On December 22, 2022 a
Party Statement
was filed
involving a dispute between
Royal Clusters Kingsbury Trace Hoa,
The Royal Clusters At Kingsbury Trace Ho,
and
Bank Of America, N.A.,
Kingsbury Trace Homeowners Assn Inc,
Quicken Loans Inc.,
Terrell, Lashawn,
Terrell, Unknown Spouse Of Lashawn,
United States Of America,
for FORECLOSURE
in the District Court of Summit County.
Preview
CV-2022-12-4301 CROCE, CHRISTINE 03/02/2023 12:38:21 PM PBRI Page 1 of 4
DF23-00002
IN THE COURT OF COMMON PLEAS
SUMMIT COUNTY, OHIO
The Royal Clusters at ) Case No. CV 2022 12 4301
Kingsbury Trace Homeowner’s )
Association, Inc. ) Judge Christine Croce
)
Plaintiff, ) DEFENDANT ROCKET MORTGAGE,
) LLC FKA QUICKEN LOANS, LLC FKA
vs. ) QUICKEN LOANS INC.’S PRETRIAL
) STATEMENT
Lashawn Terrell, et al, )
Defendant
I. FACTS
Plaintiff commenced this action seeking to foreclose on the premises located at 472
Kings Court, Copley, Ohio 44321 (the “Property”) upon which Plaintiff has a junior lien interest
for condominium fees against Lashawn Terrell. Defendant Rocket Mortgage, LLC fka Quicken
Loans, LLC fka Quicken Loans Inc. (“Rocket mortgage”) was named due to its first mortgage
(the “Mortgage”) executed by Lashawn Terrell.
Defendant Rocket Mortgage filed its answer on January 11, 2023, and since its loan was
current at that time seeks the property to be sold “subject to” its first mortgage lien.
II. ISSUES OF FACT
Whether Defendant Lashawn Terrell is in default on his unit owner’s account with
Plaintiff and amounts due.
Sandra Kurt, Summit County Clerk of Courts
CV-2022-12-4301 CROCE, CHRISTINE 03/02/2023 12:38:21 PM PBRI Page 2 of 4
III. ISSUES OF LAW
There are no issues of law before the Court regarding Defendant Rocket Mortgage first
mortgage lien. The issues are between Plaintiff and Defendant Lashawn Terrell.
IV. EXHIBITS
• The Mortgage;
• Assignment of Mortgage;
• The payment history
V. SPECIAL DAMAGES
Not Applicable.
VI. REQUESTS FOR MEDICAL EXAMINATION
Not applicable.
VII. DEPOSITIONS
Defendant Rocket Mortgage does not presently have plans to conduct depositions at this time,
but reserves the right to conduct depositions should they be deemed necessary during the course
of this litigation.
VIII. SPECIFICATION OF ANY AMENDMENT TO THE PLEADINGS
Defendant Rocket Mortgage is not presently preparing to amend its pleadings, but reserves the
right to motion the Court for leave to amend its pleadings if it is later determined that an
amendment is required.
IX. EXPERT WITNESSES
Defendant Rocket Mortgage does not presently anticipate the need to call expert witnesses, but
reserves the right to call expert witnesses if they are deemed necessary during the course of this
litigation.
X. ESTIMATE OF NUMBER OF LAY WITNESSES
• One or more representatives of Defendant Rocket Mortgage, c/o Reimer Law Co., 31500
Bainbridge Road, Suite 100, Solon, OH 44139, may testify as to all pending claims,
defenses, and allegations.
• Lashawn Terrell upon cross examination.
• All parties to this action, phone number unknown, may testify as to all pending
allegations.
Sandra Kurt, Summit County Clerk of Courts
CV-2022-12-4301 CROCE, CHRISTINE 03/02/2023 12:38:21 PM PBRI Page 3 of 4
• All witnesses called by any other party at the trial of this matter.
• All witnesses identified by any other party in this matter.
• All witnesses necessary for the purposes of impeachment or rebuttal.
• All witnesses whose testimony may be necessary to provide foundation for exhibits.
/s/ Darryl E. Gormley
Darryl E. Gormley
(0067595)
Reimer Law Co.
P.O. Box 39696
Solon, Ohio 44139
Phone: (440) 600-5500
Fax: (440) 600-5520
dgormley@reimerlaw.com
Attorney for Defendant
Rocket Mortgage
Sandra Kurt, Summit County Clerk of Courts
CV-2022-12-4301 CROCE, CHRISTINE 03/02/2023 12:38:21 PM PBRI Page 4 of 4
CERTIFICATE OF SERVICE
A copy of the foregoing was sent by regular U.S. Mail on March 2, 2023, to the following:
Shannon M. McCormick
kcattorney@kamancus.com
Tyler J. Whitney
Burdon-Marlitti@neo.rr.com
Unknown Spouse
If any, of Lashawn Terrell
472 Kings Court
Copley, OH 44321
Bank of America, N.A.
4645 Executive Drive
Columbus, OH 43220
Sara E. DeCaro
Sara.DeCaro@usdoj.gov
/s/ Darryl E. Gormley
Darryl E. Gormley (0067595)
Reimer Law Co.
Sandra Kurt, Summit County Clerk of Courts
Document Filed Date
March 02, 2023
Case Filing Date
December 22, 2022
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Preview
CV-2022-12-4301 CROCE, CHRISTINE 03/02/2023 12:38:21 PM PBRI Page 1 of 4 DF23-00002 IN THE COURT OF COMMON PLEAS SUMMIT COUNTY, OHIO The Royal Clusters at ) Case No. CV 2022 12 4301 Kingsbury Trace Homeowner’s ) Association, Inc. ) Judge Christine Croce ) Plaintiff, ) DEFENDANT ROCKET MORTGAGE, ) LLC FKA QUICKEN LOANS, LLC FKA vs. ) QUICKEN LOANS INC.’S PRETRIAL ) STATEMENT Lashawn Terrell, et al, ) Defendant I. FACTS Plaintiff commenced this action seeking to foreclose on the premises located at 472 Kings Court, Copley, Ohio 44321 (the “Property”) upon which Plaintiff has a junior lien interest for condominium fees against Lashawn Terrell. Defendant Rocket Mortgage, LLC fka Quicken Loans, LLC fka Quicken Loans Inc. (“Rocket mortgage”) was named due to its first mortgage (the “Mortgage”) executed by Lashawn Terrell. Defendant Rocket Mortgage filed its answer on January 11, 2023, and since its loan was current at that time seeks the property to be sold “subject to” its first mortgage lien. II. ISSUES OF FACT Whether Defendant Lashawn Terrell is in default on his unit owner’s account with Plaintiff and amounts due. Sandra Kurt, Summit County Clerk of Courts CV-2022-12-4301 CROCE, CHRISTINE 03/02/2023 12:38:21 PM PBRI Page 2 of 4 III. ISSUES OF LAW There are no issues of law before the Court regarding Defendant Rocket Mortgage first mortgage lien. The issues are between Plaintiff and Defendant Lashawn Terrell. IV. EXHIBITS • The Mortgage; • Assignment of Mortgage; • The payment history V. SPECIAL DAMAGES Not Applicable. VI. REQUESTS FOR MEDICAL EXAMINATION Not applicable. VII. DEPOSITIONS Defendant Rocket Mortgage does not presently have plans to conduct depositions at this time, but reserves the right to conduct depositions should they be deemed necessary during the course of this litigation. VIII. SPECIFICATION OF ANY AMENDMENT TO THE PLEADINGS Defendant Rocket Mortgage is not presently preparing to amend its pleadings, but reserves the right to motion the Court for leave to amend its pleadings if it is later determined that an amendment is required. IX. EXPERT WITNESSES Defendant Rocket Mortgage does not presently anticipate the need to call expert witnesses, but reserves the right to call expert witnesses if they are deemed necessary during the course of this litigation. X. ESTIMATE OF NUMBER OF LAY WITNESSES • One or more representatives of Defendant Rocket Mortgage, c/o Reimer Law Co., 31500 Bainbridge Road, Suite 100, Solon, OH 44139, may testify as to all pending claims, defenses, and allegations. • Lashawn Terrell upon cross examination. • All parties to this action, phone number unknown, may testify as to all pending allegations. Sandra Kurt, Summit County Clerk of Courts CV-2022-12-4301 CROCE, CHRISTINE 03/02/2023 12:38:21 PM PBRI Page 3 of 4 • All witnesses called by any other party at the trial of this matter. • All witnesses identified by any other party in this matter. • All witnesses necessary for the purposes of impeachment or rebuttal. • All witnesses whose testimony may be necessary to provide foundation for exhibits. /s/ Darryl E. Gormley Darryl E. Gormley (0067595) Reimer Law Co. P.O. Box 39696 Solon, Ohio 44139 Phone: (440) 600-5500 Fax: (440) 600-5520 dgormley@reimerlaw.com Attorney for Defendant Rocket Mortgage Sandra Kurt, Summit County Clerk of Courts CV-2022-12-4301 CROCE, CHRISTINE 03/02/2023 12:38:21 PM PBRI Page 4 of 4 CERTIFICATE OF SERVICE A copy of the foregoing was sent by regular U.S. Mail on March 2, 2023, to the following: Shannon M. McCormick kcattorney@kamancus.com Tyler J. Whitney Burdon-Marlitti@neo.rr.com Unknown Spouse If any, of Lashawn Terrell 472 Kings Court Copley, OH 44321 Bank of America, N.A. 4645 Executive Drive Columbus, OH 43220 Sara E. DeCaro Sara.DeCaro@usdoj.gov /s/ Darryl E. Gormley Darryl E. Gormley (0067595) Reimer Law Co. Sandra Kurt, Summit County Clerk of Courts