IN THE SUPREME COURT OF OHIO CASE NO. 2007-0758 TERESA L. ANGEL Plaintiff-Appellee, vs ERIC J. REED, et al. ON APPEAL FROM THE GEAUGA COUNTY COURT OF APPEALS ELEVENTH APPELLATE DISTRICT Court of Appeals Case No. C.A. 2005-G-2 669 Defendants/Appe I lants. APPELLANT ALLSTATE INSURANCE COMPANY'S MOTION FOR CONTINUANCE/RESCHEDULING OF ORAL ARGUMENT PERRIN I. SAH (0065090) PHILLIP C. KOSLA (0069086) WILLIAMS, MOLITERNO & SCULLY CO., L.P.A. 1200 Pinnacle Parkway Twinsburg, OH 44087-2367 (330) 405-5061/FAX (330) 405-5586 Email: psah@wmslawohio.com Email: pkosla@wmslawohio.com Attorneys for Appellant Allstate Insurance Company MARTIN S. DELAHUNTY, III (0039014) ELK & ELK CO., L.P.A. 6110 Parkland Blvd. Mayfield Heights, OH 44124 (440) 442-6677/FAX (440) 442-7944 Email: mdelahunty@elkandelk.coni Attorney for Plaintiff-Appellee Teresa L. Angel FRD JAN 3 12008 CLERK OF COURT ^ ^EME OURT OR 0M10
Now comes Appellant Allstate Insurance Company, by and through undersigned counsel, WILLIAMS, MOLITERNO & SCULLY CO., L.P.A., and hereby moves this Honorable Court for a continuance/rescheduling of the Oral Argument set in this matter on March 25, 2008, at 9:00 a.m. The basis of this motion is that lead counsel for the Appellant, the undersigned, Perrin I. Sah, Esq., will be on a previously scheduled vacation with his family in Orlando, Florida from March 23, 2008 through March 28, 2008. Arrangements have already been made including the purchase of airline tickets and hotel reservations. These arrangements were made made prior to the scheduling of the Oral Argument as shown in the attached Exhibit "A." Counsel for the Appellee has been contacted regarding this request and, by telephone consent given January 25, 2008, has advised that he has no objection to the continuance/rescheduling of Oral Argument and consents to same. Respectfully submitted, WILLIAMS, MOLITERNO & SCULLY CO., L.P.A. By: PERRIN I. SAH (0065090) PHILLIP C. KOSLA ( 0069086) Attorneys for Appellant Allstate Insurance Company 2241 Pinnacle Parkway Twinsburg, OH 44087-2357 (330) 405-5061/FAX ( 330) 405-5586 Email: psah wmslawohio.coni Email: pkosla@wmslawohio.com 2
CERTIFICATE OF SERVICE A true copy of the foregoing Appellant Allstate Insurance Company's Motion for Continuance/Rescheduling of Oral Argument was forwarded by regular U.S. mail, postage prepaid, on this 28' day of January 2008, to: Martin S. Delahunty III, Esq. 6110 Parkland Blvd. Mayfield Heights, Ohio 44124 Attorney for Plaintiff-Appellee WILLIAMS, MOLITERNO & SCULLY CO., L.P.A. By: PERRIN I. SAH (0065090) PHILLIP C. KOSLA (0069086) Attorneys for Appellant Allstate Insurance Company 3
ti)s://tickets.airlran.com/printltinerarv.asnx AirTran Airways Reservations Page 1 of 2 61irTranw receipt & itinerar y, N w A r e Thank you for choosing AirTran Airways. We will send you an email message containing your itinerary. To ensure you receive the message, you may wish to add confirmations@airtran.com to your address book. confirmation number: YCN7YN Booking date: Wed, Oct 03, 2007 Status: Confirmed Shorild our flight schedule change, we will notify you by email as early as possible. I Flight Details Departing: Sunday, March 23, 2008 Akron/Canton, OH (CAK) 8:00 AM, to Orlando, FL (MCO) 10:15 AM Flight 925 Class K Returning: Friday, March 28, 2008 Orlando, FL (MCO) 12:02 PM to Akron/Canton, OH (CAK) 2:17 PM Flight 207 Class K Passengers and Seat Assignments Passenger A+ Number CAK-MCO MCO-CAK Perrin Sah 12C 24C Carolyn Paschke 14C 25C Garrett Sah 12A 24A Mallory Sah 14A 25A Contact Information Emily Boxier eboxier@aaaakron.com 178 W STREETSBORO RD 440-564-8016 (Tel) HUDSON, OH 442362754 3306506727 (Alt) United States of America 440-564-8016 (Cell) 3306506537(Fax) 2'ricing Payments otal for 4 passengers full det il Payment via Credit Card Fare price: $1,272.56 Form of payment: Visa Taxes/fees: $178.64 Payment status: Confirmed Total price: $1,451.20 Payment amount: $1,451.20 erms and Conditions ire Restrictions ass K
tns'//tirlretc airrran I AirTran Airways Reservations Page 2 of 2 K class of service Coach Class Fare Ron-refundable Changes may be made through September 30, 2007, for a fee of $60 plus any applicable increase in fare. After this date, changes may be made for a fee of $75 plus any applicable increase in fare. Advance seat assignment is available for a small fee, or you may select your seats upon check-in at no cost. Reservations may be obtained or changed through an AirTran Airways Telephone Reservations Center for an additional $7.50 per person. Conditions of Contract: All AirTran Airways coach tickets are non-refundable and a $60 fee per person applies to any change made after purchase through September 30, 2007, plus any applicable increase in airfare. A $75 fee per person will apply to changes made after September 30, 2007, plus any applicable increase in airfare. Business class tickets (A and J fare classes only; not including promotional fares) are fully refundable and no fee applies to changes. Cancellations must be made at least one hour prior to departure or customer forfeils reservation and any monies paid against the reservation. This reservation is non-transferable - no name changes allowed. Baggage Policies: Familiarize yourself with our baggage Dolicies prior to your travel. iicket Counter Check-In Requirements 4irTran Airways recommends that passengers arrive at the airport 120 minutes prior to the scheduled departure of their flight. Due o security requirements, passengers and their baggage will not be accepted at the ticket counter less than 45 minutes prior to the >cheduled departure of their flight (some smaller airports may accept baggage up to 30 minutes prior to scheduled departure ime). 3ate Check-In Requirements.ustomers must present themselves at the flight departure gate no later than ten minutes prior to the scheduled departure of their light. Failure to comply will cause the customer to lose their reservation and, if so, they will not be eligible for denied boarding :ompensation.
Reservation Confinnation Page 1 of 5 Wall Disney Wor1A Congratulations Mr. PERRIN SAH! You have successfully booked your vacation package online. We thank you and look forward to making your vacation a mag'ical experience you'il never forget. Please print this page for your records and note the confirmation number. Your con8rma0on number is^ 78061487 Booked for Guest(s): Mr. PERRIN SAH Miss MALLORY SAH Mstr. GARRETT SAH Mrs. CAROLYBN PASCHKE By Travel Agency: AAA AKRON AUTO CLUB 178 W STREETSBORO ST 178 W STREETSBORO ST HUDSON, OHIO 44236 Itinerary Details Your confirmation number is: 78061487 Disney's Coronado Springs Resort Check in 03/23/2008 for 5 nights 2 Adults, 2 Children Room Type Standard View Special Rate Type AAA Magic Moments Rate Park Tickets: 5 Day Magic Your Way Ticket with Park Hopper Option Package Type Vacation Insurance Special Requests: Magic Your Way Package P!us Dining Selected Refrigerator Ground Transportation You have chosen Disney's Magical Expresst We still need your flight information in order to arrange Disney Magical Express pick-up and drop-off times. Payment Information Total $2,522.72 Insurance $133.90 Grand Total ips://secure.reservations.disney.go.com/ibcwdw/en US/ &amework/comnonents/nrncessf.npinp?naynp= t niznnn7