On February 12, 2020 a
Motion,Ex Parte
was filed
involving a dispute between
P,
Patterson, Olivia,
and
Ballester, M.D., Ashley,
Bellamy, D.O., Meredith,
Johnson, M.D., Cheryl,
Summa Health, Dba Summa Health Sys.-Akron,
Summa Physicians, Inc.,
for MEDICAL MALPRACTICE
in the District Court of Summit County.
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CV-2020-02-0578 ROWLANDS, MARY MARGARET 10/17/2023 09:53:03 AM MOTI Page 1 of 2
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 TO CLARIFY/ESTABLISH
v. ) RESPONSE DATE FILED ON BEHALF
) OF DEFENDANTS SUMMA HEALTH
SUMMA HEALTH SYSTEM, et al. ) SYSTEM, SUMMA HEALTH, SUMMA
) PHYSICIANS, INC., CHERYL JOHNSON,
Defendants. ) M.D., AND ASHLEY BALLESTER, M.D.
)
The Court recently entered a Magistrate’s Order regarding discovery. The Order required
the Defendants to produce various documents and provide responses fourteen days from the date
the Order was filed. The Order was filed by the Court on October 5, 2023 but was not served on
counsel until October 10, 2023. The Defendants hereby file this Motion to request that the Court
order various documents to be produced and responses provided fourteen days from the Order
was served on counsel, or by October 24, 2023.
A Proposed Order is attached.
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 10/17/2023 09:53:03 AM MOTI Page 2 of 2
CERTIFICATE OF SERVICE
I hereby certify that a copy of the foregoing Motion to Clarify/Establish Response Date
Filed on Behalf of Defendants Summa Health System, Summa Health, Summa Physicians,
Inc., Cheryl Johnson, M.D., and Ashley Ballester, M.D. was served via email this 17th day of
October, 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
Preview
CV-2020-02-0578 ROWLANDS, MARY MARGARET 10/17/2023 09:53:03 AM MOTI Page 1 of 2 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 TO CLARIFY/ESTABLISH v. ) RESPONSE DATE FILED ON BEHALF ) OF DEFENDANTS SUMMA HEALTH SUMMA HEALTH SYSTEM, et al. ) SYSTEM, SUMMA HEALTH, SUMMA ) PHYSICIANS, INC., CHERYL JOHNSON, Defendants. ) M.D., AND ASHLEY BALLESTER, M.D. ) The Court recently entered a Magistrate’s Order regarding discovery. The Order required the Defendants to produce various documents and provide responses fourteen days from the date the Order was filed. The Order was filed by the Court on October 5, 2023 but was not served on counsel until October 10, 2023. The Defendants hereby file this Motion to request that the Court order various documents to be produced and responses provided fourteen days from the Order was served on counsel, or by October 24, 2023. A Proposed Order is attached. 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 10/17/2023 09:53:03 AM MOTI Page 2 of 2 CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Motion to Clarify/Establish Response Date Filed on Behalf of Defendants Summa Health System, Summa Health, Summa Physicians, Inc., Cheryl Johnson, M.D., and Ashley Ballester, M.D. was served via email this 17th day of October, 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