Is the Ohio Vexatious Litigator Statute, ORC 2323.52, Unconstitutional on the basis of vagueness and insufficient standards?

QUESTIONS PRESENTED FOR REVIEW 1. Is the Ohio Vexatious Litigator Statue, ORC 2323.52, Unconstitutional on the basis of vagueness and insufficient standards? : Is it subject to abuse on these bases? Does it illegally restrict a party’s First Amendment Right to Court Access and violate Federal law with respect to filing restrictions? 2. Was the Ohio Vexatious Litigator Statute applied in a Constitutional manner with respect to Petitioner? 3. Circuit Splits: The Ohio Vexatious Litigator Statute is in contrast to all other jurisdictions and Federal standards. See 9th Circuit example “Cromer v Kraft Foods Inc.” 390 F.3d 812, infra. It provides no objective criteria by which a party is found to be vexatious or the grounds on which “leave to proceed” can be granted after a party is designated “vexatious”. sss _ wee ‘ ahd ‘ & woe . , "y + tee noe on . . . + . + ’ oh . . . ‘ . . ve on . . 4 . Hy | ii :