On August 21, 2006 a
Motion,Ex Parte
was filed
involving a dispute between
and
in the District Court of Butler County.
Preview
1D BUTLER CO:
COURT OF COMMON PEERS
Robert F. Croskery.
4% Out (Reg. No. 0064802)
“ . Attorneys for Plaintiffs
COURT OF COMMON PLEAS
- BUTLER COUNTY, OHIO
TARGET HOLDINGS, INC
dba TARGET WORLD : Case No. CV 2006 08 2952
Plaintiff
Judge Patricia Oney
vs.
CINCINNATI COMMERCIAL MOTION TO EXTEND TIME
CONSTRUCTION 3 (Affidavit of Sandra Martin attached)
Defendant
In accordance with local rules, Plaintiff Target Holdings, Inc. dba Target World, through
counsel, moves for an extension to file Reply to Defendant’s Motion to Dismiss or Stay Proceedings
Pending Arbitration until October 30, 2006 due to nonrecept of document. Affidavit of Sandra
Martin is attached as well as a proposed Judgment Entry for the Court’s convenience.
Respectfully Submitted,
Robert F. (sk ne
OF COUNSEL: Robert F. Croskery
Robert F. Croskery & Associates (Reg. No. 0064802)
Co., L.P.A. Attorney for Plaintiffs
7746 Beechmont Ave 7746 Beechmont Ave
Cincinnati, OH 45255 Cincinnati, OH 45255
Phone (513) 701-5529 Phone (513) 701-5529
Fax (513) 701-5528 Fax (513) 701-5528
E-mail: Rcroskery@Croskerylaw.comCERTIFICATE OF SERVICE
Thereby certify that a copy of Plaintiff's Motion to Extend Time was served upon Eric C.
Holzapfel Esq., 600 Vine Street, Suite 2500, Cincinnati, Ohio 45202 via ordinary mail this 20th day
of October, 2006.
Robert F. Groskan< /meK
Robert F. Croskery, Esq. (0064!Affidavit of Sandra Martin
1. Lam the Secretary to Mr. Croskery, attorney for Target Holdings, Inc. dba Target World, and
have been throughout this litigation.
2. On October 19, 2006 I was preparing a Motion for Default Judgement for Target Holdings,
Inc. vs Cincinnati Commercial Construction due to non response to Complaint filed in August
2006. I went to the Butler County Clerk of Court website to verify service date of Complaint on
Defendant when I found a Motion to Dismiss and Stay Pending Arbitration had been filed
September 14, 2006.
3. process all incoming and outgoing mail for this office and this office has never been in receipt
of the Motion to Dismiss and Stay Pending Arbitration filed by Defense Counsel. I immediately
called Counsel for Defense to let them know we had not received Service on this document as
well as Jana Assistant to Judge Oney. I also informed Mr. Croskery that the document existed so
we could begin our Reply.
Further affiant sayeth not.
bbb PX
Sandra M. Martin
Sworn and subscribed before me this 20" day of October, 2006 in Hamilton County, Ohio.
e
Notary Public { y
MELINDA E. KNISLEY, Attorney atm
yo opyng - STATE OF OHIO
wy Vommission has Ro expiration
date. Section 247208 Deals1 GROSKERY LAW OFFICES
Aya
TORNEYS AND COUNSELORS AT LAW
Robert F. Croskery, Esq.* @ Melinda E. Knisley, Esq.**
*Also admitted in Kentucky and Florida @ **Also admitted in Florida
Phone: (513) 232-LAWS (5297) @ 7746 Beechmont Avenue, Cincinnati, OH 45255 @ Fax (513) 701-5528
reroskery@croskerylaw.com @ mknisley@croskerylaw.com @ www.croskerylaw.com
Clerk of Courts
October 20, 2006
Butler County Court of Common Pleas
315 High Street, 3% Floor
Hamilton, Ohio 45011
Re: Target World vs Cincinnati Commercial Contracting
Dear Sir/Madam:
Enclosed for filing is the original and three copies of Plaintiff's Motion to Extend Time in
the above referenced matter and Judge’s Order Granting Motion in the above referenced matter.
Please file same, provide Order to the Judge and return a date stamped filed copy to this office in
the enclosed self addressed stamped envelope.
If you have any questions I can be reached at (513) 232-5297.
SMM/smm
Encl
cc Joe Blanco
Very truly “LL
Asandra M. Martin
Paralegal
Preview
1D BUTLER CO: COURT OF COMMON PEERS Robert F. Croskery. 4% Out (Reg. No. 0064802) “ . Attorneys for Plaintiffs COURT OF COMMON PLEAS - BUTLER COUNTY, OHIO TARGET HOLDINGS, INC dba TARGET WORLD : Case No. CV 2006 08 2952 Plaintiff Judge Patricia Oney vs. CINCINNATI COMMERCIAL MOTION TO EXTEND TIME CONSTRUCTION 3 (Affidavit of Sandra Martin attached) Defendant In accordance with local rules, Plaintiff Target Holdings, Inc. dba Target World, through counsel, moves for an extension to file Reply to Defendant’s Motion to Dismiss or Stay Proceedings Pending Arbitration until October 30, 2006 due to nonrecept of document. Affidavit of Sandra Martin is attached as well as a proposed Judgment Entry for the Court’s convenience. Respectfully Submitted, Robert F. (sk ne OF COUNSEL: Robert F. Croskery Robert F. Croskery & Associates (Reg. No. 0064802) Co., L.P.A. Attorney for Plaintiffs 7746 Beechmont Ave 7746 Beechmont Ave Cincinnati, OH 45255 Cincinnati, OH 45255 Phone (513) 701-5529 Phone (513) 701-5529 Fax (513) 701-5528 Fax (513) 701-5528 E-mail: Rcroskery@Croskerylaw.comCERTIFICATE OF SERVICE Thereby certify that a copy of Plaintiff's Motion to Extend Time was served upon Eric C. Holzapfel Esq., 600 Vine Street, Suite 2500, Cincinnati, Ohio 45202 via ordinary mail this 20th day of October, 2006. Robert F. Groskan< /meK Robert F. Croskery, Esq. (0064!Affidavit of Sandra Martin 1. Lam the Secretary to Mr. Croskery, attorney for Target Holdings, Inc. dba Target World, and have been throughout this litigation. 2. On October 19, 2006 I was preparing a Motion for Default Judgement for Target Holdings, Inc. vs Cincinnati Commercial Construction due to non response to Complaint filed in August 2006. I went to the Butler County Clerk of Court website to verify service date of Complaint on Defendant when I found a Motion to Dismiss and Stay Pending Arbitration had been filed September 14, 2006. 3. process all incoming and outgoing mail for this office and this office has never been in receipt of the Motion to Dismiss and Stay Pending Arbitration filed by Defense Counsel. I immediately called Counsel for Defense to let them know we had not received Service on this document as well as Jana Assistant to Judge Oney. I also informed Mr. Croskery that the document existed so we could begin our Reply. Further affiant sayeth not. bbb PX Sandra M. Martin Sworn and subscribed before me this 20" day of October, 2006 in Hamilton County, Ohio. e Notary Public { y MELINDA E. KNISLEY, Attorney atm yo opyng - STATE OF OHIO wy Vommission has Ro expiration date. Section 247208 Deals1 GROSKERY LAW OFFICES Aya TORNEYS AND COUNSELORS AT LAW Robert F. Croskery, Esq.* @ Melinda E. Knisley, Esq.** *Also admitted in Kentucky and Florida @ **Also admitted in Florida Phone: (513) 232-LAWS (5297) @ 7746 Beechmont Avenue, Cincinnati, OH 45255 @ Fax (513) 701-5528 reroskery@croskerylaw.com @ mknisley@croskerylaw.com @ www.croskerylaw.com Clerk of Courts October 20, 2006 Butler County Court of Common Pleas 315 High Street, 3% Floor Hamilton, Ohio 45011 Re: Target World vs Cincinnati Commercial Contracting Dear Sir/Madam: Enclosed for filing is the original and three copies of Plaintiff's Motion to Extend Time in the above referenced matter and Judge’s Order Granting Motion in the above referenced matter. Please file same, provide Order to the Judge and return a date stamped filed copy to this office in the enclosed self addressed stamped envelope. If you have any questions I can be reached at (513) 232-5297. SMM/smm Encl cc Joe Blanco Very truly “LL Asandra M. Martin Paralegal