On February 19, 2015 a
Party Discovery
was filed
involving a dispute between
Summa Akron City And St. Thomas Hospitals,
and
Summa Western Reserve Hospital, Llc,
Western Reserve Hospital Partners, Llc,
for INJUNCTION
in the District Court of Summit County.
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CV-2015-02-0919 MLEA 03/25/2016 14:41:00 PM CALLAHAN, LYNNE S. Page 1 of 5
IN THE COURT OF COMMON PLEAS
SUMMIT COUNTY, OHIO
SUMMA HEALTH SYSTEM f/k/a SUMMA CASE NO. CV-2015-02-0919
AKRON CITY AND ST. THOMAS
HOSPITALS JUDGE LYNNE CALLAHAN
Plaintiff,
MOTION FOR LEAVE TO FILE A
vs. REPLY IN SUPPORT OF SUMMA’S
MOTION TO COMPEL DEPOSITIONS
WESTERN RESERVE HOSPITAL
PARTNERS, LLC, et al.
Defendants.
Plaintiff Summa Health System f/k/a Summa Akron City and St. Thomas Hospitals
(“Summa”) hereby requests leave to file a brief, two-page Reply in Support of its Motion to
Compel Depositions.
Summa believes that a short response to the arguments made in the defendants’
opposition briefs will assist the Court in ruling on Summa’s Motion. Moreover, because
Summa’s proposed Reply is being filed within the time allotted under the expedited briefing
schedule, neither the court nor the parties will be prejudiced by allowing Summa’s Reply.
Accordingly, Summa respectfully requests that the Court grant Summa’s request for
leave and accept as filed Summa’s Reply in Support of its Motion to Compel Depositions. A
Proposed Order is attached as Exhibit A, and a copy of Summa’s proposed Reply will be filed
concurrently with this motion.
Sandra Kurt, Summit County Clerk of Courts
CV-2015-02-0919 MLEA 03/25/2016 14:41:00 PM CALLAHAN, LYNNE S. Page 2 of 5
Dated: March 25, 2016 /s/ Thomas R. Lucchesi ..
Thomas R. Lucchesi (0025790)
tlucchesi@bakerlaw.com
Scott C. Holbrook (0073110)
sholbrook@bakerlaw.com
Daniel M. Kavouras (0089773)
dkavouras@bakerlaw.com
BAKER & HOSTETLER LLP
Key Tower
127 Public Square, Suite 2000
Cleveland, OH 44114-1214
Phone 216-621-0200
Fax 216-696-0740
Orville L. Reed, III (0023522)
oreed@stark-knoll.com
David P. Bertsch (0023517)
dbertsch@stark-knoll.com
Stark & Knoll Co., L.P.A.
3475 Ridgewood Rd.
Akron, OH 44333
Attorneys for Plaintiff Summa Health System
f/k/a Summa Akron City and St. Thomas
Hospitals
Sandra Kurt, Summit County Clerk of Courts
CV-2015-02-0919 MLEA 03/25/2016 14:41:00 PM CALLAHAN, LYNNE S. Page 3 of 5
CERTIFICATE OF SERVICE
I hereby certify that the foregoing was electronically filed on this 25th day of March,
2016, and served by electronic mail upon the following:
John N. Childs
Donald W. Davis, Jr.
BRENNAN, MANNA & DIAMOND, LLC
75 East Market Street
Akron, Ohio 44308
(330) 253-5060/(330) 253-1977 (fax)
jnchilds@bmdllc.com
dwdavis@bmdllc.com
Counsel for Defendant Western Reserve Hospital Partners, LLC
Susan O. Scheutzow
Mary Whitmer
KOHRMAN JACKSON & KRANTZ, PLL
1375 East 9th St., 20th Floor
Cleveland, OH 44114
Phone: (216) 736-7228
Fax: (216) 621-6536
sos@kjk.com
mkw@kjk.com
John F. Hill
Melinda Smith Yeargin
BUCKINGHAM, DOOLITTLE & BURROUGHS, LLC
3800 Embassy Parkway, Suite 300
Akron, OH 44333-8332
Telephone: 330/376-5300
Fax: 330/258-6559
jhill@bdblaw.com
myeargin@bdblaw.com
Counsel for Defendant Summa Western Reserve Hospital, LLC
/s/ Thomas R. Lucchesi ..
One of the Attorneys for Plaintiff
608582858.1
Sandra Kurt, Summit County Clerk of Courts
CV-2015-02-0919 MLEA 03/25/2016 14:41:00 PM CALLAHAN, LYNNE S. Page 4 of 5
Exhibit A
Sandra Kurt, Summit County Clerk of Courts
CV-2015-02-0919 MLEA 03/25/2016 14:41:00 PM CALLAHAN, LYNNE S. Page 5 of 5
IN THE COURT OF COMMON PLEAS
SUMMIT COUNTY, OHIO
SUMMA HEALTH SYSTEM f/k/a SUMMA CASE NO. CV-2015-02-0919
AKRON CITY AND ST. THOMAS
HOSPITALS JUDGE LYNNE CALLAHAN
Plaintiff,
ORDER
vs.
WESTERN RESERVE HOSPITAL
PARTNERS, LLC, et al.
Defendants.
This matter comes before the Court on Plaintiff’s Motion for Leave to File a Reply in
Support of its Motion to Compel Depositions. Having considered the matter, this Court hereby
orders that Summa’s Motion for Leave is GRANTED. Summa’s Reply in Support of its Motion
to Compel Depositions is hereby accepted as filed.
IT IS SO ORDERED.
Dated: _____________________ _________________________________
Judge Lynn Callahan
Sandra Kurt, Summit County Clerk of Courts
Document Filed Date
March 25, 2016
Case Filing Date
February 19, 2015
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CV-2015-02-0919 MLEA 03/25/2016 14:41:00 PM CALLAHAN, LYNNE S. Page 1 of 5 IN THE COURT OF COMMON PLEAS SUMMIT COUNTY, OHIO SUMMA HEALTH SYSTEM f/k/a SUMMA CASE NO. CV-2015-02-0919 AKRON CITY AND ST. THOMAS HOSPITALS JUDGE LYNNE CALLAHAN Plaintiff, MOTION FOR LEAVE TO FILE A vs. REPLY IN SUPPORT OF SUMMA’S MOTION TO COMPEL DEPOSITIONS WESTERN RESERVE HOSPITAL PARTNERS, LLC, et al. Defendants. Plaintiff Summa Health System f/k/a Summa Akron City and St. Thomas Hospitals (“Summa”) hereby requests leave to file a brief, two-page Reply in Support of its Motion to Compel Depositions. Summa believes that a short response to the arguments made in the defendants’ opposition briefs will assist the Court in ruling on Summa’s Motion. Moreover, because Summa’s proposed Reply is being filed within the time allotted under the expedited briefing schedule, neither the court nor the parties will be prejudiced by allowing Summa’s Reply. Accordingly, Summa respectfully requests that the Court grant Summa’s request for leave and accept as filed Summa’s Reply in Support of its Motion to Compel Depositions. A Proposed Order is attached as Exhibit A, and a copy of Summa’s proposed Reply will be filed concurrently with this motion. Sandra Kurt, Summit County Clerk of Courts CV-2015-02-0919 MLEA 03/25/2016 14:41:00 PM CALLAHAN, LYNNE S. Page 2 of 5 Dated: March 25, 2016 /s/ Thomas R. Lucchesi .. Thomas R. Lucchesi (0025790) tlucchesi@bakerlaw.com Scott C. Holbrook (0073110) sholbrook@bakerlaw.com Daniel M. Kavouras (0089773) dkavouras@bakerlaw.com BAKER & HOSTETLER LLP Key Tower 127 Public Square, Suite 2000 Cleveland, OH 44114-1214 Phone 216-621-0200 Fax 216-696-0740 Orville L. Reed, III (0023522) oreed@stark-knoll.com David P. Bertsch (0023517) dbertsch@stark-knoll.com Stark & Knoll Co., L.P.A. 3475 Ridgewood Rd. Akron, OH 44333 Attorneys for Plaintiff Summa Health System f/k/a Summa Akron City and St. Thomas Hospitals Sandra Kurt, Summit County Clerk of Courts CV-2015-02-0919 MLEA 03/25/2016 14:41:00 PM CALLAHAN, LYNNE S. Page 3 of 5 CERTIFICATE OF SERVICE I hereby certify that the foregoing was electronically filed on this 25th day of March, 2016, and served by electronic mail upon the following: John N. Childs Donald W. Davis, Jr. BRENNAN, MANNA & DIAMOND, LLC 75 East Market Street Akron, Ohio 44308 (330) 253-5060/(330) 253-1977 (fax) jnchilds@bmdllc.com dwdavis@bmdllc.com Counsel for Defendant Western Reserve Hospital Partners, LLC Susan O. Scheutzow Mary Whitmer KOHRMAN JACKSON & KRANTZ, PLL 1375 East 9th St., 20th Floor Cleveland, OH 44114 Phone: (216) 736-7228 Fax: (216) 621-6536 sos@kjk.com mkw@kjk.com John F. Hill Melinda Smith Yeargin BUCKINGHAM, DOOLITTLE & BURROUGHS, LLC 3800 Embassy Parkway, Suite 300 Akron, OH 44333-8332 Telephone: 330/376-5300 Fax: 330/258-6559 jhill@bdblaw.com myeargin@bdblaw.com Counsel for Defendant Summa Western Reserve Hospital, LLC /s/ Thomas R. Lucchesi .. One of the Attorneys for Plaintiff 608582858.1 Sandra Kurt, Summit County Clerk of Courts CV-2015-02-0919 MLEA 03/25/2016 14:41:00 PM CALLAHAN, LYNNE S. Page 4 of 5 Exhibit A Sandra Kurt, Summit County Clerk of Courts CV-2015-02-0919 MLEA 03/25/2016 14:41:00 PM CALLAHAN, LYNNE S. Page 5 of 5 IN THE COURT OF COMMON PLEAS SUMMIT COUNTY, OHIO SUMMA HEALTH SYSTEM f/k/a SUMMA CASE NO. CV-2015-02-0919 AKRON CITY AND ST. THOMAS HOSPITALS JUDGE LYNNE CALLAHAN Plaintiff, ORDER vs. WESTERN RESERVE HOSPITAL PARTNERS, LLC, et al. Defendants. This matter comes before the Court on Plaintiff’s Motion for Leave to File a Reply in Support of its Motion to Compel Depositions. Having considered the matter, this Court hereby orders that Summa’s Motion for Leave is GRANTED. Summa’s Reply in Support of its Motion to Compel Depositions is hereby accepted as filed. IT IS SO ORDERED. Dated: _____________________ _________________________________ Judge Lynn Callahan Sandra Kurt, Summit County Clerk of Courts