IN THE COURT OF COMMON PLEAS CUYAHOGA COUNTY, OHIO MICKHAL GARRETT, INDIVIDUALLY AND AS ADMINISTRATOR OF THE ESTATE OF ANIYA DAY GARRETT clo Landskroner Grieco Merriman, LLC 1360 West 9th Street, Suite 200 Cleveland, Ohio 44113 Plaintif? v. CUYAHOGA COUNTY 2079 East Ninth Street Cleveland, Ohio 44115 and CUYAHOGA COUNTY EXECUTIVE c/o Armond Buddish, County Executive 2079 East Ninth Street Cleveland, Ohio 44115 Discovery Defendants and CHELSY LILLY Individually and as agent of Cuyahoga County, Division of Children Family Services c/o Cuyahoga County, Division of Children and Family Services 3955 Euclid Avenue Cleveland, Ohio 44115 and ELIZABETH GRIZER Individually and as agent of Cuyahoga County, Division of Children and Family Services c/o Cuyahoga County, Division of Children and Family Services 3955 Euclid Avenue Cleveland, Ohio 44115 and CASE NO. JUDGE COMBINED COMPLAINT and PETITION FOR DISCOVERY Jury Demand Endorsed Hereon‘TAWANA JAMES Individually and as agent of Cuyahoga County, Division of Children and Family Services c/o Cuyahoga County, Division of Children and Family Services’ 3955 Euclid Avenue Cleveland, Ohio 44115 and LORRA GREENE Individually and as agent of Cuyahoga County, Division of Children and Family Serv 12804 Benham Avenue Cleveland, Ohio 44105 and LAURA COLE Individually and as agent of Cuyahoga County, Division of Children and Family Services c/o Cuyahoga County, Division of Children and Family Services 3955 Euclid Avenue Cleveland, Ohio 44115 and LORIANNE DELSIGNORE Individually and as agent of Cuyahoga County, Division of Children and Family Services c/o Cuyahoga County, Division of Children and Family Services 3955 Euclid Avenue Cleveland, Ohio 44115 and THERESE HARPER Individually and as agent of Cuyahoga County, Division of Children and Family Services c/o Cuyahoga County, Division of Children and Family Services 3955 Euclid Avenue Cleveland, Ohio 44115 andJOHN/JANE DOES 1 THROUGH 5 Individually and as ag Cuyahoga County, Di Family Services c/o Cuyahoga County, Division of Children and Family Services 3955 Euclid Avenue Cleveland, Ohio 44115 and SIERRA REBECCA DAY Inmate No. W103150 Ohio Reformatory for Women c/o Warden, Ronette Burkes 1479 Collins Avenue Marysville, Ohio 43040 and DEONTE LEWIS Inmate No. A761427 Lorain Correctional Institution clo Warden, Kimberly Clipper 2075 South Avon-Beldon Road Grafton, Ohio 44044 and GET, READY, SET GROW PRESCHOOL, LLC dba GET READY SET GROW CHILDCARE CENTER clo Larry Osayamwen, Statutory Agent 26191 Brush Avenue Euclid, Ohio 44132 and ALTHEA CAVOR Individually and as agent of GET, READY, SET GROW PRESCHOOL, LLC. c/o Get Ready Set Grow Childcare Center 26191 Brush Avenue Euclid, Ohio 44132 and LARRY OSAYAMWEN Individually and as agent of ", READY, SET GROW PRESCHOOL,