IN THE COURT OF APPEALS, STATE OF OHIO   
 
       ELEVENTH APPELLATE DISTRICT, COUNTY OF GEAUGA 
 
 
GAIL S. BRAHIER              : CASE NO. 92-G-1705 
 
         PLAINTIFF-APPELLEE  : CT. NO. 91-DC-000792 
- vs - 
                             : MOTIONS FOR/TO: 
MAURICE E. BRAHIER 
                             : 1. LEAVE TO SUBMIT MOTION(S) 
         DEFENDANT-APPELLANT   
                             : 2. INVOKE SAVINGS OF; OR 
                             :    SUBMIT CIV R 60(B) DUE TO 
                             :    TIME LIMITATIONS AND/OR 
                             :    HOLD MOTIONS UNTIL 
                             :    JUDGEMENT ON APPEAL; OR 
                             :    SUBMIT MOTIONS TO COURT OF 
                             :    COMMON PLEAS- ACTION ON  
                             :    MOTIONS HELD PENDING  
                             :    DETERMINATION OF APPEAL 
 
                             :  ATTACHED COURT OF COMMON 
                             :  PLEAS MOTIONS 
________________ 
 
MOTION 1  
 
  I, being the defendant in this action, come before this 
 
court to request leave to submit these requests/motions/ 
 
petitions to protect and maintain rights provided under law. 
 
 I request this leave be granted. 
 
  
 MOTION 2  
 
  I, come before this court to request that these requests/ 
 
motions/petitions be introduced in the within action to 
 
protect a measure of right under law. 
 
 This request for submission of these motions/documents will 
 
protect my rights under law to equitable relief should this 
 
court find it is unable to address the items at appeal or 
 
other. These motions are presented pursuant to the limitation 
 
imposed by the laws of this state for a one (1) year 
 
submission of this motion concerning Civ R 60. 
 
 I, request that this court either hold these motions- 
 
attached to this document, preserving the right to entertain 
 
Civ R 60; or present them to the Court of Common Pleas for 
 
preservation of right to relief in that court, directing a 
 
hold to that court pending determination of appeal, this 
 
court does have final judgements or orders and other aspects 
 
of this case which it may review before remand or other. 
 
 These requests appear to be within the laws of this state 
 
and may be addressed either through appellate rules or  
 
discretional authority invested in this court by the 
 
constitution of this state. 
 
 
 I further submit that my pleadings to this court are closed, 
 
this court may proceed to order presentation of records 
 
before it for a determination or otherwise proceed with this 
 
appeal on merit or other. 
 
                              _______________________________ 
                              MAURICE E. BRAHIER 
                              137 MOFFET AVE. 
                              CHARDON, OHIO 44024 
 
 I certify that I have sent or otherwise produced these 
documents submitted this _______ day of March, 1993, to the 
attorney of record for the plaintiff-appellee. 
 
 
 
Civ60(b).txt                                     page ~ of