On September 05, 2023 a
Motion,Ex Parte
was filed
involving a dispute between
Georgeanna M. Semary,
and
James Zak,
Justin Seeton,
Leslie Ann Celebrezze,
Serpil Ergun,
Susan K. Sweeney,
for MISCELLANEOUS - OTHER
in the District Court of Cuyahoga County.
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Motion No. 5132536
NAILAH K. BYRD
CUYAHOGA COUNTY CLERK OF COURTS
1200 Ontario Street
Cleveland, Ohio 44113
Court of Common Pleas
MOTION FOR EXTENSION OF TIME
November 20,2023 17:35
By: SUBODH CHANDRA 0069233
Confirmation Nbr. 3022830
GEORGEANNAM. SEMARY CV 23 984974
vs.
Judge: ANDREW J. SANTOLI
LESLIE ANN CELEBREZZE, ET AL.
Pages Filed: 2
Electronically Filed 11/20/2023 17:35 / MOTION / CV 23 984974 / Confirmation Nbr. 3022830 / CLAMW
IN THE COURT OF COMMON PLEAS
CUYAHOGA COUNTY, OHIO
Georgeanna M. Semary,
Plaintiff,
Case No. CV-23-984974
v.
Leslie Ann Celebrezze, etal. , Judge AndrewJ. Santoli
Defendants.
Plaintiff Georgeanna Semary’s Motion for 30-Day Extensions of Time to File
Brief in Opposition to Defendant Celebrezze’s Motion to Dismiss Claims 1,
2,3,6,7, and 8 of the Complaint and to Amend the Complaint Without Leave
Plaintiff Georgeanna Semary respectfully moves this Court for 30-day extensions of time (1)
to file her Brief in Opposition to Defendant Celebrezze’s Motion to Dismiss Claims 1, 2, 3, 6, 7, and
8 of the Complaint (until December 20, 2023); and (2) to amend her Complaint without leave (until
January 4, 2024). In support of this request, Plaintiff states that while her counsel, Subodh Chandra
and Donald Screen, have been diligently preparing their response to Celebrezze’s 32-page motion,
the press of their other client business, case deadlines, and both their professional and personal
commitments have made (and will continue to make) filing a timely response extraordinarily difficult
and justify substantial extensions of both deadlines. Mr. Chandra is required to be in Texas for
depositions from December 6-11 and has additional discovery obligations and court deadlines
scheduled in both late November and early December. He is then traveling internationally to visit
elderly relatives from December 20 throughjanuary 13, and so must complete all his tasks
beforehand. Mr. Screen has several other briefing deadlines, discovery-response obligations, two
mediations, and an oral argument in the Eighth District Court of Appeals during the same time
period. Both lawyers, moreover, are either hosting or visiting out-of-town relatives for several days
during the Thanksgiving holiday and thereafter.
Electronically Filed 11/20/2023 17:35 / MOTION / CV 23 984974 / Confirmation Nbr. 3022830 / CLAMW
Plaintiff’s counsel have thus far identified at least 30 discrete legal issues in the Motion to
Dismiss, each of which must be researched, analyzed, and presented. And with new information
coming in weekly, counsel are continuing to investigate facts and research law for their anticipated
amended complaint.
For these reasons, they request extensions through December 20 to file their response to the
Motion to Dismiss and throughjanuary 4 to amend their complaint without leave.
November 20, 2023 Is! Subodh Chandra
Subodh Chandra (0069233)
Donald P. Screen (0044070)
The Chandra Law Firm LLC
1265 West 6th Street, Suite 400
Cleveland, Ohio 44113
216.578.1700 (p) / 216.578.1800 (f)
Subodh. Chandra@ChandraLaw. com
Don.Screen@ChandraLaw. com
Counsel. forVlaintiff Georgeanna M. Senary
Certificate of Service
I certify that my office served a copy of this filing through the Court’s electronic-filing system.
IslSubodh Chandra
One of the attorneys for Plaintiff Georgeanna M. Semary
Electronically Filed 11/20/2023 17:35 / MOTION / CV 23 984974 / Confirmation Nbr. 3022830 / CLAMW
Document Filed Date
November 20, 2023
Case Filing Date
September 05, 2023
Category
MISCELLANEOUS - OTHER
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Motion No. 5132536 NAILAH K. BYRD CUYAHOGA COUNTY CLERK OF COURTS 1200 Ontario Street Cleveland, Ohio 44113 Court of Common Pleas MOTION FOR EXTENSION OF TIME November 20,2023 17:35 By: SUBODH CHANDRA 0069233 Confirmation Nbr. 3022830 GEORGEANNAM. SEMARY CV 23 984974 vs. Judge: ANDREW J. SANTOLI LESLIE ANN CELEBREZZE, ET AL. Pages Filed: 2 Electronically Filed 11/20/2023 17:35 / MOTION / CV 23 984974 / Confirmation Nbr. 3022830 / CLAMW IN THE COURT OF COMMON PLEAS CUYAHOGA COUNTY, OHIO Georgeanna M. Semary, Plaintiff, Case No. CV-23-984974 v. Leslie Ann Celebrezze, etal. , Judge AndrewJ. Santoli Defendants. Plaintiff Georgeanna Semary’s Motion for 30-Day Extensions of Time to File Brief in Opposition to Defendant Celebrezze’s Motion to Dismiss Claims 1, 2,3,6,7, and 8 of the Complaint and to Amend the Complaint Without Leave Plaintiff Georgeanna Semary respectfully moves this Court for 30-day extensions of time (1) to file her Brief in Opposition to Defendant Celebrezze’s Motion to Dismiss Claims 1, 2, 3, 6, 7, and 8 of the Complaint (until December 20, 2023); and (2) to amend her Complaint without leave (until January 4, 2024). In support of this request, Plaintiff states that while her counsel, Subodh Chandra and Donald Screen, have been diligently preparing their response to Celebrezze’s 32-page motion, the press of their other client business, case deadlines, and both their professional and personal commitments have made (and will continue to make) filing a timely response extraordinarily difficult and justify substantial extensions of both deadlines. Mr. Chandra is required to be in Texas for depositions from December 6-11 and has additional discovery obligations and court deadlines scheduled in both late November and early December. He is then traveling internationally to visit elderly relatives from December 20 throughjanuary 13, and so must complete all his tasks beforehand. Mr. Screen has several other briefing deadlines, discovery-response obligations, two mediations, and an oral argument in the Eighth District Court of Appeals during the same time period. Both lawyers, moreover, are either hosting or visiting out-of-town relatives for several days during the Thanksgiving holiday and thereafter. Electronically Filed 11/20/2023 17:35 / MOTION / CV 23 984974 / Confirmation Nbr. 3022830 / CLAMW Plaintiff’s counsel have thus far identified at least 30 discrete legal issues in the Motion to Dismiss, each of which must be researched, analyzed, and presented. And with new information coming in weekly, counsel are continuing to investigate facts and research law for their anticipated amended complaint. For these reasons, they request extensions through December 20 to file their response to the Motion to Dismiss and throughjanuary 4 to amend their complaint without leave. November 20, 2023 Is! Subodh Chandra Subodh Chandra (0069233) Donald P. Screen (0044070) The Chandra Law Firm LLC 1265 West 6th Street, Suite 400 Cleveland, Ohio 44113 216.578.1700 (p) / 216.578.1800 (f) Subodh. Chandra@ChandraLaw. com Don.Screen@ChandraLaw. com Counsel. forVlaintiff Georgeanna M. Senary Certificate of Service I certify that my office served a copy of this filing through the Court’s electronic-filing system. IslSubodh Chandra One of the attorneys for Plaintiff Georgeanna M. Semary Electronically Filed 11/20/2023 17:35 / MOTION / CV 23 984974 / Confirmation Nbr. 3022830 / CLAMW