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IN THE COURT OF COMMON PLEAS LAKE COUNTY, OHIO
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Ruth N. Bumheimer, etc.,
Plaintiff, v.
Uniroyal Chemical Company, Inc., et al..
Defendants.
) Case No. 93 CV 001758
) Judge Martin O. Parks
) MOTION FOR SUMMARY
JUDGMENT ON BEHALF OF
) DEFENDANT UNIROYAL
CHEMICAL COMPANY. INC.
)
Robert A. Bunda (0019775) ) Anne Y. Koester (0040609)
) BUNDA, STUTZ & DEWITT One SeaGate, Suite 650
) Toledo, OH 43604 Telephone: (419)247-2777
) Telecopy: (419)247-2727
) Trial Counsel for Defendant Uniroyal Chemical Company, Inc.
)
Defendant Uniroyal Chemical Company, Inc. ["UniroyaT] moves this Court, pursuant to Rule 56(B) of the Ohio Rules of Civil Procedure, for entry of an order granting it summary judgment. Upon the pleadings, the deposition testimony taken in plaintiffs originally filed action, other discovery responses, the entire record, and the law as stated in the brief in support of this motion, reasonable minds can come to but one conclusion, and
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that conclusion is adverse to plaintiff. There is no basis upon which to impose liability upon
defendant Uniroyal because plaintiff cannot present evidence which would enable a
reasonable jury to tender a verdict in plaintiffs favor on the causes of action plaintiff has
alleged against this defendant; and therefore, Uniroyal is entitled to judgment as a matter of
law.
A brief in support of this motion has beei
ith.
Of Counsel for Defendant Uniroyal Chemical Company, Inc.
BUNDA, STUTZ & DEWITT One SeaGate, Suite 650 Toledo, Ohio 43604
BUNDA, STUTZ & DEWITT One SeaGate, Suite 650 Toledo, Ohio 43604 Telephone: (419) 247-2777 Telecopy: (419)247-2727
Attorney for Defendant Uniroyal Chemical Company, Inc.
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CERTIFICATE OF SERVICE "his is to certify that a copy of the Motion for Summary Judgment on Behalf of Defendant Uniroyal Chemical Company, Inc. was mailed this & ' day of June, 1994, to Peter J. Brodhead, Esq., attorney for plaintiff, at his office located at Spangenberg, Shibley, Traci, Lancione & Liber, 2400 National City Bank Building, Cleveland, Ohio 44114, and Victoria L. Vance, Esq., attorney for defendants, Borden, Inc. and Monochem, Inc., at her office located at Arter & Hadden, 1100 Huntington Building, Cleveland, Ohio 44115-1475.
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