Preview
COPY
Pleas Court
wepinayon on oT
MEDINA COUNTY, OHIO
3 3
Ss
RS
PLAINTIFF ) eos
) cfm 2 fm
DANIEL MORAN ) sZ> BB
) JUDGE: =s § 2
vs ) _ “eg os
) CHASTOPHER J. COLUER, JODG
DEFENDANT )
)
CORDELL CORDELL ) CASE# S 7 C J Voo 29 ~
ATTORNEY FIRM & )
CAROLIN SOEDER )
REPRESENTING ATTORNEY )
COMPLAINT
Now comes the plaintiff filing suit for damages from defendants for attorney
misconduct, attorney legal malpractice, and failure to fulfil their professional
responsibility/duty to zealously defend their client. All allegations about the
defendant attorney in this lawsuit may be proven by examining all attached
emails and the dates in which they were sent.
Any potential non litigation agreement is null and void due to the defendants
failure to abide by the laws governing their conduct, duty, and behaviour.
1) The defendant attorney failed to represent their client to the best of their
abilities by not filing any motions to compel the opposing counsel in the
divorce case in the proper time frame, to compel reporting of all assets.
And arguing with their client to protect the ex-wife's assets while ignoring
their duty to represent their client and compel opposing counsel to report
current and necessary documentation in time to be considered by the
divource court.
a) The Email research attachment (attachment EM11-EM12)(sent to
client dec 21, 2020) from defendant was the defendant's answer to
their client requesting multiple times to compel the reporting of theCOPY
ex-wifes sick pay assets for division. Rather than performing their
due diligence, the defendant charged me for alleged research that
the client already knew to be true, proving that sick pay not only
should have been reported by the ex wife, but also divided by the
divorce trial court. (Bergman v Bergman and Weller v Weller).
b) As a direct result of the abandoned disabled non-attorney client's
improper filings with the divorce court, the divorce court found that
the sick pay funds cannot be divided since the client did not provide
any division policy of the unreported asset belonging to the ex wife.
See attached divorce decree. (attachment F27) which does not agree
with the case law that the Defendant paid the defendant for, but was
never used by the defendant attorney due to the abandonment of the
disabled client.
c) The ex wifes sick pay account held 95 2 days which was found on
the ex wife's pay stub sent to defendant attorney by ex-wife’s
attorney on november 6th 2020 (attachment E)
d) Using the Ohio revised code (124.38) to calculate the ex-wife's sick
pay account is valued as, one days pay is equal to one sick day's
current pay amount. (Using ex-wife’s contract attachment D)
e) since one sick day was valued at the time of decree at $438.46 times
95.5 = $41,872.93 should have been reported by the ex-wife and
divided by the divorce court. However it appears that the attorney
defendant was more interested in helping opposing counsel hide
assets for the ex wife, rather than compel their disclosure, the
divorce law 3105.171 requires that the divorce court shall require the
reporting of ALL litigant assets. NO EXCEPTIONS.
i) 50% of that asset entitled to the abandoned client was
$20,936.46 (item f’s calculation based on that 50% figure)
f) The defendant Attorney totally ignored the opposing counsel's
willingness to hide the sick pay asset with the help of the clients own
attorney/firm. As shown by the emails and text messages the only
thing the defendant attorney did was prove that the ex-wifes sick pay
was in fact a divisible asset by both ORC and CASELAW, while
ignoring their own clients' wishes that the ex-wife be compelled to
report ALL assets prior to trial.
i) It appears The defendant attorney spent the whole time
charging the client for non-service while trying to mislead their
clients attention away from wanting the assets reported as
required by laws governing attorney professional behaviour.COPY
ii) ORC 3105.171.E,3 requires each litigant to disclose ALL
assets and income
iii) | The excuse from the defendant attorney, that the discovery
phase of the case was over is misleading, there are measures
a dutiful lawyer can take to protect their client from a
dishonest legal attack up to and including the trial time frame,
and beyond.
g) The written ORC penalty (ORC3501.171(E,5) for willfully hiding
assets is a penalty of three times the amount hidden from division of
the divorce court.
i) Since the defendant attorney assisted the ex wife in hiding
those assets then, the defendant attorney should be directly
responsible for the three times penalty of the clients rightfully
owed amount. making the direct loss to the client $62,809.39
2) The defendant attorney also did not pursue any of the protections by law to
protect their disabled veteran client from being removed from his VA
disability remodeled home, as ordered by the veterans disability protection
act (no non cash disability benefit may be divided unless there is
extenuating circumstances such as minor children living in the home,
which there were none.)
a) This directly resulted in the disabled veteran client being
permanently removed from his VA disability remodeled home, and
the home being ordered sold by the divorce court. (attachment F23)
b) their disabled client cannot afford and still does not have the dignity
of disability accommodated showering facilities at his disposal, still
to this date! Since the accommodated (once in a lifetime VA benefit
remodel (attachment LO) ) home was not protected by proper filings
from the defense attorney.
c) The defendant attorney knew of the VA accommodations from their
client. but also from the email November 6th 2020 that the opposing
counsel informed the defendant attorney of the VA accommodations.
If the defendant had been doing their sworn duty there was plenty of
time to demand the protections of the veterans disability protection
act on the behalf of their client. (Attachment LO)
3) The defendant attorney kept attempting to mislead their client while client
was attempting to get them to compel the ex-wife to report all currentCOPY
4)
assets by telling their client to pay for QDRO groups retainer while never
telling their client that the QDRO group was not even a factor to figure
pension valuation until after the trial awarded their client something to
calculate the value of. especially since no QDRO professional group can
establish a value of anything that ISN'T REPORTED or awarded prior to
trial. (Attachments E multiple places)
The defendant attorney abandoned their mentally and physically disabled
client claiming it was a professional dispute between the defendant
attorney and their client.
a)
b)
qd)
The defendant attorney mentioned this to the client as early as
December 28th 2020,, 6 days after they intentionally. withdrew from
the case. Further damaging any defense their client might be able to
produce prior to the trial deadline of January 4th 2021, that directly
benefited the ex-wife and her attorneys undefended case.
As for the attorney defendant's reason for not filing any defense
relevant documents or motions with the divorce court in a proper
time frame as shown by the divorce courts docket (ATTACHMENT
DO1 - DOS) although the only time frame relevant to this case is on
(page DO2) and intentional withdrawal from their clients case, no
reasonable honest excuse has ever been given.
Defendant attorney filed their withdrawal / abandonment on
December 22nd as shown in the divorce courts attached docket
after the continuance had already been denied and ensured that the
defendants client would have no ability to retain any counsel in the
allowed time frame.
Also note that Jason Lasser cordell’s firm leader emailed the client
on January 4 th 2021 stating that the client could pick his file (court
documents, evidence etc.(Attachment EM16-EM20) up from the
defendant attorney on January 6th 2021 two days after the deadline
for documents/evidence for the consideration of the court had
passed. Further preventing their client from being able to establish
any reasonable defense.
5) The defendant attorney was also viciously charging their client to continue
to victimize his misplaced faith in the protection of law and the American
judicial system’s and protections of citizens rights. by failing to perform the
required attorney duties in a timely fashion.COPY
6) The entire time the defendant attorney was charging their client for work
that was never done or not done in a timely fashion is also against the law
governing attorney conduct. (billing)
a) the client had already paid the defendant for TRIAL representation
and had a positive balance on Dec 14th 2020 of $5,915.80
(attachment B1-B2)
b) This was after the defendant attorney charged their client $3,415.80
for work that did not benefit their client whatsoever and research that
proved that their client advised them correctly about what needed
done since October 26th 2020
c) somehow with the defendants abandonment of their client the
defendant charged their clint the entire amount of $5,915.80 but
continues to attempt to collect an additional $1,818.60 (attachment
B3) of excessive charges using email and harassing phone calls. To
the abandoned client.
d) Directly costing their client $9,331.60, for professional attorney fees
that were useless in the case at least, and victimizing their own client
at best.
e) During the entire representation by the defendant, the defendant only
filed a few items with the divorce court none of which pertained to
anything that was contested by their client in the divorce.
Knowing that the defendant was working for the ex wifes attorneys
interests and not paying any attention to their own client’s interests
starting 3weeks after a suicide attempt (Oct26th 2020) by their disabled
client, and ending with the abandonment of the disabled client Dec 22 2020,
and not informing their client until the 28th of December 2020 has made
this last year of abuse from the ex wife and her attorney extremely difficult
with his PTSD AND DEPRESSION. Directly aggravated by being abandoned
by the defendant client. Therefore plaintiff is requesting $1,000,000,000.00
payment for unnecessary pain and suffering the plaintiff endured as a
direct result of the defendant attorneys abandonment at a critical time of
the case.
These events have prevented the plaintiff from trusting anyone associated
with the legal system and have led to a majority of sleepless nights
worrying about what else the legal system might do to the unrepresented
plaintiff client, especially since the divorce court alleges that all my filings
which the totally court ignored was due to the disabled clients filings being
misfiled or missing deadlines to file documents.the late filed subpoena byCOPY
the defendant was just another disturbing example of the defendant firm,
not representing their client zealously as commanded by law.
Timeline of events (See attachment A1-A3)
It is in the best interest of all parties to mandate the 7th Amendment to the
united states constitution to demand a jury trial for this matter
Therefore the plaintiff demands compensation from the defendant in the
amount of: $1,633,740.99 as itemized below
1:$ 62,809.39to payback the plaintiff's entitlement to the ex-wife's sick pay
2:$561,600 to payback the plaintiffs entitlement to his boilermaker disability
benefit $90.00 a month for 52 years = $561,600.00 (attachment BM1)
3:$1,000,000 to pay the disabled plaintiff for pain and suffering, for over a
year of mental anxiety, and the disabled defendant not having the ability or
dignity to take a complete shower at his residence. And funds to replace the
disabled veterans disability accommodations to prevent the ongoing anxiety that
the plaintiff has and allow the client some aspect of dignity of a complete shower.
4: It is also this disabled veterans demand that ALL cordell cordell
associates no matter what their employment title is be made to attend a class on
the veterans disability protection act and a class on how to approach and deal
with clients with mental disabilities such as but not limited to PTSD &
DEPRESSION. All costs associated with these employment mandatory classes
shall be covered by cordell cordell with payments to the VETERANS
ADMINISTRATION to develop these courses
5: for overcharging their client for irrelevant or non existent work
performed on the case plaintiff requests a full refund of $9,331.60
It is my hope that this case will replace what the plaintiff has lost and prevent the
abuse and denial of constitutional rights of any future disabled veterans that the
Defendant might have the opportunity to represent in the future.
Respectfully submitted
Plaintiff
Daniel MoranCOPY
BOILERMAKER-BLACKSMITH NATIONAL PENSION TRUST
PO Box 909700
Kansas City, MO 64190-9700
866-342-6555 or 913-342-6555
February 16, 2021
Daniel Moran
1114 N Court st
Medina, OH 44256-1579
Re: Domestic Relations Order Benefit Hold
Dear Mr. Moran:
This letter is to notify you that the Boilermaker-Blacksmith
National Pension Trust has received a Court Filed Divorce Decree,
advising Kelly Moran is awarded 50% of the Pension Benefit.
To effectively divide your retirement benefits, we must receive a
Domestic Relations Order and it must be qualified, meaning that it
must comply with certain requirements of both the law and the
Order (QDRO), the portion of your benefits assigned under the
Divorce Decree will be held by the Plan. The Plan will hold
benefits until a qualifying QDRO is achieved (up to a maximum of
eighteen months) . Any portion of benefits not assigned under the
Domestic Relations Order will still be available to you.
The Divorce Decree that assigns 50% of the monthly pension to
Kelly Moran. Therefore, effective March 1, 2021, we-must reduce
your pension by $900.99. Your adjusted gross” monthly pension
effective March 1, 2021 will be $900.99, This amount will remain
segregated and will be paid to the alternate payee once a court
filed QDRO has been received, reviewed and approved by our Legal
Counsel. At this time, the Divorce Decree will be forwarded to our
Legal Counsel for review. Please allow a minimum of 60 days for
the response by our Legal Counsel.
MLCOPY
TIMELINE
date and item/action, attachment __
1) 26 Oct, 2020 defendant accepts case EM17&EM1
2) 5Nov,2020 defendant requests client docs via TEXT 1
3) Ex-wife's attorney provided defendant via email E,D,L
E proves sick day balance. L shows again that defendant
knew about the VA remodeled home and did not defend it
4) 9 Nov, 2020 defendant files notice of appearance DO2, F1-F2
5) 12 November defendant informed to use VETERANS
DISABILITY PROTECTION ACT to protect their clients home 110
6) 19 Nov 2020Defendant files motion to continue F3
7) 25 Nov, 2020 client asked why nothings been filed to compel
ex-wifes reporting of assets asked if | should ask the opposing
counsel for asset reporting : T11
8) 25 Nov, 2020defendant filed another motion to continue
9) 25 Nov 2020 Defendant reported change of address F7
10) Dec 16. 2020 client getting frantic that ex-wife's assets still
not reported by the ex wife and still NOT compelled by the
defendant attorney. 711-T12
11) 30 Nov 2020 Defendant files third motion for continuance F8 -F10
12) 3 Dec 2020 hearing defendant did not bring up the disabled
vet home or the ex wife's sick pay assets —_—-
13) 14 Dec client emailed defendant again asking about his
VETERAN rights and unreported sick pay EM2
14) 14 DEC 2020 defendant attorney admits they needed to
subpoena the sick pay EM3
15) 14 Dec 2020 Defendant emailed client about OHIO
RULES OF PROFESSIONAL CONDUCT & alleged there
was no basis for the client to ALLEGE the ex wife hiding
assets(PAYSTUBS) . EM3-EM3A
16) 14 Dec 2020 client starts making the excuse that they
did not miss any deadlines and said it was too late in the
case to file any evidentiary motions (what happened to the
A |COPY
8 4 weeks defendant attorney spent arguing with the client
that sick pay is not divisible!
17) 14 Dec 2020Defendant states that they know client
wants back into his VA accommodated home but still
fails to act on their clients behalf
18) 14 Dec 2020 defendant emails client again trying to
change his direction by asking about QDRO again which has
nothing to do with the unreported asset.
19) 14 Dec 2020 Defendant emails ex-wife's attorney and
does not ask about the sick pay or the
clients necessary VA accommodated home
20) 16Dec 2020 Defendant advises client of Jan 4, 2021
deadline for production of documents set by the divorce court.
21) 21Dec 2020 Defendant finally agrees with client that the
ex wife’s sick pay is divisible and charges the client to prove
He was right about the law! :
22) 16 Dec 2020 defendant finally files subpoena to compel
reporting of ex-wifes sick pay account (after frantic text)
23) 16 Dec 2020 defendant filed a witness list exhibit list
24) 21 Dec 2020 client emailed defendant asking if he read
the “research” docs correctly.
25) 21 Dec 2020 defendant admits to “missing” an offer from
opposing counsel??
26) 22 Dec 2020 Defendant filed motion to continue / leave
and motion to withdrawal from the case abandoning the client
27) 22 Dec 2020 divorce court denies continuance
28) 28 Dec 2020 Defendant informes client of the defendants
intentions to abandon their client after admitting client was
correct about the sick pay being divisible
29) Divorce court releases defendant from the case
13 days till trial
30) 4 Jan 2021 defendant firm leader allows client the ability
to retrieve his file on WEDNESDAY JANUARY 6, 2021
31) 5 Jan 2021 defendant firm leader says he doesn't know
what client mean by clients allegation of defendant
blocking client from establishing his defense proving that
Ad
EM4
EM5
EM6
EM7-EM8
Emg9
EM11 - 12
$1-S5
F1-F15
EM13
EM10
F16 -F21
F21
EM14-15
F22
EM16COPY
defendant firm never cared to know what was going on
in their clients case EM19-EM20
32) 5 January 2021 Defendant wrote letter stating that
defendant would still provide exhibits as needed by the client,
the day after all exhibits/documents were due by the divorce
courts deadline LE1-LE3
33) 6 Jan 2021 client was allowed to retrieve his exhibits / file
that was still in the same box and disorganized as it was from
when the client delivered the file to them on October 26th P1
34) 22Jan 2021 divorce court decree is issued F22-F28
35) 19 Jan 2021 Ex-wife's attorney produced document to
claim 50% of clients disability benefit “for life” even though
that was not awarded by the decree. Unfortunately the client
did not have representation to combat this attack from
ex-wifes counsel re-defining simple english definitions in
the decree to form their division of property order F29- F32
ASCOPY
Cordell Cordell
A Domestic Litigation Firm
A Partner Men Can Count On.®
December 15, 2020
Matter: 258986.268014
Invoice No: 3177698
Priot ‘iaeart Balance Due $ 915.80
ew “SS New Charges “= $ 1,923.60
Charges Due This Statement $ 2,839.40
CLIENT TRUST ACTIVITY DETAILS
TRUST:ACTIVITY. THROUGH 12/15/2020
. : t Beginning Retainer Trust Balance Le : $0.00
42/14/20 cited ss : $ 2,500.00
12/14/20 $ 3,415.80
Ending Retainer Trust Balance $ 5,915.80
Onur
he RIG
Ending Trust Only Balance $0.00
You can ‘view up to date.information regarding your case, billing history, or make a payment by
registering and logging into your Client Case Center:
https://cportal.cordelilaw.com.
Remember to visit our websites DadsDivorce.com and MensDivorce.com for helpful divorce resources,
information, articles, podcasts, videos, and more.
8 4 Page 4|4
—COPY
Cordell Cordell
A Domestic Litigation Firm
A Partner Men Carl Count on.®
November 2, 2021
Matter: 258986.268014
Lee Invoice No: 3448270
TOTAL CURRENT CHARGES FOR FEES & COST/EXPENSES $ 0.00
Stake apy
CARLA EY
PAYMENTS/CREDITS APPLIED
Prior Statement Balance Due $ 1,818.60
New Charges’’ | | $0.00
’ Charges Dué This Statement $ 1,818.60
CLIENT TRUST ACTIVITY DETAILS
TRUST ACTIVITY THROUGH “11/02/2021
a ~
Beginning Retainer Trust Balance,: ; -- . $0.00
Ending Retainer Trust Balance $0.00
Ending Trust Only Balance : $0.00
You can view up to date information regarding your-éase, billing history, or make a payment by
registering and logging into your Client Case Center:
. ht
' tps://cportal.cordelllaw.com.
Remember to visit our websites DadsDivorce.com and MensDivorce.com for helpful divorce resources,
information, articles, podcasts, videos, and more.
Page 2|2
B2GORY
172.16.1.21/medet_epublicnodr_int/Default.aspx
prtikengat D6 L
Case Details
Case Information
Case # Caption | Filed Date; Status | Judge Assigned |
200R0135 KELLY A MORAN -VS- DANIEL M MORAN 07-Apr-2020 HEARING... KOVACK, MARY :
Parties Involved
Name | Address Associated Party
MORAN , KELLY (Plaintif ) 3812 FOSKETT RD, MEDINA OH, 44256 MCARTOR,DAVID
MCARTOR , DAVID (Plt Attorney ) 208 W LIBERTY ST, MEDINA OH, 44256 MORAN.KELLY
MORAN , DANIEL (Defendant ) 1114 N COURT ST, MEDINA OH, 44256 JONES.L
Actions
Action Date | Action Description i Notes
te/Mari2021 HEARING SET RE: MOTION FOR CLERICAL CORRECTION ON DIVORCE DEbRES~-
HRG. WILL BE CONDUCTED VIA ZOOM VIDEO CONFERENCE =
26/Febi2021 REQUEST FOR WITHDRAWAL DETERMINATION OF PLACEMENT OF A COURT 6a.
APPOINTED MEDIATOR FILED BY DANIEL MORAN li
2alFebI2021 NOTICE OF SUBMISSION RE: PLEASE ADD QORO'S TO THE TOPIC LIST FOR 3/18/2021 HRG, - S
LETTER--FILED BY DANIEL MORAN 2 a ih
18/Feb/2021 DEFENDANT'S NOMINATION OF PROFESSIONAL TAZ SERVICES FILED BY DANIEL EAL
MORAN. 3
18/Feb/2021 NOTICE OF SUBMISSION RE: QDRO FILED BY ATTY DANIEL MORAN 2
18iFeb2021 NOTICE OF HEARING RE: MOTION FOR CLERICAL CORRECTION ON DIVORCE DECREE 3
(HRG. 3/18/2021 @ 10:00 A.M. UNTIL 11:00 A.M. BEFORE/MAG. ROSS)— 3
HRG. WILL BE CONDUCTED VIA ZOOM VIDEO CONFERENCE By
17/Feb/2021 DEFENDANT BEGS THIS COURT FOR RELIEF
17iFebi2021 DEFENDANT'S. NOMINATION FOR REAL ESTATE AGENT View
O5/Feb/2021 REQUEST (EMAIL COPY) REQUEST FOR NUNC PRO TUNC WIPROOF OF SERVICE—EMAILEDTO Vi
DR COURT BY ATTY DAVID MCARTOR
04/Feb/2021 MOTION (EMAIL COPY) MOTION FOR CLERICAL CORRECTION ON DIVORCE DECREE— Vi
EMAILED TO DR COURT BY DEFENDANT DANIEL MORAN
22iJan/2021 —- MAGISTRATE'S DECISION View
22iJanl2021 DECREE OF DIVORCE CERT COPY MAILED TO PARTIES BY THE COURT View
2tldani2021 DOCKET NOTATION View
t2iJan2021 SUBMISSION OF EVIDENCE RE: MCARTER MAIL SIGNATURE... FILED BY DEF DANIEL No Document
MORAN
12ian/2021 - SUBPOENA(S) FILED SERVED BY ATTORNEY FILED BY BY ATTY CAROLYN SOEDER No Document
tiJani2021 TRIAL SET HRG WILL BE CONDUCTED TELEPHONICALLYIVIA VIDEO No Document
CONFERENCE- REQUEST FOR RULE 75 HEARING (RESET FROM
. - DECEMBER 03 2020)
o8iJan/2021 SUBMISSION OF EVIDENCE 2019 TAXES FILED BY DANIEL —-HE DID NOT WANT IN No Document
THE CONFIDENTIAL FILE
O7/Jan/2021 PLAINTIFFS TRIAL BRIEF (EMAIL COPY) WIPROOF OF SERVICE- EMAILED TO DR COURT BY ATTY DAVIDL View
MCARTOR
o6iJan/2021 SUBMISSION OF EVIDENCE RE: INCOME/SUPPORT... FILED BY DEF DANIEL MORAN No Document
oGiJan/2021 SUBMISSION OF EVIDENCE RE: PENSIONS... FILED BY DEF DANIEL MORAN No Document
o6iJani2021 SUBMISSION OF EVIDENCE RE: VEHICLES... FILED BY DEF DANIEL MORAN No Document
O6iJan/2021 SUBMISSION OF EVIDENCE RE: OTHER MARITAL ASSETS... FILED BY DEF DANIEL No Document
MORAN
o6/Jani2021 SUBMISSION OF EVIDENCE RE: REAL ESTATE ... FILED BY DEF DANIEL MORAN No Document
oGiJan/2021 SUBMISSION OF EVIDENCE RE: BOAT.. FILED BY DEF DANIEL MORAN No Document
OSiJan/2021 ORDER RE: MOTION TO WITHDRAW AS COUNSEL IS HEREBY GRANTED View
0S/Jan/2021 SUPPLEMENTAL WITNESS & EXHIBIT LIST (EMAIL WICERT OF SERVICE FILED BY PLT'S ATTY DAVID MCARTOR (EMAIL... No Document
copy) TO DR COURT BY ATTY MCARTOR)
O4/Jan/2021 MOTION TO WITHDRAW CONTINUANCE FILED BY DEFENDANT View
28/Dec!2020 ORDER GRANTING ATTY CAROLYN C SOEDER MOT TO WITHORAW AS View
COUNSEL FOR DEF
26/Dec!2020 MOTION FOR CONTINUANCE (EMAIL COPY) WICERTIFICATE OF SERVICE—-FAXED TO DR COURT BY ATTY View
: CAROLYN SOEDER
28/Dec!2020 MOTION TO WITHDRAW AS COUNSEL (EMAILCOPY) _ WICERTIFICATE OF SERVICE— EMAILED TO DR COURT BY ATTY View
CAROLYN SOEDER
22iDec!2020 ORDER OF CONTINUANCE DENIED.. HRG WILL BE HEARD ON 1/11/2021 @ 9:00 AM BEFORE View
JUDGE KOVACK
(HEARING WILL BE CONDUCTED TELEPHONICALLYIMIA VIDEO
CONFERENCE)
15CARY
22Mec!2020 -- MOTION FOR CONTINUANCE (FAX COPY)
* || 22/Decr2020 MOTION TO WITHDRAW AS COUNSEL (FAX COPY)
| t6/Decr2020 EXHIBIT LIST (FAX COPY)
16/Deci2020 _- SUBPOENA(S) FILED SERVED BY ATTORNEY (FAX
COPY)
16/Deci2020 —- WITNESS AND EXHIBIT LIST (FAX COPY)
16/Dec/2020 PRETRIAL HEARING SET
15/Dec/2020 WITNESS AND EXHIBIT LIST (EMAIL COPY)
04/Dec!2020 -—- MAGISTRATE'S ORDER FOR CONTINUANCE
03/Dec!2020 «HEARING SET
30/Novi2020 MOTION FOR CONTINUANCE (ORIGINAL COPY)
25/Novi2020 COURT NOTICE OF RECEIPT OF RELOCATION NOTICE
25/Novi2020 MOTION FOR CONTINUANCE (FAX COPY)
49/Novi2020 MAGISTRATE'S ORDER FOR CONTINUANCE
16!Novi2020 MOTION TO CONTINUE (EMAIL COPY)
| 12INow2020 ORDER
09/Novi2020 MOTION FOR CONTINUANCE(ORIGNIAL COPY)
O9/Novi2020 NOTICE OF APPEARANCE OF COUNSEL (ORIGNIAL
copy)
O9/Now/2020 DOCKET NOTATION
09/Novi2020 NOTICE OF HEARING
O8/Novi2020 HEARING SET
05/Novi2020 MOTION FOR CONTINUANCE (FAX COPY)
5/Novi2020 NOTICE OF APPEARANCE OF COUNSEL (FAX COPY)
19/0ct/2020 —- MOTION TO WITHDRAW (EMAILED COPY)
19/0ct’2020 TRANSCRIPT
19/0cv2020 NOTICE OF SUBMISSION OF TRANSCRIPT
19/0ct’2020 NOTICE OF SUBMISSION
19/0cv2020 “NOTICE OF CHANGE OF ADDRESS
1610cv2020 JUDGMENT ENTRY
07/0cv2020 - MOTION TO CONTINUE (EMAIL COPY)
01/0cv2020 NOTICE OF HEARING
| 28/Sep/2020 - MAGISTRATE’S ORDER FOR CONTINUANCE
24/Sep/2020 MOTION TO CONTINUE (EMAILED COPY)
24/Sep/2020 MAGISTRATES ORDER FOR CONTINUANCE
16/Sep/2020 MOTION TO CONTINUE (EMAIL COPY)
15/Sep/2020 NOTICE OF HEARING
|
172.16.1,21/medct_epublicnodr_int/Default.aspx
Case Details
WICERTIFICATE OF SERVICE--FAXED TO DR COURT BY ATTY lew
CAROLYN SOEDER
WICERTIFICATE OF SERVICE--FAXED TO DR COURT BY ATTY View
CAROLYN SOEDER
OF DEFENDANTWICERTIFICATE OF SREVICE—FAXED TO DR COURT —_No Document
BY ATTY CAROLYN SOEDER
SUBPOENA TO ATTEND AND PRODUCE DOCUMENTS WICERTIFICATE _ No Document
OF SERVICE--FAXED TO DR COURT BY ATTY CAROLYN SOEDER.
WICERTIFICATE OF SERVICE--FAXED TO DR COURT BY ATTY No Document
CAROLYN SOEDER
HRG WILL BE CONDUCTED TELEPHONICALLY/VIA VIDEO No Document
CONFERENCE,
PLAINTIFF'S WIPROOF OF SERVICE —-EMAILED TO DR COURT BY ATTY No Document
DAVID MCARTOR
GRANTED- MATTER WILL BE HEARD ON JANUARY 11 2021 @9AM -
RESET FROM DECEMBER 03 2020
RE: REQUEST FOR RULE 75 HRG.-HRG. WILL BE CONDUCTED
No Document
‘TELEPHONICALLY/VIA VIDEO CONFERENCE
RESET FROM DEC 2, 2020
WICERT OF SERVICE ~- FAXED TO DR COURT BY ATTY CAROLYN View
SOEDER
DANIEL View
WICERT OF SERVICE ~ FAXED TO DR COURT BY ATTY CAROLYN View
SOEDER
GRANTED.. HRG SCHEDULED FOR 12/2/2020 IS CONTD TO 12/3/2020 View
@ 9:00 AM BEFORE MAG. D. LUKE ROSS
(HEARING WILL BE CONDUCTED TELEPHONICALLY/VIA VIDEO
CONFERENCE)
WIPROOF OF SERVICE~ EMAILED TO DR COURT BY ATTY DAVID L View
MCARTOR
GRANTING ATTY RAY JONES REQUEST TO WITHDRAW AS COUNSEL View
FOR DEF
OF HRG, ON NOVEMBER 6, 2020 WICERTIFICATE OF SERVICE--FAXED View
TO DR COURT BY ATTY CAROLYN SOEDER
FOR THE DEFENDANT DANIEL M MORAN WICERTIFICATE OF SERVICE Viow
--FILED BY ARRT CAROLYN SOEDER
View
RE: REQUEST FOR RULE 75 HRG. 12/2/2020 @ 1:00 P.M, UNTIL 2:00 PM. View
BEFORE/MAG. ROSS.--HRG. WILL BE CONDUCTED.
TELEPHONICALLYIVIA VIDEO CONFERENCE
HEARING TO BE CONDUCTED TELEPHONICALLY/ ViA VIDEO
CONFERENCE - REQUEST FOR RULE 75 HEARING-
OF HRG. ON NOVEMBER 6, 2020 WICERTIFICATE OF SERVICE---FAXED View
TO DR COURT BY ATTY CAROLYN SOEDER
FOR THE DEFENDANT DANIEL M MORAN WICERTIFICATE OF SERVICE-
No Document
Mew
~FAXED TO DR COURT BY ATTY CAROLYN SOEDER
RE: ATTY L RAY JONES TO WITHDRAW AS COUNSEL FOR THE View
DEFENDANT WIPROOF OF SERVICE
OF MOTION HEARING AUG 20, 2020 No Document
OF HRG ON AUG 20, 2020 . View
RE: ADA ACCOMODATIONS FOR DEF'S VA REMODELED HOME; FILED View
BY DEF DANIEL MORAN
RE: DANIEL MORAN View
RE: MOTION TO CONTINUE -GRANTED (HRG. 11/6/2020 @ 9:00AM. View
BEFORE/MAG. ROSS) RE: HRG, DATE SET FOR 10/19/2020 @ 11:00 AM,
-~-~HRG WILL BE CONDUCTED TELEPHONICALLY/VIA VIDEO
CONFERENCE,
WICERTIFICATE OF SERVICE--EMAILED TO DR COURT BY ATTY LRAY View
JONES:
HEARING TO BE CONDUCTED TELEPHONICALLY/ VIA VIDEO
CONFERENCE - MOT TO SET ASIDE MAG ORDER ON NOVEMBER 06
2020 @9AM UNTIL 11AM BEFORE MAG ROSS,
GRANTED- MATTER WILL BE HEARD ON OCTOBER 19 2020 @11AM
BEFORE MAG ROSS- HEARING RESET FROM OCTOBER 07 2020
WICERT OF SERVICE~ EMAILED TO DR COURT BY ATTY LRAY JONES View
w
GRANTED- MATTER WILL BE HEARD ON NOVEMBER 06 2020 @9AM
BEFORE MAG ROSS - HEARING DATE RESET FROM OCTOBER 21 2020
W/ PROOF OF SERVICE-- EMAILED TO COURT FILED BY PLT ATTY fiew
DAVID MCARTOR
HEARING TO BE CONDUCTED TELEPHONICALLY/ VIA VIDEO
CONFERENCE - REQUEST FOR RULE 75 HEARING- ON OCTOBER 07
2020 @1PM UNITL 2PM BEFORE MAG ROSS.
AHack ment DOA
is
I=
215COPY
11/$ep/2020
11/Sep/2020
09/Sep/2020
34/Augi2020
31/Aug/2020
31/Aug/2020
‘31/Aug/2020
31/Aug/2020
21/Augl2020
20/Aug/2020
18/Aug/2020
18/Aug/2020
12/Aug!2020
O7/Aug/2020
o5/Aug/2020
34/4u2020
30/Juu2020
29/5uv2020
29/Jul/2020
27H4ul'2020
271dul2020
21/duv2020
24/2020
24NuV/2020
06/Juv/2020
o2/Juv2020
02/Juv72020
o2/Jul/2020
o2iuv2020
O2/Juv2020
01/Juv2020
30/un/2020
30/Jun/2020
MOTION TO SET ASIDE (EMAIL COPY)
REQUEST (EMAIL COPY)
DEPOSITION
NOTICE OF HEARING
MAGISTRATE'S ORDER
NOTICE OF HEARING
TEMPORARY ORDER(S) OF SUPPORT
DOCKET NOTATION
NOTICE OF SUBMISSION (EMAIL COPY)
HEARING SET
MAGISTRATE'S ORDER
MOTION TO CONTINUE (EMAILED COPY)
NOTICE OF HEARING
MOTION TO COMPEL (EMAIL COPY)
MULTI-BRANCH MOTION (EMAILED COPY)
RESPONSE TO MOTION (EMAIL COPY)
ORDER
AGREED JOURNAL ENTRY FILED
NOTICE OF HEARING
DEPOSITION
DEPOSITION
DOCKET NOTATION
CASE MANAGEMENT ORDER
NOTICE OF HEARING
MOTION FOR TEMPORARY ORDERS (EMAIL COPY)
ORDER
‘41 A DISMISSAL OF MOTION (EMAILED COPY)
NOTICE OF FAILURE OF SERVICE MAILED TO ATTY
SHERIFFS RETURN FILED
UNCONT. DIVORCE OR CASE MGMT HEARING
COPIES W/INSTRUCTIONS ISSUED SHERIFF
SUMMONS AND ORDER TO APPEAR
NOTICE OF HEARING
172.16.1.21/medct_epublicnodr_int/Default.aspx
Case Details
THE MAG. ORDER OF 8/31/2020;JULY 31, 2020 NEVER SERVED ISSUES
CONCERNING RULE 11 AND CONTEMPT SHOULD BE RETURNED TO.
MAG. ~-EMAILED TO DR COURT BY ATTY L RAY JONES
REQUEST FOR RULE 75 N 2 HRG, ORAL HRG. REQUEST
WICERTIFICATE OF SERVICE --EMAILED TO DR COURT BY ATTY L RAY
JONES:
OF KELLY A MORAN TAKEN ON JULY 8, 2020 WEXHIBIT
RESPONSE TO MOTION TO COMPEL; MOTION FOR RULE 11
SANCTIONS; MOTION FOR ATTY FEES
OCT 21, 2020 @9-11AM WI MAG ROSS
HRG WILL BE CONDUCTED TELEPHONICALLY/VIA VIDEO.
CONFERENCE
MAG WILL ISSUE TEMP ORDERS ON AFFIDAVIT WITH REGARD TO
WIFE'S MOTION FILED JULY 6, 2020 HUSBAND'S FILED AUG 5, 2020;
HUSBANDS MOTION TO COMPEL WAS DENIED, WIFES'S MOTION FOR
SANCTIONS & ATTY FEES FILED JULY 31, 2020 TO BE SET FOR
HEARING
RE; PENDING MOTIONS.
OCT 21, 2020 @9-11AM W/ MAG ROSS
HRG WILL BE CONDUCTED TELEPHONICALLY/VIA VIDEO
CONFERENCE
SPOUSAL SUPPORT
RE: FINANCIAL SOURCE DOCUMENTS WICERTIFICATE OF SERVICE —
EMAILED TO DR COURT BY ATTY L RY JONES
EVIDENTIARY HEARING; MOT FOR TEMPORARY ORDERS-
DEFENDANTS MTSC FILED 05/26/2020
(HRG WILL BE CONDUCTED TELEPHONICALLY/VIA VIDEO
CONFERENCE)
RE: PLAINTIFF'S MOTION TO CONTINUE NOT WELL-TAKEN AND
HEREBY DENIES THE SAME
WIPROOF OF SERVICE-- EMAILED TO DR COURT BY ATTY DAVID L
MCARTOR
OR IN THE ALTERNATIVE REQUEST TO SIGN STRS RELEASE;REQUEST
FOR ATTORNEY FEES REQUEST TO SET HRG. ON MOTION FOR
CONTEMOT ON COMPUTER WICERTIFICATE OF SERVICE--EMAILED
TO DR COURT BY ATTY L RAY JONES
WICERT OF SERVICE-- EMAILED TO DR COURT BY ATTY L RAY JONES
TO COMPEL AND REQUEST FOR HRG.MOT FOR RULE 11 SANCTIONS
AND ATTORNEY FEES W/PROOF OF SERVICE-—EMAILED TO DR
COURT BY ATTY DAVID MCARTOR
GRANTING 41 (A) DISMISSAL OF MOTION FOR CONTEMPT FILED
6/25/2020 FILED 7/2/2020
$5000 MAY BE RELEASED TO THE DEF FROM ATTY RAY JONES JOLTA
ACCT
MOT FOR TEMP ORDERS AUG 20, 2020 @9-10AM W/ MAG ROSS
HRG WILL BE CONDUCTED TELEPHONICALLY/VIA VIDEO
CONFERENCE
TAKEN OF MICHAEL MORAN ON JULY 8, 2020
OF COLLEEN KOPP TAKEN ON JULY 8, 2020
PRE-TRIAL: DEC 16, 2020 10:30-11AM
TRIAL: JAN 11,2021 9-4PM
EVIDENTIARY HEARING AUG 20, 2020 @9-10AM WIMAG ROSS.
HRG WILL BE CONDUCTED TELEPHONICALLYIVIA VIDEO
CONFERENCE
WICERTIFICATE OF SERVICE --EMAILED TO DR COURT BY ATTY DAVID
MCARTOR
RE: 41 A DISMISSAL OF JP MORGAN CHASE BANK-—-GRANTED
FOR CONTEMPT FILED 6/25/2020 WICERT OF SERVICE~ EMAILED TO
DR COURT BY ATTY L RAY JONES
TO ATTY L RAY JONES RE: FAILURE OF SERVICE ON KELLY A MORAN
FAILURE OF SERVICE ON KELLY MORAN; UNABLE TO LOCATE ON
FIRST SERVICE ATTEMPT 7/1/2020
AND MOTION FOR CONTEMPT (HEARING WILL BE CONDUCTED
TELEPHONICALLY)
CERT COPY OF MOTION FOR CONTEMPT, SUMMONS AND ORDER TO
APPEAR, AND NOH WIATTACHED COVID-19 ORDER TO KELLY A
MORAN ISSUED TO MEDINA COUNTY SHERIFF
KELLY A MORAN IS SUMMONED AND ORDERED TO APPEAR 7/2/2020
@ 9:00 AM
MOTION FOR CONTEMPT 7/2/2020 @ 8:00 AM- 9:30 AM BEFORE MAG.
AHtAchwent DO3
View
Mew
No Document
View
Mew
View
Mew
View
No Document
Mew
View
View
View
View
Miew
No Document
No Document
View
View
é
eR EF &
No Document
I<
2
&
3/5GARY
.
25/dun/2020
25/Jun/2020
25/Jun/2020
24/Jun/2020
22/Jun/2020
22fJun/2020
2alsunt2020
49/Jun/2020
49/Jun/2020
19/Jun/2020
‘11/dun/2020
04/Jun/2020
03/Jun/2020
o2/Jun/2020
02/Jun/2020
O2/Jun/2020
29May/2020
28/Mayi2020
26/May/2020
26/May/2020
14/May/2020
O7/May/2020
07/May/2020
O7/May/2020
06/May/2020
O6/May/2020
| 05/May/2020
‘05/May/2020
28/Apr/2020
271Apr2020
24/pr12020
23/Apr/2020
| 23/Apr/2020
23/Apr/2020
MOTION FOR CONTEMPT (EMAILED COPY)
INSTRUCTIONS FOR SERVICE (EMAILED COPY)
‘SUBPOENA(S) RETURNED FROM MEDINA CO SHERIFF
GOOD SERVICE
PERSONAL SERVICE MADE ON
PERSONAL SERVICE MADE ON
SUBPOENA(S) RETURNED FROM MEDINA CO SHERIFF
GOOD SERVICE
SUBPOENA(S) ISSUED TO SHERIFF
‘SUBPOENA(S) ISSUED
PRAECIPE
NOTICE OF DEPOSITION
CERTIFIED MAIL SERVICE COMPLETED ON
CERTIFIED MAIL SENT RETURN RECEIPT REQUESTED
NOTICE OF SERVICE (FAX COPY)
DOCKET NOTATION
SUMMONS AND ORDER TO APPEAR
NOTICE OF HEARING
DISMISSAL
NOTICE OF SERVICE (FAX COPY)
MOTION FOR CONTEMPT
INSTRUCTIONS FOR SERVICE
JOURNAL ENTRY
MAGISTRATE'S ORDER
HEARING SET
SHERIFFS RETURN FILED
PERSONAL SERVICE MADE ON
COPIES WIINSTRUCTIONS ISSUED SHERIFF
MAGISTRATE'S ORDER
NOTICE OF HEARING
EMERGENCY (ORIGNIAL COPY)
NOTICE OF HEARING
EMERGENCY REQUEST (FAX COPY)
NOTICE OF SERVICE
REQUEST (ORIGINAL)
INSTRUCTIONS FOR SERVICE (ORIGINAL)
172.16.1.21/medct_epublicnodr_int/Default.aspx
Case Details
D. LUKE ROSS (HEARING WILL BE CONDUCTED TELEPHONICALLY/VIA
VIDEO CONFERENCE)
FAXED TO DR COURT BY ATTY L, RAY JONES
‘SERVE KELLY MORAN (SHERIFF SERVICE) EMAILED TO DR COURT BY
ATTY L .RAY JONES.
(1)
MICHAEL MORAN
GOOD SERVICE ON COLLEEN
(1)
2)
(2)
‘SERVE PARTIES SUBPOENAS (SHERIFF SERVICE)
FILED BY ATTY L RAY JONES WICERT OF SERVICE
KELLY A MORAN (4209 55)
CERT COPY OF MOT FOR CONTEMPT, SUMMONS AND ORDER TO
APPEAR AND NOT OF HRG W/INSTR SENT TO KELLY A MORAN (4209
58)
WISERVICE--FAXED TO DR COURT BY ATTY DAVID MCARTOR
KELLY A MORAN IS ORDERED TO APPEAR ON JUL 2, 2020 @ 9:00 AM
“HRG WILL BE CONDUCTED TELEPHONICALLY VIA VIDEO
CONFERENCE“ MOT FOR CONTEMPT ON JUL 2, 2020 @ 9:00 AM
WIMAG ROSS.
41 A DISMISSAL OF JP MORGAN CHASE BANK WICERTIFICATE OF
SERVICE
WICERT OF SERVICE-- FAXED TO DR COURT BY ATTY DAVID
MCARTOR
FILED BY DEF'S ATTY L RAY JONES WICERT OF SERVICE
RE: JP MORGAN CHASE IS ADDED as THIRD PARTY DEFEDANT
JP MORGAN CHS BANK TO RELEASE RESTRAINING ORDER; PLT
‘SHALL DELIVER A CHECK PAYABLE TO "L RAY JONES ILOTA ACCOUNT
OF $12,500; DEF FRIEND MAY REMOVE THE PARTIE'S BOAT &
ACCESSORIES, TRAILER, DEF'S COMPUTER, WALKER, VA RECORDS,
TAX DOCUMENTS, PASSPORT , TITLES TO 2 VEHICLES USED BY THE
PARTIES ADULT SON. DEF TO SIGN THE TITLES OVER TO THE SON,
MICHAEL E MORAN, PLT SHALL HAVE EXGLUSIVE USE OF THE
MARITAL HOME; EQUALLY DIVIDE AUTO INSURANCE THRU STATE
FARM; PLT SHALL PAY MORTGAGE FOR MONTHS OF JUNE & JULY;
PARTIES SHALL HIRE JOSEPHY MARYNOSKI CPA TO PREPARE 2019 IT
RETURNS & PARTIES EQUALLY DIVIDE REFUND OR INDEBTEDNESS
EQUALLY PAYING THE CPA
RE: EMERGENCY REQUEST TO HAVE ACCESS TO BOAT AND
PERSONAL ITEMS --"*HRG, WILL BE CONDUCTED TELEPHONICALLY
VIAVVIDEO CONFERENCE” MOT TO ADD THIRD PARTY, MOT FOR
RESTRAINING ORDER
GOOD SERVICE ON CHASE BANK
GOOD SERVICE ON CHASE BANK
(MEDINA COUNTY) CERT COPY OF MOT TO ADD THIRD PARTY, MAG'S
ORDER AND NOTICE OF HRG FOR SERVICE ON JP MORGAN CHASE
BANK
JP MORGAN CHASE BANK IS ADDED AS A THIRD PARTY DEF AND
‘SHALL PLACE A HOLD ON ALL ACCOUNTS UNTIL FURTHER ORDER OF
THE COURT
** HRG WILL BE CONDUCTED TELEPHONICALLY/VIA VIDEO
CONFERENCE* MOT TO ADD THIRD PARTY, MOT FOR RESTRAINING.
ORDER ON MAY 7, 2020 @ 2:00 PM W/MAG ROSS:
EMERGENCY REQUEST TO HAVE ACCESS TO BOAT AND PERSONAL
ITEMS -—FILED BY ATTY L. RAY JONES
RE: EMERGENCY REQUEST TO HAVE ACCESS TO BOAT AND
PERSONAL ITEMS (HRG. 5/7/2020 @ 2:00 P.M. UNTIL 3:00 P.M.
RG, WILL BE CONDUCTED TELEPHONICALLY
BEFORE/MAG, ROSS)
VIAVIDEO CONFERENCE
‘TO HAVE ACCESS TO BOAT AND PERSONAL ITEMS FAXED TO DR
COURT BY ATTY L RAY JONES WICERT OF SERVICE
OF DISCOVERY WICERT OF SERVICE FILED BY DEF'S ATTY L RAY
JONES:
TO ADD THIRD PARTY DEF; REQUEST FOR RESTRAINING ORDER
WICERT OF SERVICE FILED BY ATTY L RAY JONES
FILED BY ATTY L RAY JONES
Attar ec ANU
No Document
View
View
&
45CORY
| 23/Apr!2020 RESPONSE (ORIGINAL)
23/Apr!2020 ANSWER (ORIGINAL)
23/Apr12020. WAIVER OF SERVICE AND VENUE (ORIGINAL)
23/Apr/2020 NOTICE OF APPEARANCE (ORIGINAL)
221Apr/2020 NOTICE OF SUBMISSION (FAX COPY)
21/Apr/2020 NOTICE OF SUBMISSION (FAX COPY)
21/Apri2020 —- WAIVER OF SERVICE AND VENUE (EMAIL COPY)
21/Apr/2020 REQUEST (EMAILED COPY)
21/Apr!2020 RESPONSE (EMAILED COPY)
211Apri2020 ANSWER (EMAILED COPY)
24/Apr/2020 NOTICE OF APPEARANCE (EMAILED COPY)
21/Apri2020 INSTRUCTIONS FOR SERVICE (EMAILED COPY)
‘18/Apri2020 CERTIFIED MAIL SERVICE COMPLETED ON
16/Apr/2020 CERTIFIED MAIL SENT RETURN RECEIPT REQUESTED
46/Apr/2020 SUMMONS
10/Apr/2020 NOTICE OF HEARING
10/Apr/2020 “MOTION FOR EXCLUSIVE USE
o7/Apri2020 INSTRUCTIONS FOR SERVICE
07/Apr12020 NOTICE OF SUBMISSION
07/Apr12020 © MUTUAL RESTRAINING ORDER
07/Apr!2020. © COMPLAINT FILED
O7/Apr/2020 MARRIAGE TERMINATION NO CHILDREN
Case Details
‘TO MOT FOR EXCLUSIVE USE OF MARITAL HOME W/CERT OF
‘SERVICE FILED BY ATTY L RAY JONES
WICERT OF SERVICE FILED BY ATTY L RAY JONES
WICERT OF SERVICE FILED BY ATTY L RAY JONES
FILED BY ATTY L RAY JONES WICERT OF SERVICE
RE: INCOME AND EXPENSE FORMS;PROPERTY AFFIDAVIT W/PROOF
OF SERVICE-——-FAXED TO DR COURT BY ATTY MCARTOR
RE: AFFIDAVIT OF INCOME AND EXPENSES FAXED TO DR COURT BY
ATTY DAVID MCARTOR WI/PROOF OF SERVICE
EMAILED TO DR COURT BY ATTY L RAY JONES WICERT OF SERVICE
TO ADD THIRD PARTY DEFENDANT, REQUEST FOR RESTRAINING
ORDER EMAILED TO DR COURT BY ATTY L RAY JONES W/CERT OF
SERVICE
TO MOTION FOR EXCLUSIVE USE OF MARITAL HOME EMAILED TO OR
COURT BY ATTY L RAY JONES WICERT OF SERVICE
EMAILED TO DR COURT BY ATTY L RAY JONES WICERT OF SERVICE
RE: ATTY L RAY JONES ENTERS HIS APPEARANCE AS ATTORNEY OF
RECORD FOR THE DEFENDANT EMAILED TO DR COURT BY ATTY L
RAY JONES WICERT OF SERVICE
‘SERVE SRD PARTY DEFENDANT (SHERIFF SERVICE) EMAILED TO DR
COURT BY ATTY L RAY JONES:
DANIEL MORAN #4549 32; SIGNED BY GAIL FISHER
‘SUMMONS, CERTIFIED COPY OF COMPLAINT FOR DIVORCE, MUTUAL
RESTRAINING ORDER, NOTICE OF SUBMISSION W/DOCUMENT, AND
(1) NOTICE OF HEARING TO DANIEL MORAN #4543 32
DANIEL M MORAN
UNCONTESTED OR CASE MANAGEMENT HEARING 7/2/2020 @ 9:00 AM
- 9:30 AM BEFORE MAG. D. LUKE ROSS (HEARING WILL BE
CONDUCTED TELEPHONICALLY)
FILED BY ATTY DAVID MCARTOR WIPROOF OF SERVICE
CSEA IV-D APPLICATION W/ PROOF OF SERVICE
View
eR EF FREE
A
I<
is
=
RE Ee EFI
FE
Is
Iz
REI
Is
ls
I=
IS
Is
=
No Document
172.16.1.2\/medct_epublicnodr_inDefault.aspx
artackwent DOS
5/5, COPY
SALARY NOTICE
INSTRUCTOR'S LIMITED CONTRACT
Tenure
From: 07/01/2020 - 06/30/2021 April 28, 2020
KELLY MORAN
3812 Foskett Road
Medina, OH 44256
Notice is hereby given to the employee named above of. salary change for services rendered to the Board
of Education of the Medina County Joint Vocational School District for the school year 2020-2021.
Rate per Day..
Rate per Pay...
Available Extended Day:
Available Extended Pay
Professional Development D:
Professional Development Pay
Gap Pay.
President, Board of Education
Treasurer, Board of Education
EXHIBIT
Please signall three coptes, keep one for your files and return last two coples to tho Superintendent's office.
1101 West Liberty Street, Medina, OH 44256 | 330-725-8461 | 330-723-6573 (fax) | wenw.mcjvem
‘Wout Gatigy saree
ConnectionCOPY i(- 6-J090
MEDINA COUNTY JVSD NO. _ 085553
“EMPLOYEE ID - “| JOB# T- < . "
-000/2.75§\% 008/078 56.00
ex Feo: 00 So \ festa: 01 ‘TOTAL DEDUCTIONS 1,133.44
AN _ _NET PAY 1,969.51
Awourtt yf Soe
Steck DAY 3
EXHIBIT
—_E—COPY /I-LW20
From Fyne’
RY weymore since July
Sick pay
Sick pay
Th | yew Hy
Kelly has been getting
her new pay raise
amount for five months
already
Also my pension is ei-
ther an asset or income
if mcarter wants a pay-
out then | need alimony
since that takes my in-cory Nov 25, 2020, 14:47
Oech On nome
Core Ce a
Wed, Dec 16, 10:38
Gretel Nl oe
MC EE cr re mele
| ( She is bene d earning; pieced ae ene 4
BU ac benefit bathroom |
ici being EVEL Rol
Re eaves
eae
Nov 12, 2020, 16:48
attack moat “T 10COPY
Preece: meee
- maid receipt for easy
reading ;
~ | still have all individual
Receipts please advise
“when you want me to
Me Rtas)
eee
low the continuance
Me-vale R@r-T ce) V0)
Bodied
i Breet
dmagis-
Meigs} i) EL ly right:
texted
' Sorry mistext to my sis-
mls
Log back in®
Court wants youto
fi Everyone else has
We (olececcromlamgurcle|tiie-1i-)
| said he was giving you
| ten minutes to log in
Go to meeting .com
This was not:on my cal-
endar until 17 tiwill log
in now
Whatis the meeting ID
, 233-490-429
Omg Medina didn't al-
low the continuance
WSyi Nike (r=
mec reac etek fet
. terrogatories may 2020
ol: (2)
Nov 6 hearing...
STRS Subpoe...
Moran, Daniel...
This is a combined
Attachment T4COPY ' © Swdtnsrugeesies- ana
Can ry charter te cept? Ha panda. Se tno pote io
Rey ° \ ‘
. - ‘Wied, Jun 3, 2029 28 4201 PA J
Fe thera herds ce naggenabey onan cer \
111 cornice har to tum over fhe “other computer” wll ha drop fis exrbaerpl? \
. L.
‘She cannot find any other lndormetica concerriing the VA, by the wry. 4 ‘
pata ete
Medeor, Auppadie, & CO:
(0) 723-4019 , :
CAUTION - CONFIDENTIAL MATERIAL , \ i
‘edinte rovessage io saomey Bede Or goed recpoecac to ceiver B }
‘Tha nboration Coe rae wocra, you ere rk tha nerd TESTES. ex copying of is \ |
{ote nemned replat, you are hereby rotted D2 Fad by facerel ia, Te £7 SC 005, Ot Lidrim |
Sr ba beg cota AS oa cc at YO 4 |
fe jor }
acted i Core te novo no Tr ofon wi reimburse you 8 posh :
|
i
ie |
—Orighal Message 3 {
Shania Arnokd [maniscstsannoes fee 1
Bore Weare, e200 9 item \ i
i
\
I
1
‘Tos David MeArtor ae SEER RE | ronnciscamt
mt ones
enh .
copra ane a
eae egret ae be
anaemia
- Aftactent TTCOPY
Nov 5, 2020, 16:06
Hi! This is Carolyn
Soeder. Remember to
text or email me the
hearing info! Take care
of yourself:)
“COMMON PLEAS COURT
cHbAYt FER wont
vis aie coe
aeons 5° PHL IS
Artachttent TLCOPY
CAROLYN C. SOEDER
CSOEDER@CORDELLLAW.COM
LICENSED IN OHIO
October 26, 2020
PERSONAL AND CONFIDENTIAL
Via E-Mail
Mr. Daniel Moran
3904 Fitchville River Road
Wakeman, OH 44889
kdsmm2001@yahoo.com
RE: Kelly A. Moran v. Daniel M. Moran
Medina County Domestic Relations Court
Case No: 20 DR 0135
Dear Dan:
Welcome! I am glad that you have chosen to retain Cordell & Cordell: It was very nice to
meet with you one on one today to discuss your case in more detail.
As a reminder, please obtain your file from your previous attorney and get the file to my
office. The best way to do this is by arranging for the file delivery through my Paralegal, Heather
(216-278-7630; hearly@cordelllaw.com) or with our front desk (216-278-7620). I will be able to
better discuss case strategy with you once I have your full file.
The primary purpose of this correspondence is to get you more acquainted with our firm
and policies.
At Cordell & Cordell, we operate under a team approach. This means that I will
occasionally a strategy conference with my direct manager, Jason Lasser. Additionally, I
strategize with other associate attorneys in my office on a regular basis. Those associate attorneys
are Robert Vizmeg, Carly Boyd and Oliver Herthneck. During a strategy conference we discuss
what is going on in your case and strategize as to the best way to proceed. It is a good method of
obtaining fresh ideas for your case- as they say, often two heads are better than one.
These conferences are extremely beneficial to your case and often are the genesis of
productive strategy for your case. For example, if there is a unique issue in your case that I have
not encountered, there is a good chance that one of my colleagues has. By working together under
a team approach, we can avoid “reinventing the wheel” on your case and ultimately, secure a better
result for you.COPY
From: Daniel Moran
Sent: Monday, December 14, 2020 3:07 PM
To: Heather Early ; Carolyn C Soeder < \cordelilaw.com>
Subject: Re: Moran QDRO .
there is not an outstanding balance on my account as | paid the balance this morning.
| am still very concerned that the plaintiff / plaintiff counsel still has not reported the Plaintiffs:
‘plaintiffs'ct rent work contract 2020-2021 school year. as you know they reported last years
contract. w-plaintiff to. fraudulently receive temporary spousal support!
2)Plaintiffs accrued sick pay 86.5 days X current contracted pay per day= $37,926 of unreported
asset belonging to the plaintiff.
3)As | have said before pertaining to the STRS. | am already retired and with my health conditions
will probably-not live long enough till plaintiff retires. therefore the PLOP NOT THE DOPO is what
+ you will argue for in court, since | am your client and that is my request! _ if the Judge doesn't
agree, then | will just have to appeal to get a 50/50 non punitive legally acceptable result.
plaintiff counsel to enter the trial phase of this divorce while allowing them to continue hiding
it concerns me that the pretrial is in two days, and it appears to me that we are allowing the
assets!
is from my primary care VA Doctor, mandating the residence be remanded to me (the disabled
veteran) as doctors orders! further protected by the vet disability protection act that no VA
disability benefit (without minor children) can be awarded or encumbered by any court. that
It. concerns, me that there are current documents showing the VA remodeled my residence for me,
that haven't been turned in to the court except for Ray Jones multi branch motion! that document
bathroom remodel is a veteran disability benefit.
threatened to quit being my counsel if | filed evidence of those financial income and assets the
It further bothers me that | had those evidence documents, ready to turn in to the court, but you
plaintiff is hiding with the court!
lam placing my trust and my financial future in yours and your firm's hands knowing your going to
represent me professionally, and attain a non punitive legal 50/50 result.
Ex2COPY
RE: Moran QDRO
From: Carolyn C Soeder (csoeder@cordelllaw.com)
€
To: kdsmm2001@yahoo.com
Cc: hearly@cordelllaw.com
Date: Monday, December 14, 2020, 04:30 PM EST
ee
Mr. Moran-
Heather is correct regarding the payment to QDRO Group. From what | understand the Trial retainer, which is $5,000,
was not paid. | note that the file reflects a payment by you, but my file also reflects an unpaid balance of $915.80, in
addition to the Trial retainer not being paid which | referenced. | am sorry if this correspondence regarding your unpaid
legal fees causes you stress. However, given the issue with the unpaid legal fees and the fact that we have Trial
approaching very quickly with a lot of work to be done to prepare for Trial as second Counsel joining the case at the tail
end, the firm must have confirmation that there will be adequate funds to continue representation.
| will now answer your concerns in the manner in which you reported them, but first | must again express that if you feel
the firm/myself is not adequately representing you, you should not continue the representation. You seem resistant to
my legal advice when it isn’t in line with what you want, and my job is not just to tell you what you want to hear. As your
advocate, the Ohio Rules of Professional Conduct advise me that | have a duty to use legal procedure for the fullest
benefit of the client's cause, but also a duty not to abuse legal procedure. The law, both procedural and substantive,
establishes the limits within which | can proceed as your advocate. When | give you advice that you don’t like, it is
because there is a limit to what | can do and | am advising you within those limits.
| encourage you to stop using “Plaintiff to refer to your Wife, and to start now in correcting yourself so that you
Preview
COPY Pleas Court wepinayon on oT MEDINA COUNTY, OHIO 3 3 Ss RS PLAINTIFF ) eos ) cfm 2 fm DANIEL MORAN ) sZ> BB ) JUDGE: =s § 2 vs ) _ “eg os ) CHASTOPHER J. COLUER, JODG DEFENDANT ) ) CORDELL CORDELL ) CASE# S 7 C J Voo 29 ~ ATTORNEY FIRM & ) CAROLIN SOEDER ) REPRESENTING ATTORNEY ) COMPLAINT Now comes the plaintiff filing suit for damages from defendants for attorney misconduct, attorney legal malpractice, and failure to fulfil their professional responsibility/duty to zealously defend their client. All allegations about the defendant attorney in this lawsuit may be proven by examining all attached emails and the dates in which they were sent. Any potential non litigation agreement is null and void due to the defendants failure to abide by the laws governing their conduct, duty, and behaviour. 1) The defendant attorney failed to represent their client to the best of their abilities by not filing any motions to compel the opposing counsel in the divorce case in the proper time frame, to compel reporting of all assets. And arguing with their client to protect the ex-wife's assets while ignoring their duty to represent their client and compel opposing counsel to report current and necessary documentation in time to be considered by the divource court. a) The Email research attachment (attachment EM11-EM12)(sent to client dec 21, 2020) from defendant was the defendant's answer to their client requesting multiple times to compel the reporting of theCOPY ex-wifes sick pay assets for division. Rather than performing their due diligence, the defendant charged me for alleged research that the client already knew to be true, proving that sick pay not only should have been reported by the ex wife, but also divided by the divorce trial court. (Bergman v Bergman and Weller v Weller). b) As a direct result of the abandoned disabled non-attorney client's improper filings with the divorce court, the divorce court found that the sick pay funds cannot be divided since the client did not provide any division policy of the unreported asset belonging to the ex wife. See attached divorce decree. (attachment F27) which does not agree with the case law that the Defendant paid the defendant for, but was never used by the defendant attorney due to the abandonment of the disabled client. c) The ex wifes sick pay account held 95 2 days which was found on the ex wife's pay stub sent to defendant attorney by ex-wife’s attorney on november 6th 2020 (attachment E) d) Using the Ohio revised code (124.38) to calculate the ex-wife's sick pay account is valued as, one days pay is equal to one sick day's current pay amount. (Using ex-wife’s contract attachment D) e) since one sick day was valued at the time of decree at $438.46 times 95.5 = $41,872.93 should have been reported by the ex-wife and divided by the divorce court. However it appears that the attorney defendant was more interested in helping opposing counsel hide assets for the ex wife, rather than compel their disclosure, the divorce law 3105.171 requires that the divorce court shall require the reporting of ALL litigant assets. NO EXCEPTIONS. i) 50% of that asset entitled to the abandoned client was $20,936.46 (item f’s calculation based on that 50% figure) f) The defendant Attorney totally ignored the opposing counsel's willingness to hide the sick pay asset with the help of the clients own attorney/firm. As shown by the emails and text messages the only thing the defendant attorney did was prove that the ex-wifes sick pay was in fact a divisible asset by both ORC and CASELAW, while ignoring their own clients' wishes that the ex-wife be compelled to report ALL assets prior to trial. i) It appears The defendant attorney spent the whole time charging the client for non-service while trying to mislead their clients attention away from wanting the assets reported as required by laws governing attorney professional behaviour.COPY ii) ORC 3105.171.E,3 requires each litigant to disclose ALL assets and income iii) | The excuse from the defendant attorney, that the discovery phase of the case was over is misleading, there are measures a dutiful lawyer can take to protect their client from a dishonest legal attack up to and including the trial time frame, and beyond. g) The written ORC penalty (ORC3501.171(E,5) for willfully hiding assets is a penalty of three times the amount hidden from division of the divorce court. i) Since the defendant attorney assisted the ex wife in hiding those assets then, the defendant attorney should be directly responsible for the three times penalty of the clients rightfully owed amount. making the direct loss to the client $62,809.39 2) The defendant attorney also did not pursue any of the protections by law to protect their disabled veteran client from being removed from his VA disability remodeled home, as ordered by the veterans disability protection act (no non cash disability benefit may be divided unless there is extenuating circumstances such as minor children living in the home, which there were none.) a) This directly resulted in the disabled veteran client being permanently removed from his VA disability remodeled home, and the home being ordered sold by the divorce court. (attachment F23) b) their disabled client cannot afford and still does not have the dignity of disability accommodated showering facilities at his disposal, still to this date! Since the accommodated (once in a lifetime VA benefit remodel (attachment LO) ) home was not protected by proper filings from the defense attorney. c) The defendant attorney knew of the VA accommodations from their client. but also from the email November 6th 2020 that the opposing counsel informed the defendant attorney of the VA accommodations. If the defendant had been doing their sworn duty there was plenty of time to demand the protections of the veterans disability protection act on the behalf of their client. (Attachment LO) 3) The defendant attorney kept attempting to mislead their client while client was attempting to get them to compel the ex-wife to report all currentCOPY 4) assets by telling their client to pay for QDRO groups retainer while never telling their client that the QDRO group was not even a factor to figure pension valuation until after the trial awarded their client something to calculate the value of. especially since no QDRO professional group can establish a value of anything that ISN'T REPORTED or awarded prior to trial. (Attachments E multiple places) The defendant attorney abandoned their mentally and physically disabled client claiming it was a professional dispute between the defendant attorney and their client. a) b) qd) The defendant attorney mentioned this to the client as early as December 28th 2020,, 6 days after they intentionally. withdrew from the case. Further damaging any defense their client might be able to produce prior to the trial deadline of January 4th 2021, that directly benefited the ex-wife and her attorneys undefended case. As for the attorney defendant's reason for not filing any defense relevant documents or motions with the divorce court in a proper time frame as shown by the divorce courts docket (ATTACHMENT DO1 - DOS) although the only time frame relevant to this case is on (page DO2) and intentional withdrawal from their clients case, no reasonable honest excuse has ever been given. Defendant attorney filed their withdrawal / abandonment on December 22nd as shown in the divorce courts attached docket after the continuance had already been denied and ensured that the defendants client would have no ability to retain any counsel in the allowed time frame. Also note that Jason Lasser cordell’s firm leader emailed the client on January 4 th 2021 stating that the client could pick his file (court documents, evidence etc.(Attachment EM16-EM20) up from the defendant attorney on January 6th 2021 two days after the deadline for documents/evidence for the consideration of the court had passed. Further preventing their client from being able to establish any reasonable defense. 5) The defendant attorney was also viciously charging their client to continue to victimize his misplaced faith in the protection of law and the American judicial system’s and protections of citizens rights. by failing to perform the required attorney duties in a timely fashion.COPY 6) The entire time the defendant attorney was charging their client for work that was never done or not done in a timely fashion is also against the law governing attorney conduct. (billing) a) the client had already paid the defendant for TRIAL representation and had a positive balance on Dec 14th 2020 of $5,915.80 (attachment B1-B2) b) This was after the defendant attorney charged their client $3,415.80 for work that did not benefit their client whatsoever and research that proved that their client advised them correctly about what needed done since October 26th 2020 c) somehow with the defendants abandonment of their client the defendant charged their clint the entire amount of $5,915.80 but continues to attempt to collect an additional $1,818.60 (attachment B3) of excessive charges using email and harassing phone calls. To the abandoned client. d) Directly costing their client $9,331.60, for professional attorney fees that were useless in the case at least, and victimizing their own client at best. e) During the entire representation by the defendant, the defendant only filed a few items with the divorce court none of which pertained to anything that was contested by their client in the divorce. Knowing that the defendant was working for the ex wifes attorneys interests and not paying any attention to their own client’s interests starting 3weeks after a suicide attempt (Oct26th 2020) by their disabled client, and ending with the abandonment of the disabled client Dec 22 2020, and not informing their client until the 28th of December 2020 has made this last year of abuse from the ex wife and her attorney extremely difficult with his PTSD AND DEPRESSION. Directly aggravated by being abandoned by the defendant client. Therefore plaintiff is requesting $1,000,000,000.00 payment for unnecessary pain and suffering the plaintiff endured as a direct result of the defendant attorneys abandonment at a critical time of the case. These events have prevented the plaintiff from trusting anyone associated with the legal system and have led to a majority of sleepless nights worrying about what else the legal system might do to the unrepresented plaintiff client, especially since the divorce court alleges that all my filings which the totally court ignored was due to the disabled clients filings being misfiled or missing deadlines to file documents.the late filed subpoena byCOPY the defendant was just another disturbing example of the defendant firm, not representing their client zealously as commanded by law. Timeline of events (See attachment A1-A3) It is in the best interest of all parties to mandate the 7th Amendment to the united states constitution to demand a jury trial for this matter Therefore the plaintiff demands compensation from the defendant in the amount of: $1,633,740.99 as itemized below 1:$ 62,809.39to payback the plaintiff's entitlement to the ex-wife's sick pay 2:$561,600 to payback the plaintiffs entitlement to his boilermaker disability benefit $90.00 a month for 52 years = $561,600.00 (attachment BM1) 3:$1,000,000 to pay the disabled plaintiff for pain and suffering, for over a year of mental anxiety, and the disabled defendant not having the ability or dignity to take a complete shower at his residence. And funds to replace the disabled veterans disability accommodations to prevent the ongoing anxiety that the plaintiff has and allow the client some aspect of dignity of a complete shower. 4: It is also this disabled veterans demand that ALL cordell cordell associates no matter what their employment title is be made to attend a class on the veterans disability protection act and a class on how to approach and deal with clients with mental disabilities such as but not limited to PTSD & DEPRESSION. All costs associated with these employment mandatory classes shall be covered by cordell cordell with payments to the VETERANS ADMINISTRATION to develop these courses 5: for overcharging their client for irrelevant or non existent work performed on the case plaintiff requests a full refund of $9,331.60 It is my hope that this case will replace what the plaintiff has lost and prevent the abuse and denial of constitutional rights of any future disabled veterans that the Defendant might have the opportunity to represent in the future. Respectfully submitted Plaintiff Daniel MoranCOPY BOILERMAKER-BLACKSMITH NATIONAL PENSION TRUST PO Box 909700 Kansas City, MO 64190-9700 866-342-6555 or 913-342-6555 February 16, 2021 Daniel Moran 1114 N Court st Medina, OH 44256-1579 Re: Domestic Relations Order Benefit Hold Dear Mr. Moran: This letter is to notify you that the Boilermaker-Blacksmith National Pension Trust has received a Court Filed Divorce Decree, advising Kelly Moran is awarded 50% of the Pension Benefit. To effectively divide your retirement benefits, we must receive a Domestic Relations Order and it must be qualified, meaning that it must comply with certain requirements of both the law and the Order (QDRO), the portion of your benefits assigned under the Divorce Decree will be held by the Plan. The Plan will hold benefits until a qualifying QDRO is achieved (up to a maximum of eighteen months) . Any portion of benefits not assigned under the Domestic Relations Order will still be available to you. The Divorce Decree that assigns 50% of the monthly pension to Kelly Moran. Therefore, effective March 1, 2021, we-must reduce your pension by $900.99. Your adjusted gross” monthly pension effective March 1, 2021 will be $900.99, This amount will remain segregated and will be paid to the alternate payee once a court filed QDRO has been received, reviewed and approved by our Legal Counsel. At this time, the Divorce Decree will be forwarded to our Legal Counsel for review. Please allow a minimum of 60 days for the response by our Legal Counsel. MLCOPY TIMELINE date and item/action, attachment __ 1) 26 Oct, 2020 defendant accepts case EM17&EM1 2) 5Nov,2020 defendant requests client docs via TEXT 1 3) Ex-wife's attorney provided defendant via email E,D,L E proves sick day balance. L shows again that defendant knew about the VA remodeled home and did not defend it 4) 9 Nov, 2020 defendant files notice of appearance DO2, F1-F2 5) 12 November defendant informed to use VETERANS DISABILITY PROTECTION ACT to protect their clients home 110 6) 19 Nov 2020Defendant files motion to continue F3 7) 25 Nov, 2020 client asked why nothings been filed to compel ex-wifes reporting of assets asked if | should ask the opposing counsel for asset reporting : T11 8) 25 Nov, 2020defendant filed another motion to continue 9) 25 Nov 2020 Defendant reported change of address F7 10) Dec 16. 2020 client getting frantic that ex-wife's assets still not reported by the ex wife and still NOT compelled by the defendant attorney. 711-T12 11) 30 Nov 2020 Defendant files third motion for continuance F8 -F10 12) 3 Dec 2020 hearing defendant did not bring up the disabled vet home or the ex wife's sick pay assets —_—- 13) 14 Dec client emailed defendant again asking about his VETERAN rights and unreported sick pay EM2 14) 14 DEC 2020 defendant attorney admits they needed to subpoena the sick pay EM3 15) 14 Dec 2020 Defendant emailed client about OHIO RULES OF PROFESSIONAL CONDUCT & alleged there was no basis for the client to ALLEGE the ex wife hiding assets(PAYSTUBS) . EM3-EM3A 16) 14 Dec 2020 client starts making the excuse that they did not miss any deadlines and said it was too late in the case to file any evidentiary motions (what happened to the A |COPY 8 4 weeks defendant attorney spent arguing with the client that sick pay is not divisible! 17) 14 Dec 2020Defendant states that they know client wants back into his VA accommodated home but still fails to act on their clients behalf 18) 14 Dec 2020 defendant emails client again trying to change his direction by asking about QDRO again which has nothing to do with the unreported asset. 19) 14 Dec 2020 Defendant emails ex-wife's attorney and does not ask about the sick pay or the clients necessary VA accommodated home 20) 16Dec 2020 Defendant advises client of Jan 4, 2021 deadline for production of documents set by the divorce court. 21) 21Dec 2020 Defendant finally agrees with client that the ex wife’s sick pay is divisible and charges the client to prove He was right about the law! : 22) 16 Dec 2020 defendant finally files subpoena to compel reporting of ex-wifes sick pay account (after frantic text) 23) 16 Dec 2020 defendant filed a witness list exhibit list 24) 21 Dec 2020 client emailed defendant asking if he read the “research” docs correctly. 25) 21 Dec 2020 defendant admits to “missing” an offer from opposing counsel?? 26) 22 Dec 2020 Defendant filed motion to continue / leave and motion to withdrawal from the case abandoning the client 27) 22 Dec 2020 divorce court denies continuance 28) 28 Dec 2020 Defendant informes client of the defendants intentions to abandon their client after admitting client was correct about the sick pay being divisible 29) Divorce court releases defendant from the case 13 days till trial 30) 4 Jan 2021 defendant firm leader allows client the ability to retrieve his file on WEDNESDAY JANUARY 6, 2021 31) 5 Jan 2021 defendant firm leader says he doesn't know what client mean by clients allegation of defendant blocking client from establishing his defense proving that Ad EM4 EM5 EM6 EM7-EM8 Emg9 EM11 - 12 $1-S5 F1-F15 EM13 EM10 F16 -F21 F21 EM14-15 F22 EM16COPY defendant firm never cared to know what was going on in their clients case EM19-EM20 32) 5 January 2021 Defendant wrote letter stating that defendant would still provide exhibits as needed by the client, the day after all exhibits/documents were due by the divorce courts deadline LE1-LE3 33) 6 Jan 2021 client was allowed to retrieve his exhibits / file that was still in the same box and disorganized as it was from when the client delivered the file to them on October 26th P1 34) 22Jan 2021 divorce court decree is issued F22-F28 35) 19 Jan 2021 Ex-wife's attorney produced document to claim 50% of clients disability benefit “for life” even though that was not awarded by the decree. Unfortunately the client did not have representation to combat this attack from ex-wifes counsel re-defining simple english definitions in the decree to form their division of property order F29- F32 ASCOPY Cordell Cordell A Domestic Litigation Firm A Partner Men Can Count On.® December 15, 2020 Matter: 258986.268014 Invoice No: 3177698 Priot ‘iaeart Balance Due $ 915.80 ew “SS New Charges “= $ 1,923.60 Charges Due This Statement $ 2,839.40 CLIENT TRUST ACTIVITY DETAILS TRUST:ACTIVITY. THROUGH 12/15/2020 . : t Beginning Retainer Trust Balance Le : $0.00 42/14/20 cited ss : $ 2,500.00 12/14/20 $ 3,415.80 Ending Retainer Trust Balance $ 5,915.80 Onur he RIG Ending Trust Only Balance $0.00 You can ‘view up to date.information regarding your case, billing history, or make a payment by registering and logging into your Client Case Center: https://cportal.cordelilaw.com. Remember to visit our websites DadsDivorce.com and MensDivorce.com for helpful divorce resources, information, articles, podcasts, videos, and more. 8 4 Page 4|4 —COPY Cordell Cordell A Domestic Litigation Firm A Partner Men Carl Count on.® November 2, 2021 Matter: 258986.268014 Lee Invoice No: 3448270 TOTAL CURRENT CHARGES FOR FEES & COST/EXPENSES $ 0.00 Stake apy CARLA EY PAYMENTS/CREDITS APPLIED Prior Statement Balance Due $ 1,818.60 New Charges’’ | | $0.00 ’ Charges Dué This Statement $ 1,818.60 CLIENT TRUST ACTIVITY DETAILS TRUST ACTIVITY THROUGH “11/02/2021 a ~ Beginning Retainer Trust Balance,: ; -- . $0.00 Ending Retainer Trust Balance $0.00 Ending Trust Only Balance : $0.00 You can view up to date information regarding your-éase, billing history, or make a payment by registering and logging into your Client Case Center: . ht ' tps://cportal.cordelllaw.com. Remember to visit our websites DadsDivorce.com and MensDivorce.com for helpful divorce resources, information, articles, podcasts, videos, and more. Page 2|2 B2GORY 172.16.1.21/medet_epublicnodr_int/Default.aspx prtikengat D6 L Case Details Case Information Case # Caption | Filed Date; Status | Judge Assigned | 200R0135 KELLY A MORAN -VS- DANIEL M MORAN 07-Apr-2020 HEARING... KOVACK, MARY : Parties Involved Name | Address Associated Party MORAN , KELLY (Plaintif ) 3812 FOSKETT RD, MEDINA OH, 44256 MCARTOR,DAVID MCARTOR , DAVID (Plt Attorney ) 208 W LIBERTY ST, MEDINA OH, 44256 MORAN.KELLY MORAN , DANIEL (Defendant ) 1114 N COURT ST, MEDINA OH, 44256 JONES.L Actions Action Date | Action Description i Notes te/Mari2021 HEARING SET RE: MOTION FOR CLERICAL CORRECTION ON DIVORCE DEbRES~- HRG. WILL BE CONDUCTED VIA ZOOM VIDEO CONFERENCE = 26/Febi2021 REQUEST FOR WITHDRAWAL DETERMINATION OF PLACEMENT OF A COURT 6a. APPOINTED MEDIATOR FILED BY DANIEL MORAN li 2alFebI2021 NOTICE OF SUBMISSION RE: PLEASE ADD QORO'S TO THE TOPIC LIST FOR 3/18/2021 HRG, - S LETTER--FILED BY DANIEL MORAN 2 a ih 18/Feb/2021 DEFENDANT'S NOMINATION OF PROFESSIONAL TAZ SERVICES FILED BY DANIEL EAL MORAN. 3 18/Feb/2021 NOTICE OF SUBMISSION RE: QDRO FILED BY ATTY DANIEL MORAN 2 18iFeb2021 NOTICE OF HEARING RE: MOTION FOR CLERICAL CORRECTION ON DIVORCE DECREE 3 (HRG. 3/18/2021 @ 10:00 A.M. UNTIL 11:00 A.M. BEFORE/MAG. ROSS)— 3 HRG. WILL BE CONDUCTED VIA ZOOM VIDEO CONFERENCE By 17/Feb/2021 DEFENDANT BEGS THIS COURT FOR RELIEF 17iFebi2021 DEFENDANT'S. NOMINATION FOR REAL ESTATE AGENT View O5/Feb/2021 REQUEST (EMAIL COPY) REQUEST FOR NUNC PRO TUNC WIPROOF OF SERVICE—EMAILEDTO Vi DR COURT BY ATTY DAVID MCARTOR 04/Feb/2021 MOTION (EMAIL COPY) MOTION FOR CLERICAL CORRECTION ON DIVORCE DECREE— Vi EMAILED TO DR COURT BY DEFENDANT DANIEL MORAN 22iJan/2021 —- MAGISTRATE'S DECISION View 22iJanl2021 DECREE OF DIVORCE CERT COPY MAILED TO PARTIES BY THE COURT View 2tldani2021 DOCKET NOTATION View t2iJan2021 SUBMISSION OF EVIDENCE RE: MCARTER MAIL SIGNATURE... FILED BY DEF DANIEL No Document MORAN 12ian/2021 - SUBPOENA(S) FILED SERVED BY ATTORNEY FILED BY BY ATTY CAROLYN SOEDER No Document tiJani2021 TRIAL SET HRG WILL BE CONDUCTED TELEPHONICALLYIVIA VIDEO No Document CONFERENCE- REQUEST FOR RULE 75 HEARING (RESET FROM . - DECEMBER 03 2020) o8iJan/2021 SUBMISSION OF EVIDENCE 2019 TAXES FILED BY DANIEL —-HE DID NOT WANT IN No Document THE CONFIDENTIAL FILE O7/Jan/2021 PLAINTIFFS TRIAL BRIEF (EMAIL COPY) WIPROOF OF SERVICE- EMAILED TO DR COURT BY ATTY DAVIDL View MCARTOR o6iJan/2021 SUBMISSION OF EVIDENCE RE: INCOME/SUPPORT... FILED BY DEF DANIEL MORAN No Document oGiJan/2021 SUBMISSION OF EVIDENCE RE: PENSIONS... FILED BY DEF DANIEL MORAN No Document o6iJani2021 SUBMISSION OF EVIDENCE RE: VEHICLES... FILED BY DEF DANIEL MORAN No Document O6iJan/2021 SUBMISSION OF EVIDENCE RE: OTHER MARITAL ASSETS... FILED BY DEF DANIEL No Document MORAN o6/Jani2021 SUBMISSION OF EVIDENCE RE: REAL ESTATE ... FILED BY DEF DANIEL MORAN No Document oGiJan/2021 SUBMISSION OF EVIDENCE RE: BOAT.. FILED BY DEF DANIEL MORAN No Document OSiJan/2021 ORDER RE: MOTION TO WITHDRAW AS COUNSEL IS HEREBY GRANTED View 0S/Jan/2021 SUPPLEMENTAL WITNESS & EXHIBIT LIST (EMAIL WICERT OF SERVICE FILED BY PLT'S ATTY DAVID MCARTOR (EMAIL... No Document copy) TO DR COURT BY ATTY MCARTOR) O4/Jan/2021 MOTION TO WITHDRAW CONTINUANCE FILED BY DEFENDANT View 28/Dec!2020 ORDER GRANTING ATTY CAROLYN C SOEDER MOT TO WITHORAW AS View COUNSEL FOR DEF 26/Dec!2020 MOTION FOR CONTINUANCE (EMAIL COPY) WICERTIFICATE OF SERVICE—-FAXED TO DR COURT BY ATTY View : CAROLYN SOEDER 28/Dec!2020 MOTION TO WITHDRAW AS COUNSEL (EMAILCOPY) _ WICERTIFICATE OF SERVICE— EMAILED TO DR COURT BY ATTY View CAROLYN SOEDER 22iDec!2020 ORDER OF CONTINUANCE DENIED.. HRG WILL BE HEARD ON 1/11/2021 @ 9:00 AM BEFORE View JUDGE KOVACK (HEARING WILL BE CONDUCTED TELEPHONICALLYIMIA VIDEO CONFERENCE) 15CARY 22Mec!2020 -- MOTION FOR CONTINUANCE (FAX COPY) * || 22/Decr2020 MOTION TO WITHDRAW AS COUNSEL (FAX COPY) | t6/Decr2020 EXHIBIT LIST (FAX COPY) 16/Deci2020 _- SUBPOENA(S) FILED SERVED BY ATTORNEY (FAX COPY) 16/Deci2020 —- WITNESS AND EXHIBIT LIST (FAX COPY) 16/Dec/2020 PRETRIAL HEARING SET 15/Dec/2020 WITNESS AND EXHIBIT LIST (EMAIL COPY) 04/Dec!2020 -—- MAGISTRATE'S ORDER FOR CONTINUANCE 03/Dec!2020 «HEARING SET 30/Novi2020 MOTION FOR CONTINUANCE (ORIGINAL COPY) 25/Novi2020 COURT NOTICE OF RECEIPT OF RELOCATION NOTICE 25/Novi2020 MOTION FOR CONTINUANCE (FAX COPY) 49/Novi2020 MAGISTRATE'S ORDER FOR CONTINUANCE 16!Novi2020 MOTION TO CONTINUE (EMAIL COPY) | 12INow2020 ORDER 09/Novi2020 MOTION FOR CONTINUANCE(ORIGNIAL COPY) O9/Novi2020 NOTICE OF APPEARANCE OF COUNSEL (ORIGNIAL copy) O9/Now/2020 DOCKET NOTATION 09/Novi2020 NOTICE OF HEARING O8/Novi2020 HEARING SET 05/Novi2020 MOTION FOR CONTINUANCE (FAX COPY) 5/Novi2020 NOTICE OF APPEARANCE OF COUNSEL (FAX COPY) 19/0ct/2020 —- MOTION TO WITHDRAW (EMAILED COPY) 19/0ct’2020 TRANSCRIPT 19/0cv2020 NOTICE OF SUBMISSION OF TRANSCRIPT 19/0ct’2020 NOTICE OF SUBMISSION 19/0cv2020 “NOTICE OF CHANGE OF ADDRESS 1610cv2020 JUDGMENT ENTRY 07/0cv2020 - MOTION TO CONTINUE (EMAIL COPY) 01/0cv2020 NOTICE OF HEARING | 28/Sep/2020 - MAGISTRATE’S ORDER FOR CONTINUANCE 24/Sep/2020 MOTION TO CONTINUE (EMAILED COPY) 24/Sep/2020 MAGISTRATES ORDER FOR CONTINUANCE 16/Sep/2020 MOTION TO CONTINUE (EMAIL COPY) 15/Sep/2020 NOTICE OF HEARING | 172.16.1,21/medct_epublicnodr_int/Default.aspx Case Details WICERTIFICATE OF SERVICE--FAXED TO DR COURT BY ATTY lew CAROLYN SOEDER WICERTIFICATE OF SERVICE--FAXED TO DR COURT BY ATTY View CAROLYN SOEDER OF DEFENDANTWICERTIFICATE OF SREVICE—FAXED TO DR COURT —_No Document BY ATTY CAROLYN SOEDER SUBPOENA TO ATTEND AND PRODUCE DOCUMENTS WICERTIFICATE _ No Document OF SERVICE--FAXED TO DR COURT BY ATTY CAROLYN SOEDER. WICERTIFICATE OF SERVICE--FAXED TO DR COURT BY ATTY No Document CAROLYN SOEDER HRG WILL BE CONDUCTED TELEPHONICALLY/VIA VIDEO No Document CONFERENCE, PLAINTIFF'S WIPROOF OF SERVICE —-EMAILED TO DR COURT BY ATTY No Document DAVID MCARTOR GRANTED- MATTER WILL BE HEARD ON JANUARY 11 2021 @9AM - RESET FROM DECEMBER 03 2020 RE: REQUEST FOR RULE 75 HRG.-HRG. WILL BE CONDUCTED No Document ‘TELEPHONICALLY/VIA VIDEO CONFERENCE RESET FROM DEC 2, 2020 WICERT OF SERVICE ~- FAXED TO DR COURT BY ATTY CAROLYN View SOEDER DANIEL View WICERT OF SERVICE ~ FAXED TO DR COURT BY ATTY CAROLYN View SOEDER GRANTED.. HRG SCHEDULED FOR 12/2/2020 IS CONTD TO 12/3/2020 View @ 9:00 AM BEFORE MAG. D. LUKE ROSS (HEARING WILL BE CONDUCTED TELEPHONICALLY/VIA VIDEO CONFERENCE) WIPROOF OF SERVICE~ EMAILED TO DR COURT BY ATTY DAVID L View MCARTOR GRANTING ATTY RAY JONES REQUEST TO WITHDRAW AS COUNSEL View FOR DEF OF HRG, ON NOVEMBER 6, 2020 WICERTIFICATE OF SERVICE--FAXED View TO DR COURT BY ATTY CAROLYN SOEDER FOR THE DEFENDANT DANIEL M MORAN WICERTIFICATE OF SERVICE Viow --FILED BY ARRT CAROLYN SOEDER View RE: REQUEST FOR RULE 75 HRG. 12/2/2020 @ 1:00 P.M, UNTIL 2:00 PM. View BEFORE/MAG. ROSS.--HRG. WILL BE CONDUCTED. TELEPHONICALLYIVIA VIDEO CONFERENCE HEARING TO BE CONDUCTED TELEPHONICALLY/ ViA VIDEO CONFERENCE - REQUEST FOR RULE 75 HEARING- OF HRG. ON NOVEMBER 6, 2020 WICERTIFICATE OF SERVICE---FAXED View TO DR COURT BY ATTY CAROLYN SOEDER FOR THE DEFENDANT DANIEL M MORAN WICERTIFICATE OF SERVICE- No Document Mew ~FAXED TO DR COURT BY ATTY CAROLYN SOEDER RE: ATTY L RAY JONES TO WITHDRAW AS COUNSEL FOR THE View DEFENDANT WIPROOF OF SERVICE OF MOTION HEARING AUG 20, 2020 No Document OF HRG ON AUG 20, 2020 . View RE: ADA ACCOMODATIONS FOR DEF'S VA REMODELED HOME; FILED View BY DEF DANIEL MORAN RE: DANIEL MORAN View RE: MOTION TO CONTINUE -GRANTED (HRG. 11/6/2020 @ 9:00AM. View BEFORE/MAG. ROSS) RE: HRG, DATE SET FOR 10/19/2020 @ 11:00 AM, -~-~HRG WILL BE CONDUCTED TELEPHONICALLY/VIA VIDEO CONFERENCE, WICERTIFICATE OF SERVICE--EMAILED TO DR COURT BY ATTY LRAY View JONES: HEARING TO BE CONDUCTED TELEPHONICALLY/ VIA VIDEO CONFERENCE - MOT TO SET ASIDE MAG ORDER ON NOVEMBER 06 2020 @9AM UNTIL 11AM BEFORE MAG ROSS, GRANTED- MATTER WILL BE HEARD ON OCTOBER 19 2020 @11AM BEFORE MAG ROSS- HEARING RESET FROM OCTOBER 07 2020 WICERT OF SERVICE~ EMAILED TO DR COURT BY ATTY LRAY JONES View w GRANTED- MATTER WILL BE HEARD ON NOVEMBER 06 2020 @9AM BEFORE MAG ROSS - HEARING DATE RESET FROM OCTOBER 21 2020 W/ PROOF OF SERVICE-- EMAILED TO COURT FILED BY PLT ATTY fiew DAVID MCARTOR HEARING TO BE CONDUCTED TELEPHONICALLY/ VIA VIDEO CONFERENCE - REQUEST FOR RULE 75 HEARING- ON OCTOBER 07 2020 @1PM UNITL 2PM BEFORE MAG ROSS. AHack ment DOA is I= 215COPY 11/$ep/2020 11/Sep/2020 09/Sep/2020 34/Augi2020 31/Aug/2020 31/Aug/2020 ‘31/Aug/2020 31/Aug/2020 21/Augl2020 20/Aug/2020 18/Aug/2020 18/Aug/2020 12/Aug!2020 O7/Aug/2020 o5/Aug/2020 34/4u2020 30/Juu2020 29/5uv2020 29/Jul/2020 27H4ul'2020 271dul2020 21/duv2020 24/2020 24NuV/2020 06/Juv/2020 o2/Juv2020 02/Juv72020 o2/Jul/2020 o2iuv2020 O2/Juv2020 01/Juv2020 30/un/2020 30/Jun/2020 MOTION TO SET ASIDE (EMAIL COPY) REQUEST (EMAIL COPY) DEPOSITION NOTICE OF HEARING MAGISTRATE'S ORDER NOTICE OF HEARING TEMPORARY ORDER(S) OF SUPPORT DOCKET NOTATION NOTICE OF SUBMISSION (EMAIL COPY) HEARING SET MAGISTRATE'S ORDER MOTION TO CONTINUE (EMAILED COPY) NOTICE OF HEARING MOTION TO COMPEL (EMAIL COPY) MULTI-BRANCH MOTION (EMAILED COPY) RESPONSE TO MOTION (EMAIL COPY) ORDER AGREED JOURNAL ENTRY FILED NOTICE OF HEARING DEPOSITION DEPOSITION DOCKET NOTATION CASE MANAGEMENT ORDER NOTICE OF HEARING MOTION FOR TEMPORARY ORDERS (EMAIL COPY) ORDER ‘41 A DISMISSAL OF MOTION (EMAILED COPY) NOTICE OF FAILURE OF SERVICE MAILED TO ATTY SHERIFFS RETURN FILED UNCONT. DIVORCE OR CASE MGMT HEARING COPIES W/INSTRUCTIONS ISSUED SHERIFF SUMMONS AND ORDER TO APPEAR NOTICE OF HEARING 172.16.1.21/medct_epublicnodr_int/Default.aspx Case Details THE MAG. ORDER OF 8/31/2020;JULY 31, 2020 NEVER SERVED ISSUES CONCERNING RULE 11 AND CONTEMPT SHOULD BE RETURNED TO. MAG. ~-EMAILED TO DR COURT BY ATTY L RAY JONES REQUEST FOR RULE 75 N 2 HRG, ORAL HRG. REQUEST WICERTIFICATE OF SERVICE --EMAILED TO DR COURT BY ATTY L RAY JONES: OF KELLY A MORAN TAKEN ON JULY 8, 2020 WEXHIBIT RESPONSE TO MOTION TO COMPEL; MOTION FOR RULE 11 SANCTIONS; MOTION FOR ATTY FEES OCT 21, 2020 @9-11AM WI MAG ROSS HRG WILL BE CONDUCTED TELEPHONICALLY/VIA VIDEO. CONFERENCE MAG WILL ISSUE TEMP ORDERS ON AFFIDAVIT WITH REGARD TO WIFE'S MOTION FILED JULY 6, 2020 HUSBAND'S FILED AUG 5, 2020; HUSBANDS MOTION TO COMPEL WAS DENIED, WIFES'S MOTION FOR SANCTIONS & ATTY FEES FILED JULY 31, 2020 TO BE SET FOR HEARING RE; PENDING MOTIONS. OCT 21, 2020 @9-11AM W/ MAG ROSS HRG WILL BE CONDUCTED TELEPHONICALLY/VIA VIDEO CONFERENCE SPOUSAL SUPPORT RE: FINANCIAL SOURCE DOCUMENTS WICERTIFICATE OF SERVICE — EMAILED TO DR COURT BY ATTY L RY JONES EVIDENTIARY HEARING; MOT FOR TEMPORARY ORDERS- DEFENDANTS MTSC FILED 05/26/2020 (HRG WILL BE CONDUCTED TELEPHONICALLY/VIA VIDEO CONFERENCE) RE: PLAINTIFF'S MOTION TO CONTINUE NOT WELL-TAKEN AND HEREBY DENIES THE SAME WIPROOF OF SERVICE-- EMAILED TO DR COURT BY ATTY DAVID L MCARTOR OR IN THE ALTERNATIVE REQUEST TO SIGN STRS RELEASE;REQUEST FOR ATTORNEY FEES REQUEST TO SET HRG. ON MOTION FOR CONTEMOT ON COMPUTER WICERTIFICATE OF SERVICE--EMAILED TO DR COURT BY ATTY L RAY JONES WICERT OF SERVICE-- EMAILED TO DR COURT BY ATTY L RAY JONES TO COMPEL AND REQUEST FOR HRG.MOT FOR RULE 11 SANCTIONS AND ATTORNEY FEES W/PROOF OF SERVICE-—EMAILED TO DR COURT BY ATTY DAVID MCARTOR GRANTING 41 (A) DISMISSAL OF MOTION FOR CONTEMPT FILED 6/25/2020 FILED 7/2/2020 $5000 MAY BE RELEASED TO THE DEF FROM ATTY RAY JONES JOLTA ACCT MOT FOR TEMP ORDERS AUG 20, 2020 @9-10AM W/ MAG ROSS HRG WILL BE CONDUCTED TELEPHONICALLY/VIA VIDEO CONFERENCE TAKEN OF MICHAEL MORAN ON JULY 8, 2020 OF COLLEEN KOPP TAKEN ON JULY 8, 2020 PRE-TRIAL: DEC 16, 2020 10:30-11AM TRIAL: JAN 11,2021 9-4PM EVIDENTIARY HEARING AUG 20, 2020 @9-10AM WIMAG ROSS. HRG WILL BE CONDUCTED TELEPHONICALLYIVIA VIDEO CONFERENCE WICERTIFICATE OF SERVICE --EMAILED TO DR COURT BY ATTY DAVID MCARTOR RE: 41 A DISMISSAL OF JP MORGAN CHASE BANK-—-GRANTED FOR CONTEMPT FILED 6/25/2020 WICERT OF SERVICE~ EMAILED TO DR COURT BY ATTY L RAY JONES TO ATTY L RAY JONES RE: FAILURE OF SERVICE ON KELLY A MORAN FAILURE OF SERVICE ON KELLY MORAN; UNABLE TO LOCATE ON FIRST SERVICE ATTEMPT 7/1/2020 AND MOTION FOR CONTEMPT (HEARING WILL BE CONDUCTED TELEPHONICALLY) CERT COPY OF MOTION FOR CONTEMPT, SUMMONS AND ORDER TO APPEAR, AND NOH WIATTACHED COVID-19 ORDER TO KELLY A MORAN ISSUED TO MEDINA COUNTY SHERIFF KELLY A MORAN IS SUMMONED AND ORDERED TO APPEAR 7/2/2020 @ 9:00 AM MOTION FOR CONTEMPT 7/2/2020 @ 8:00 AM- 9:30 AM BEFORE MAG. AHtAchwent DO3 View Mew No Document View Mew View Mew View No Document Mew View View View View Miew No Document No Document View View é eR EF & No Document I< 2 & 3/5GARY . 25/dun/2020 25/Jun/2020 25/Jun/2020 24/Jun/2020 22/Jun/2020 22fJun/2020 2alsunt2020 49/Jun/2020 49/Jun/2020 19/Jun/2020 ‘11/dun/2020 04/Jun/2020 03/Jun/2020 o2/Jun/2020 02/Jun/2020 O2/Jun/2020 29May/2020 28/Mayi2020 26/May/2020 26/May/2020 14/May/2020 O7/May/2020 07/May/2020 O7/May/2020 06/May/2020 O6/May/2020 | 05/May/2020 ‘05/May/2020 28/Apr/2020 271Apr2020 24/pr12020 23/Apr/2020 | 23/Apr/2020 23/Apr/2020 MOTION FOR CONTEMPT (EMAILED COPY) INSTRUCTIONS FOR SERVICE (EMAILED COPY) ‘SUBPOENA(S) RETURNED FROM MEDINA CO SHERIFF GOOD SERVICE PERSONAL SERVICE MADE ON PERSONAL SERVICE MADE ON SUBPOENA(S) RETURNED FROM MEDINA CO SHERIFF GOOD SERVICE SUBPOENA(S) ISSUED TO SHERIFF ‘SUBPOENA(S) ISSUED PRAECIPE NOTICE OF DEPOSITION CERTIFIED MAIL SERVICE COMPLETED ON CERTIFIED MAIL SENT RETURN RECEIPT REQUESTED NOTICE OF SERVICE (FAX COPY) DOCKET NOTATION SUMMONS AND ORDER TO APPEAR NOTICE OF HEARING DISMISSAL NOTICE OF SERVICE (FAX COPY) MOTION FOR CONTEMPT INSTRUCTIONS FOR SERVICE JOURNAL ENTRY MAGISTRATE'S ORDER HEARING SET SHERIFFS RETURN FILED PERSONAL SERVICE MADE ON COPIES WIINSTRUCTIONS ISSUED SHERIFF MAGISTRATE'S ORDER NOTICE OF HEARING EMERGENCY (ORIGNIAL COPY) NOTICE OF HEARING EMERGENCY REQUEST (FAX COPY) NOTICE OF SERVICE REQUEST (ORIGINAL) INSTRUCTIONS FOR SERVICE (ORIGINAL) 172.16.1.21/medct_epublicnodr_int/Default.aspx Case Details D. LUKE ROSS (HEARING WILL BE CONDUCTED TELEPHONICALLY/VIA VIDEO CONFERENCE) FAXED TO DR COURT BY ATTY L, RAY JONES ‘SERVE KELLY MORAN (SHERIFF SERVICE) EMAILED TO DR COURT BY ATTY L .RAY JONES. (1) MICHAEL MORAN GOOD SERVICE ON COLLEEN (1) 2) (2) ‘SERVE PARTIES SUBPOENAS (SHERIFF SERVICE) FILED BY ATTY L RAY JONES WICERT OF SERVICE KELLY A MORAN (4209 55) CERT COPY OF MOT FOR CONTEMPT, SUMMONS AND ORDER TO APPEAR AND NOT OF HRG W/INSTR SENT TO KELLY A MORAN (4209 58) WISERVICE--FAXED TO DR COURT BY ATTY DAVID MCARTOR KELLY A MORAN IS ORDERED TO APPEAR ON JUL 2, 2020 @ 9:00 AM “HRG WILL BE CONDUCTED TELEPHONICALLY VIA VIDEO CONFERENCE“ MOT FOR CONTEMPT ON JUL 2, 2020 @ 9:00 AM WIMAG ROSS. 41 A DISMISSAL OF JP MORGAN CHASE BANK WICERTIFICATE OF SERVICE WICERT OF SERVICE-- FAXED TO DR COURT BY ATTY DAVID MCARTOR FILED BY DEF'S ATTY L RAY JONES WICERT OF SERVICE RE: JP MORGAN CHASE IS ADDED as THIRD PARTY DEFEDANT JP MORGAN CHS BANK TO RELEASE RESTRAINING ORDER; PLT ‘SHALL DELIVER A CHECK PAYABLE TO "L RAY JONES ILOTA ACCOUNT OF $12,500; DEF FRIEND MAY REMOVE THE PARTIE'S BOAT & ACCESSORIES, TRAILER, DEF'S COMPUTER, WALKER, VA RECORDS, TAX DOCUMENTS, PASSPORT , TITLES TO 2 VEHICLES USED BY THE PARTIES ADULT SON. DEF TO SIGN THE TITLES OVER TO THE SON, MICHAEL E MORAN, PLT SHALL HAVE EXGLUSIVE USE OF THE MARITAL HOME; EQUALLY DIVIDE AUTO INSURANCE THRU STATE FARM; PLT SHALL PAY MORTGAGE FOR MONTHS OF JUNE & JULY; PARTIES SHALL HIRE JOSEPHY MARYNOSKI CPA TO PREPARE 2019 IT RETURNS & PARTIES EQUALLY DIVIDE REFUND OR INDEBTEDNESS EQUALLY PAYING THE CPA RE: EMERGENCY REQUEST TO HAVE ACCESS TO BOAT AND PERSONAL ITEMS --"*HRG, WILL BE CONDUCTED TELEPHONICALLY VIAVVIDEO CONFERENCE” MOT TO ADD THIRD PARTY, MOT FOR RESTRAINING ORDER GOOD SERVICE ON CHASE BANK GOOD SERVICE ON CHASE BANK (MEDINA COUNTY) CERT COPY OF MOT TO ADD THIRD PARTY, MAG'S ORDER AND NOTICE OF HRG FOR SERVICE ON JP MORGAN CHASE BANK JP MORGAN CHASE BANK IS ADDED AS A THIRD PARTY DEF AND ‘SHALL PLACE A HOLD ON ALL ACCOUNTS UNTIL FURTHER ORDER OF THE COURT ** HRG WILL BE CONDUCTED TELEPHONICALLY/VIA VIDEO CONFERENCE* MOT TO ADD THIRD PARTY, MOT FOR RESTRAINING. ORDER ON MAY 7, 2020 @ 2:00 PM W/MAG ROSS: EMERGENCY REQUEST TO HAVE ACCESS TO BOAT AND PERSONAL ITEMS -—FILED BY ATTY L. RAY JONES RE: EMERGENCY REQUEST TO HAVE ACCESS TO BOAT AND PERSONAL ITEMS (HRG. 5/7/2020 @ 2:00 P.M. UNTIL 3:00 P.M. RG, WILL BE CONDUCTED TELEPHONICALLY BEFORE/MAG, ROSS) VIAVIDEO CONFERENCE ‘TO HAVE ACCESS TO BOAT AND PERSONAL ITEMS FAXED TO DR COURT BY ATTY L RAY JONES WICERT OF SERVICE OF DISCOVERY WICERT OF SERVICE FILED BY DEF'S ATTY L RAY JONES: TO ADD THIRD PARTY DEF; REQUEST FOR RESTRAINING ORDER WICERT OF SERVICE FILED BY ATTY L RAY JONES FILED BY ATTY L RAY JONES Attar ec ANU No Document View View & 45CORY | 23/Apr!2020 RESPONSE (ORIGINAL) 23/Apr!2020 ANSWER (ORIGINAL) 23/Apr12020. WAIVER OF SERVICE AND VENUE (ORIGINAL) 23/Apr/2020 NOTICE OF APPEARANCE (ORIGINAL) 221Apr/2020 NOTICE OF SUBMISSION (FAX COPY) 21/Apr/2020 NOTICE OF SUBMISSION (FAX COPY) 21/Apri2020 —- WAIVER OF SERVICE AND VENUE (EMAIL COPY) 21/Apr/2020 REQUEST (EMAILED COPY) 21/Apr!2020 RESPONSE (EMAILED COPY) 211Apri2020 ANSWER (EMAILED COPY) 24/Apr/2020 NOTICE OF APPEARANCE (EMAILED COPY) 21/Apri2020 INSTRUCTIONS FOR SERVICE (EMAILED COPY) ‘18/Apri2020 CERTIFIED MAIL SERVICE COMPLETED ON 16/Apr/2020 CERTIFIED MAIL SENT RETURN RECEIPT REQUESTED 46/Apr/2020 SUMMONS 10/Apr/2020 NOTICE OF HEARING 10/Apr/2020 “MOTION FOR EXCLUSIVE USE o7/Apri2020 INSTRUCTIONS FOR SERVICE 07/Apr12020 NOTICE OF SUBMISSION 07/Apr12020 © MUTUAL RESTRAINING ORDER 07/Apr!2020. © COMPLAINT FILED O7/Apr/2020 MARRIAGE TERMINATION NO CHILDREN Case Details ‘TO MOT FOR EXCLUSIVE USE OF MARITAL HOME W/CERT OF ‘SERVICE FILED BY ATTY L RAY JONES WICERT OF SERVICE FILED BY ATTY L RAY JONES WICERT OF SERVICE FILED BY ATTY L RAY JONES FILED BY ATTY L RAY JONES WICERT OF SERVICE RE: INCOME AND EXPENSE FORMS;PROPERTY AFFIDAVIT W/PROOF OF SERVICE-——-FAXED TO DR COURT BY ATTY MCARTOR RE: AFFIDAVIT OF INCOME AND EXPENSES FAXED TO DR COURT BY ATTY DAVID MCARTOR WI/PROOF OF SERVICE EMAILED TO DR COURT BY ATTY L RAY JONES WICERT OF SERVICE TO ADD THIRD PARTY DEFENDANT, REQUEST FOR RESTRAINING ORDER EMAILED TO DR COURT BY ATTY L RAY JONES W/CERT OF SERVICE TO MOTION FOR EXCLUSIVE USE OF MARITAL HOME EMAILED TO OR COURT BY ATTY L RAY JONES WICERT OF SERVICE EMAILED TO DR COURT BY ATTY L RAY JONES WICERT OF SERVICE RE: ATTY L RAY JONES ENTERS HIS APPEARANCE AS ATTORNEY OF RECORD FOR THE DEFENDANT EMAILED TO DR COURT BY ATTY L RAY JONES WICERT OF SERVICE ‘SERVE SRD PARTY DEFENDANT (SHERIFF SERVICE) EMAILED TO DR COURT BY ATTY L RAY JONES: DANIEL MORAN #4549 32; SIGNED BY GAIL FISHER ‘SUMMONS, CERTIFIED COPY OF COMPLAINT FOR DIVORCE, MUTUAL RESTRAINING ORDER, NOTICE OF SUBMISSION W/DOCUMENT, AND (1) NOTICE OF HEARING TO DANIEL MORAN #4543 32 DANIEL M MORAN UNCONTESTED OR CASE MANAGEMENT HEARING 7/2/2020 @ 9:00 AM - 9:30 AM BEFORE MAG. D. LUKE ROSS (HEARING WILL BE CONDUCTED TELEPHONICALLY) FILED BY ATTY DAVID MCARTOR WIPROOF OF SERVICE CSEA IV-D APPLICATION W/ PROOF OF SERVICE View eR EF FREE A I< is = RE Ee EFI FE Is Iz REI Is ls I= IS Is = No Document 172.16.1.2\/medct_epublicnodr_inDefault.aspx artackwent DOS 5/5, COPY SALARY NOTICE INSTRUCTOR'S LIMITED CONTRACT Tenure From: 07/01/2020 - 06/30/2021 April 28, 2020 KELLY MORAN 3812 Foskett Road Medina, OH 44256 Notice is hereby given to the employee named above of. salary change for services rendered to the Board of Education of the Medina County Joint Vocational School District for the school year 2020-2021. Rate per Day.. Rate per Pay... Available Extended Day: Available Extended Pay Professional Development D: Professional Development Pay Gap Pay. President, Board of Education Treasurer, Board of Education EXHIBIT Please signall three coptes, keep one for your files and return last two coples to tho Superintendent's office. 1101 West Liberty Street, Medina, OH 44256 | 330-725-8461 | 330-723-6573 (fax) | wenw.mcjvem ‘Wout Gatigy saree ConnectionCOPY i(- 6-J090 MEDINA COUNTY JVSD NO. _ 085553 “EMPLOYEE ID - “| JOB# T- < . " -000/2.75§\% 008/078 56.00 ex Feo: 00 So \ festa: 01 ‘TOTAL DEDUCTIONS 1,133.44 AN _ _NET PAY 1,969.51 Awourtt yf Soe Steck DAY 3 EXHIBIT —_E—COPY /I-LW20 From Fyne’ RY weymore since July Sick pay Sick pay Th | yew Hy Kelly has been getting her new pay raise amount for five months already Also my pension is ei- ther an asset or income if mcarter wants a pay- out then | need alimony since that takes my in-cory Nov 25, 2020, 14:47 Oech On nome Core Ce a Wed, Dec 16, 10:38 Gretel Nl oe MC EE cr re mele | ( She is bene d earning; pieced ae ene 4 BU ac benefit bathroom | ici being EVEL Rol Re eaves eae Nov 12, 2020, 16:48 attack moat “T 10COPY Preece: meee - maid receipt for easy reading ; ~ | still have all individual Receipts please advise “when you want me to Me Rtas) eee low the continuance Me-vale R@r-T ce) V0) Bodied i Breet dmagis- Meigs} i) EL ly right: texted ' Sorry mistext to my sis- mls Log back in® Court wants youto fi Everyone else has We (olececcromlamgurcle|tiie-1i-) | said he was giving you | ten minutes to log in Go to meeting .com This was not:on my cal- endar until 17 tiwill log in now Whatis the meeting ID , 233-490-429 Omg Medina didn't al- low the continuance WSyi Nike (r= mec reac etek fet . terrogatories may 2020 ol: (2) Nov 6 hearing... STRS Subpoe... Moran, Daniel... This is a combined Attachment T4COPY ' © Swdtnsrugeesies- ana Can ry charter te cept? Ha panda. Se tno pote io Rey ° \ ‘ . - ‘Wied, Jun 3, 2029 28 4201 PA J Fe thera herds ce naggenabey onan cer \ 111 cornice har to tum over fhe “other computer” wll ha drop fis exrbaerpl? \ . L. ‘She cannot find any other lndormetica concerriing the VA, by the wry. 4 ‘ pata ete Medeor, Auppadie, & CO: (0) 723-4019 , : CAUTION - CONFIDENTIAL MATERIAL , \ i ‘edinte rovessage io saomey Bede Or goed recpoecac to ceiver B } ‘Tha nboration Coe rae wocra, you ere rk tha nerd TESTES. ex copying of is \ | {ote nemned replat, you are hereby rotted D2 Fad by facerel ia, Te £7 SC 005, Ot Lidrim | Sr ba beg cota AS oa cc at YO 4 | fe jor } acted i Core te novo no Tr ofon wi reimburse you 8 posh : | i ie | —Orighal Message 3 { Shania Arnokd [maniscstsannoes fee 1 Bore Weare, e200 9 item \ i i \ I 1 ‘Tos David MeArtor ae SEER RE | ronnciscamt mt ones enh . copra ane a eae egret ae be anaemia - Aftactent TTCOPY Nov 5, 2020, 16:06 Hi! This is Carolyn Soeder. Remember to text or email me the hearing info! Take care of yourself:) “COMMON PLEAS COURT cHbAYt FER wont vis aie coe aeons 5° PHL IS Artachttent TLCOPY CAROLYN C. SOEDER CSOEDER@CORDELLLAW.COM LICENSED IN OHIO October 26, 2020 PERSONAL AND CONFIDENTIAL Via E-Mail Mr. Daniel Moran 3904 Fitchville River Road Wakeman, OH 44889 kdsmm2001@yahoo.com RE: Kelly A. Moran v. Daniel M. Moran Medina County Domestic Relations Court Case No: 20 DR 0135 Dear Dan: Welcome! I am glad that you have chosen to retain Cordell & Cordell: It was very nice to meet with you one on one today to discuss your case in more detail. As a reminder, please obtain your file from your previous attorney and get the file to my office. The best way to do this is by arranging for the file delivery through my Paralegal, Heather (216-278-7630; hearly@cordelllaw.com) or with our front desk (216-278-7620). I will be able to better discuss case strategy with you once I have your full file. The primary purpose of this correspondence is to get you more acquainted with our firm and policies. At Cordell & Cordell, we operate under a team approach. This means that I will occasionally a strategy conference with my direct manager, Jason Lasser. Additionally, I strategize with other associate attorneys in my office on a regular basis. Those associate attorneys are Robert Vizmeg, Carly Boyd and Oliver Herthneck. During a strategy conference we discuss what is going on in your case and strategize as to the best way to proceed. It is a good method of obtaining fresh ideas for your case- as they say, often two heads are better than one. These conferences are extremely beneficial to your case and often are the genesis of productive strategy for your case. For example, if there is a unique issue in your case that I have not encountered, there is a good chance that one of my colleagues has. By working together under a team approach, we can avoid “reinventing the wheel” on your case and ultimately, secure a better result for you.COPY From: Daniel Moran Sent: Monday, December 14, 2020 3:07 PM To: Heather Early ; Carolyn C Soeder < \cordelilaw.com> Subject: Re: Moran QDRO . there is not an outstanding balance on my account as | paid the balance this morning. | am still very concerned that the plaintiff / plaintiff counsel still has not reported the Plaintiffs: ‘plaintiffs'ct rent work contract 2020-2021 school year. as you know they reported last years contract. w-plaintiff to. fraudulently receive temporary spousal support! 2)Plaintiffs accrued sick pay 86.5 days X current contracted pay per day= $37,926 of unreported asset belonging to the plaintiff. 3)As | have said before pertaining to the STRS. | am already retired and with my health conditions will probably-not live long enough till plaintiff retires. therefore the PLOP NOT THE DOPO is what + you will argue for in court, since | am your client and that is my request! _ if the Judge doesn't agree, then | will just have to appeal to get a 50/50 non punitive legally acceptable result. plaintiff counsel to enter the trial phase of this divorce while allowing them to continue hiding it concerns me that the pretrial is in two days, and it appears to me that we are allowing the assets! is from my primary care VA Doctor, mandating the residence be remanded to me (the disabled veteran) as doctors orders! further protected by the vet disability protection act that no VA disability benefit (without minor children) can be awarded or encumbered by any court. that It. concerns, me that there are current documents showing the VA remodeled my residence for me, that haven't been turned in to the court except for Ray Jones multi branch motion! that document bathroom remodel is a veteran disability benefit. threatened to quit being my counsel if | filed evidence of those financial income and assets the It further bothers me that | had those evidence documents, ready to turn in to the court, but you plaintiff is hiding with the court! lam placing my trust and my financial future in yours and your firm's hands knowing your going to represent me professionally, and attain a non punitive legal 50/50 result. Ex2COPY RE: Moran QDRO From: Carolyn C Soeder (csoeder@cordelllaw.com) € To: kdsmm2001@yahoo.com Cc: hearly@cordelllaw.com Date: Monday, December 14, 2020, 04:30 PM EST ee Mr. Moran- Heather is correct regarding the payment to QDRO Group. From what | understand the Trial retainer, which is $5,000, was not paid. | note that the file reflects a payment by you, but my file also reflects an unpaid balance of $915.80, in addition to the Trial retainer not being paid which | referenced. | am sorry if this correspondence regarding your unpaid legal fees causes you stress. However, given the issue with the unpaid legal fees and the fact that we have Trial approaching very quickly with a lot of work to be done to prepare for Trial as second Counsel joining the case at the tail end, the firm must have confirmation that there will be adequate funds to continue representation. | will now answer your concerns in the manner in which you reported them, but first | must again express that if you feel the firm/myself is not adequately representing you, you should not continue the representation. You seem resistant to my legal advice when it isn’t in line with what you want, and my job is not just to tell you what you want to hear. As your advocate, the Ohio Rules of Professional Conduct advise me that | have a duty to use legal procedure for the fullest benefit of the client's cause, but also a duty not to abuse legal procedure. The law, both procedural and substantive, establishes the limits within which | can proceed as your advocate. When | give you advice that you don’t like, it is because there is a limit to what | can do and | am advising you within those limits. | encourage you to stop using “Plaintiff to refer to your Wife, and to start now in correcting yourself so that you