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FILED
COMMON PLEAS COURT
JACKSON,OHIO
11/05/2023 10:14 PM
SETH I. MICHAEL,CLERK
IN THE COMMON PLEAS COURT OF JACKSON, OHIO
DIVISION OF DOMESTIC RELATIONS
STEPHEN KOMOREK
7833 MORSE ROAD CASE # 23DIVO071¢
NEW ALBANY, OHIO
43054
Plaintiff
JUDGE REGAN
SARAH KOMEREK ) MOTION TO COMPEL
3183 LESMIL RD.
WELLSTON, OHO
45692
Now comes the Plaintiff, STEPHEN KOMOREK, by and through counsel, William G. Knapp
Ill, and Moves the Court for an Order Compelling Defendant, SARAH KOMOREK to produce the
following documents:
1. Defendant, SARAH KOMOREK, by and through Counsel provided a Statement alleging a
debt of One Hundred and Fifty Thousand Dollars to the Defendant, SARAH KOMOREK’S
Father. Plaintiff, STEPHEN KOMOREK realized that his signature on this document was
not his. Additionally, additional information was provided by the Notary on said
document who advised the Plaintiff, STEPHEN KOMOREK, that the signature on the
document was not hers. The bank further stated that had they ever seen this document,
and they would not have approved the loan that was obtained for the residence at 3183
Lesmil Road, Wellston, Ohio had they seen this document.
Additionally, the Plaintiff, STEPHEN KOMOREK, was advised by his bank that SARAH
KOMOREK, had logged into the Plaintiff, STEPHEN KOMOREK’S bank account and
attempted to withdraw several payments, both in the present as well as over the next
several weeks that would be used to pay the debt on the Defendant. SARAH KOMOREK’S
one vehicle. The final payment was to be in excess of Five Thousand Dollars,
($5,000.00). When asked about these transactions, the Defendant, SARAH KOMOREK, by
and through Counsel accused the Plaintiff, STEPHEN KOMOREK, of hacking into her
account through her computer in order to to this. This would be a clear violation of
Federal Law and could very well jeopardize the Plaintiff, STEPHEN KOMOREK’S licenses,
and present and future Business dealings.
Additionally, Defendant, SARAH KOMOREK, and Counsel for the Defense have continually
gone through the entire operational bank account of the Plaintiff, STEPHEN KOMOREK,
even though they have both been notified on numerous occasions that this bank
account is subject to the provisions of National Security. Plaintiff, STEPHEN KOMOREK
requested original copies of this bank account. Defendant, SARAH KOMOREK, by and
through Counsel provided only PDF copies of this account, and not copies of the original
Statements received by mail by the Defendant, SARAH KOMOREK.
Plaintiff, STEPHEN KOMOREK wishes to remind the Court that the Defendant, SARAH
KOMOREK, by and through Counsel have repeatedly attacked the credibility of the
Plaintiff, STEPHEN KOMOREK’S operational account and Plaintiff, STEPHEN KOMOREK has
gone to extensive steps both in the past, in the present and also will be doing so in the
future to prove the veracity of the Plaintiff’s Statement.
The Defendant, SARH KOMOREK, should therefore be required to provide similar,
conclusive evidence of the nature of the aforementioned documents.
Plaintiff, STEPHEN KOMOREK moves the Court for an Order requiring the Defendant,
SARAH KOMOREK to produce the original notarized document claiming a debt to
Plaintiff, SARAH KOMOREK’S Father, so that it can be analyzed by an accredited
handwriting expert. This was submitted to Plaintiff's Counsel by Defendant’s Counsel as
evidence of a debt.
Plainttiff, STEPHEN KOMOREK further moves the Court for an Order requiring the
Defendant, SARAH KOMOREK to produce the original mortgage document for the
property on Lesmil Road that would indicate that the bank had not received, or been
notified of the document of the alleged claim of a debt to SARAH KOMOREK’S father.
Plaintiff, STEPHEN KOMOREK, further moves the Court for an Order requiring the
Defendant, SARAH KOMOREK to produce evidence of where the alleged One Hundred
and Fifty Thousand Dollars was deposited when allegedly received from her FATHER.
Plaintiff, STEPHEN KOMOREK further moves the Court for the Court for an Order
requiring the Defendant, SARAH KOMOREK to produce her computer and her phone as
she can log into accounts with her phone, to the Court so that It can be analyzed by a
professional expert to determine if Plaintiff, STEPHEN KOMOREK did in fact hack the
Defendant, SARAH KOMOREK’s account through her computer, or to determine if the
Defendant, SARAH KOMOREK actually ordered the fraudulent payments from Plaintiff,
STEPHEN KOMOREK’S Account. These allegations from Defendant, SARAH KOMOREK,
were relayed by and through her Counsel to the Plaintiff, by and through Counsel.
Plaintiff, STEPHEN KOMOREK, by and through Counsel advises the Court that he will pay
for the analysis of both the statement claiming the debt to Defendant’s Father, and the
evaluation of the Defendant, SARAH KOMOREK’S computer. He moves that the Court
have the computer presented to the Court for independent analysis, and states that he
person doing the analysis will pick up the computer from the Court, or in the alternative,
Plaintiff, STEPHEN KOMOREK will pay for the Court to mail the computer to a recognized,
independent electronics expert , and return the computer to the Court, and at no time
will the Plaintiff, STEPHEN KOMOREK have access to the computer.
Plaintiff, STEPHEN KOMOREK, by and through Counsel states that the results of the
analysis of the handwriting and the computer shall be delivered to the Court and both
parties at the same time.
Plaintiff, STEPHEN KOMOREK, further moves the Court for an Order, requiring the
Defendant, SARAH KOMOREK, to produce the documents requested in Plaintiff, STEPHEN
KOMOREK’s Interrogatories submitted to the Defendant, SARAH KOMOREK, on August
28, 2024. Defendant, SARAH KOMOREK, by and through Counsel, submitted a statement
to this Court stating that they had complied with the tnterrogatories, when clearly they
have not.
Wherefore, the Plaintiff, STEPHEN KOMOREK, Moves the Court for an Order requiring the
Defendant, SARAH KOMOREK to produce all of the documents requested in this motion, as well
as the production of documents that were requested in the interrogatories submitted by the
Plaintiff, STEPHEN KOMOREK. Plaintiff, STEPHEN KOMOREK, further moves the Court for an
Order requiring the Defendant, SARAH KOMOREK to produce her computer, and her phone,
unaltered to the Court so as to determine the veracity of the Defendant, as well as clear the
Plaintiff, STEPHEN KOMOREK of the accusations that he committed several Federal Offenses.
Plaintiff, STEPHEN KOMOREK, further moves the Court for sanctions and attorney fees should it
be determined that the information provided by the Defendant, SARAH KOMOREK, by and
through Counsel was fraudulent and should the Court determine that the alleged Federal
Offenses claimed by the Defendant were fraudulent. The Defendant, SARAH KOMOREK must be
held accountable because the Defendant, SARAH KOMOREK, was advised, not just by the
Plaintiff, STEPHEN KOMOREK but also the representative of the bank that these statements and
documents were fraudulent, and yet she continues to assert they are valid and should be
considered by the Court.
Respectfully submitted:
/s/ William Knapp
William G. Knapp Wl
Attorney for Plaintiff, STEPHEN KOMOREK
2548 Blue Mountain Trail
Lyons, Colorado, 80540
(937) 477-4057
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FILED COMMON PLEAS COURT JACKSON,OHIO 11/05/2023 10:14 PM SETH I. MICHAEL,CLERK IN THE COMMON PLEAS COURT OF JACKSON, OHIO DIVISION OF DOMESTIC RELATIONS STEPHEN KOMOREK 7833 MORSE ROAD CASE # 23DIVO071¢ NEW ALBANY, OHIO 43054 Plaintiff JUDGE REGAN SARAH KOMEREK ) MOTION TO COMPEL 3183 LESMIL RD. WELLSTON, OHO 45692 Now comes the Plaintiff, STEPHEN KOMOREK, by and through counsel, William G. Knapp Ill, and Moves the Court for an Order Compelling Defendant, SARAH KOMOREK to produce the following documents: 1. Defendant, SARAH KOMOREK, by and through Counsel provided a Statement alleging a debt of One Hundred and Fifty Thousand Dollars to the Defendant, SARAH KOMOREK’S Father. Plaintiff, STEPHEN KOMOREK realized that his signature on this document was not his. Additionally, additional information was provided by the Notary on said document who advised the Plaintiff, STEPHEN KOMOREK, that the signature on the document was not hers. The bank further stated that had they ever seen this document, and they would not have approved the loan that was obtained for the residence at 3183 Lesmil Road, Wellston, Ohio had they seen this document. Additionally, the Plaintiff, STEPHEN KOMOREK, was advised by his bank that SARAH KOMOREK, had logged into the Plaintiff, STEPHEN KOMOREK’S bank account and attempted to withdraw several payments, both in the present as well as over the next several weeks that would be used to pay the debt on the Defendant. SARAH KOMOREK’S one vehicle. The final payment was to be in excess of Five Thousand Dollars, ($5,000.00). When asked about these transactions, the Defendant, SARAH KOMOREK, by and through Counsel accused the Plaintiff, STEPHEN KOMOREK, of hacking into her account through her computer in order to to this. This would be a clear violation of Federal Law and could very well jeopardize the Plaintiff, STEPHEN KOMOREK’S licenses, and present and future Business dealings. Additionally, Defendant, SARAH KOMOREK, and Counsel for the Defense have continually gone through the entire operational bank account of the Plaintiff, STEPHEN KOMOREK, even though they have both been notified on numerous occasions that this bank account is subject to the provisions of National Security. Plaintiff, STEPHEN KOMOREK requested original copies of this bank account. Defendant, SARAH KOMOREK, by and through Counsel provided only PDF copies of this account, and not copies of the original Statements received by mail by the Defendant, SARAH KOMOREK. Plaintiff, STEPHEN KOMOREK wishes to remind the Court that the Defendant, SARAH KOMOREK, by and through Counsel have repeatedly attacked the credibility of the Plaintiff, STEPHEN KOMOREK’S operational account and Plaintiff, STEPHEN KOMOREK has gone to extensive steps both in the past, in the present and also will be doing so in the future to prove the veracity of the Plaintiff’s Statement. The Defendant, SARH KOMOREK, should therefore be required to provide similar, conclusive evidence of the nature of the aforementioned documents. Plaintiff, STEPHEN KOMOREK moves the Court for an Order requiring the Defendant, SARAH KOMOREK to produce the original notarized document claiming a debt to Plaintiff, SARAH KOMOREK’S Father, so that it can be analyzed by an accredited handwriting expert. This was submitted to Plaintiff's Counsel by Defendant’s Counsel as evidence of a debt. Plainttiff, STEPHEN KOMOREK further moves the Court for an Order requiring the Defendant, SARAH KOMOREK to produce the original mortgage document for the property on Lesmil Road that would indicate that the bank had not received, or been notified of the document of the alleged claim of a debt to SARAH KOMOREK’S father. Plaintiff, STEPHEN KOMOREK, further moves the Court for an Order requiring the Defendant, SARAH KOMOREK to produce evidence of where the alleged One Hundred and Fifty Thousand Dollars was deposited when allegedly received from her FATHER. Plaintiff, STEPHEN KOMOREK further moves the Court for the Court for an Order requiring the Defendant, SARAH KOMOREK to produce her computer and her phone as she can log into accounts with her phone, to the Court so that It can be analyzed by a professional expert to determine if Plaintiff, STEPHEN KOMOREK did in fact hack the Defendant, SARAH KOMOREK’s account through her computer, or to determine if the Defendant, SARAH KOMOREK actually ordered the fraudulent payments from Plaintiff, STEPHEN KOMOREK’S Account. These allegations from Defendant, SARAH KOMOREK, were relayed by and through her Counsel to the Plaintiff, by and through Counsel. Plaintiff, STEPHEN KOMOREK, by and through Counsel advises the Court that he will pay for the analysis of both the statement claiming the debt to Defendant’s Father, and the evaluation of the Defendant, SARAH KOMOREK’S computer. He moves that the Court have the computer presented to the Court for independent analysis, and states that he person doing the analysis will pick up the computer from the Court, or in the alternative, Plaintiff, STEPHEN KOMOREK will pay for the Court to mail the computer to a recognized, independent electronics expert , and return the computer to the Court, and at no time will the Plaintiff, STEPHEN KOMOREK have access to the computer. Plaintiff, STEPHEN KOMOREK, by and through Counsel states that the results of the analysis of the handwriting and the computer shall be delivered to the Court and both parties at the same time. Plaintiff, STEPHEN KOMOREK, further moves the Court for an Order, requiring the Defendant, SARAH KOMOREK, to produce the documents requested in Plaintiff, STEPHEN KOMOREK’s Interrogatories submitted to the Defendant, SARAH KOMOREK, on August 28, 2024. Defendant, SARAH KOMOREK, by and through Counsel, submitted a statement to this Court stating that they had complied with the tnterrogatories, when clearly they have not. Wherefore, the Plaintiff, STEPHEN KOMOREK, Moves the Court for an Order requiring the Defendant, SARAH KOMOREK to produce all of the documents requested in this motion, as well as the production of documents that were requested in the interrogatories submitted by the Plaintiff, STEPHEN KOMOREK. Plaintiff, STEPHEN KOMOREK, further moves the Court for an Order requiring the Defendant, SARAH KOMOREK to produce her computer, and her phone, unaltered to the Court so as to determine the veracity of the Defendant, as well as clear the Plaintiff, STEPHEN KOMOREK of the accusations that he committed several Federal Offenses. Plaintiff, STEPHEN KOMOREK, further moves the Court for sanctions and attorney fees should it be determined that the information provided by the Defendant, SARAH KOMOREK, by and through Counsel was fraudulent and should the Court determine that the alleged Federal Offenses claimed by the Defendant were fraudulent. The Defendant, SARAH KOMOREK must be held accountable because the Defendant, SARAH KOMOREK, was advised, not just by the Plaintiff, STEPHEN KOMOREK but also the representative of the bank that these statements and documents were fraudulent, and yet she continues to assert they are valid and should be considered by the Court. Respectfully submitted: /s/ William Knapp William G. Knapp Wl Attorney for Plaintiff, STEPHEN KOMOREK 2548 Blue Mountain Trail Lyons, Colorado, 80540 (937) 477-4057