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Defendants.
Persuant to Civ. R. (7) , and Civ. R. (12) (F), Defendants Michael Lance Griffin et al
timely requests this Court to rule that Defendant Tintmasters International, LLC, is a defunct
company and therefore is not required to be a party to this case. Tintmasters International, LLC
was lawfully dissolved prior to the Plaintiffs personal service and Michael Lance Griffin was not
the Statutory Agent for Tintmasters International, LLC when the Hamilton County Sherriff’s
2015 and this court never had established personal jurisdiction over the Defendant Tintmasters
disqualified to appear as a Defendant and should be stricken from the record as a matter of law.
Defendant Michael Lance Griffin Trust was never named in the Plaintiff’s first complaint “case
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number 13 CV 012976”, that was voluntarily dismissed even though the Plaintiff was aware of
its existence prior to its filing of a rule 41 (A) (1) (a) dismissal. Michael Lance Griffin Trust
cannot be named as a defendant in this case because the Plaintiff is collaterally estopped due to
the fact that it failed to name it as a party to its suit in 2013, and because when personal service
was allegedly given on November 9, 2015, none of the named defendants in the Plaintiff’s
instant action existed so this court did not have personal jurisdiction to grant the Plaintiff’s
amended complaint on May 2, 2016, so the Defendant Michael Lance Griffin Trust should be
stricken from the record and this court should render the Plaintiff’s amended complaint moot
and all of its exhibits attached to its amended complaint stricken because the Plaintiff lacked
personal jurisdiction to amend its complaint and all orders and judgments would be void ab
“As the court explained, a motion in limine (if granted) operates to avoid injecting
the court to consider the evidence, outside the presence of the jury, before is
offered. If the motion in limine is denied, the extra step is not added—the
the opponent to object to it then”. State v. Maurer, 473 N.E.2d 768, 787-88 (Ohio
1984)
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MEMORANDUM IN SUPPORT
1. The Primary Defendant Michael Lance Griffin, in this case, is an agent for all of his
principals. The Plaintiff has failed to prove that an agent for his principal is required to
register as a motor vehicle repair operator and a window tint operator so all Plaintiff
affidavits, statements, and presentments that name Michael Lance Griffin as being a
motor vehicle repair operator, or a window tint operator, should be inadmissible in this
case because they conflict with the definitions in R.C. 4775.01 (D) (E), and because the
plaintiff’s omitted the definitions of motor vehicle repair operator, and window tint
operator, has prejudiced the defendant and should not be permitted in this case. 4775.01
Motor vehicle repair and window tint operator definitions. (D) "Motor vehicle collision
repair operator" means any person, sole proprietorship, foreign or domestic partnership,
limited liability corporation, or other legal entity that is not an employee or agent of a
principal and performs five or more motor vehicle collision repairs in a calendar year.
(E) "Motor vehicle window tint operator" means any person, sole proprietorship, foreign
or domestic partnership, limited liability corporation, or other legal entity that is not an
2. Tintmasters International, LLC was civilly dead prior to the perfection of service so it
should be removed from this case. It was properly dissolved in the State of Ohio on
November 2, 2015 and had no successors or assigns. This court should declare it a
Tintmasters International, LLC, acted as an agent for its principal Michael Lance Griffin
Trust as evidenced on the Ohio Secretary of States web site under document number
201425801876.
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3. Business Trusts are governed by their trust agreements and any business trust that
has complied with R.C. 1746.06 shall be allowed to transact its business affairs in
this state as long as it is not in conflict with its trust agreement. In 2014 the Plaintiff
failed to name the Michael Lance Griffin Trust as a defendant even though it knew
the business trust existed. Instead it named a nonexistent Mid City Collision and
Custom to its claim. Because the Plaintiff was aware of the Michael Lance Griffin
Trust and failed to make a claim against it in their last case, they should be estopped
4. All of the statements, arguments, presentments, and briefs should not be admissible in
this case. Statements of counsel in brief or in argument are not facts before the court and
are therefore insufficient for a motion to dismiss or for summary judgment. Trinsey v.
5. All of the affidavits that the Plaintiffs attorney filed into this case on behalf of his client
asserting the status of that client should be disapproved as it was in Porter. Porter v.
6. The Plaintiff filed a document entitled REPLY MEMO on August 19, 2016 that should
be stricken from the record as moot because it was unripe. On July 29, 2016 the Plaintiff
filed a Motion for Summary Judgment. The Defendants had not filed a Memorandum In
Opposition to the Plaintiffs Summary Judgment Motion which renders the Plaintiff’s
REPLY MEMO prematurely filed and unripe. This court should strike it as a nullity
The Defendant Michael Lance Griffin requests this Court to issue an Order Persuant to Civ.
R. (7) , and Civ. R. (12) (F), that removes Defendant(s) Tintmasters International, LLC, and Michael
Lance Griffin Trust from this case, and deem all unqualified inadmissible evidence that has been
presented by the Plaintiffs attorney disapproved in all dispositive hearings, and the trials of this case,
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and strike the Plaintiff’s REPLY MEMO that was filed on 8/19/2016.
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CERTIFICATE OF SERVICE
The undersigned certifies that a true copy of the foregoing Defendant Michael Lance Griffin's Motion in Limine was
served upon the following delivered by email, and certified mail, to Ohio Board of Motor Vehicle Repair c/o
FEDERICO G BARRERA III 0090739 Assistant Attorney General, Executive Agencies Section 30 East Broad
Street, 26th Floor Columbus, Ohio 43215-3428, rico.barrera@attorneygeneral.gov, on this 26th day of August,
2016.
Michael L. Griffin
7805 Affinity Place
Cincinnati, Ohio 45231
Mikebg1693@yahoo.com
(513) 364-3772