On February 13, 2024 a
Motion,Ex Parte
was filed
involving a dispute between
Roche', Celeste,
and
1993-2 Trust Dated 12Th Day Of Aug. 2015, Jason A. Cichowicz, Ind. And As Trustee Of The Levering Russell Cartwright,
Cartwright, Charles Levering,
Hudak, Jennifer,
Levering Russell Cartwright, Christopher Potts, Ind. And As Pr Of The Estate Of,
Potts, Christopher, As Personal Rep, Of Estate,
Redhead, Erin Anne,
for PL - Civil Plenary
in the District Court of St. Joseph County.
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Filed: 3/13/2024 5:30 PM
St. oseph Superior Court 7
St. J oseph County, Indiana
STATE OF INDIANA, COUNTY OF ST. JOSEPH
IN THE ST. JOSEPH SUPERIOR COURT 7
CELESTE ROCHE.
Plaintiff
VS. CAUSE NO. 71D07-2402-PL-000028
CHRISTOPHER POTTS, et al.,
Defendants
MOTION FOR EXTENSION OF TIME
Pursuant to Ind. Trial Rule 6, the defendant, Christopher Potts, Individually and as
Personal Representative of the Estate of Levering Russell Cartwright, states as follows:
1. The complaint in this case was filed on or about February 13, 2024 and a motion for
change of venue was filed by the plaintiff
on March 11, 2024;
2. A copy of the summons and complaint was left at the defendant’s former office
located at 218 W. Washington Street, South Bend, Indiana.
3. The defendant is in the process of retiring, closed the Washington Street office
permanently on December 31, 2023, was out of state on an extended vacation from January 16 to
March 5, 2024, and did not receive the summons and complaint until March 8, 2024.
4. For the foregoing reasons, the defendant is unable to file a timely responsive pleading
to the complaint and will require additional time to review the complaint and the motion,
research the applicable law, and respond to the complaint and motion for change of venue.
WHEREFORE, the defendant, Christopher Potts, prays that the Court grant an extension
of time to and including April 15, 2024 to file a response to the complaint and to the plaintiff's
motion for change of venue.
Respectfully submitted,
/s/ CHRISTOPHER POTTS # 6428-7
Attorney at Law
53220 Towhee Lane
South Bend, IN 46637
CERTIFICATE OF SERVICE
I certify that this document was e-filed using the Indiana Electronic Filing Service (IEFS)
on March 13, 2024. I further certify that on the same date, a copy of this document was
electronically served on all counsel of record using the Indiana Filing Service (IEFS), and was
served upon the following persons via U.S. First Class Mail.
Charles Cartwright
15 Sleeper Street, Apt. 305
Boston, MA 02210
Erin Anne Redhead
9 Rolling Ridge Court
Mount Kisco, NY 10549
/s/ CHRISTOPHER POTTS.
Christopher Potts
Document Filed Date
March 14, 2024
Case Filing Date
February 13, 2024
Category
PL - Civil Plenary
Status
02/13/2024 , Pending (active)
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Filed: 3/13/2024 5:30 PM St. oseph Superior Court 7 St. J oseph County, Indiana STATE OF INDIANA, COUNTY OF ST. JOSEPH IN THE ST. JOSEPH SUPERIOR COURT 7 CELESTE ROCHE. Plaintiff VS. CAUSE NO. 71D07-2402-PL-000028 CHRISTOPHER POTTS, et al., Defendants MOTION FOR EXTENSION OF TIME Pursuant to Ind. Trial Rule 6, the defendant, Christopher Potts, Individually and as Personal Representative of the Estate of Levering Russell Cartwright, states as follows: 1. The complaint in this case was filed on or about February 13, 2024 and a motion for change of venue was filed by the plaintiff on March 11, 2024; 2. A copy of the summons and complaint was left at the defendant’s former office located at 218 W. Washington Street, South Bend, Indiana. 3. The defendant is in the process of retiring, closed the Washington Street office permanently on December 31, 2023, was out of state on an extended vacation from January 16 to March 5, 2024, and did not receive the summons and complaint until March 8, 2024. 4. For the foregoing reasons, the defendant is unable to file a timely responsive pleading to the complaint and will require additional time to review the complaint and the motion, research the applicable law, and respond to the complaint and motion for change of venue. WHEREFORE, the defendant, Christopher Potts, prays that the Court grant an extension of time to and including April 15, 2024 to file a response to the complaint and to the plaintiff's motion for change of venue. Respectfully submitted, /s/ CHRISTOPHER POTTS # 6428-7 Attorney at Law 53220 Towhee Lane South Bend, IN 46637 CERTIFICATE OF SERVICE I certify that this document was e-filed using the Indiana Electronic Filing Service (IEFS) on March 13, 2024. I further certify that on the same date, a copy of this document was electronically served on all counsel of record using the Indiana Filing Service (IEFS), and was served upon the following persons via U.S. First Class Mail. Charles Cartwright 15 Sleeper Street, Apt. 305 Boston, MA 02210 Erin Anne Redhead 9 Rolling Ridge Court Mount Kisco, NY 10549 /s/ CHRISTOPHER POTTS. Christopher Potts