VIRG INIA: IN THE CIRCUIT COURT FOR THE CITY OF ALEXANDRIA ERIC J. BONETTI,
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Plaintiff,
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v.
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GRACE EPISCOPAL CHURCH,
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Defendant. *
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Case No.: CL20002178
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OBJECTION TO PLAINTIFF’S AGREED STATEMENT OF FACTS COMES NOW, defendant, Grace Episcopal Church (“Grace Church”), through counsel, files this Objection to Plaintiff’s Agreed Statement of Facts and for the reasons stated below, Grace Church respectfully requests that this Honorable Court sustain its objection and not sign the Agreed Statement of Facts as they are incomplete and erroneous. 1.
On December 23, 2020, this Court granted Defendant’s Plea in Bar on the basis that
the statute of limitations had tolled on Plaintiff’s claim. 2.
Plaintiff noted an appeal the same day.
3.
Va. Sup. Ct. R. 5:11(a)(1) provides that “[i]t is the obligation of the
petitioner/appellant to ensure that the record is sufficient to enable the Court to evaluate and resolve the assignments of error. When the appellant fails to ensure that the record contains transcripts or a written statement of facts necessary to permit resolution of appellate issues related to the assignments of error, any assignments of error affected by the omission will not be considered.”
1 4830-3007-6639, v. 2