Stolz v. J & B Steel Erectors, Inc. et al
Plaintiff: Daniel Stolz
Defendant: Doe 1, D.A.G. Construction Co., Inc., Pendleton Construction Group, LLC, Messer Construction Co., Terracon Consultants, Inc., Triversity Construction Co., LLC, J & B Steel Erectors, Inc. and ABC Corporation
Case Number: 1:2014cv00044
Filed: January 14, 2014
Court: US District Court for the Southern District of Ohio
Office: Cincinnati Office
County: XX US, Outside State
Presiding Judge: Douglas R Cole
Nature of Suit: P.I.: Other
Cause of Action: 28:1332
Jury Demanded By: Both
Docket Report

This docket was last retrieved on March 17, 2020. A more recent docket listing may be available from PACER.

Date Filed Document Text
March 17, 2020 Filing 121 USCA Case Number 20-3291 for #119 Notice of Appeal filed by Daniel Stolz. (pb)
March 16, 2020 Filing 120 NOTICE by Defendant J & B Steel Erectors, Inc. OF WITHDRAWAL OF JORDAN T. STEINER AS CO-COUNSEL (Blandford, Colleen)
March 13, 2020 Filing 119 NOTICE OF APPEAL re #118 Order on Motion to Dismiss (Filing fee has been paid, receipt number 0648-7378478) by Plaintiff Daniel Stolz. Appeal Record due by 3/16/2020. (Day, Stephanie)
February 13, 2020 Opinion or Order Notation Order: Pursuant to the Opinion and Order (Doc. 118) entered today, Defendants' Joint Motion to Lift Stay and for Reconsideration of Decision Denying Defendants' Motions for Summary Judgment (Doc. 80) is denied as moot. SO ORDERED. Signed by Judge Douglas R. Cole on 2/13/20. (sct)
February 13, 2020 Opinion or Order Filing 118 ORDER granting #111 the Enrolled Sub-contractor Parties' Motion to Dismiss and dismissing with prejudice Stolz's claims against the Enrolled Subcontractor Parties. Signed by Judge Douglas R. Cole on 2/13/20. (sct)
February 5, 2020 Minute Entry for proceedings held before Judge Douglas R. Cole: On February 5, 2020, this Court held Oral Argument regarding Defendants' Joint Motion to Dismiss (ECF No. 111). Kristen Myers, Stephanie Day, and Caroline Drennen appeared for Plaintiff; Colleen Blandford and Jordan Steiner appeared for Defendant J&B Steel Erectors, Inc.; Susan Salyer appeared for Defendants Pendleton Construction Group, LLC, D.A.G. Construction Co., Inc., and Triversity Construction Co., LLC. The Court heard arguments of counsel and took the matters under advisement. Order to issue. (Court Reporter: Sue Lopreato-Official) (sct)
January 2, 2020 NOTICE of Hearing on Joint Motion to Dismiss #111 : Please be aware that oral argument is set for 2/5/2020 2:30 PM in Courtroom 2 - Cincinnati before Judge Douglas R. Cole. (ss)
December 31, 2019 Opinion or Order Filing 117 This cause comes before the Court on Plaintiff's Motion Requesting Oral Argument (ECF No. 115) regarding Defendants' Motions to Dismiss. For good cause shown, the Court GRANTS Plaintiff's Motion (ECF No. 115), and hereby SCHEDULES oral argument for February 5, 2020 at 2:30 p.m. The Court will file a Notice of Hearing following this Order. SO ORDERED. Signed by Judge Douglas R. Cole on 12/31/2019. (co)
December 11, 2019 Opinion or Order Filing 116 ORDER REASSIGNING CASE. Case reassigned to Judge Douglas R. Cole for all further proceedings. Signed by Chief Judge Algenon L. Marbley on 12/11/2019. (ss)(This document has been sent by regular mail to the party(ies) listed in the NEF that did not receive electronic notification.)
July 9, 2019 Filing 115 MOTION for Hearing re #114 Reply to Response to Motion, #113 Response in Opposition to Motion, #111 Joint MOTION to Dismiss by Plaintiff Daniel Stolz. (Day, Stephanie)
July 3, 2019 Filing 114 REPLY to Response to Motion re #111 Joint MOTION to Dismiss filed by Defendants D.A.G. Construction Co., Inc., J & B Steel Erectors, Inc., Pendleton Construction Group, LLC, Triversity Construction Co., LLC. (Blandford, Colleen)
June 20, 2019 Filing 113 RESPONSE in Opposition re #111 Joint MOTION to Dismiss filed by Plaintiff Daniel Stolz. (Myers, Kristen)
June 7, 2019 Filing 112 NOTICE of Appearance by Caroline M. Drennen for Plaintiff Daniel Stolz (Drennen, Caroline)
May 30, 2019 Filing 111 Joint MOTION to Dismiss by Defendants D.A.G. Construction Co., Inc., J & B Steel Erectors, Inc., Pendleton Construction Group, LLC, Triversity Construction Co., LLC. (Attachments: #1 Exhibit A - Stolz v. JB Steel Erector - Unofficially published opinion dated 5-21-14, #2 Exhibit B - Bertolino v Wheeling Pittsburgh Steel Corp - Case Law) (Blandford, Colleen)
May 30, 2019 Filing 110 NOTICE of Appearance by Jordan T. Steiner for Defendant J & B Steel Erectors, Inc. (Steiner, Jordan)
April 23, 2019 Filing 109 Judgment Entry from the Supreme Court of Ohio (Filed 12/20/18): This cause, here on the certification of a state-law question from the United States District Court for the Southern District of Ohio, Western Division, was considered in the the manner prescribed by law. Upon review pursuant to S.Ct.Prac.R. 9.08, the Court answers the certified state-law question in the negative, consistent with the opinion rendered herein. (sct)
April 22, 2019 Opinion or Order Minute Entry and Notation Order: This civil action came before the Court for a status conference by telephone on 4/22/19 at 11:00 a.m. Stephanie Day appeared on behalf of Plaintiff; Colleen Blandford appeared on behalf of Defendant J & B Steel Erectors, Inc.; Robert Hojnoski and Nate Lennon appeared on behalf of Defendant Terracon Consultants, Inc.; Susan Salyer appeared on behalf of Defendants Pendleton Construction Group, LLC, D.A.G. Constructoin Co., Inc., and TriVersity Construction Co., LLC. The stay is hereby LIFTED. Defendants J & B Steel, D.A.G., and TriVersity shall file motions directed to Plaintiff's United States Constitutional claim by 5/31/19. IT IS SO ORDERED. Signed by Judge Timothy S. Black on 4/24/2019. (rrs)
April 17, 2019 Filing 108 NOTICE of Appearance by Kristen Marie Myers for Plaintiff Daniel Stolz (Myers, Kristen)
April 12, 2019 Opinion or Order NOTATION ORDER: This civil action is set for a status conference by telephone on 4/22/2019 at 11:00 a.m. COUNSEL SHALL CALL: 1-888-684-8852; Access code: 8411435; Security code: 123456, and wait for the Court to join the conference. IT IS SO ORDERED. Signed by Judge Timothy S. Black on 4/12/19. (rrs)
September 18, 2017 Certified copy of #107 Amended Certification Order sent to the Ohio Supreme Court Clerk's Office via regular mail. (gs)
September 15, 2017 Opinion or Order Filing 107 AMENDED CERTIFICATION ORDER. Signed by Judge Timothy S. Black on 9/15/17. (gs)
September 5, 2017 Certified copies of #105 Order on Motion and #106 CERTIFICATION ORDER have been sent to the Ohio Supreme Court Clerk's office via regular mail. (sct)
August 23, 2017 Opinion or Order Filing 106 CERTIFICATION ORDER. Signed by Judge Timothy S. Black on 8/22/17. (gs)
August 23, 2017 Opinion or Order Filing 105 ORDER granting #94 Defendants J & B Steel Erectors, Inc., D.A.G. Construction Co., Inc., and Triversity Construction Co., LLC's Motion to Certify a Question of State Law to the Supreme Court of Ohio. Signed by Judge Timothy S. Black on 8/22/17. (gs)
June 7, 2017 Filing 104 NOTICE of Change of Address by Stephanie M Day (Day, Stephanie)
May 26, 2017 Filing 103 NOTICE by Plaintiff Daniel Stolz Notice of Withdrawal (Rust, Katlin)
May 8, 2017 Filing 102 REPLY to Response to Motion re #94 Joint MOTION for Order to Certify Question of State Law to the Ohio Supreme Court filed by Defendant Messer Construction Co.. (Wagner, Jared)
April 24, 2017 Filing 101 Response re #99 Brief in Support of Certification by Plaintiff Daniel Stolz. (Rust, Katlin)
April 12, 2017 NOTATION ORDER: This case is before the Court regarding Plaintiffs motion for leave to file a response to the amicus brief filed by Messer Construction Co. concerning the pending motion to certify a question of state law. (Doc. #100 ). For good cause shown, that motion (Doc. #100 ) is granted. Plaintiff shall file his response on or before 4/24/17. IT IS SO ORDERED. (ss)
April 12, 2017 Filing 100 MOTION for Leave to File Response to Messer Construction Co.'s Amicus Curiae Brief in Support of Certification by Plaintiff Daniel Stolz. (Rust, Katlin)
April 7, 2017 Filing 99 BRIEF re #94 Joint MOTION for Order to Certify Question of State Law to the Ohio Supreme Court by Amicus Messer Construction Co.. (Wagner, Jared)
April 7, 2017 Notation Order: This matter is before the Court regarding Messer Construction Co.s motion for leave to appear as amicus curiae. (Doc. 98). For good cause shown, that motion (Doc. 98) is GRANTED. Messer Construction Co. shall file its amicus curiae brief separately into the record. IT IS SO ORDERED. (ss)
April 6, 2017 Filing 98 MOTION for Leave to Appear amicus curiae by Defendant Messer Construction Co.. (Attachments: #1 Exhibit A - Amicus Curiae Brief) (Wagner, Jared)
March 16, 2017 Filing 97 REPLY to Response to Motion re #94 Joint MOTION for Order to Certify Question of State Law to the Ohio Supreme Court filed by Defendants D.A.G. Construction Co., Inc., J & B Steel Erectors, Inc., Triversity Construction Co., LLC. (Blandford, Colleen)
March 16, 2017 Notice of Correction re: #96 Response to Motion, This document was filed incorrectly. Counsel was notified and will refile using Civil Events Motions and Related Filings Responses and RepliesReply to Response to Motion. Clerk restricted #96 to court users only. (jlw)
March 16, 2017 Filing 96 *DISREGARD THIS ENTRY IT WAS FILED IN ERROR* RESPONSE to Motion re #94 Joint MOTION for Order to Certify Question of State Law to the Ohio Supreme Court - Joint Reply in Support of Joint Motion filed by Defendants D.A.G. Construction Co., Inc., J & B Steel Erectors, Inc., Triversity Construction Co., LLC. (Blandford, Colleen) Modified to restrict entry to court users only on 3/16/2017 (jlw).
March 2, 2017 Filing 95 RESPONSE in Opposition re #94 Joint MOTION for Order to Certify Question of State Law to the Ohio Supreme Court filed by Plaintiff Daniel Stolz. (Rust, Katlin)
February 9, 2017 Filing 94 Joint MOTION for Order to Certify Question of State Law to the Ohio Supreme Court by Defendants D.A.G. Construction Co., Inc., J & B Steel Erectors, Inc., Pendleton Construction Group, LLC, Triversity Construction Co., LLC. (Blandford, Colleen)
February 9, 2017 Minute Entry: This civil action came before the Court for a status conference by telephone on 2/9/17 at 3:30 p.m. Attorneys Stephanie Day, Katlin Rust, Colleen Blandford, Bob Hojnoski, Susan Salyer, and Stephen Yeager participated. Moving Defendants will file their motion forthwith. (mr)
February 3, 2017 Opinion or Order NOTATION ORDER: A telephone status conference shall be held in this civil action on 2/9/2017 at 3:30 p.m. COUNSEL SHALL CALL: 1-888-684-8852; Access code: 8411435; Security code: 123456, and wait for the Court to join the conference. IT IS SO ORDERED by Judge Timothy S. Black on 2/3/2017. (mr)
November 21, 2016 Filing 93 ANSWER to #90 Amended Complaint,, filed by D.A.G. Construction Co., Inc., Pendleton Construction Group, LLC, Triversity Construction Co., LLC. (Yeager, Stephen)
November 18, 2016 Filing 92 ANSWER to #90 Amended Complaint,, filed by Terracon Consultants, Inc.. (Hojnoski, Robert)
November 18, 2016 Filing 91 ANSWER to #90 Amended Complaint,, filed by J & B Steel Erectors, Inc.. (Blandford, Colleen)
November 4, 2016 Filing 90 SECOND AMENDED COMPLAINT WITH JURY DEMAND against D.A.G. Construction Co., Inc., J & B Steel Erectors, Inc., Pendleton Construction Group, LLC, Terracon Consultants, Inc., Triversity Construction Co., LLC, filed by Daniel Stolz. (mr) (mr). Modified entry to note that Counsel contacted Chambers, concerned about the lack of date in the Certificate of Service on the docketed second amended complaint. On 11/10/16, counsel provided a dated second amended complaint that has been now been uploaded in entry 90. A NEF has been regenerated. No further action is required. on 11/10/2016 (mr).
November 4, 2016 Opinion or Order Filing 89 ORDER GRANTING PLAINTIFF'S MOTION TO FILE SECOND AMENDED COMPLAINT (Doc. #81 ) ANDTAKING DEFENDANTS' MOTION FOR RECONSIDERATION (Doc. #80 ) UNDER ADVISEMENT. Signed by Judge Timothy S. Black on 11/4/2016. (mr)
July 29, 2016 Filing 88 REPLY to Response to Motion re #81 MOTION to Amend/Correct #49 Amended Complaint File Second Amended Complaint MOTION re #75 Order Staying Case Lift Stay filed by Plaintiff Daniel Stolz. (Day, Stephanie)
July 15, 2016 Filing 87 RESPONSE in Opposition re #81 MOTION to Amend/Correct #49 Amended Complaint File Second Amended Complaint MOTION re #75 Order Staying Case Lift Stay DEFENDANTS D.A.G. CONSTRUCTION CO., INC., TRIVERSITY CONSTRUCTION CO., LLC, AND PENDLETON CONSTRUCTION GROUP, LLC'S MEMORANDUM IN OPPOSITION TO PLAINTIFF'S MOTION TO FILE SECOND AMENDED COMPLAINT filed by Defendants D.A.G. Construction Co., Inc., Pendleton Construction Group, LLC, Triversity Construction Co., LLC. (Salyer, Susan)
July 15, 2016 Filing 86 NOTICE of Appearance by Susan Salyer for Defendants D.A.G. Construction Co., Inc., Pendleton Construction Group, LLC, Triversity Construction Co., LLC (Salyer, Susan)
July 15, 2016 Filing 85 RESPONSE to Motion re #80 Joint MOTION TO LIFT STAY AND FOR RECONSIDERATION OF DECISION DENYING DEFENDANTS' MOTIONS FOR SUMMARY JUDGMENT re #75 Order Staying Case Joint Reply In Support of Motion to Lift Stay and for Reconsideration of Decision Denying Defendants' Motions For Summary Judgment filed by Defendant J & B Steel Erectors, Inc.. (Blandford, Colleen)
July 15, 2016 Filing 84 RESPONSE in Opposition re #81 MOTION to Amend/Correct #49 Amended Complaint File Second Amended Complaint MOTION re #75 Order Staying Case Lift Stay filed by Defendant J & B Steel Erectors, Inc.. (Blandford, Colleen)
June 30, 2016 Filing 83 RESPONSE in Opposition re #80 Joint MOTION TO LIFT STAY AND FOR RECONSIDERATION OF DECISION DENYING DEFENDANTS' MOTIONS FOR SUMMARY JUDGMENT re #75 Order Staying Case filed by Plaintiff Daniel Stolz. (Rust, Katlin)
June 23, 2016 Set Deadlines per 6/23/16 Notation Order: Responses due by 7/1/2016, Replies due by 7/15/2016 re #80 Joint MOTION TO LIFT STAY AND FOR RECONSIDERATION OF DECISION DENYING DEFENDANTS' MOTIONS FOR SUMMARY JUDGMENT. (eh)
June 23, 2016 Opinion or Order Notation Order: This civil action is before the Court on Plaintiffs motion to stay briefing with respect to the Subcontractor Defendants motion for reconsideration (Doc. #80 ), or, in the alternative, for an extension of time to respond to that motion. (Doc. #82 ). It is well established that the Court has the inherent authority to manage its docket. See Link v. Wabash, 370 U.S. 626, 630-31 (1962). Notwithstanding Plaintiffs argument to the contrary, the Court finds that simultaneous briefing of Subcontractor Defendants motion for reconsideration (Doc. #80 ) and Plaintiffs recently-filed motion for leave to amend the complaint (Doc. #81 ) is appropriate. Nonetheless, the Court also finds that Plaintiff has demonstrated good cause for an extension of time to respond to the Subcontractor Defendants motion. Accordingly, for the foregoing reasons, Plaintiffs motion (Doc. #82 ) is GRANTED IN PART and DENIED IN PART as follows: Plaintiffs request for a stay of briefing on Subcontractor Defendants' motion for reconsideration (Doc. #80 ) is DENIED; Plaintiffs request for an extension of time to respond to that motion is GRANTED. Plaintiff shall file his response to Defendants motion for reconsideration (Doc. #80 ) on or before 7/1/16; Defendants shall file their reply on or before 7/15/16. The Court will not rule on Defendants motion for reconsideration (Doc. #80 ) or Plaintiffs motion for leave to amend (Doc. #81 ) until both have been fully briefed. IT IS SO ORDERED. Signed by Judge Timothy S. Black on 6/23/16. (eh)
June 23, 2016 Filing 82 MOTION to Stay re #80 Joint MOTION TO LIFT STAY AND FOR RECONSIDERATION OF DECISION DENYING DEFENDANTS' MOTIONS FOR SUMMARY JUDGMENT re #75 Order Staying Case , MOTION for Reconsideration re #81 MOTION to Amend/Correct #49 Amended Complaint File Second Amended Complaint MOTION re #75 Order Staying Case Lift Stay ( Responses due by 7/18/2016) by Plaintiff Daniel Stolz. (Attachments: #1 Exhibit A - Proposed Order) (Rust, Katlin)
June 21, 2016 Filing 81 MOTION to Amend/Correct #49 Amended Complaint File Second Amended Complaint, MOTION re #75 Order Staying Case Lift Stay ( Responses due by 7/15/2016) by Plaintiff Daniel Stolz. (Attachments: #1 Exhibit A - Second Amended Complaint) (Rust, Katlin)
June 13, 2016 Opinion or Order NOTATION ORDER: This civil action is before the Court on the motion of Defendants J&B Steel Erectors, Inc., D.A.G. Construction Co., Inc., and Triversity Construction Co., L.L.C. ("Subcontractor Defendants") to lift the stay and for reconsideration of the Court's earlier decision denying the Subcontractor Defendants' motions for summary judgment. (Doc. #80 ). The Court sua sponte expedites briefing. Responses in opposition are now due on or before 6/24/16; replies, if any, are now due on or before 7/1/16. IT IS SO ORDERED by Judge Timothy S. Black on 6/13/2016. (mr)
June 10, 2016 Filing 80 Joint MOTION TO LIFT STAY AND FOR RECONSIDERATION OF DECISION DENYING DEFENDANTS' MOTIONS FOR SUMMARY JUDGMENT re #75 Order Staying Case by Defendant J & B Steel Erectors, Inc.. Responses due by 7/5/2016 (Blandford, Colleen)
May 27, 2016 Filing 79 Judgment Entry from the Supreme Court of Ohio: This cause, here on the certification of the state law question from the U.S. District Court for the Southern District of Ohio, Western Division, was considered in the the manner prescribed by law. Upon consideration thereof, the Court answers the certified state-law question in the affirmative, consistent with the opinion rendered herein. (sct)
August 6, 2015 Filing 78 NOTICE by Defendant J & B Steel Erectors, Inc. of Withdrawal of Co-Counsel (Pramaggiore, Kimberly)
August 5, 2015 Filing 77 NOTICE of Appearance by Colleen Marie Blandford for Defendant J & B Steel Erectors, Inc. (Blandford, Colleen)
April 22, 2015 Filing 76 ACKNOWLEDGMENT OF SERVICE Executed via Certified Mail upon Supreme Court of Ohio as to #73 ORDER GRANTING MOTION TO CERTIFY A QUESTION OF STATE LAW TO THE SUPREME COURT OF OHIO and #74 CERTIFICATION ORDER. (eh)
April 15, 2015 NOTICE: Certified copies of #73 ORDER GRANTING DEFENDANTS J & B STEEL ERECTORS, INC., D.A.G. CONSTRUCTION CO., INC., AND TRIVERSITY CONSTRUCTION CO., LLC'S MOTION TO CERTIFY A QUESTION OF STATE LAW TO THE SUPREME COURT OF OHIO and #74 CERTIFICATION ORDER have been sent to the Ohio Supreme Court Clerk's office via certified mail by the Clerk's office. (Article # 70140510000083622421.) (mr)
April 15, 2015 Opinion or Order Filing 75 ORDER STAYING CASE - This case is STAYED pending resolution of the certified question by the Supreme Court of Ohio. Signed by Judge Timothy S. Black on 4/15/2015. (mr)
April 13, 2015 Opinion or Order Filing 74 CERTIFICATION ORDER. Signed by Judge Timothy S. Black on 4/13/2015. (mr1)
April 13, 2015 Opinion or Order Filing 73 ORDER GRANTING DEFENDANTS J & B STEEL ERECTORS, INC., D.A.G. CONSTRUCTION CO., INC., AND TRIVERSITY CONSTRUCTION CO., LLC'S MOTION TO CERTIFY A QUESTION OF STATE LAW TO THE SUPREME COURT OF OHIO (Doc. 70). Signed by Judge Timothy S. Black on 4/13/2015. (mr1)
March 2, 2015 Filing 72 REPLY to Response to Motion re #70 Joint MOTION for Order to Certify Question of State Law to the Ohio Supreme Court, or, in the Alternative, to Certify Order to the United States Court of Appeals for the Sixth Circuit J & B Steel Erectors, Inc.'s, D.A.G. Construction Co., Inc.'s and TriVersity Construction Co., LLC' Joint Reply in Support of their Motion to Certify Question of State Law to the Ohio Supreme Court, or, in the Alternative, to Certify Order to the United States Court of Appeals for the Sixth Circuit filed by Defendants D.A.G. Construction Co., Inc., J & B Steel Erectors, Inc., Triversity Construction Co., LLC. (Pramaggiore, Kimberly)
February 23, 2015 Filing 71 RESPONSE in Opposition re #70 Joint MOTION for Order to Certify Question of State Law to the Ohio Supreme Court, or, in the Alternative, to Certify Order to the United States Court of Appeals for the Sixth Circuit filed by Plaintiff Daniel Stolz. (Day, Stephanie)
February 9, 2015 Opinion or Order NOTATION ORDER: This civil action is before the Court on Defendants J&B Steel Erectors, Inc., D.A.G. Construction Co., and Triversity Construction Co., LLC's motion to certify a question to the Ohio Supreme Court or, in the alternative, to certify its Order to the Sixth Circuit Court of Appeals (Doc. #70 ). The Court sua sponte expedites briefing. Memoranda in opposition are now due on or before 2/23/15; replies, if any, are now due on or before 3/2/15. The status conference by telephone set for 2/23/15 is hereby VACATED. IT IS SO ORDERED by Judge Timothy S. Black on 2/9/2015. (mr1)
February 6, 2015 Filing 70 Joint MOTION for Order to Certify Question of State Law to the Ohio Supreme Court, or, in the Alternative, to Certify Order to the United States Court of Appeals for the Sixth Circuit by Defendants D.A.G. Construction Co., Inc., J & B Steel Erectors, Inc., Pendleton Construction Group, LLC, Triversity Construction Co., LLC. (Pramaggiore, Kimberly)
January 26, 2015 Opinion or Order Filing 69 *** VACATED per Order Staying Case (Doc. #75 ) *** CALENDAR ORDER: Motions to amend the pleadings and add additional parties:January 30, 2015. Status conference by telephone: February 23, 2015 at 11:30 a.m. Plaintiff's Disclosure of Lay Witnesses: June 1, 2015. Defendants' Disclosure of Lay Witnesses: August 3, 2015. Plaintiff's Disclosure of Expert Witnesses: September 1, 2015. Defendants' Disclosure of Expert Witnesses: December 1, 2015. Status conference by telephone: December 2, 2015 at 10:00 a.m.Disclosure of Rebuttal Experts:February 1, 2016. Discovery cut-off: March 1, 2016. Dispositive Motion Deadline: April 11, 2016. Final pretrial conference in Cincinnati Chambers, Room 815: August 15, 2016 at 10:00 a.m. Jury Trial in Cincinnati: August 22, 2016 at 9:00 a.m. Signed by Judge Timothy S. Black on 1/26/2015. (mr1) Modified entry language to update status on 8/4/2015 (mr).
December 31, 2014 Opinion or Order Filing 68 ORDER GRANTING DEFENDANT MESSER CONSTRUCTION CO'S #14 MOTION FOR SUMMARY JUDGMENT AND DENYING THE ( #37 & #40 ) MOTIONS FOR SUMMARY JUDGMENT OF DEFENDANTS D.A.G. CONSTRUCTION CO., INC., TRIVERSITY CONSTRUCTION CO., LLC, AND J & B STEEL ERECTORS, INC. The remaining parties shall jointly submit a proposed litigation calendar by 1/23/2015. Signed by Judge Timothy S. Black on 12/31/14. (eh1) Modified on 12/31/2014 (eh1).
December 1, 2014 Filing 67 ANSWER to #49 Amended Complaint filed by Terracon Consultants, Inc.. (Lennon, Nathan)
November 21, 2014 Filing 66 REPLY to Response to Motion re #37 MOTION for Summary Judgment on Plaintiff's Negligence and Punitive Damages (Workers' Compensation Immunity and Election of Remedies) filed by Defendants D.A.G. Construction Co., Inc., Triversity Construction Co., LLC. (Attachments: #1 Affidavit of Dale White (Exhibit 1), #2 Wrap Up Insurance Manual (Exhibit 2)) (Patsfall, Stephen) Modified text for clarity on 11/24/2014 (mr1).
November 21, 2014 Filing 65 REPLY to Response to Motion re #40 MOTION for Summary Judgment Reply in Support of its Motion for Summary Judgment filed by Defendant J & B Steel Erectors, Inc.. (Pramaggiore, Kimberly)
November 18, 2014 Opinion or Order Filing 64 ORDER DENYING DEFENDANT TERRACON CONSULTANTS, INC.'S MOTION TO DISMISS (Doc. #52 ). Signed by Judge Timothy S. Black on 11/18/2014. (mr1)
November 3, 2014 Filing 63 RESPONSE in Opposition re #37 MOTION for Summary Judgment on Plaintiff's Negligence and Punitive Damages (Workers' Compensation Immunity and Election of Remedies), #40 MOTION for Summary Judgment filed by Plaintiff Daniel Stolz. (Attachments: #1 Exhibit A, #2 Exhibit B) (Day, Stephanie)
November 3, 2014 Filing 62 NOTICE of Filing Discovery Responses of Defendants, J&B Steel, D.A.G. & Triversity re: #63 RESPONSE in Opposition re Motions for Summary Judgment #37 , #40 by Plaintiff Daniel Stolz (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3) (Day, Stephanie) Modified to create links and edit text on 11/4/2014 (mr1).
October 20, 2014 Filing 61 REPLY to Response to Motion re #14 MOTION for Summary Judgment filed by Defendant Messer Construction Co.. (Attachments: #1 Exhibit Transcript of Angela Guenther) (Wagner, Jared)
October 17, 2014 Filing 60 REPLY to Response to Motion re #52 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Defendant Terracon Consultants, Inc.. (Hojnoski, Robert)
October 3, 2014 Filing 59 RESPONSE in Opposition re #52 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM filed by Plaintiff Daniel Stolz. (Day, Stephanie)
September 30, 2014 Filing 58 AMENDED ANSWER with Jury Deman to #49 Amended Complaint filed by Messer Construction Co.. (Wagner, Jared) Modified docket text on 10/1/2014 (eh).
September 30, 2014 Filing 57 NOTICE OF FILING DEPOSITION of Sandra Meyer by Plaintiff Daniel Stolz. (Attachments: #1 Exhibit Deposition of Sandra Meyer, #2 Exhibit Attachment to Deposition of Sandra Meyer) (Day, Stephanie)
September 30, 2014 Filing 56 RESPONSE in Opposition re #14 MOTION for Summary Judgment filed by Plaintiff Daniel Stolz. (Day, Stephanie)
September 16, 2014 Filing 55 ANSWER OF DEFENDANTS PENDLETON CONSTRUCTION GROUP, LLC, D.A.G. CONSTRUCTION CO., INC. AND TRIVERSITY CONSTRUCTION CO., LLC TO PLAINTIFF'S FIRST AMENDED COMPLAINT JURY DEMANDED ANSWER to #49 Amended Complaint filed by Pendleton Construction Group, LLC. (Patsfall, Stephen)
September 15, 2014 Filing 54 Witness List by Defendant J & B Steel Erectors, Inc.. (Pramaggiore, Kimberly)
September 15, 2014 Filing 53 Witness List by Defendant Messer Construction Co.. (Lynch, Jane)
September 15, 2014 Filing 52 MOTION TO DISMISS FOR FAILURE TO STATE A CLAIM by Defendant Terracon Consultants, Inc.. (Hojnoski, Robert)
September 10, 2014 Filing 51 ANSWER to #49 Amended Complaint filed by J & B Steel Erectors, Inc.. (Pramaggiore, Kimberly)
September 10, 2014 Filing 50 ANSWER to #49 Amended Complaint Answer of Defendant Messer Construction Co. to Plaintiff's First Amended Complaint with Jury Demand Endorsed Hereon filed by Messer Construction Co.. (Lynch, Jane)
September 2, 2014 Filing 49 AMENDED COMPLAINT against All Defendants, filed by Daniel Stolz. (Goodson, Brett)
September 2, 2014 Notice of Correction re: 48 Amended Document. This pleading will need to be refiled using the appropriate civil event for an Amended Complaint (Civil Events/ Initial Pleadings and Service/Complaints and Other Initiating Documents) or by using "Search" function with Amended Complaint for the correct link. Counsel has been contacted. The pleading at 48 will be restricted. Thank you. (mr1)
September 2, 2014 Filing 47 Lay Witness List by Defendant J & B Steel Erectors, Inc.. (Pramaggiore, Kimberly) Modified on 9/3/2014 (eh1).
August 29, 2014 Opinion or Order NOTATION ORDER: This civil action is before the Court on Defendant Terracon Consultants, Inc.'s motion for judgment on the pleadings (Doc. #36 ) and Plaintiff's unopposed motion to amend the complaint (Doc. #43 ). For good cause shown, Plaintiff's motion to amend (Doc. #43 ) is GRANTED. Plaintiff shall file his amended complaint forthwith. Because the amended complaint will supersede the original complaint, and because Defendant Terracon Consultants's motion for judgment on the pleadings is directed to the original complaint, the motion for judgment on the pleadings (Doc. #36 ) is DENIED without prejudice as MOOT. See Perkins v. Sun Chemical Corp., No. 1:10cv810, 2011 WL 1403069, at *2 (S.D. Ohio Apr. 12, 2011). IT IS SO ORDERED by Judge Timothy S. Black on 8/29/2014. (mr1) Modified on 8/29/2014 (mr1).
August 28, 2014 Notice of Correction re: 45 MOTION for Disclosure OF LAY WITNESSES ON THE WORKERS' COMPENSATION IMMUNITY ISSUE, 46 Notice (Other). Counsel be aware that Doc. 45 is not a motion, and the motion event has been terminated. When filing lay witness disclosures, please consider using "Search" in the blue band and text in 'witness list' so the appropriate option will present or use Civil Events/Other Filings/Trial Documents/Witness List for docketing. No further action is required. (mr1)
August 28, 2014 Filing 44 Witness List by Defendant Messer Construction Co.. (Lynch, Jane)
August 28, 2014 Filing 43 First MOTION to Amend/Correct #1 Complaint by Plaintiff Daniel Stolz. (Attachments: #1 Exhibit First Amended Complaint) (Goodson, Brett)
August 28, 2014 Filing 42 RESPONSE in Opposition re #36 MOTION for Judgment on the Pleadings filed by Plaintiff Daniel Stolz. (Attachments: #1 Exhibit First Amended Complaint) (Goodson, Brett)
July 17, 2014 Filing 41 NOTICE of Appearance by Nathan Andrew Lennon for Defendant Terracon Consultants, Inc. (Lennon, Nathan)
July 16, 2014 Filing 40 MOTION for Summary Judgment by Defendant J & B Steel Erectors, Inc.. Responses due by 11/3/2014 (Attachments: #1 Exhibit A - Affidavit of Angela Guenther in Support of Defendant Messer Construction Co.'s Motion for Summary Judgment, #2 Exhibit B - Proposed Undisputed Facts, #3 Exhibit C - Entry Granting Summary Judgment in Favor of Defendants D.A.G. Construction Company, Inc., J&B Steel Erectors, Inc., and Triversity Construction Company, LLC) (Pramaggiore, Kimberly) Modified to correct response date in accordance with the Order Doc #35 on 8/29/2014 (mr1).
July 16, 2014 Opinion or Order NOTATION ORDER: This civil action is before the Court on Plaintiff's Motion for Extension of Time to Response to Defendant Terracon Consultants' Motion for Judgment on the Pleadings (Doc. #39 ). As it is unopposed and for good cause shown, this motion is hereby GRANTED. Plaintiff shall file his memorandum in opposition on or before 8/29/14. IT IS SO ORDERED by Judge Timothy S. Black on 7/16/2014. (mr1)
July 16, 2014 Filing 39 MOTION for Extension of Time to File Response/Reply as to #36 MOTION for Judgment on the Pleadings New date requested 8/29/2014. by Plaintiff Daniel Stolz. (Day, Stephanie)
July 10, 2014 Filing 38 NOTICE by Defendant D.A.G. Construction Co., Inc. and Triversity Construction Co., LLC re #37 MOTION for Summary Judgment on Plaintiff's Negligence and Punitive Damages (Workers' Compensation Immunity and Election of Remedies) (Attachments: #1 Exhibit Exhibit "A" to Motion for Summary Judgment Doc. No. 37) (Yeager, Stephen) Modified to add additional filer on 7/11/2014 (sct1).
July 10, 2014 Filing 37 MOTION for Summary Judgment on Plaintiff's Negligence and Punitive Damages (Workers' Compensation Immunity and Election of Remedies) by Defendant D.A.G. Construction Co., Inc. and Triversity Construction Co., LLC. Responses due by 11/3/14 (Yeager, Stephen) Modified to add additional filer details on 7/11/2014 (sct1). Modified text to update response date per Calendar Order #35 on 7/15/2014 (mr1).
July 7, 2014 Filing 36 MOTION for Judgment on the Pleadings by Defendant Terracon Consultants, Inc.. Responses due by 7/31/2014 (Hojnoski, Robert)
June 24, 2014 Opinion or Order Filing 35 CALENDAR ORDER: Motions directed to the pleadings: 7/7/14. J&B Steel, D.A.G., and Triversity dispositive motion briefing schedule: Motion: 7/16/14; Response: 11/3/14; Reply: 11/24/14. Disclosure of lay witnesses re: WC issue: 9/1/14. Disclosure of expert witnesses re: WC issue: 9/15/14. Discovery deadline as to Messer re: WC issue: 9/15/14. Messer dispositive motion briefing schedule: Response: 10/1/14; Reply: 10/20/14. Pendleton dispositive motion briefing schedule: Motion: 10/1/14; Response: 1/19/15; Reply: 2/9/15. Discovery deadline as to as to J&B Steel, D.A.G., and Triversity re: WC issue: 10/14/14. Discovery deadline as to Pendleton re: WC issue: 12/30/14. Motions to amend the pleadings and add additional parties: 30 days after the Court rules on the issue of workers compensation immunity. Status conference by telephone: 2/23/15 at 11:30 a.m. Signed by Judge Timothy S. Black on 6/24/2014. (mr1)
June 24, 2014 Minute Entry: This civil action came on before the Court for a preliminary pretrial conference by telephone on 6/24/14 at 10:00 a.m. Attorneys Brett Goodson, Stephanie Day, Kimberly Pramaggiore, Jane Lynch, Robert Hojnoski, and Stephen Patsfall participated. A calendar order will issue by separate entry. (mr1)
June 16, 2014 NOTICE of Hearing: The Preliminary Pretrial Conference by telephone set 6/18/2014 is VACATED and RESCHEDULED for 6/24/2014 at 10:00 a.m. before Judge Timothy S. Black. COUNSEL SHALL CALL: 1-888-684-8852; Access code: 8411435; Security code: 123456, and wait for the Court to join the conference. (mr1)
June 16, 2014 NOTICE of Hearing: The Preliminary Pretrial Conference by telephone set for 6/16/2014 is VACATED and RESCHEDULED for 6/18/2014 at 1:30 p.m. before Judge Timothy S. Black. COUNSEL SHALL CALL: 1-888-684-8852; Access code: 8411435; Security code: 123456, and wait for the Court to join the conference. (mr1)
June 9, 2014 Filing 34 RULE 26(f) REPORT OF THE PARTIES by Defendant Messer Construction Co.. (Wagner, Jared)
May 21, 2014 NOTICE of Hearing: A Preliminary Pretrial Conference is set before Judge Timothy S. Black for 6/16/2014 at 12:30 p.m. Counsel shall call 1-888-684-8852; Access code: 8411435; Security code: 123456, and wait for the Court to join the conference. Before the pretrial conference counsel must comply with the MANDATORY, pre-preliminary pretrial conference between counsel, required by Fed.R.Civ.P. 26(f). THE REPORT MUST BE FILED 7 DAYS PRIOR TO THE PRELIMINARY PRETRIAL CONFERENCE. Pretrial procedures and forms can be found at our website at www.ohsd.uscourts.gov. (mr1)
May 21, 2014 Opinion or Order Filing 33 ORDER GRANTING MESSER CONSTRUCTION COMPANY'S MOTION FOR JUDGMENT ON THE PLEADINGS ON THE EMPLOYER INTENTIONAL TORT AND PUNITIVE DAMAGES CLAIMS (Doc. #13 ). Signed by Judge Timothy S. Black on 5/21/2014. (mr1)
March 28, 2014 Filing 32 REPLY to Response to Motion re #13 MOTION for Judgment on the Pleadings as to Plaintiff's Employer Intentional Tort and Punitive Damages Claims filed by Defendant Messer Construction Co.. (Lynch, Jane) Modified docket text on 3/31/2014 (eh1).
March 14, 2014 Filing 31 RESPONSE in Opposition re #13 MOTION for Judgment on the Pleadings filed by Plaintiff Daniel Stolz. (Goodson, Brett)
March 14, 2014 Opinion or Order Filing 30 ORDER GRANTING PLAINTIFF'S MOTION TO EXTEND TIME TO RESPOND TO DEFENDANT MESSER CONSTRUCTION COMPANYS MOTION FOR SUMMARY JUDGMENT PURSUANT TO RULE 56(d) (Doc. #22 ). Briefing on Defendant Messer Construction Companys Motion for Summary Judgment (Doc. #14 ) is STAYED and a briefing schedule will be established along with the rest of the litigation calendar at the Preliminary Pretrial Conference. Signed by Judge Timothy S. Black on 3/14/2014. (mr1)
March 10, 2014 Filing 29 REPLY to Response to Motion re #22 MOTION for Extension of Time to File Response/Reply as to #14 MOTION for Summary Judgment , #13 MOTION for Judgment on the Pleadings New date requested 3/17/2014. filed by Plaintiff Daniel Stolz. (Goodson, Brett)
March 4, 2014 Filing 28 Corporate Disclosure Statement by Defendant Terracon Consultants, Inc.. (Hojnoski, Robert)
March 4, 2014 Filing 27 ANSWER to #1 Complaint filed by Terracon Consultants, Inc.. (Hojnoski, Robert)
March 4, 2014 Opinion or Order NOTATION ORDER: This civil action is before the Court on Plaintiff's Motion to Extend Time to Respond to Defendant Messer Construction Company's Motion for Summary Judgment and Judgment on the Pleadings Pursuant to Rule 56(d) with Affidavit of Brett Goodson Attached (Doc. #22 ). Any reply in support of this motion shall be filed on an accelerated basis on or before 3/10/14. IT IS SO ORDERED by Judge Timothy S. Black on 3/4/2014. (mr1)
February 26, 2014 Filing 26 RESPONSE to Motion re #22 MOTION for Extension of Time to File Response/Reply as to #14 MOTION for Summary Judgment , #13 MOTION for Judgment on the Pleadings New date requested 3/17/2014. filed by Defendant Messer Construction Co.. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C) (Lynch, Jane)
February 21, 2014 Opinion or Order NOTATION ORDER: This civil action is before the Court on Plaintiff's Motion to Extend Time to Respond to Defendant Messer Construction Company's Motion for Summary Judgment and Judgment on the Pleadings Pursuant to Rule 56(d) with Affidavit of Brett Goodson Attached (Doc. #22 ). For good cause shown, Plaintiff's motion to extend his time to respond to Defendant Messer Construction Company's Motion for Judgment on the Pleadings is hereby GRANTED. Plaintiff shall respond to Defendant Messer Construction Company's Motion for Judgment on the Pleadings (Doc. #13 ) on or before 3/17/14. If Defendant Messer Construction Company intends to oppose Plaintiff's motion to extend his time to respond to its Motion for Summary Judgment (Doc. #14 ), given Fed. R. Civ. P. 56(d) and the affidavit of Brett Goodson (Doc. 22-1), any such opposition shall be filed on an accelerated basis on or before 3/1/14. IT IS SO ORDERED by Judge Timothy S. Black on 2/21/2014. (mr1)
February 21, 2014 Filing 25 SUMMONS Returned Executed as to Defendant Terracon Consultants, Inc. served on 2/19/2014, answer due 3/12/2014. (eh1)
February 20, 2014 Filing 24 CERTIFICATE OF SERVICE by Defendants D.A.G. Construction Co., Inc., Triversity Construction Co., LLC, and Pendleton Construction Group, LLC re #16 Corporate Disclosure Statement, #18 Corporate Disclosure Statement, #17 Corporate Disclosure Statement (Patsfall, Stephen) Modified to add filer details on 2/21/2014 (sct1).
February 20, 2014 Filing 23 SUMMONS Returned Executed as to Defendants J & B Steel Erectors, Inc. served on 2/19/2014, answer due 3/12/2014; Messer Construction Co. served on 2/19/2014, answer due 3/12/2014. (eh1)
February 19, 2014 Filing 22 MOTION for Extension of Time to File Response/Reply as to #14 MOTION for Summary Judgment , #13 MOTION for Judgment on the Pleadings New date requested 3/17/2014. by Plaintiff Daniel Stolz. (Attachments: #1 Affidavit) (Goodson, Brett)
February 18, 2014 Filing 21 CERTIFICATE of Clerk: Certified mailing of summons and complaint through the Clerk's Office pursuant to Local Rule 4.2. (lk) (Additional attachment(s) added on 2/20/2014: #1 Certified Mail Return Receipts (Rescanned to capture tracking number)) (lk1).
February 18, 2014 Filing 20 Summons Issued as to J & B Steel Erectors, Inc., Messer Construction Co., Terracon Consultants, Inc.. (lk)
February 18, 2014 Filing 19 NOTICE of Appearance by Robert W Hojnoski for Defendant Terracon Consultants, Inc. (Hojnoski, Robert)
February 18, 2014 Filing 18 Corporate Disclosure Statement by Defendants D.A.G. Construction Co. (Patsfall, Stephen) Modified to identify filer on 2/19/2014 (eh1).
February 18, 2014 Filing 17 Corporate Disclosure Statement by Defendants Triversity Construction Co., LLC. (Patsfall, Stephen) Modified to identify filer on 2/19/2014 (eh1).
February 18, 2014 Filing 16 Corporate Disclosure Statement by Defendants Pendleton Construction Group, LLC. (Patsfall, Stephen) Modified to identify filer on 2/19/2014 (eh1).
February 14, 2014 Filing 15 Corporate Disclosure Statement by Defendant Messer Construction Co.. (Wagner, Jared)
February 13, 2014 Filing 14 MOTION for Summary Judgment by Defendant Messer Construction Co. Responses due by 10/1/2014 (Attachments: #1 Exhibit A Proposed Undisputed Facts, #2 Exhibit B Affidavit of Guenther, #3 Exhibit 1 to affidavit of Guenther, #4 Exhibit 2 to affidavit of Guenther) (Lynch, Jane) Modified response date per Order #35 on 9/15/2014 (mr1).
February 13, 2014 Filing 13 MOTION for Judgment on the Pleadings by Defendant Messer Construction Co.. Responses due by 3/10/2014 (Lynch, Jane)
February 12, 2014 Filing 12 WAIVER OF SERVICE Returned Executed. Waiver sent to Triversity Construction Co., LLC on 1/14/2014, answer due 3/17/2014. (Goodson, Brett)
February 12, 2014 Filing 11 WAIVER OF SERVICE Returned Executed. Waiver sent to Pendleton Construction Group, LLC on 1/14/2014, answer due 3/17/2014. (Goodson, Brett)
February 12, 2014 Filing 10 WAIVER OF SERVICE Returned Executed. Waiver sent to D.A.G. Construction Co., Inc. on 1/14/2014, answer due 3/17/2014. (Goodson, Brett)
February 11, 2014 Filing 9 NOTICE by Defendant J & B Steel Erectors, Inc. re #8 Corporate Disclosure Statement Certificate of Service (Pramaggiore, Kimberly)
February 11, 2014 Notice of Correction re #8 Corporate Disclosure Statement: Document did not contain a certificate of service. Counsel to file certificate of service using the event certificate of service under the service of process category. (sct1)
February 10, 2014 Filing 8 Corporate Disclosure Statement by Defendant J & B Steel Erectors, Inc.. (Pramaggiore, Kimberly)
February 10, 2014 Filing 7 ANSWER to #1 Complaint filed by J & B Steel Erectors, Inc.. (Pramaggiore, Kimberly)
February 5, 2014 Filing 6 CERTIFICATE OF SERVICE by Defendants D.A.G. Construction Co., Inc., Pendleton Construction Group, LLC, Triversity Construction Co., LLC re #5 Certificate of Service, #4 Answer to Complaint, SECOND AMENDED CERTIFICATE OF SERVICE (Patsfall, Stephen)
February 5, 2014 Filing 5 AMENDED CERTIFICATE OF SERVICE re #4 Answer to Complaint by Defendants D.A.G. Construction Co., Inc., Pendleton Construction Group, LLC, Triversity Construction Co., LLC (Patsfall, Stephen) Modified to edit text for clarity on 2/5/2014 (mr1).
February 5, 2014 Filing 4 Answer of Defendant Pendleton Construction Group, LLC, D.A.G. Construction Co., Inc., and Triversity Construction Co., LLC to Plaintiff's Complaint ANSWER to #1 Complaint filed by D.A.G. Construction Co., Inc., Pendleton Construction Group, LLC, Triversity Construction Co., LLC. (Patsfall, Stephen)
February 3, 2014 Filing 3 ANSWER to #1 Complaint with Jury Demand Answer of Defendant Messer Constructions Co. to Plaintiff's Complaint with Jury Demand Endorsed Hereon filed by Messer Construction Co.. (Lynch, Jane)
January 15, 2014 ***If this case is referred, it will be to Magistrate Judge Karen L. Litkovitz. (lk)
January 14, 2014 Filing 2 NOTICE of Appearance by Stephanie M Day for Plaintiff Daniel Stolz (Day, Stephanie)
January 14, 2014 Filing 1 COMPLAINT with JURY DEMAND against All Defendants ( Filing fee $ 400 paid - receipt number: 0648-4406689), filed by Daniel Stolz. (Attachments: #1 Civil Cover Sheet) (Goodson, Brett)

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Search for this case: Stolz v. J & B Steel Erectors, Inc. et al
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Defendant: Doe 1
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Defendant: D.A.G. Construction Co., Inc.
Represented By: Stephen James Patsfall
Represented By: Stephen Michael Yeager
Represented By: Susan Salyer
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Defendant: Pendleton Construction Group, LLC
Represented By: Stephen James Patsfall
Represented By: Stephen Michael Yeager
Represented By: Susan Salyer
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Defendant: Messer Construction Co.
Represented By: Jared A Wagner
Represented By: Jane Michele Lynch
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Defendant: Terracon Consultants, Inc.
Represented By: Nathan Andrew Lennon
Represented By: Robert W Hojnoski
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Defendant: Triversity Construction Co., LLC
Represented By: Stephen James Patsfall
Represented By: Stephen Michael Yeager
Represented By: Susan Salyer
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Defendant: J & B Steel Erectors, Inc.
Represented By: Jordan T. Steiner
Represented By: Kimberly A Pramaggiore
Represented By: Colleen Marie Blandford
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Defendant: ABC Corporation
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Plaintiff: Daniel Stolz
Represented By: Stephanie M Day
Represented By: Katlin E. Rust
Represented By: Kristen Marie Myers
Represented By: Caroline M. Drennen
Represented By: Brett Colbert Goodson
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