorney Mr. Renne who was appointed as Guardian of the Estate for the child in Summit County Probate Court. SCCS holds Permanent Custody and stands in full /oco parentis to the child. SCCS never initiated nor consented to the within lawsuit. The Attorney/Guardian ad Litem who was appointed to represent the best interest of the child in Summit County Juvenile Court did not initiate or consent to the within lawsuit. At this time, SCCS is standing neutral because the child’s prospective adoptive parents are interested in pursuing this lawsuit. The Court may wish to consider staying this matter until the child has been adopted. On November 9, 2021, the Summit County Probate Court issued an Order (see attached Exhibit A, Summit County Probate Court Case No. 2020 GM 00028) that requires specific steps from SCCS in working with Guardian of the Estate Michael Renne. SCCS has abided by this Order. SCCS has disclosed to Mr. Renne a list of the medical providers, institutions, and social services agencies that the child has received services from. SCCS has provided the names of the individual physicians who work with the child. SCCS has executed and renewed releases as requested. SCCS has worked with counsel for a mutually agreeable date for the 30 minute “meet and greet” with the child, which was set for August 9, 2022. FOSTER PARENT AND/OR PROSPECTIVE ADOPTIVE PARENT IDENTITY: SCCS strongly urges the Court to quash the subpoena requiring disclosure of the name, residential address, and contact information for all persons who have lived with the minor child Sandra Kurt, Summit County Clerk of Courts CV-2020-02-0578 ROWLANDS, MARY MARGARET 08/30/2022 12:05:58 PM MQUH Page 3 of 9 since February 12, 2019. The individuals with whom the child has resided are foster parents. Other foster children placed in the home would also fall under this category. O.R.C. 5101.29(D) states that names, documentation, and other identifying information regarding a foster caregiver or prospective foster caregiver, when contained in a record held by a county agency, are not public records for purposes of section 149.43 of the Revised Code. The Ohio Supreme Court has reiterated this confidentiality where a foster caregiver receives federal foster care maintenance on behalf of a child. State ex rel. Cincinnati Enquirer v. Jones-Kelly, 118 Ohio St.3d 81, 886 N.E.2d 206 (2008). Additionally, the records maintained by a public children services agency are confidential per O.R.C. 5153.17. SCCS has a Policy to maintain the confidentiality of foster parent identity (see attached Exhibit B). The public purpose behind the agency’s policy as well as the aforementioned legal authority is to maintain confidentiality and prevent harassment of individuals who opt to undergo hours of training and open their homes to provide care for abused, neglected and dependent children. To allow a foster parent’s identifying information to be disclosed, without their consent, will have a chilling effect upon those who might consider becoming foster parents. In the within case, the child’s current foster parents do not consent to their personal identifying information being disclosed in this lawsuit. If and when the child is placed with his prospective adoptive parents, SCCS shares the concern of maintaining their confidentiality and privacy. Furthermore, because the child’s biological mother instituted the within lawsuit prior to her parental rights being terminated, biological mother is aware of the pending litigation. Information on the public docket that identifies the child’s foster parent(s) or potential adoptive parent(s) could jeopardize the safety and privacy of the child and the families. It could even lead Sandra Kurt, Summit County Clerk of Courts CV-2020-02-0578 ROWLANDS, MARY MARGARET 08/30/2022 12:05:58 PM MQUH Page 4 of 9 to a placement disruption if the family chooses to put in their notice to terminate the child’s placement in their home. None of this would be in the child’s best interest. MEDICAL RECORDS AND BILLS FROM OTHER ENTITIES: SCCS does not disseminate medical records that the agency might have received from other entities. SCCS has already executed releases to allow plaintiff to access the records regarding the minor child L.P. directly from the child’s providers, including the child’s medical providers as well as school/educational records and any records from other providers. SCCS renewed the releases as recently as July of 2022. With these executed releases, plaintiffs should be able to subpoena full and complete medical records and bills directly from the providers. AGENCY RECORDS: Insofar as SCCS records are requested, the subpoena should be quashed as it calls for the disclosure of privileged or otherwise protected confidential information relating to a child/family, which SCCS is not permitted to divulge absent a court order. Under Ohio law, written records of investigations relating to children performed by public children services agencies ("PCSA") are confidential. R.C. 5153.17, O.A.C. 5101:2-33- 21 and R.C. 2151.421 (Records maintained by a PCSA are confidential and may not be disseminated.) The Ohio Supreme Court has held that investigatory records of child abuse, neglect and/or dependency are not public records. State ex re Renfro v. Cuyahoga County Dept. of Human Services, 54 Ohio St3d 25, 560 NE2d 230 (1990). Rather, they are confidential records that are not subject to disclosure. Jd. Sandra Kurt, Summit County Clerk of Courts CV-2020-02-0578 ROWLANDS, MARY MARGARET 08/30/2022 12:05:58 PM MQUH Page 5 of 9 Although the provisions of R.C. 5153.17 and R.C. 2151.421 grant confidentiality to PCSA records, it has been established that the confidentiality is not absolute. (See, e.g., State ex rel. Renfro v. Cuyahoga County Dep't of Human Services, id.; Hughes v. Butler County Children Services Bd., 12" Dist. Butler No. CA2001-07-178, 2002-Ohio-184; Johnson v. Johnson, 134 Ohio App. 3d 579, 583, 731 N.E.2d 1144 (3rd Dist.1999); Sharpe v. Sharpe, 85 Ohio App. 3d 638, 642, 620 N.E.2d 916 (11th Dist.1993).) To gain access to records kept pursuant to R.C. 5153.17, it is necessary for a person “to demonstrate ‘good cause’ that outweighs any need to keep the records confidential.” Wiley v. Summit County Children Services, 9th Dist. No. 23372, 2007-Ohio-1476, at 410. The determination as to whether there is “good cause” to disclose records involves two issues. First, whether disclosure is in the best interests of the child; and second, whether due process rights are implicated. Swartzentruber v. Orrville Grace Brethren Church, 163 Ohio App. 3d 96, 2005-Ohio-4264, 836 N.E. 2d 619, at §9; Johnson at 583; 1991 Ohio Atty Gen.Ops. No. 91-003, at 2-19 to 2-20. In the instant case, Plaintiff has not demonstrated whether good cause exists to produce the records. A court may conduct an in-camera review of child abuse reports or records and “has the inherent power to order disclosure of such reports where: (1) the records or reports are relevant to the pending action; (2) good cause for such a request has been established by the person seeking disclosure; and (3) where admission of the records or reports outweighs the confidentiality considerations set forth in R.C. 5153.17 and R.C. 2151.421(H)(1)."_ See Johnson at 583; See also Nash v. Cleveland Clinic, 8th Dist. Cuyahoga No. 99128, 2013 Ohio 3618; Vaughn v. City of Shaker Heights, No. 1:10 CV 609, 2013 WL 3940790 (N.D. Ohio 2013). Sandra Kurt, Summit County Clerk of Courts CV-2020-02-0578 ROWLANDS, MARY MARGARET 08/30/2022 12:05:58 PM MQUH Page 6 of 9 The Ohio Attorney General has held that if a PCSA receives a subpoena for confidential information—issued in conjunction with a criminal and/or civil proceeding—then the PCSA, in order to preserve the confidentiality prescribed by statute, may file a motion to quash the subpoena, thereby seeking from the court an in camera review of the PCSA records and a determination as to whether and to what extent the information may be disclosed. 2007 Ohio Atty. Gen.Op. No. 2007-025. WHEREFORE, SCCS requests that the Court quash the records subpoena in its entirety. Should the Court not quash the subpoena in its entirety, SCCS requests a reasonable amount of time be permitted for the agency to compile and submit the records to the Court for in camera review if the Court so orders. SCCS will need time beyond September 8, 2022 to comply. If the Court deems that the records should be released, then SCCS would further request protective orders prohibiting their re-release and/or dissemination beyond purposes of the above captioned case, and for purposes of maintaining the records under seal. SCCS especially urges the Court to protect the confidentiality of the child’s foster and/or prospective adoptive caregivers. Respectfully submitted, _/s/_Catherine P. Van Horne __ Catherine P. Van Horne Deputy Executive Director/ Chief Legal Counsel Summit County Children Services 264 S. Arlington Street Akron, Ohio 44306 330-379-2002 Sup. Ct. No: 0061082 catherine.pomeroy-vanhorne@summitkids.org Sandra Kurt, Summit County Clerk of Courts CV-2020-02-0578 ROWLANDS, MARY MARGARET 08/30/2022 12:05:58 PM MQUH Page 7 of 9 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing motion was sent by regular U.S. mail on the 31st_ day of August, 2022, to the following individuals: Attorneys for Plaintiff Lisa Weinstein Edward Aucoin, Jr. Grant & Eisenhoffer 30 N. Lasalle St., Suite 2350 Chicago, IL 60602 Pamela Pantages Nurenberg Paris Heller & McCarthy, LPA 600 Superior Ave. East, Suite 1200 Cleveland, OH 44114 Attorney for Defendant Gregory Rossi Hanna Campbell & Powell 3737 Embassy Parkway, Suite 100 Akron, OH 44333 /s/ Catherine P. Van Horne Catherine P. Van Horne Chief Legal Counsel Summit County Children Services CVH cc: SCCS, Legal Department Sandra Kurt, Summit County Clerk of Courts CV-2020-02-0578 ROWLANDS, MARY MARGARET 08/30/2022 12:05:58 PM MQUH Page 8 of 9 RECEIVED By sheas at is pi, Nov 16, 2024 ROBATE COURT COUNTY OF suMMat, OH NOV 9 2021 NORE MARSH STORMEL PROBATE COURT OF SUMMIT COUNTY, OHIO JUDGE EL! ELINORE MARSH STORMER, JUDGE IN THE MATTER OF GUARDIANSHIP OF LEVI LEON PATTERSON, a minor Case No. 2020 GM 00028 ORDER Michael A. Renne, Guardian of the Estate of Levi Leon Patterson, a minor, having filed a Petition for Access to Minor and Minor's Medical and Education/Social Services Records, has shown good cause for said Petition and the Court finds that the relief requested therein is in the best interest of Levi Leon Patterson. The Court grants the Guardian's Petition and orders Summit County Children Services, as permanent custodian of Levi Patterson, to do the following: Allow the experts in the fields of pediatric neurology, physical medicine and rehabilitation, life care planning and pediatric neuropsychology retained by Mr. Renne and his counsel in the civil matter to each examine Levi in order to prepare their reports and/or life care plan; Disclose to Mr. Renne and his counsel in the civil matter all medical care that Levi has received since his birth and update that information as Levi receives additional medical treatment for the pendency of the civil matter; Disclose to Mr. Renne and his counsel in the civil matter all educational institutions and social services agencies, including but not limited to Early Intervention, Help Me Grow, Home Visiting, and Moms and Babies First, that Levi has received services from since his birth and update that information as Levi receives additional services for the pendency of the civil matter; Execute any medical and/or education/social service authorizations that Mr. Renne and his counsel in the civil matter submit for Levi's records throughout the pendency of the civil matter; Allow defense counsel in the civil matter to have a “meet and greet" not to last longer than 30 minutes on a date and time agreeable by SCCS; Allow Mr. Renne and his counsel's videographer to prepare a Day in the Life video of Levi for use at mediation and/or trial of the civil matter; and Se Fil 8. Present Levi at trial of the civil matter for a brief introduction to the jury ona date and ti ho: Mr. Renne an his counsel.. Judge “ 23170995.1 Sandra Kurt, Summit County CoS Badu A Clerk of Courts CV-2020-02-0578 ROWLANDS, MARY MARGARET 08/30/2022 12:05:58 PM MQUH Page 9 of 9 Summit County CHILDREN SERVICES Building Families . . Building Futures [conFrost ce carghen rentyt SUMMIT COUNTY CHILDREN SERVICES ORC: 5153.17 ORIGINAL: 5/24/07 OAC: N/A REVISIONS: 8/03/18 USC: N/A RELATED FORM(S): N/A CFR: N/A RELATED PROCEDURE/POLICY(IES): N/A O Administrative O Legal O Fiscal O Safety & Security C1 Human Resources O Social Services - All Departments 0 Information Technology Social Services - Foster & Adoption All Staff & Bargaining Unit 0 Non-Bargaining 0 Management 0 POLICY: Summit County Children Services (SCCS) will assure confidentiality of foster caregiver's identity with the birth family and friends of children placed in the foster home. PROCEDURE: SCCS staff will not release the identity of a foster caregiver to the birth family or friends of a child placed with the foster caregiver without the permission of the foster parent. It is recommended that the child's caseworker discuss the foster parent's comfort with release of identity regularly throughout the case as the foster caregiver's decision on the release of their identity may change as they know the child's family and friends. Secs Sandra Kurt, Summit County Clerk abet 0