SUCCESS IN FOUR CIVIL CASES in 2021

We started year 2021 with 4 winning cases. CV-19-925835 and CV-20-930311 are two companion cases in Cuyahoga Common Pleas Court filed by a plaintiff against our client, a defendant.  CV-19-925835 was filed on November 26, 2019. Plaintiff alleged breach of two contracts. Based on evidence, we quickly filed counterclaims against the plaintiff and a third-party complaint against plaintiff company’s owner. Evidence showed that the lawsuit was frivolous. More appalling, Plaintiff filed second suit against our client on March 3, 2020 with similar claims.

Plaintiff filed numerous motions to distort, delay and/or disrupt the cases, most of them were meritless. In a short period of one year during the global pandemic, a total of 46 motions/briefs were filed (21 in CV-19-925835 and 25 in CV-20-930311), not to mention many other documents, pleadings, and hearings.  This was extraordinary. Yet, our defense team defeated and dissolved all these baseless motions.

In the end, Plaintiff ran out of gas and tricks. On March 26, 2021, Plaintiff voluntarily dismissed all claims against our client in these two cases. Thus, our client achieved final success and was satisfied with our representation.

We also defended our clients in two other cases and obtained measurable success. 20CV000003 is a civil case in Lake County Common Pleas. This was another highly contested case (if not more) involved the same entity in above two Cuyahoga cases (plaintiff there). Approximately 53 motions/briefs were filed in one year. Types of motions filed by this entity (third party defendants here) included but not limited to

  • Motion to disqualify defense counsel
  • Motion to reconsideration
  • Motion for extension of time
  • Motion to compel discovery
  • Renewed and amended motion to disqualify
  • Motion for protective order
  • Motion to strike
  • Motion to dismiss
  • Substituted motion to strike
  • Motion for non-prejudicial dismissal under doctrine of forum non conveniens
  • Motion to continue
  • Motion in limine
  • Motion for leave to file sur-reply

We defeated all these motions and obtained a success for the client.

The fourth case was in Cleveland Height Municipal Court where our client, a defendant, prevailed after the trial. Case number is CVI2001426.

Big or small, plaintiff or defense work, we handle the cases with the highest level of care, professionalism and skill. If you have a business dispute, please contact us for help. 

© 2021 Copyright by Lei Jiang LLC. All rights reserved.

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