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CV-2020-02-0578 ROWLANDS, MARY MARGARET 11/07/2023 15:59:51 PM MFET Page 1 of 3
IN THE COURT OF COMMON PLEAS
SUMMIT COUNTY, OHIO
MICHAEL A. RENNE, as Guardian of the ) CASE NO. CV-2020-02-0578
Estate of LP, a minor, )
) JUDGE MARY MARGARET ROWLANDS
Plaintiff, )
) MOTION FOR EXTENSION OF TIME TO
v. ) FILE REPLY BRIEF IN SUPPORT OF
) DEFENDANTS SUMMA HEALTH
SUMMA HEALTH SYSTEM, et al. ) SYSTEM, SUMMA HEALTH, SUMMA
) PHYSICIANS, INC., CHERYL JOHNSON,
Defendants. ) M.D., ASHLEY L. BALLESTER, M.D. AND
) MEREDITH BELLAMY, D.O.’S MOTION
) TO SET ASIDE MAGISTRATE’S ORDER
)
Defendants Summa Health System, Summa Health, Summa Physicians, Inc., Cheryl
Johnson, M.D., Ashley L. Ballester, M.D. and Meredith Bellamy, D.O. (hereinafter collectively
referred to as “Summa”) move the Court for an extension of time within which to file their Reply
Brief in Support of their Motion to Set Aside Magistrate’s Order. As a result of current work
schedules, Defense counsel would request additional time within which to file the Reply.
Summa filed the Motion to Set Aside the Magistrate’s Order on October 16, 2023.
Plaintiffs’ Brief in Opposition was due on October 30, 2023. Plaintiff requested of the Court an
additional week, or until November 6, 2023 to file their Brief. Counsel for Summa did not object
and Plaintiffs were verbally provided by the Court an extension of one week to file the Brief in
Opposition. Summa’s Reply is currently due on November 13, 2023.
Defense counsel now requests a similar extension of time. Summa requests a seven day
extension over the date upon which its Reply in support of the Motion is currently due, or until
November 20, 2023.
Accordingly, and for the reasons set forth above, Summa requests that its Motion for
Extension of Time be granted. A Proposed Order is attached.
Sandra Kurt, Summit County Clerk of Courts
CV-2020-02-0578 ROWLANDS, MARY MARGARET 11/07/2023 15:59:51 PM MFET Page 2 of 3
Respectfully submitted,
/s/ Gregory T. Rossi, Esq.
Gregory T. Rossi, Esq. (0047595)
Rocco D. Potenza, Jr., Esq. (0059577)
Emily R. Yoder, Esq. (0084013)
HANNA, CAMPBELL & POWELL, LLP
3737 Embassy Parkway, Suite 100
Akron, Ohio 44333
Phone: 330-670-7300
Fax: 330-670-0977
E-mail: grossi@hcplaw.net
rpotenza@hcplaw.net
eyoder@hcplaw.net
Counsel for Defendants Summa Health System,
Summa Health, Summa Physicians, Inc., Cheryl
Johnson, M.D., Ashley L. Ballester, M.D. and
Meredith Bellamy, D.O.
Sandra Kurt, Summit County Clerk of Courts
CV-2020-02-0578 ROWLANDS, MARY MARGARET 11/07/2023 15:59:51 PM MFET Page 3 of 3
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing Motion For Extension of Time to File Reply
Brief in Support of Defendants Summa Health System, Summa Health, Summa Physicians,
Inc., Cheryl Johnson, M.D., Ashley L. Ballester, M.D. and Meredith Bellamy, D.O.’s Motion
to Set Aside Magistrate’s Order was served via email this 7th day of November, 2023 to:
James B. Puritz, Esq. Counsel for Plaintiff
Edward J. Aucoin, Jr., Esq.
Lisa Weinstein, Esq.
Grant & Eisenhofer
30 N. LaSalle Street, Suite 2350
Chicago IL 60602
jpuritz@gelaw.com
eaucoin@gelaw.com
lweinstein@gelaw.com
Pamela Pantages, Esq.
Nurenberg Paris Heller & McCarthy, Co., LPA
600 Superior Avenue East, Suite 1200
Cleveland OH 44114
ppantages@nphm.com
/s/ Gregory T. Rossi, Esq.
Gregory T. Rossi, Esq. (0047595)
>
Sandra Kurt, Summit County Clerk of Courts
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CV-2020-02-0578 ROWLANDS, MARY MARGARET 11/07/2023 15:59:51 PM MFET Page 1 of 3 IN THE COURT OF COMMON PLEAS SUMMIT COUNTY, OHIO MICHAEL A. RENNE, as Guardian of the ) CASE NO. CV-2020-02-0578 Estate of LP, a minor, ) ) JUDGE MARY MARGARET ROWLANDS Plaintiff, ) ) MOTION FOR EXTENSION OF TIME TO v. ) FILE REPLY BRIEF IN SUPPORT OF ) DEFENDANTS SUMMA HEALTH SUMMA HEALTH SYSTEM, et al. ) SYSTEM, SUMMA HEALTH, SUMMA ) PHYSICIANS, INC., CHERYL JOHNSON, Defendants. ) M.D., ASHLEY L. BALLESTER, M.D. AND ) MEREDITH BELLAMY, D.O.’S MOTION ) TO SET ASIDE MAGISTRATE’S ORDER ) Defendants Summa Health System, Summa Health, Summa Physicians, Inc., Cheryl Johnson, M.D., Ashley L. Ballester, M.D. and Meredith Bellamy, D.O. (hereinafter collectively referred to as “Summa”) move the Court for an extension of time within which to file their Reply Brief in Support of their Motion to Set Aside Magistrate’s Order. As a result of current work schedules, Defense counsel would request additional time within which to file the Reply. Summa filed the Motion to Set Aside the Magistrate’s Order on October 16, 2023. Plaintiffs’ Brief in Opposition was due on October 30, 2023. Plaintiff requested of the Court an additional week, or until November 6, 2023 to file their Brief. Counsel for Summa did not object and Plaintiffs were verbally provided by the Court an extension of one week to file the Brief in Opposition. Summa’s Reply is currently due on November 13, 2023. Defense counsel now requests a similar extension of time. Summa requests a seven day extension over the date upon which its Reply in support of the Motion is currently due, or until November 20, 2023. Accordingly, and for the reasons set forth above, Summa requests that its Motion for Extension of Time be granted. A Proposed Order is attached. Sandra Kurt, Summit County Clerk of Courts CV-2020-02-0578 ROWLANDS, MARY MARGARET 11/07/2023 15:59:51 PM MFET Page 2 of 3 Respectfully submitted, /s/ Gregory T. Rossi, Esq. Gregory T. Rossi, Esq. (0047595) Rocco D. Potenza, Jr., Esq. (0059577) Emily R. Yoder, Esq. (0084013) HANNA, CAMPBELL & POWELL, LLP 3737 Embassy Parkway, Suite 100 Akron, Ohio 44333 Phone: 330-670-7300 Fax: 330-670-0977 E-mail: grossi@hcplaw.net rpotenza@hcplaw.net eyoder@hcplaw.net Counsel for Defendants Summa Health System, Summa Health, Summa Physicians, Inc., Cheryl Johnson, M.D., Ashley L. Ballester, M.D. and Meredith Bellamy, D.O. Sandra Kurt, Summit County Clerk of Courts CV-2020-02-0578 ROWLANDS, MARY MARGARET 11/07/2023 15:59:51 PM MFET Page 3 of 3 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Motion For Extension of Time to File Reply Brief in Support of Defendants Summa Health System, Summa Health, Summa Physicians, Inc., Cheryl Johnson, M.D., Ashley L. Ballester, M.D. and Meredith Bellamy, D.O.’s Motion to Set Aside Magistrate’s Order was served via email this 7th day of November, 2023 to: James B. Puritz, Esq. Counsel for Plaintiff Edward J. Aucoin, Jr., Esq. Lisa Weinstein, Esq. Grant & Eisenhofer 30 N. LaSalle Street, Suite 2350 Chicago IL 60602 jpuritz@gelaw.com eaucoin@gelaw.com lweinstein@gelaw.com Pamela Pantages, Esq. Nurenberg Paris Heller & McCarthy, Co., LPA 600 Superior Avenue East, Suite 1200 Cleveland OH 44114 ppantages@nphm.com /s/ Gregory T. Rossi, Esq. Gregory T. Rossi, Esq. (0047595) > Sandra Kurt, Summit County Clerk of Courts