COURT OF COMMON PLEAS HAMILTON COUNTY, OHIO GRANT TROJA, : CASE NO. A 1307690 Plaintiff, : JUDGE JODY LUEBBERS vs. JOINT MOTION. ‘0 SHOW CAUSE CRYSTA PLEATMAN, et al., Defendants. Comes now the Plaintiff, Grant Troja, and former Third-Party Defendants Sibey Cligg and Nat Comisar, by and through counsel, and respectfully request this Court for anorder % requiring Defendant Crysta Pleatman to appear before it and show caused as to why $i shoul? not be held in contempt for her failure to comply with this Court's Order dated, May 28°01 al in the altemative, for sanctions asa result of her violation of tis Court's Order. The reasons for the Motion are more fully set forth in the accompanying Memorandum. Respectfully submitted, es F, Brocksnan (0009469) Dey + Charles F. Reynolds (0019935) INDHORST & DREIDAME '" @ y Hoy) py Allison S. Cox (0091036) 312 Walnut Street, Suite 3100 SANTEN & HUGHES, LPA Cincinnati, Ohio 45202 600 Vine Street, Suite 2700 Tel: (513) 345-5798/Fax: (513) 421-0212 Cincinnati, Ohio 45202 jbrockman@lindhorstlaw.com Tel: (513) 721-4450/Fax: (513) 721-0109 Attorney for Third Party Defendants, cer@santen-hughes.com Sibey Cline, Inc, & Nat Comisar ask(@santen-hughes.com Attorneys for Plaintiff. Grant TrojaMEMORANDUM In January 2015, Plaintiff Grant Troja and former Third Party Defendants Nat Comisar and Sibcy Cline, filed a Motion for Sanctions on the basis of an allegedly forged e-mail and a number of frivolous emails sent by the Defendants Crysta and Stephen Pleatman. On the final day of oral argument, the Court addressed Mrs. Pleatman’s unrelenting e-mailing of parties, witnesses, and counsel. In addressing Mrs. Pleatman directly, the Court stated, “You don’t send e-mails, You have an attorney, your attomey handles all that. Stop it. You do it again, sanctions will be that you're going to jail. So no e-mails about this case to anyone involved in this case except to your attorney. Understood?” Motion for Sanctions, Trans. Vol. 3, P. 299-300. In. response Mrs. Pleatman answered, “Understood.” Jd, Despite this Court’s Order, the Pleatmans continue to e-mail parties, witnesses, and counsel, While they managed to stop communicating with parties, witnesses, and counsel, for a whole six weeks, on July 20, 2015, Mrs, Pleatman e-mailed Nat Comisar in order to harass and intimidate him immediately before the scheduled trial date. She stated, “You are a liar and we can prove it! I can’t believe that you have allowed your lies to hurt our family. You lied to keep your job-but this has gone too far, Tell the truth as the church expects you to do!” (Exhibit A), On August 25, 2015, the Pleatmans e-mailed three witnesses: Nat Comisar; Stephanie Sudbrack-Busam; and Rob Sibcy, Plaintiff's counsel, and Mr. Troja. In the frivolous e-mail to ‘witnesses in this litigation, the Pleatmans question and threaten Sibey Cline real estate agents in stating, “Will you loose [sic] your license and be front page news? Or will Sibey Cline be accountable and pay for their actions against us?” (Exhibit B). This email, along with another sent to Plaintiff’s counsel, was sent directly to Mr. Troja by the Defendants. Along with the two previously mentioned emails sent August 25, 2015, the Pleatmans composed an individual e-mailto Mr. Troja with the intent to harass and intimidate him. It begins, “Last week your gitlftiend told Chris Nicholson that you never wanted this case to get this dirty and that you wanted to end things but Chuck Reynolds refused your demand because he needed to recoup the ineome he lost by representing you for free. You started this nightmare.” Defendants end the email with “Nice job Grant!”(Exhibit C) (See attached Affidavit of Charles E. Reynolds), Both Exhibits B and C were signed “C & S.” Mrs, Pleatman also continues to threaten Mr. Reynolds's volunteer position with the Indian Hill mock trial team by e-mailing various individuals who work at Indian Hill High School and making overtly false statements regarding the case, Mr. Reynolds, the parties, and witnesses, (Exhibit D). The Pleatmans continue to send harassing, threatening, intimidating, and frivolous e- mails to parties, witnesses, and counsel. These actions overtly defy this Courts previous Order entered on May 28, 2015. Consequently, Plaintiff and former Third-Party Defendants ask this Court to impose sanctions sufficient to finally quell the perpetual harassment and intimidation of witnesses, parties, and counsel, Plaintiff and Third-Party Defendants reserve the right to file supplemental affidavits to the motion at a later point. Respectfully submitted, fe F, Brockman (0009469) Charles E. fynolds (0019935) LINDHORST & DREIDAME, Allison S. Cox (0091036) 312 Walnut Street, Suite 3100 SANTEN & HUGHES, LPA Cincinnati, Ohio 45202 600 Vine Street, Suite 2700 Tel: (513) 345-5798/Fax: (513) 421-0212 Cincinnati, Ohio 45202 ibrockman@lindhorstlaw.com Tel: (513) 721-4450/Fax: (513) 721-0109 Attorney for Third Party Defendants, cer(@santen-hughes.com Sibey Cline, Inc. & Nat Comisar ask@santen-hughes.com Attorneys for Plaintiff. Grant TrojaCERT! "ATE OF ‘The undersigned hereby certifies that on the 28"" da foregoing was served upon the following via electronic ma Paul Croushore, Esq, P.O. Box 75170 Cincinnati, Ohio 45275 croushlaw@fuuse.net Allison S. Cox s8i927_1 of August, 2015, a copy of theCOURT OF COMMON PLEAS HAMILTON COUNTY, OHIO GRANT TROIA, + Case No. A 1307690 Plaintiff, Judge Luebbers vs. AFFIDAVIT OF CHARLES E. REYNOLDS CRYSTA PLEATMAN, et al., Defendants. STATE OF OHIO ss HAMILTON COUNTY ‘Comes now the affiant and hereby deposes and states as follows: 1. My name Charles E. Reynolds. 2. [am an attorney licensed in the State of Ohio, employed as an associate at Santen & Hughes, LPA. 3. Trepresent Grant Troja, the Plaintiff, in Hamilton County Ci ‘Common Pleas Case Number A 1307690. 4, { make the statements contained herein based on personal knowledge, 5. Lam competent to testify and am not operating under any mental disabilities, 6. Tam over the age of 18 years and make this Affidavit upon personal knowledge. 7, Exhibits B and C are true and accurate copies of e-mails sent to me and my client Grant Troja, from the email address that I know to be Crysta Pleatman’s.FURTHER AFFIANT SAYETH NAUGHT. kuke ¢ Cea, ‘Charles E. Reynolds STATE OF OHIO ss COUNTY OF HAMILTON Before me, a Notary Public in and for said County and State, personally appeared the above-named Charles B. Reynolds, Esq., who acknowledged that she did sign the foregoing instrument and that the same is her free act and deed. IN pystimony WHEREOF, | have hereinto set my hand and official seal on this lay of August, 2015. numpameasn ry Pit SO by Comin Ha a Scion 7.08 Notary Public 830660From: Nat Comisar (maitto:nat@natcomisar.com) ‘Sent: Thursday, July 23, 2015 10:04 PM To: James Brockman ‘Subject: Fwd: Trial ‘Nat Comisar - from my mobile 513-378-5801 Forwarded message ——~ From: "Crysta Pleatman" Date: Jul 20, 2015 10:34 PM Subject: Trial To: ce: Nat, You are a liar and we can prove it !| can't believe that you have allowed your lies to hurt our family. You lied to keep your job- but this has gone too far. Tell the truth as the church expects you to do! c Sent from Crysta's iWatch EXHIBIT AReyr Charles E From: Crysta Pleatman Sent: Tuesday, August 25, 2015 9:15 PM To: Reynolds, Charles E ‘Subject: Fwd: Game Changer ‘Chuck, Did you know that Mercer and Gabby are my godparents ? Game over! Sent from Crysta's iWatch Begin forwarded message: From: Crysta Pleatman Date: August 25, 2015 at 9:09:30 PM EDT To: “nat@natcomisar.com" , "ssudbrack-busam@sibeycline.com” , Rob Sibcy Subject: Game Changer Good Evening All, By now you have received your certified letters from the Ohio Board of Commerce. The board has concluded that Sibcy Cline and you as their agents have breached fiduciary duty, failed to disclose information that was known to you, conspired to conceal such facts from us, colluded to defame our reputation and engaged in frivolous litigation as a tactic to sway the courts opinion and force us to back down. The game has changed, you have been checked! Sibcy Cline has 10 days to make their move. They can settle, or let the board publicly sanction you and Sibey Cline for you actions against us. Will you loose your license and be front page news? Or will Sibey Cline finally be accountable and pay for their actions against us? C&S Sent from Crysta’s {Watch EXHIBIT |Reynolds, Charles E From: Crysta Pleatman Sent: Tuesday, August 25, 2015 10:01 PM To: Reynolds, Charles E; Stephen Reger Subject: Fwd: Game Changer Begin forwarded message: From: Crysta Pleatman Date: August 25, 2015 at 9:58:31 PM EDT To: Grant Troja Subject: Fwd: Game Changer Grant (and Karen and Gwen Bender-) Grant, This email is factual and affects the case against you and Karen. Last week your girlfriend told Chris Nicholson that you never wanted this case to get this dirty and that YOU wanted to end things but Chuck Reynolds refused your demand because he needed to recoup the income he lost by representing you for free. You started this nightmare, but the Ohio Board of commerce has taken away your control. The agents involved better hope that Sibcy Cline has their back before they become headline news and loose their license to sell real estate. Nice job Grant! C&S c Sent from Crysta's Watch Begin forwarded message: From: Crysta Pleatman Date: August 25, 2015 at 9:15:11 PM EDT To: Charles E Reynolds < iten-hughes.com> Subject: Fwd: Game Changer ‘Chuck, Did you know that Mercer and Gabby are my godparents ?” Game over! Sent from Crysta's Watch Begin forwarded message:From: Crysta Pleatman Date: August 25, 2015 at 9:09:30 PM EDT ‘To: "nat@natcomisar.com" , "ssudbrack- busam@sibcycline.com" , Rob Sibey Subject: Game Changer Good Evening All, By now you have received your certified letters from the Ohio Board of Commerce. The board has concluded that Sibcy Cline and you as their agents have breached fiduciary duty, failed to disclose information that was known to you, conspired to conceal such facts from us, colluded to defame our reputation and engaged in frivolous litigation as a tactic to sway the courts opinion and force us to back down. ‘The game has changed, you have been checked! Sibcy Cline has 10 days to make their move. ‘They can settle, or let the board publicly sanction you and Sibey Cline for you actions against us. Will you loose your license and be front page news? Or will Sibey Cline finally be accountable and pay for their actions against us? C&S Sent from Crysta's iWatcholds, Charles E From: ‘Stephen Reger Sent: Monday, August 24, 2025 11:50 AM To: Reynolds, Charles E Subject: Fwd: West Steve -— Forwarded message -———— From: Crysta Pleatman Date: Mon, Aug 24, 2015 at 9:50 AM. Subject: West EXHIBIT To: Stephen Reger H D Hi Steve, ‘You are an outstanding teacher and we have the utmost respect for you. We regret that you have been forced to| be involved in this mess. ‘West mentioned that you spoke with him last week in regard to Chuck Reynolds role in the Mock trial program and that you requested to speak with him again after school today. As West is testifying against Mr Reynolds in a criminal case, and you are a witness for Mr. Reynolds, it is probably not wise to speak with West at this time. I'm sure you understand our position. I want you to know that Mr Reynolds has been representing his client Grant Troja at no cost for 2 years and we have paid over $150,000 to date in defending ourselves. Just yesterday, a mutual friend told us that Grant never expected this lawsuit to get so out of hand. She went on to say that Grant is willing to settle for a nominal amount, but that Chuck Reynolds won't allow him to do so because Chuck needs to"save face” with Sibey Cline and his law firm by winning a 6 figure settlement against us. It's not going to happen and he knows it. Chuck tried a similar contract case 12 years ago and lost. This lawsuit has become a personal case of revenge for Chuck. All we did was make a decision not to buy a house next to a felon who was convicted of brutally stabbing and attempting to murder his 13 year old neighbor. For this decision we have suffered greatly. We have endured a huge financial loss in defending ourselves against ‘Chucks client who again, has never paid Chuck one penny. We have been socially ostracized for being “overzealous” in defending our case. I was arrested not once but twice for emailing Chuck Reynolds and Grant Troja in the hopes of settling this case and moving on. I was sanctioned $28,000 by the judge for utilizing my right to free speech, and my husband Steve was fired suddenly from his medical practice of 32 years because of the recent press coverage in this case. I was not in court in July because Mr. Reynolds never said he was calling me as witness and my name was not on his witness list as the court mandates. Mr Reynolds clearly has the intent of dragging this case out for another year or more. We have no income, we are paying huge amounts to cobra for health insurance and even if Chuck somehow won this case, we don't have any disposable income to pay him. There is no good outcome for anyone here. Mr Reynolds tactics continue to be self serving and unethical. This is not what Indian Hill parents want their children to lea in the Mock trial program.The situation at home is stressful enough for West, but the added stress of Mr Reynolds as a coach for Mock trial is just too much for any kid to have to endure in a schoo! setting. { had no intention of reaching out to the school board this year in regard to. Mr. Reynolds position, but if he is going to drag this case out, then the school board will need to consider replacing Reynolds permanently to avoid a potential lawsuit against the 1district. We have never sued anyone nor have we ever been sued, so it is not our intention to pursue a legal. remédy unless absolutely necessary. Feel free to share this email with Chuck. If I copy him on it he will likely call the Rangers and have me arrested. have lost all faith in the justice system. Best, Crysta