Plaintiff's Brief In Opposition to Defendant Verizon Wireless’s Motion to Compel Arbitration Indigency 1
`
`IN THE COMMON PLEAS
`
`T OF CUYAHOGA COUNTY OHIO
`
`Plaintiffs
`
`Myron Grace
`
`202^1 JUN 13 P 3= 5b ■
`
`County Common Pleas Court
`
`of Cuyahoga County Ohio
`
`1200 Ontario Street, Cleveland Ohio 44113
`
`Plaintiffs Brief In Opposition to Defendant
`Verizon Wireless’s Motion to Compel
`
`Arbitration Due to Defendant’s Indigent State
`
`' CV24995657
`182790573
`
`182790573
`
`)
`)
`
`)
`
`)
`
`) )
`
`)
`
`Rakhshanda Talib
`4
`3495 E. 98th Street, #301
`
`Cleveland, Ohio 44104
`
`+1(440)444-4413
`
`E: Tvpilots@yahoo.com
`
`Defendants
`
`Verizon Wireless Headquarters )
`
`Legal Department
`
`1095 Avenue of the Americas
`
`New York, NY 10036 USA
`
`1-212-395-1000
`
`Attorneys Verizon Wireless
`
`Christine M Haaker (0063225)
`
`)
`
`)
`
`)
`
`)
`
`)
`
`)
`
`10050 Innovation Drive, Suite 400 )
`
`Miamisburg, Ohio 45342
`
`)
`
`Christine.Haaker@ThompsonHine.com
`
`Brianna D. Vollman (0101144)
`
`312 Walnut Street, Suite 2000
`
`Cincinnati, Ohio 45202
`
`)
`
`)
`
`)
`
`Brianna. V ollman@ThompsonHine. com
`
`
`
`IN THE COMMON PLEAS
`
`T OF CUYAHOGA COUNTY OHIO
`
`Plaintiffs
`
`Myron Grace
`
`202^1 JUN 13 P 3= 5b ■
`
`County Common Pleas Court
`
`of Cuyahoga County Ohio
`
`1200 Ontario Street, Cleveland Ohio 44113
`
`Plaintiffs Brief In Opposition to Defendant
`Verizon Wireless’s Motion to Compel
`
`Arbitration Due to Defendant’s Indigent State
`
`' CV24995657
`182790573
`
`182790573
`
`)
`)
`
`)
`
`)
`
`) )
`
`)
`
`Rakhshanda Talib
`4
`3495 E. 98th Street, #301
`
`Cleveland, Ohio 44104
`
`+1(440)444-4413
`
`E: Tvpilots@yahoo.com
`
`Defendants
`
`Verizon Wireless Headquarters )
`
`Legal Department
`
`1095 Avenue of the Americas
`
`New York, NY 10036 USA
`
`1-212-395-1000
`
`Attorneys Verizon Wireless
`
`Christine M Haaker (0063225)
`
`)
`
`)
`
`)
`
`)
`
`)
`
`)
`
`10050 Innovation Drive, Suite 400 )
`
`Miamisburg, Ohio 45342
`
`)
`
`Christine.Haaker@ThompsonHine.com
`
`Brianna D. Vollman (0101144)
`
`312 Walnut Street, Suite 2000
`
`Cincinnati, Ohio 45202
`
`)
`
`)
`
`)
`
`Brianna. V ollman@ThompsonHine. com
`
`
`
`Plaintiff's Brief In Opposition to Defendant Verizon Wireless's Motion to Compel Arbitration Indigency 2
`
`Plaintiffs Brief In Opposition to Defendant Verizon Wireless’s Motion to Compel
`
`Arbitration Due to Defendant’s Indigent State
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`Arguments In Opposition
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`1) Plaintiff Myron Grace is Indigent, and therefore any fees to Compel Arbitration is unfair
`
`to him.
`
`2) Plaintiff Myron Grace has no financial means to pay the costs of Arbitration.
`
`3) Plaintiff Myron Grace should not be denied his right to due process, and the trial court
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`should set a trial date to hear the case.
`
`4) The Plaintiff Myron Grace has filed his Indigency form and attached it to this document
`
`in response.
`
`5) Judge Shannon M Gallagher should vacate her ruling on 05/30/24 allowing Arbitration to
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`Verizon Wireless, and set a trial date.
`
`Issues
`
`1) Now comes Myron Grace and Rakhshanda Talib on behalf of themselves residing at
`
`3495 E. 98th street, 301, Cleveland Ohio 44104 being known as the plaintiffs. Here comes
`
`also the defendants Verizon Wireless Corporate Headquarters, 95 Avenue of the
`
`Americas, New York, NY 10036, USA and Basking Ridge Operational Headquarters,
`
`One Verizon Way, Basking Ridge, New Jersey 07920, USA. Myron Grace Verizon
`
`Numbers l-(440)444-4413 and l-(440)902-1668. Rakhshanda Talib Verizon
`
`Numbers 1-(440)465-8945.
`
`2) That Myron Grace is a disabled U.S. Navy Veteran, and that Verizon Wireless did
`
`violate The American Disabilities Act. That on 02-06-24 Myron Grace did call Verizon
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`Wireless and request a plan for 55 and older that was advertised on Google Search
`
`
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`Plaintiff's Brief In Opposition to Defendant Verizon Wireless's Motion to Compel Arbitration Indigency 3
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`Engine by Verizon. That the Verizon Wireless representative stated the advertisement
`
`was for Florida only, but she would make an exception for Myron Grace and apply
`
`the 55 and older plan to his phone bills in February and March 2024. That Myron
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`Grace did rely on the statement by the Verizon Wireless representative on 02-06-24. That
`
`on February 6,2024 Myron Grace did call back Verizon Wireless and was told he would
`
`be given a discount for the 55 and older plan for sure, and that it would take a few weeks
`
`to kick in, and that Myron Grace did rely on the statement by the Verizon Wireless
`
`representative on 02-06-24. That on March 1,2024 Myron Grace did call back Verizon
`
`Wireless and a Verizon Wireless Supervisor did tell him he was eligible for the 55 and
`
`older did, as long as he switched from the military discount. Myron Grace did rely on the
`
`statement by the Verizon Wireless representative on 03-01-24. That on March 5,2024
`
`Myron Grace did call back Verizon Wireless. That on 03-05-24 Myron Grace was told by
`
`a Verizon Wireless representative and supervisor that he was not eligible for the 55 and
`
`older discount, despite what Myron Grace was promised on several other phone calls.
`
`Myron Grace did rely on the statement by the Verizon Wireless representative on 03-05-
`
`24. Verizon Wireless did make several promises to give Myron Grace the 55 and older
`
`discount, but did not keep the promise made to him.
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`Other Issues
`
`3) My name is Rakhshanda Talib and I am speaking about the issue that I have with Verizon
`
`Wireless. The issue is that Verizon is trying to make me pay for a stolen phone, an
`
`iPhonel3. Back in November 2022, my son who was 18 years old at the time, stole the
`
`phone. Upon asking the police if I can retrieve the phone since it was my property, the
`
`police advised me that if I went and retrieved the phone I would be charged with assault.
`
`
`
`Plaintiff's Brief In Opposition to Defendant Verizon Wireless's Motion to Compel Arbitration Indigency 4
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`I had no choice but to contact Verizon and Verizon told me that they could not do
`
`anything about the phone without a police report. I should not have had to have a police
`
`report to report my own property stolen. Even with this non-viable option, I tried to work
`
`with this with Verizon. Verizon told me that I could pay $25/month for the Iphone until it
`
`was paid off, along with paying my own bill. I thought again that this was unfair because
`
`as a consumer I should not have to pay for a stolen device. Afterwards, my bill became
`
`very confusing from Verizon, and I was constantly being billed out in total for the iPhone
`
`along with my own phone line. I had to call Verizon Wireless at least 2-3 times a month
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`for at least 4 months to try and get my bill straight. As a consumer, I should be able to
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`know what my bill will be each month, there should not be any surprises. Afterwards,
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`Verizon began to add extra items onto my bill that I did not ask for. Rakhshanda Talib
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`would like the phone debt removed from her credit report.
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`Signatures
`
`Now comes Myron Grace and Rakhshanda Talib in The Cuyahoga County Court of Common
`
`Pleas in Cleveland, Ohio. Myron Grace and Rakhshanda Talib on Behalf of himself residing at
`
`3495 E. 98th street, 301, Cleveland Ohio 44104 being known as the plaintiff(s). Plaintiffs
`
`making claim against the defendant Verizon Wireless Headquarters Legal Department, 1095
`
`Avenue of the Americas, New York, NY 10036 USA 1-212-395-1000 and Verizon Wireless
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`Basking Ridge Operational Headquarters One Verizon Way, Basking Ridge, New Jersey 07920,
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`USA, 1- 908-559-2001. A copy of this document will be delivered by U.S. Mail to the Attorneys
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`for Verizon Wireless being Christine M Haaker (0063225), 10050 Innovation Drive, Suite 400,
`
`Miamisburg, Ohio 45342, (937) 443-6822 and Brianna D. Vollman, 312 Walnut Street, Suite
`
`2000, Cincinnati, Ohio 45202, (513) 352-6751.
`
`
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`Plaintiff's Brief In Opposition to Defendant Verizon Wireless's Motion to Compel Arbitration Indigency 5
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`________ ~~
`
`Myron Grace, Pro Se
`
`3495 E. 98th Street, 301
`
`Cleveland, Ohio 44104
`
`T:(440)902-1668
`
`E: Tvpilots@yahoo.com
`
`Rakhshanda Talib, Pro Se, 3495 E. 98th Street, 301, Cleveland, Ohio 44104
`
`T: (440) 465-8945, E: rockiethunder@hotmail.com
`
`Proof of Mailing
`
`The plaintiffs do herby state a copy of the complaint will be delivered to all defendants on
`. At the
`6 the / day of
`
`following addresses. Now comes Myron Grace on Behalf of himself residing at 3495 E. 98th
`
`street, 301, Cleveland Ohio 44104 being known as the plaintiff(s). Plaintiffs making claim
`
`against the defendant Verizon Wireless Headquarters Legal Department, 1095 Avenue of the
`
`Americas, New York, NY 10036 USA 1-212-395-1000 and Verizon Wireless Basking Ridge
`
`Operational Headquarters One Verizon Way, Basking Ridge, New Jersey 07920, USA, 1- 908-
`
`559-2001. A copy of this document will be delivered by U.S. Mail to the Attorneys for Verizon
`
`Wireless being Christine M Haaker (0063225), 10050 Innovation Drive, Suite 400, Miamisburg,
`
`Ohio 45342, (937) 443-6822 and Brianna D. Vollman, 312 Walnut Street, Suite 2000,
`
`Cincinnati, Ohio 45202, (513) 352-6751.
`
`
`
`Plaintiff's Brief In Opposition to Defendant Verizon Wireless's Motion to Compel Arbitration Indigency 6
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`*
`
`Myron Grace, Pro Se
`
`3495 E. 98th Street, 301
`
`Cleveland, Ohio 44104
`
`T:(440)902-1668
`
`E: Tvpilots@yahoo.com
`
`Rakhshanda Talib, Pro Se, 3495 E. 98th Street, 301, Cleveland, Ohio 44104
`
`T: (440) 465-8945, E: rockiethunder@hotmail.com
`
`
`
`53944009
`
`case: CV-24-995657
`
`MYRON GRACE
`VS.
`VERIZON WIRELESS
`
`2499847
`
`JUDGE: SHANNON M GALLAGHER
`ROOM: 22D JUSTICE CENTER
`DOCKET DATE: 05/30/2024
`
`MOTION OF DEFENDANT VERIZON WIRELESS TO
`COMPEL ARBITRATION OR TO DISMISS, FILED 05/07/2024,
`IS GRANTED. THIS MATTER IS STAYED PENDING
`COMPLETION OF ARBITRATION PROCEEDINGS AS
`REQUIRED BY THE VERIZON WIRELESS CUSTOMER
`AGREEMENT THAT PLAINTIFF CONSENTED TO. THIS
`MATTER WILL REMAIN STAYED UNTIL THE COMPLETION
`OF ARBITRATION PROCEEDINGS AND WILL ONLY BE
`REINSTATED UPON MOTION. COURT COST ASSESSED TO
`THE PLAINTIFF(S). NOTICE ISSUED
`
`I First-Class Mail
`I U. S. Postage Paid
`I Cleveland, OH
`I Permit No. 1962
`i_____________________
`
`! FROM:
`
`I CUYAHOGA COUNTY - COURT OF COMMON PLEAS
`I NAILAHK. BYRD-CLERK OF COURTS
`I JUSTICE CENTER - COURT TOWER
`I 1200 ONTARIO ST
`I CLEVELAND, OH44II3
`I___________________________________________________ I
`
`TO:
`RAKHSHANDA TALIB
`3495 E. 98TH STREET, #301
`CLEVELAND, OH 44104
`
`'feFPi 4.4.10^
`
`
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