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Frankjin County Ohio Clerk of Courts of the Common Pleas- 2018 Apr 25 10:16 AM-18CV002036
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IN THE COURT OF COMMON PLEAS, FRANKLIN COUNTY, OHIO
AMANDA KNISELY, Admin.,
Plaintiff, Case No. 18 CV 002036
vs. Judge Cocroft
OHIOHEALTH CORPORATION,
et al.,
Defendants.
MOTION TO CHANGE CASE CLASSIFICATION
Now come Defendants, Kwang |. Suh, M.D. and Riverside Surgical Associates,
Inc., and hereby request that this Court change the case classification of the above-
captioned matter, have a case schedule re-issued and reschedule the trial in
accordance with the proper case classification.
Rule 35 of the Local Rules of the Court of Common Pleas, Franklin County, Ohio
sets forth the guidelines for case classification and specifically states that “professional
tort cases” are to be classified as “A” cases.
As the Court can see, Plaintiffs Complaint asserts allegations of medical
negligence against these Defendants. Accordingly, pursuant to Local Rule 35, the
proper classification for claims of this nature would be “A” for professional torts.
Defendants hereby request that this Honorable Court change the case classification in
this matter to “A”, professional tort.
Rule 37 of the Local Rules of the Court of Common Pleas, Franklin County, Ohio
sets forth the scheduled time limits based on the specific case classifications. Rule
37.03, “Longer Tracks,” specifically states that a 24 month time track is warranted for
1Frankjin County Ohio Clerk of Courts of the Common Pleas- 2018 Apr 25 10:16 AM-18CV002036
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classification “A’, professional tort cases. This Rule is reflected in a trial date that is
scheduled for two years from the date the Complaint is filed. Accordingly, Defendants
respectfully request that an amended Clerk’s case schedule be issued and filed to reflect
proper time limits for the classification “A”, professional tort case, and to set a trial date
at least two years from the date the Complaint was filed.
For the foregoing reasons, Defendants Kwang |. Suh, M.D. and Riverside
Surgical Associates, Inc. request the Court order this case be classified properly as “A”
and order modification of the case schedule and trial date accordingly.
Respectfully submitted,
ARNOLD TODARO & WELCH CO., L.P.A.
By: // Zachary J. Lyon
Zachary J. Lyon (0090572)
John B. Welch (0055337)
Gerald J. Todaro (0000946)
2075 Marble Cliff Office Park
Columbus, Ohio 43215
zivorn@arnoldiaw net
Phone: (614) 485-1800
Fax: (614) 485-1944
Counsel for Defendants David M. Drees, M.D.
and Radiology, Inc.
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and accurate copy of the foregoing
was served upon all parties or counsel of record by regular U.S. mail, postage prepaid,
this 25" day of April, 2018.
Charles M. Murray, Esq.
TAN OFRES OF Jake A. Elliott, Esq.
ARNOLD TODARO Murray & Murray Co., LPA
— BWELCH 111 East Shoreline Drive
2075 Marae CuFFOrAce Pant Sandusky, OH 44870
Couns Co 5 Counsel for Plaintiff
Fax (614) 485-1944Frankjin County Ohio Clerk of Courts of the Common Pleas- 2018 Apr 25 10:16 AM-18CV002036
0E125 - s29
John H. Burtch, Esq.
Baker & Hostetler, LLP
200 Civic Center Dr., Suite 1200
Columbus, OH 43215
Counsel for Defendant OhioHealth
Corporation
¢s/_ Zachary J. Lyon
Zachary J. Lyon
Law OFFices OF
ARNOLD TODARO
& WELCH
2075 Mana. CuFF OFACE PARK
Couuaus, On10 43215
Hone (614) 485-1800
Fax (614) 485-1944
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Frankjin County Ohio Clerk of Courts of the Common Pleas- 2018 Apr 25 10:16 AM-18CV002036 0E125 - S27 IN THE COURT OF COMMON PLEAS, FRANKLIN COUNTY, OHIO AMANDA KNISELY, Admin., Plaintiff, Case No. 18 CV 002036 vs. Judge Cocroft OHIOHEALTH CORPORATION, et al., Defendants. MOTION TO CHANGE CASE CLASSIFICATION Now come Defendants, Kwang |. Suh, M.D. and Riverside Surgical Associates, Inc., and hereby request that this Court change the case classification of the above- captioned matter, have a case schedule re-issued and reschedule the trial in accordance with the proper case classification. Rule 35 of the Local Rules of the Court of Common Pleas, Franklin County, Ohio sets forth the guidelines for case classification and specifically states that “professional tort cases” are to be classified as “A” cases. As the Court can see, Plaintiffs Complaint asserts allegations of medical negligence against these Defendants. Accordingly, pursuant to Local Rule 35, the proper classification for claims of this nature would be “A” for professional torts. Defendants hereby request that this Honorable Court change the case classification in this matter to “A”, professional tort. Rule 37 of the Local Rules of the Court of Common Pleas, Franklin County, Ohio sets forth the scheduled time limits based on the specific case classifications. Rule 37.03, “Longer Tracks,” specifically states that a 24 month time track is warranted for 1Frankjin County Ohio Clerk of Courts of the Common Pleas- 2018 Apr 25 10:16 AM-18CV002036 0E125 - S28 classification “A’, professional tort cases. This Rule is reflected in a trial date that is scheduled for two years from the date the Complaint is filed. Accordingly, Defendants respectfully request that an amended Clerk’s case schedule be issued and filed to reflect proper time limits for the classification “A”, professional tort case, and to set a trial date at least two years from the date the Complaint was filed. For the foregoing reasons, Defendants Kwang |. Suh, M.D. and Riverside Surgical Associates, Inc. request the Court order this case be classified properly as “A” and order modification of the case schedule and trial date accordingly. Respectfully submitted, ARNOLD TODARO & WELCH CO., L.P.A. By: // Zachary J. Lyon Zachary J. Lyon (0090572) John B. Welch (0055337) Gerald J. Todaro (0000946) 2075 Marble Cliff Office Park Columbus, Ohio 43215 zivorn@arnoldiaw net Phone: (614) 485-1800 Fax: (614) 485-1944 Counsel for Defendants David M. Drees, M.D. and Radiology, Inc. CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and accurate copy of the foregoing was served upon all parties or counsel of record by regular U.S. mail, postage prepaid, this 25" day of April, 2018. Charles M. Murray, Esq. TAN OFRES OF Jake A. Elliott, Esq. ARNOLD TODARO Murray & Murray Co., LPA — BWELCH 111 East Shoreline Drive 2075 Marae CuFFOrAce Pant Sandusky, OH 44870 Couns Co 5 Counsel for Plaintiff Fax (614) 485-1944Frankjin County Ohio Clerk of Courts of the Common Pleas- 2018 Apr 25 10:16 AM-18CV002036 0E125 - s29 John H. Burtch, Esq. Baker & Hostetler, LLP 200 Civic Center Dr., Suite 1200 Columbus, OH 43215 Counsel for Defendant OhioHealth Corporation ¢s/_ Zachary J. Lyon Zachary J. Lyon Law OFFices OF ARNOLD TODARO & WELCH 2075 Mana. CuFF OFACE PARK Couuaus, On10 43215 Hone (614) 485-1800 Fax (614) 485-1944