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Photo of Cuyahoga County

Court

Cuyahoga County

Ohio

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Case Information

Filed 2022-05-04
Status INACTIVE
Type Commercial Docket
Docket 105 entries

Parties

Plaintiff James Derow|Aj 2 Llc
Defendant Fall Creek Promote, Llc C/o Highland Park Service Corp.|Pepper Pike Capital Partners, Llc C/o Highland Park Service Corp.|Pepper Pike Acquisition Associates, Llc C/o Highland Park Service Corp.|Paul E. Kiebler, Iv
Photo of Hon. MICHAEL J RUSSO

Judge

Hon. MICHAEL J RUSSO

Cuyahoga County (OH)

Ohio

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Lawyers

Docket Entries

  1. ASE FILED: COMPLAINT, SERVICE REQUEST
  2. OURT COST ASSESSED PEPPER PIKE ACQUISITION ASSOCIATES, LLC BILL AMOUNT 20.5 PAID AMOUNT 18.75 AMOUNT DUE 1.75
  3. OURT COST ASSESSED PEPPER PIKE CAPITAL PARTNERS, LLC BILL AMOUNT 20.5 PAID AMOUNT 18.75 AMOUNT DUE 1.75
  4. OURT COST ASSESSED FALL CREEK PROMOTE, LLC BILL AMOUNT 20.5 PAID AMOUNT 18.75 AMOUNT DUE 1.75
  5. OURT COST ASSESSED JAMES DEROW BILL AMOUNT 263.84 PAID AMOUNT 250 AMOUNT DUE 13.84
  6. TIPULATION FILED BY PLAINTIFF(S) JAMES DEROW(P1) and AJ2 LLC(P2) ATTORNEY DOUGLAS M EPPLER 0087018 JOINT STIPULATION OF DISMISSAL OF ALL CLAIMS WITH PREJUDICE
  7. UDGMENT ENTRY(52453560) SENT BY EMAIL. TO: DOUGLAS M EPPLER [email protected]
  8. UDGMENT ENTRY(52453559) SENT BY EMAIL. TO: SARAH FONTANA [email protected]
  9. UDGMENT ENTRY(52453558) SENT BY EMAIL. TO: JOSEPH S SIMMS [email protected]
  10. UDGMENT ENTRY(52453557) SENT BY EMAIL. TO: MARK FUSCO [email protected]
  11. HE COURT HAS BEEN ADVISED THAT THIS MATTER HAS RESOLVED. AS SUCH, IT IS REMOVED FROM THE COURT'S ACTIVE DOCKET. THIS COURT RETAINS JURISDICTION TO ENFORCE SETTLEMENT IN THIS CASE. PARTIES HAVE 30 DAYS FROM THE DATE OF THIS ENTRY TO SUPPLEMENT THE DOCKET WITH A NOTICE OF DISMISSAL WITH INSTRUCTIONS AS TO COURT COSTS. COURT COST ASSESSED AS DIRECTED. PURSUANT TO CIV.R. 58(B), THE CLERK OF COURTS IS DIRECTED TO SERVE THIS JUDGMENT IN A MANNER PRESCRIBED BY CIV.R. 5(B). THE CLERK MUST INDICATE ON THE DOCKET THE NAMES AND ADDRESSES OF ALL PARTIES, THE METHOD OF SERVICE, AND THE COSTS ASSOCIATED WITH THIS SERVICE. THIS ENTRY TAKEN BY JUDGE TIMOTHY J MCGINTY. NOTICE ISSUED
  12. RIAL BY JURY SCHEDULED FOR 11/29/2023 AT 10:00 AM IS CANCELLED.
  13. OTICE FILED BY PLAINTIFF(S) JAMES DEROW(P1) and AJ2 LLC(P2) ATTORNEY MARK FUSCO 0040604 NOTICE OF WITHDRAWAL OF COUNSEL
  14. RIAL BY JURY SCHEDULED FOR 10/10/2023 AT 10:00 AM IS CANCELLED.
  15. FINAL PRETRIAL HELD. ALL PARTIES APPEAR THROUGH COUNSEL AND PROVIDE THE COURT WITH AN UPDATE ON THE CASE. MATTER REMAINS UNRESOLVED. FOR GOOD CAUSE SHOWN, THE JURY TRIAL ORIGINALLY SCHEDULED FOR 10/10/2023 IS CONTINUED AS FOLLOWS: TRIAL BY JURY SET FOR 11/29/2023 AT 10:00 AM. COURTROOM 18-B. TRIAL BRIEFS; JOINT JURY INSTRUCTIONS; VERDICT FORMS AGREED UPON BY COUNSEL; WITNESS LISTS; EXHIBIT LISTS; AND MOTIONS IN LIMINE ARE TO BE FILED AND COPIES DELIVERED TO THE COURTROOM OR STAFF ATTORNEY BY 11/08/2023; AN E-MAILED COPY TO THE STAFF ATTORNEY IS PREFERRED, INCLUDING ALL JURY INSTRUCTIONS, INTERROGATORIES, AND VERDICT FORMS IN MICROSOFT WORD FORMAT. PRIOR TO THE START OF JURY SELECTION, THE PARTIES ARE TO DELIVER TO THE COURT OR THE STAFF ATTORNEY A BRIEF AGREED-TO STATEMENT OF THE CASE TO BE READ TO THE PROSPECTIVE JURORS AS CONTEMPLATED BY CIV.R. 47(A). NOTE TAKING BY JURORS IS PERMITTED. JURY QUESTIONNAIRES AND SUBMISSION OF QUESTIONS BY JURORS TYPICALLY IS NOT PERMITTED. THIS ENTRY TAKEN BY JUDGE TIMOTHY J MCGINTY. NOTICE ISSUED
  16. FINAL PRE-TRIAL HELD; COUNSEL FOR ALL PARTIES PRESENT. ISSUES DISCUSSED. PLAINTIFFS' PARTIAL MOTION FOR SUMMARY JUDGMENT, FILED 07/10/2023, IS DENIED IN PART AND HELD IN ABEYANCE IN PART. DEFENDANTS MOTION FOR SUMMARY JUDGMENT (PART II), FILED 07/10/2023, IS GRANTED AND DENIED IN PART. ***BREACH OF CONTRACT*** PLAINTIFFS' MOTION FOR SUMMARY JUDGMENT ON ITS CLAIM FOR BREACH OF CONTRACT IS DENIED. DEFENDANTS' MOTION FOR SUMMARY JUDGMENT ON PLAINTIFFS' BREACH OF CONTRACT CLAIM IS DENIED. THE FOLLOWING FACTS ARE UNDISPUTED THE PARTIES ENTERED INTO A CONTRACT ON 11/03/2017 FOR PLAINTIFF DEROW'S EMPLOYMENT WITH DEFENDANTS THAT INCLUDED AN OPPORTUNITY TO INVEST IN DEFENDANTS' REAL ESTATE INVESTMENTS THROUGH A VEHICLE THAT DEFENDANTS REFER TO AS A "PROMOTE OPPORTUNITY." DEFENDANT KIEBLER ENCOURAGED DEROW TO INVEST IN A SPECIFIC PROMOTE NAMED "FALL CREEK PROMOTE" THROUGH E-MAILS AND TEXT MESSAGES LATER THAT MONTH. ON 01/03/2018 DEROW MOVED HIS FAMILY TO CLEVELAND FROM NEW YORK IN RELIANCE ON THIS JOB OPPORTUNITY AND INVESTMENT OPPORTUNITY. DEROW BEGAN WORKING WITH DEFENDANTS ON 01/08/2018. ON 01/09/2018 DEFENDANTS FORMED "FALL CREEK PROMOTE." PLAINTIFFS PROVIDED A $5,000 CHECK TO INVEST IN PROMOTE WHICH WAS DEPOSITED INTO DEFENDANTS' BANK ACCOUNTS ON 03/18/2018. DEFENDANTS DREW FUNDS AGAINST THIS DEPOSIT AND DRAFTS OF FALL CREEK'S OPERATING AGREEMENT AND OTHER DOCUMENTS THROUGH AUGUST 2018 INCLUDED PLAINTIFFS AS MEMBERS OF THE ENTITY. THE ACTIONS OF THE PARTIES, BY ALL ACCOUNTS, CREATES A PRESUMPTION THAT PLAINTIFFS-WITH DEFENDANTS' KNOWLEDGE AND AFFIRMATION-VALIDLY INVESTED IN FALL CREEK. DEFENDANTS, HOWEVER, BRING FORTH EVIDENCE THAT THEY RESCINDED THE PROMOTE INVESTMENT OPPORTUNITY TO ALL EMPLOYEES BEGINNING IN EARLY 2018. DEFENDANTS ALLEGE THAT PLAINTIFFS DEPOSITED THE INVESTMENT FUNDS WITHOUT THEIR KNOWLEDGE OR CONSENT, ALTHOUGH THEY APPEAR NOT TO CONTEST THE LEGITIMACY OF A SECOND INVESTMENT CHECK FROM PLAINTIFFS FOR $20,000 THAT WAS INVESTED IN A DIFFERENT OPPORTUNITY. DEFENDANTS ALSO ARGUE, DESPITE THEIR ACTIONS TO THE CONTRARY, THAT PLAINTIFF WAS UNABLE TO INVEST IN FALL CREEK BECAUSE IT "STARTED" BEFORE HE WAS AN EMPLOYEE OF DEFENDANTS. THE SCANT WRITINGS BETWEEN THE PARTIES LACK CLARITY FOR MANY OF THESE DISPUTED TERMS AND ISSUES. WHILE THE COURT FINDS THAT SOME OF DEFENDANTS' EVIDENCE APPEARS TO BE SELF-SERVING, THE COURT IS UNABLE TO WEIGH THE VERACITY OF SUCH EVIDENCE ON SUMMARY JUDGMENT. PLAINTIFFS' MOTION FOR SUMMARY JUDGMENT ON DEFENDANTS' COUNTERCLAIM FOR BREACH OF CONTRACT IS GRANTED. WHILE DEFENDANTS STYLE THIS CLAIM AS A BREACH OF CONTRACT, IT IS ACTUALLY A CLAIM OF WHETHER DEROW BREACHED HIS FIDUCIARY DUTY TO DEFENDANTS BY ENGAGING IN COMPETITIVE ACTION WHILE STILL EMPLOYED. ***DECLARATORY ACTION*** DEFENDANTS' MOTION FOR SUMMARY JUDGMENT ON PLAINTIFFS' DECLARATORY ACTION CLAIM IS HELD IN ABEYANCE. THE COURT WILL RULE ON THIS CLAIM, IF NECESSARY, FOLLOWING A DETERMINATION OF THE FACTS IN THIS MATTER BY A TRIER-OF-FACTS. ***CONVERSION*** DEFENDANTS' MOTION FOR SUMMARY JUDGMENT ON PLAINTIFFS' CLAIM OF CONVERSION IS HELD IN ABEYANCE. A FACTUAL DISPUTE EXISTS REGARDING THIS CLAIM THAT MUST BE DETERMINED BY A TRIER-OF-FACT. DEFENDANTS ARGUE THAT THE CLAIM IS DUPLICATIVE, BUT IT IS AN ALTERNATE FINDING FOR A FACTFINDER. FOR EXAMPLE, A FACTFINDER COULD FIND THAT NO CONTRACT BETWEEN THE PARTIES EXISTED FOR PLAINTIFFS' PARTICIPATION IN FALL CREEK PROMOTE; IN THAT INSTANCE, THE FACTFINDER MAY DETERMINE THAT DEFENDANTS WRONGFULLY CONVERTED THE $5,000 THAT PLAINTIFFS ATTEMPTED TO CONTRIBUTE AS AN INVESTMENT. IF A FACTFINDER FINDS, HOWEVER, THAT A CONTRACT DID EXIST FOR PLAINTIFFS' PARTICIPATION IN THE INVESTMENT OPPORTUNITY, THE PLAINTIFFS' CLAIM FOR CONVERSION COULD NOT LIE. PLAINTIFFS' MOTION FOR SUMMARY JUDGMENT ON DEFENDANTS' CLAIM OF CONVERSION IS GRANTED. THE UNDISPUTED FACTS SHOW THAT DEROW MADE COPIES OF DEFENDANTS' DOCUMENT DURING HIS EMPLOYMENT, WHICH WERE RELATED TO HIS EMPLOYMENT, AND WHICH HE WAS PERMITTED TO DO. THERE IS NO ALLEGATION THAT DEROW TOOK ANY ORIGINAL COPIES OF DOCUMENTS, ONLY THAT HE RETAINED THESE COPIES FOLLOWING HIS TERMINATION. ALTHOUGH DEFENDANTS KNEW THAT DEROW HAD RETAINED THESE DOCUMENTS, THEY DID NOT SEEK THEIR RETURN, AND DEROW DID NOT REFUSE TO RETURN THEM. DEFENDANTS FURTHER ALLEGE THAT DEROW MAY OR MAY NOT HAVE USED THE BUSINESS MODEL OF DEFENDANTS, WHICH IS THEORETICALLY CONTAINED WITHIN THESE COPIES, TO FURTHER HIS CAREER. DEROW, HOWEVER, WOULD HAVE LEARNED DEFENDANTS' BUSINESS MODEL DURING HIS EMPLOYMENT NEVER REQUESTED THAT DEROW SIGN A NON-COMPETE AGREEMENT OR SET ANY BOUNDARIES ON HIS USE OF THEIR INTELLECTUAL PROPERTY FOLLOWING HIS TERMINATION. THEY NOW ASK THE COURT TO ENFORCE A NON-COMPETE AGREEMENT BETWEEN THE PARTIES THROUGH AN ACTION FOR CONVERSION. BECAUSE DEFENDANTS CANNOT PROVE A WRONGFUL CONTROL OVER THEIR PERSONAL PROPERTY, NOR CAN THEY PROVE A REQUEST FOR A RETURN OF THE PERSONAL PROPERTY THAT WAS REFUSED, DEFENDANTS CANNOT SUCCEED ON THEIR CLAIM AS A MATTER OF LAW. ***BREACH OF FIDUCIARY DUTY*** DEFENDANTS' MOTION FOR SUMMARY JUDGMENT ON PLAINTIFFS' CLAIM OF BREACH OF FIDUCIARY DUTY IS HELD IN ABEYANCE. A FACTUAL DISPUTE EXISTS REGARDING THIS CLAIM THAT MUST BE DETERMINED BY A TRIER-OF-FACT. IF THE FACTFINDER ULTIMATELY DECIDES THAT PLAINTIFFS HELD A VALID INTEREST IN FALL CREEK PROMOTE, THEN DEFENDANTS OWED A FIDUCIARY DUTY TO PLAINTIFFS. IF A FACTFINDER DETERMINES THAT PLAINTIFFS HELD NO INTEREST IN FALL CREEK PROMOTE, THEN NO FIDUCIARY DUTY EXISTED. PLAINTIFFS' MOTION FOR SUMMARY JUDGMENT ON DEFENDANTS' COUNTERCLAIM FOR BREACH OF FIDUCIARY DUTY IS DENIED. THERE EXISTS A DISPUTE OF MATERIAL FACT OF WHETHER DEROW ENGAGED IN COMPETITIVE BEHAVIOR DURING HIS EMPLOYMENT WITH DEFENDANTS THAT WAS ADVERSE TO THEIR INTERESTS. FINAL PRETRIAL SET FOR 09/15/2023 AT 09:00 AM. FINAL PRE-TRIAL TO BE HELD IN COURTROOM 18-B. ATTORNEYS TO BE PRESENT IN PERSON. CLIENTS TO BE AVAILABLE IN PERSON OR VIA ZOOM. THE COURT WILL DISTRIBUTE A ZOOM LINK TO ALL PARTICIPANTS. THIS ENTRY TAKEN BY JUDGE TIMOTHY J MCGINTY. NOTICE ISSUED
  17. OTICE FILED BY DEFENDANT(S) FALL CREEK PROMOTE, LLC(D1), PEPPER PIKE CAPITAL PARTNERS, LLC(D2), PEPPER PIKE ACQUISITION ASSOCIATES, LLC(D3) and PAUL E. KIEBLER, IV(D4) ATTORNEY JOSEPH S SIMMS 0066584 NOTICE OF REFILING FULL SET OF EXHIBITS TO DEFENDANTS' PREVIOUSLY FILED MOTION FOR SUMMARY JUDGMENT
  18. DEFENDANTS MOTION FOR SUMMARY JUDGMENT, FILED 07/10/2023, IS STRICKEN. DEFENDANTS FILED TWO MOTIONS FOR SUMMARY JUDGMENT THREE MINUTES APART WHICH APPEAR TO BE NEARLY IDENTICAL. THE SECOND MOTION APPEARS TO CONTAIN ADDITIONAL PAGES NOT SUBMITTED IN THE FIRST FILED MOTION. TO CLARIFY THE DOCKET, THIS ENTRY STRIKES ONLY THE FIRST FILED MOTION. THIS ENTRY TAKEN BY JUDGE TIMOTHY J MCGINTY. NOTICE ISSUED
  19. EPLY BRIEF FILED BY DEFENDANT(S) FALL CREEK PROMOTE, LLC(D1), PEPPER PIKE CAPITAL PARTNERS, LLC(D2), PEPPER PIKE ACQUISITION ASSOCIATES, LLC(D3) and PAUL E. KIEBLER, IV(D4) JOSEPH S SIMMS 0066584 DEFENDANTS REPLY IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT
  20. EPLY BRIEF FILED BY PLAINTIFF(S) JAMES DEROW(P1) and AJ2 LLC(P2) DOUGLAS M EPPLER 0087018 PLAINTIFFS' REPLY IN SUPPORT OF THEIR PARTIAL MOTION FOR SUMMARY JUDGMENT
  21. RIEF IN OPPOSITION FILED BY DEFENDANT(S) FALL CREEK PROMOTE, LLC(D1), PEPPER PIKE CAPITAL PARTNERS, LLC(D2), PEPPER PIKE ACQUISITION ASSOCIATES, LLC(D3) and PAUL E. KIEBLER, IV(D4) JOSEPH S SIMMS 0066584 DEFENDANTS BRIEF IN OPPOSITION TO PLAINTIFFS PARTIAL MOTION FOR SUMMARY JUDGMENT
  22. RIEF IN OPPOSITION FILED BY PLAINTIFF(S) JAMES DEROW(P1) and AJ2 LLC(P2) DOUGLAS M EPPLER 0087018 PLAINTIFFS' BRIEF IN OPPOSITION TO DEFENDANTS' MOTION FOR SUMMARY JUDGMENT
  23. OTICE FILED BY PLAINTIFF(S) JAMES DEROW(P1) and AJ2 LLC(P2) ATTORNEY DOUGLAS M EPPLER 0087018 NOTICE OF FILING CERTAIN DEPOSITION EXHIBITS THAT THE COURT DIRECTED MAY NOT BE SEALED
  24. PLAINTIFF(S) JAMES DEROW(P1) AND AJ2 LLC(P2) DOUGLAS M EPPLER 0087018 MOTION TO FILE CERTAIN DEPOSITION EXHIBITS UNDER SEAL INSTANTER, FILED 07/10/2023, IS DENIED. THIS ENTRY TAKEN BY JUDGE TIMOTHY J MCGINTY. NOTICE ISSUED
  25. INAL PRETRIAL SCHEDULED FOR 08/03/2023 AT 02:00 PM IS CANCELLED.
  26. RIAL BY JURY SCHEDULED FOR 09/05/2023 AT 10:00 AM IS CANCELLED.
  27. UPON AGREEMENT BY THE PARTIES, DEADLINE FOR MOTION FOR SUMMARY JUDGMENT FILINGS IS EXTENDED THROUGH 07/10/2023. THIS ENTRY TAKEN BY JUDGE TIMOTHY J MCGINTY. NOTICE ISSUED
  28. OTICE OF TRANSCRIPT FILED DEFENDANT(S) FALL CREEK PROMOTE, LLC(D1), PEPPER PIKE CAPITAL PARTNERS, LLC(D2), PEPPER PIKE ACQUISITION ASSOCIATES, LLC(D3) and PAUL E. KIEBLER, IV(D4), JOSEPH S SIMMS 0066584 NOTICE OF FILING DEPOSITION TRANSCRIPT OF PAUL KIEBLER
  29. OTICE OF TRANSCRIPT FILED DEFENDANT(S) FALL CREEK PROMOTE, LLC(D1), PEPPER PIKE CAPITAL PARTNERS, LLC(D2), PEPPER PIKE ACQUISITION ASSOCIATES, LLC(D3) and PAUL E. KIEBLER, IV(D4), JOSEPH S SIMMS 0066584 NOTICE OF FILING DEPOSITION TRANSCRIPT OF JAMES DEROW AND PAUL KIEBLER
  30. OTION FOR SUMMARY JUDGMENT FILED DEFENDANTS MOTION FOR SUMMARY JUDGMENT (PART II) 09/05/2023 - GRANTED AND DENIED IN PART
  31. OTION FOR SUMMARY JUDGMENT FILED DEFENDANTS MOTION FOR SUMMARY JUDGMENT 08/30/2023 - STRICKEN
  32. OTICE OF TRANSCRIPT FILED PLAINTIFF(S) JAMES DEROW(P1) and AJ2 LLC(P2), DOUGLAS M EPPLER 0087018 NOTICE OF FILING DEPOSITION TRANSCRIPTS OF KENNETH M. LAPINE
  33. OTICE OF TRANSCRIPT FILED PLAINTIFF(S) JAMES DEROW(P1) and AJ2 LLC(P2), DOUGLAS M EPPLER 0087018 NOTICE OF FILING DEPOSITION TRANSCRIPT (WITH EXHIBITS NOT MARKED CONFIDENTIAL) OF PAUL E. KIEBLER, IV
  34. OTION FILED FOR PLAINTIFF(S) JAMES DEROW(P1) and AJ2 LLC(P2) DOUGLAS M EPPLER 0087018 MOTION TO FILE CERTAIN DEPOSITION EXHIBITS UNDER SEAL INSTANTER 08/01/2023 - DENIED
  35. OTION FOR SUMMARY JUDGMENT FILED PLAINTIFFS' PARTIAL MOTION FOR SUMMARY JUDGMENT 09/05/2023 - DENIED IN PART
  36. FFIDAVIT FILED BY PLAINTIFF(S) JAMES DEROW(P1) and AJ2 LLC(P2) ATTORNEY DOUGLAS M EPPLER 0087018 AFFIDAVIT OF DOUGLAS M. EPPLER IN SUPPORT OF PLAINTIFFS' PARTIAL MOTION FOR SUMMARY JUDGMENT
  37. FFIDAVIT FILED BY PLAINTIFF(S) JAMES DEROW(P1) and AJ2 LLC(P2) ATTORNEY DOUGLAS M EPPLER 0087018 AFFIDAVIT OF JAMES DEROW IN SUPPORT OF PLAINTIFF'S PARTIAL MOTION FOR SUMMARY JUDGMENT
  38. IN CONNECTION WITH THE ORDER GRANTING IN PART AND DENYING IN PART PLAINTIFFS' MOTION TO QUASH SUBPOENA, THE PARTIES--THROUGH COUNSEL--HAVE STIPULATED THAT THE DOCUMENTS COVERING THE PERIOD OF JANUARY 8, 2018 TO JULY 31, 2019 MAY BE PRODUCED UNDER AN ATTORNEYS-EYES-ONLY DESIGNATION PER THE STIPULATED PROTECTIVE ORDER PREVIOUSLY ISSUED HEREIN. THEREAFTER, THE PARTIES, THROUGH COUNSEL, WILL WORK TOGETHER TO IDENTIFY WHAT PORTIONS ARE IRRELEVANT AND THEREFORE MUST BE REDACTED PRIOR TO CONVERTING THE DESIGNATION FROM AEO TO CONFIDENTIAL. SHOULD THE PARTIES HAVE ANY DISPUTE AS TO ANY PROPOSED REDACTIONS, THOSE LIMITED ISSUES WILL BE SUBMITTED TO THE COURT FOR CONSIDERATION. SO ORDERED. THIS ENTRY TAKEN BY JUDGE TIMOTHY J MCGINTY. NOTICE ISSUED
  39. JOINT MOTION FOR AMENDED CASE MANAGEMENT SCHEDULE, FILED 05/25/2023 BY DOUGLAS M EPPLER 0087018, IS GRANTED. ALL DISPOSITIVE MOTIONS TO BE FILED BY 07/03/2023; BRIEFS IN OPPOSITION AND REPLIES TO BE FILED PURSUANT TO THE CIVIL RULES. FINAL PRETRIAL SET FOR 09/05/2023 AT 10:00 AM. THE PARTIES ARE TO CONTACT THE STAFF ATTORNEY IN ADVANCE TO DETERMINE THE BEST METHOD BY WHICH TO CONDUCT THE FINAL PRE-TRIAL. TRIAL BY JURY SET FOR 10/10/2023 AT 10:00 AM. TRIAL BRIEFS; JOINT JURY INSTRUCTIONS; VERDICT FORMS AGREED UPON BY COUNSEL; WITNESS LISTS; EXHIBIT LISTS; AND MOTIONS IN LIMINE ARE TO BE FILED AND COPIES DELIVERED TO THE COURTROOM OR STAFF ATTORNEY BY 09/19/2023; AN E-MAILED COPY TO THE STAFF ATTORNEY IS PREFERRED, INCLUDING ALL JURY INSTRUCTIONS, INTERROGATORIES, AND VERDICT FORMS IN MICROSOFT WORD FORMAT. PRIOR TO THE START OF JURY SELECTION, THE PARTIES ARE TO DELIVER TO THE COURT OR THE STAFF ATTORNEY A BRIEF AGREED-TO STATEMENT OF THE CASE TO BE READ TO THE PROSPECTIVE JURORS AS CONTEMPLATED BY CIV.R. 47(A). NOTE TAKING BY JURORS IS PERMITTED. JURY QUESTIONNAIRES AND SUBMISSION OF QUESTIONS BY JURORS TYPICALLY IS NOT PERMITTED. THIS ENTRY TAKEN BY JUDGE TIMOTHY J MCGINTY. NOTICE ISSUED
  40. OTICE OF APPEARANCE, FILED PLAINTIFF(S) JAMES DEROW(P1) and AJ2 LLC(P2) SARAH FONTANA 0100077. NOTICE OF APPEARANCE OF ADDITIONAL COUNSEL
  41. PLAINTIFF(S) JAMES DEROW(P1) AND AJ2 LLC(P2) DOUGLAS M EPPLER 0087018 PLAINTIFFS JAMES DEROW AND AJ2, LLC'S AND NON-PARTY CEORA DEROW'S MOTION TO QUASH AND FOR PROTECTIVE ORDER, FILED 05/18/2023, IS GRANTED IN PART. THE COURT IS WILLING TO PERMIT THE SUBPOENA TO CHASE BANK FOR THE TIME PERIOD DURING WHICH MR. DEBROW WAS AN OFFICER/EMPLOYEE FOR PPCP. THE BANK RECORDS ARE NOT TO BE PRODUCED UNTIL THE PARTIES HAVE PROPOSED A METHOD TO THE COURT BY WHICH THE CONFIDENTIAL, PRIVATE, AND TOTALLY IRRELEVANT PORTIONS OF THE BANKING RECORDS CAN BE REDACTED. THIS ENTRY TAKEN BY JUDGE JANET R BURNSIDE. NOTICE ISSUED
  42. OTION FILED FOR PLAINTIFF(S) JAMES DEROW(P1) and AJ2 LLC(P2) DOUGLAS M EPPLER 0087018 JOINT MOTION FOR AMENDED CASE MANAGEMENT SCHEDULE 06/15/2023 - GRANTED
  43. EPLY BRIEF FILED BY PLAINTIFF(S) JAMES DEROW(P1) and AJ2 LLC(P2) DOUGLAS M EPPLER 0087018 PLAINTIFFS JAMES DEROW AND AJ2, LLC'S AND NON-PARTY CEORA DEROW'S REPLY IN SUPPORT OF MOTION TO QUASH AND FOR PROTECTIVE ORDER
  44. OTICE OF TRANSCRIPT FILED DEFENDANT(S) FALL CREEK PROMOTE, LLC(D1), PEPPER PIKE CAPITAL PARTNERS, LLC(D2), PEPPER PIKE ACQUISITION ASSOCIATES, LLC(D3) and PAUL E. KIEBLER, IV(D4), JOSEPH S SIMMS 0066584 DEFENDANTS NOTICE OF FILING DEPOSITION TRANSCRIPT OF CEORA DEROW
  45. RIEF IN OPPOSITION FILED BY DEFENDANT(S) FALL CREEK PROMOTE, LLC(D1), PEPPER PIKE CAPITAL PARTNERS, LLC(D2), PEPPER PIKE ACQUISITION ASSOCIATES, LLC(D3) and PAUL E. KIEBLER, IV(D4) JOSEPH S SIMMS 0066584 DEFENDANTS OPPOSITION TO PLAINTIFFS AND NON-PARTY CEORA DEROWS MOTION TO QUASH AND FOR PROTECTIVE ORDER
  46. OTION FILED FOR PLAINTIFF(S) JAMES DEROW(P1) and AJ2 LLC(P2) DOUGLAS M EPPLER 0087018 PLAINTIFFS JAMES DEROW AND AJ2, LLC'S AND NON-PARTY CEORA DEROW'S MOTION TO QUASH AND FOR PROTECTIVE ORDER 05/30/2023 - GRANTED
  47. DEFENDANT(S) FALL CREEK PROMOTE, LLC(D1), PEPPER PIKE CAPITAL PARTNERS, LLC(D2), PEPPER PIKE ACQUISITION ASSOCIATES, LLC(D3) AND PAUL E. KIEBLER, IV(D4)'S MOTION FOR PROTECTIVE ORDER, FILED 05/05/2023 BY JOSEPH S SIMMS 0066584, IS GRANTED. THE PARTIES ARE NOT PERMITTED TO DEPOSE KENNETH LAPINE UNTIL LAPINE HAS COMPLIED FULLY WITH DEFENDANTS' SUBPOENA(S). ALTERNATIVELY, SHOULD THE PARTIES AGREE TO DEPOSE KENNETH LAPINE AT THE CURRENTLY NOTICED DEPOSITION, DEFENDANTS ARE PERMITTED TO CONDUCT A SECOND DEPOSITION OF LAPINE AFTER HE HAS RESPONDED FULLY TO THEIR OUTSTANDING SUBPOENA, AND MAY QUESTION HIM ON ANY TOPIC NECESSARY, EVEN IF HE HAS PREVIOUSLY TESTIFIED TO THE SAME MATTER. DEFENDANT(S) FALL CREEK PROMOTE, LLC(D1), PEPPER PIKE CAPITAL PARTNERS, LLC(D2), PEPPER PIKE ACQUISITION ASSOCIATES, LLC(D3) AND PAUL E. KIEBLER, IV(D4)'S MOTION TO COMPEL KENNETH LAPINE'S RESPONSE TO SUBPOENA, FILED 05/05/2023 BY JOSEPH S SIMMS 0066584, IS GRANTED. KENNETH LAPINE IS ORDERED TO FULLY RESPOND TO THE DEFENDANTS' SUBPOENA AS SOON AS POSSIBLE, AND NO LATER THAN 48 HOURS PRIOR TO THE START OF HIS CURRENTLY SCHEDULED DEPOSITION IN THIS CASE. IN ANY EVENT, ALL RESPONSIVE DOCUMENTS ARE TO BE PRODUCED BY 06/01/2023 BY 4:30 P.M. FAILURE TO COMPLY WITH THE COURT'S ORDERS MAY RESULT IN SANCTIONS TO THE EXTENT PERMITTED BY LAW. THIS ENTRY TAKEN BY JUDGE JOHN J RUSSO. NOTICE ISSUED
  48. RIAL BY JURY SCHEDULED FOR 06/12/2023 AT 10:00 AM IS CANCELLED.
  49. ENERAL PLEADING FILED BY DEFENDANT(S) FALL CREEK PROMOTE, LLC(D1), PEPPER PIKE CAPITAL PARTNERS, LLC(D2), PEPPER PIKE ACQUISITION ASSOCIATES, LLC(D3) and PAUL E. KIEBLER, IV(D4) ATTORNEY JOSEPH S SIMMS 0066584 DEFENDANTS REPLY IN SUPPORT OF MOTION TO COMPEL KENNETH LAPINES RESPONSE TO SUBPOENA
  50. RIEF IN OPPOSITION FILED BY DEBORAH J MICHELSON 0059044 NON-PARTY KENNETH LAPINE'S BRIEF IN OPPOSITION TO DEFENDANTS' MOTION TO COMPEL
  51. ENERAL PLEADING FILED BY DEFENDANT(S) FALL CREEK PROMOTE, LLC(D1), PEPPER PIKE CAPITAL PARTNERS, LLC(D2), PEPPER PIKE ACQUISITION ASSOCIATES, LLC(D3) and PAUL E. KIEBLER, IV(D4) ATTORNEY JOSEPH S SIMMS 0066584 DEFENDANTS' REPLY IN SUPPORT OF MOTION TO COMPEL KENNETH LAPINE'S RESPONSE TO SUBPOENA
  52. EPLY BRIEF FILED BY P1 JAMES DEROW DOUGLAS M EPPLER 0087018 PLAINTIFFS' RESPONSE TO DEFENDANTS' MOTION TO COMPEL KENNETH LAPINE'S RESPONSE TO SUBPOENA AND DEFENDANTS' MOTION FOR PROTECTIVE ORDER
  53. UBPOENA SERVICE RETURN FILED KENNETH LAPINE, DOUGLAS M EPPLER (0087018) SUBPOENA SERVICE RETURN OF KENNETH LAPINE
  54. OTION FILED FOR DEFENDANT(S) FALL CREEK PROMOTE, LLC(D1), PEPPER PIKE CAPITAL PARTNERS, LLC(D2), PEPPER PIKE ACQUISITION ASSOCIATES, LLC(D3) and PAUL E. KIEBLER, IV(D4) JOSEPH S SIMMS 0066584 DEFENDANTS' MOTION TO COMPEL KENNETH LAPINE'S RESPONSE TO SUBPOENA 05/18/2023 - GRANTED
  55. MOTION FILED FOR DEFENDANT(S) FALL CREEK PROMOTE, LLC(D1), PEPPER PIKE CAPITAL PARTNERS, LLC(D2), PEPPER PIKE ACQUISITION ASSOCIATES, LLC(D3) and PAUL E. KIEBLER, IV(D4) JOSEPH S SIMMS 0066584 DEFENDANTS' MOTION FOR PROTECTIVE ORDER 05/18/2023 - GRANTED
  56. SUBPOENA RETURN: DAVID B. ST. PIERRE 19560 ARGYLE OVAL ROCKY RIVER, OHIO 44116 SERVICE: 03/10/23 ON DAVID B. ST. PIERRE AS FOLLOWS: HAND DELIVERED
  57. SUBPOENA RETURN: MITCHELL C. SCHNEIDER C/O FIRST INTERSTATE PROPERTIES, LTD THE OFFICES AT LEGACY VILLAGE, 25333 CEDAR ROAD, SUITE 300 LYNDHURST, OHIO 44124 SERVICE: 03/10/23 ON MITCHELL C. SCHNEIDER C/O FIRST INTERSTATE PROPERTIES, LTDAS FOLLOWS: HAND DELIVERED
  58. SUBPOENA RETURN: KENNETH LAPINE C/O BUCKLEY KING 1400 FIFTH THIRD CENTER, 600 SUPERIOR AVENUE, EAST CLEVELAND, OHIO 44114 SERVICE: 03/10/23 ON KENNETH LAPINE AS FOLLOWS: HAND DELIVERED
  59. SUBPOENA RETURN: JEFF DECHELLIS C/O THE MID-AMERICA MANAGEMENT CORPORATION 3333 RICHMOND ROAD, SUITE 350 BEACHWOOD, OHIO 44122 SERVICE: 03/10/23 ON JEFF DECHELLIS AS FOLLOWS: HAND DELIVERED BY PROCESS SERVER, SERVED THE RECEPTIONIST, WHO REFUSED TO GIVE HER NAME
  60. SUBPOENA SERVICE RETURN FILED JEFF DECHELLIS, JOSEPH S SIMMS (0066584) SUBPOENA SERVICE RETURN - JEFF DECHELLIS
  61. SUBPOENA SERVICE RETURN FILED KENNETH LAPINE, JOSEPH S SIMMS (0066584) SUBPOENA SERVICE RETURN - KENNETH LAPINE
  62. SUBPOENA SERVICE RETURN FILED MITCHELL C. SCHNEIDER, JOSEPH S SIMMS (0066584) SUBPOENA SERVICE RETURN - MITCHELL SCHNEIDER
  63. SUBPOENA SERVICE RETURN FILED, JOSEPH S SIMMS (0066584) SUBPOENA SERVICE RETURN - DAVID ST. PIERRE
  64. : STIPULATED PROTECTIVE ORDER. THE PARTIES ARE REMINDED THAT THE DOCKET OF THE CUYAHOGA COUNTY COURT OF COMMON PLEAS IS A PUBLIC RECORD AND OHIO LAW ONLY PERMITS THE FILING OF DOCUMENTS UNDER SEAL AFTER A MOTION FOR THAT RELIEF AND COURT APPROVAL, PURSUANT TO STATE LAW. ANY DOCUMENT FILED UNDER SEAL WITHOUT PRIOR COURT APPROVAL WILL BE STRICKEN FROM THE DOCKET AND DESTROYED. OSJ. THIS ENTRY TAKEN BY JUDGE JANET R BURNSIDE. NOTICE ISSUED
  65. NOTICE FILED BY P1 JAMES DEROW ATTORNEY DOUGLAS M EPPLER 0087018 PLAINTIFF'S NOTICE OF FILING STIPULATED PROTECTIVE ORDER
  66. SUBPOENA SERVICE RETURN FILED JEF DECHELLIS, JOSEPH S SIMMS (0066584) SUBPOENA RETURN ON JEFF DECHELLIS
  67. SUBPOENA SERVICE RETURN FILED, NON-PARTY 9999999 SUBPOENA RETURN ON MITCHELL SCHNEIDER
  68. SUBPOENA SERVICE RETURN FILED, NON-PARTY 9999999 SUBPOENA RETURN ON BLOSSOM PROPERTIES
  69. SUBPOENA SERVICE RETURN FILED DAVID B ST PIERRE, JOSEPH S SIMMS (0066584) SUBPOENA RETURN ON DAVID B. ST. PIERRE
  70. : UPON NOTICE BY THE PARTIES, THE CASE SCHEDULE IS EXTENDED AS FOLLOWS: ALL DISCOVERY TO BE COMPLETED BY 05/12/2023. ANY DISPOSITIVE MOTION TO BE FILED BY 06/02/2023; BRIEFS IN OPPOSITION AND REPLIES TO BE FILED PURSUANT TO THE CIVIL RULES. FINAL PRETRIAL SET FOR 08/03/2023 AT 02:00 PM. TRIAL BY JURY SET FOR 09/05/2023 AT 10:00 AM. TRIAL BRIEFS; JOINT JURY INSTRUCTIONS; VERDICT FORMS AGREED UPON BY COUNSEL; WITNESS LISTS; EXHIBIT LISTS; AND MOTIONS IN LIMINE ARE TO BE FILED AND COPIES DELIVERED TO THE COURTROOM OR STAFF ATTORNEY BY 08/15/2023; AN E-MAILED COPY TO THE STAFF ATTORNEY IS PREFERRED, INCLUDING ALL JURY INSTRUCTIONS, INTERROGATORIES, AND VERDICT FORMS IN MICROSOFT WORD FORMAT. PRIOR TO THE START OF JURY SELECTION, THE PARTIES ARE TO DELIVER TO THE COURT OR THE STAFF ATTORNEY A BRIEF AGREED-TO STATEMENT OF THE CASE TO BE READ TO THE PROSPECTIVE JURORS AS CONTEMPLATED BY CIV.R. 47(A). NOTE TAKING BY JURORS IS PERMITTED. JURY QUESTIONNAIRES AND SUBMISSION OF QUESTIONS BY JURORS TYPICALLY IS NOT PERMITTED. THIS ENTRY TAKEN BY JUDGE JANET R BURNSIDE. NOTICE ISSUED
  71. : JOINT MOTION TO EXTEND DISCOVERY DEADLINE, FILED 02/09/2023, IS GRANTED. FACT DISCOVERY EXTENDED TO 03/17/2023. THIS ENTRY TAKEN BY JUDGE JANET R BURNSIDE. NOTICE ISSUED
  72. MOTION FOR EXTENSION OF TIME JOINT MOTION TO EXTEND DISCOVERY DEADLINE 02/10/2023 - GRANTED
  73. : JOINT MOTION TO EXTEND DISCOVERY AND DISPOSITIVE MOTION DEADLINES, FILED 11/17/2022 DOUGLAS M EPPLER 0087018, IS GRANTED. FACT DISCOVERY TO BE COMPLETED BY 02/15/2023 ANY DISPOSITIVE MOTION TO BE FILED BY 03/15/2023; BRIEFS IN OPPOSITION AND REPLIES TO BE FILED PURSUANT TO THE CIVIL RULES. THIS ENTRY TAKEN BY JUDGE JANET R BURNSIDE. NOTICE ISSUED
  74. MOTION FILED FOR P1 JAMES DEROW DOUGLAS M EPPLER 0087018 JOINT MOTION TO EXTEND DISCOVERY AND DISPOSITIVE MOTION DEADLINES 01/30/2023 - GRANTED
  75. : PRE-TRIAL HELD; COUNSEL FOR ALL COUNSEL PARTICIPATING. ISSUES DISCUSSED, DISCOVERY IS UNDERWAY. ALL FACTUAL DISCOVERY TO BE COMPLETED BY 12/02/2022. ANY DISPOSITIVE MOTION TO BE FILED BY 01/06/2023; BRIEFS IN OPPOSITION AND REPLIES TO BE FILED PURSUANT TO THE CIVIL RULES. THE PARTIES MAY CONTACT THE STAFF ATTORNEY FOR A REFERRAL TO MEDIATION WITH ROBERT MCCLELLAND. FINAL PRETRIAL SET FOR 05/10/2023 AT 01:00 PM. TRIAL BY JURY SET FOR 06/12/2023 AT 10:00 AM. TRIAL BRIEFS; JOINT JURY INSTRUCTIONS; VERDICT FORMS AGREED UPON BY COUNSEL; WITNESS LISTS; EXHIBIT LISTS; AND MOTIONS IN LIMINE ARE TO BE FILED AND COPIES DELIVERED TO THE COURTROOM OR STAFF ATTORNEY BY 05/22/2023; AN E-MAILED COPY TO THE STAFF ATTORNEY IS PREFERRED, INCLUDING ALL JURY INSTRUCTIONS, INTERROGATORIES, AND VERDICT FORMS IN MICROSOFT WORD FORMAT. PRIOR TO THE START OF JURY SELECTION, THE PARTIES ARE TO DELIVER TO THE COURT OR THE STAFF ATTORNEY A BRIEF AGREED-TO STATEMENT OF THE CASE TO BE READ TO THE PROSPECTIVE JURORS AS CONTEMPLATED BY CIV.R. 47(A). NOTE TAKING BY JURORS IS PERMITTED. JURY QUESTIONNAIRES AND SUBMISSION OF QUESTIONS BY JURORS TYPICALLY IS NOT PERMITTED. NOTICE ISSUED
  76. GENERAL PLEADING FILED BY P1 JAMES DEROW ATTORNEY DOUGLAS M EPPLER 0087018 REPORT OF PARTIES' PLANNING MEETING UNDER CIV.R. 26(F)
  77. REPLY TO COUNTERCLAIM FILED P1 JAMES DEROW, ATTORNEY DOUGLAS M EPPLER 0087018 PLAINTIFF JAMES DEROW'S REPLY TO COUNTERCLAIMS OF DEFENDANT PEPPER PIKE CAPITAL PARTNERS, LLC.
  78. CERTIFIED MAIL NUMBER 47466507 ADDRESSED TO PAUL E. KIEBLER, IV(D4) NOT RETURNED BY THE U.S. POSTAL SERVICE AFTER 60 DAYS. NOTICE MAILED TO PLAINTIFF(S) ATTORNEY.
  79. DEPOSIT AMOUNT PAID JOSEPH S SIMMS
  80. ANSWER AND COUNTERCLAIM $75 ANSWER AND COUNTERCLAIM
  81. PRETRIAL CONFERENCE SET FOR 08/16/2022 AT 10:30 AM. PHONE PRE-TRIAL CONFERENCE TO BE HELD IN LIEU OF CMC. ALL PARTIES ARE TO JOIN ONE LINE AND THEN CALL THE STAFF ATTORNEY AT 216.443.8591 AT THE TIME OF THE PRE-TRIAL OR PROVIDE A CONFERENCE NUMBER TO THE STAFF ATTORNEY IN ADVANCE. IF THE CALL IS UNANSWERED, THE PARTIES SHOULD CONTINUE TO CALL UNTIL THE COURT IS ABLE TO ANSWER. IF THE PARTIES DO NOT CALL AS DIRECTED, THE COURT WILL CONSIDER IT A NON-APPEARANCE AND THE CASE MAY BE DISMISSED OR SET FOR EX PARTE TRIAL. LITIGANTS WHO PLAN TO REPRESENT THEMSELVES OR HAVE NOT YET HIRED AN ATTORNEY MAY CONTACT THE STAFF ATTORNEY AT ANY TIME TO INQUIRE ABOUT THE COURT PROCESS AND TO MAKE ARRANGEMENTS TO APPEAR. THE STAFF ATTORNEY CAN BE CONTACTED AT [email protected] OR 216.443.8591. DEFENDANTS IN DEBT COLLECTION CASES MAY CONTACT THE COURT RESOURCE CENTER AT 216.443.8204 OR [email protected] FOR ADDITIONAL ASSISTANCE. LITIGANTS NEED NOT PARTICIPATE IF THEY ARE REPRESENTED BY COUNSEL. FAILURE OF PRO SE PLTF OR PLTF'S COUNSEL TO PARTICIPATE OR APPEAR AT THIS OR ANY COURT DATE OR TO FOLLOW ANY COURT ORDER WILL RESULT IN ACTION BEING DISMISSED. FAILURE OF PRO SE DEFT OR DEFT'S COUNSEL TO PARTICIPATE OR APPEAR AT THIS OR ANY COURT DATE OR TO FOLLOW ANY COURT ORDER WILL RESULT IN COURT HOLDING EX PARTE TRIAL OR WILL RESULT IN ENTRY OF DEFAULT JUDGMENT. JUDGE MICHAEL J. RUSSO'S STANDING ORDERS AND LITIGATION PREFERENCES ARE AVAILABLE ON HIS PROFILE ON THE COURT'S WEBSITE. THE PARTIES ARE EXPECTED TO HAVE COMPLIED WITH THE PRE-TRIAL DISCLOSURES REQUIRED BY CIV. R. 26 PRIOR TO THE FIRST PRE-TRIAL. FAILURE TO COMPLY WITH CIV.R 26 WILL RESULT IN THE COURT SETTING A DISCOVERY HEARING WITH THE POSSIBILITY OF DISMISSAL OR DEFAULT JUDGMENT FOR FAILING TO COMPLY. THE PARTIES MAY REQUEST ORAL ARGUMENT OR FORMAL HEARING ON ANY MATTER BY CONTACTING THE STAFF ATTORNEY. ANY COURT DATE MAY BE HELD IN PERSON, BUT THE PARTIES MUST MAKE ARRANGEMENTS IN ADVANCE BY CONTACTING THE STAFF ATTORNEY. NOTICE ISSUED
  82. STIPULATION FOR LEAVE TO PLEAD FILED
  83. USPS RECEIPT NO. 47466506 DELIVERED BY USPS 05/09/2022 PEPPER PIKE ACQUISITION ASSOCIATES, LLC PROCESSED BY COC 05/18/2022.
  84. USPS RECEIPT NO. 47466505 DELIVERED BY USPS 05/09/2022 PEPPER PIKE CAPITAL PARTNERS, LLC PROCESSED BY COC 05/18/2022.
  85. USPS RECEIPT NO. 47466504 DELIVERED BY USPS 05/09/2022 FALL CREEK PROMOTE, LLC PROCESSED BY COC 05/18/2022.
  86. SUMS COMPLAINT(47466507) SENT BY CERTIFIED MAIL. TO: PAUL E. KIEBLER, IV 2916 NOTTINGHAM LANE HUNTING VALLEY, OH 44022
  87. SUMS COMPLAINT(47466506) SENT BY CERTIFIED MAIL. TO: PEPPER PIKE ACQUISITION ASSOCIATES, LLC 28601 CHAGRIN BLVD., SUITE 600 CLEVELAND, OH 44122
  88. SUMS COMPLAINT(47466505) SENT BY CERTIFIED MAIL. TO: PEPPER PIKE CAPITAL PARTNERS, LLC 28601 CHAGRIN BLVD., SUITE 600 CLEVELAND, OH 44122
  89. SUMS COMPLAINT(47466504) SENT BY CERTIFIED MAIL. TO: FALL CREEK PROMOTE, LLC 28601 CHAGRIN BLVD., SUITE 600 CLEVELAND, OH 44122
  90. SUMMONS E-FILE COPY COST
  91. SUMMONS E-FILE COPY COST
  92. WRIT FEE
  93. WRIT FEE
  94. SUMMONS E-FILE COPY COST
  95. SUMMONS E-FILE COPY COST
  96. WRIT FEE
  97. WRIT FEE
  98. JUDGE MICHAEL J RUSSO ASSIGNED (RANDOM)
  99. LEGAL RESEARCH
  100. LEGAL NEWS
  101. LEGAL AID
  102. COURT SPECIAL PROJECTS FUND
  103. COMPUTER FEE
  104. CLERK'S FEE
  105. DEPOSIT AMOUNT PAID WALTER & HAVERFIELD, L.L.P.

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