OJL QRP, LLC v. IN 123 Rentals LLC

Indiana Court of Appeals·Decided July 15, 2026·No. 25A-CE-03217·Published·Judge Tavitas

Opinion

FILED Jul 15 2026, 9:17 am

CLERK Indiana Supreme Court Court of Appeals and Tax Court

IN THE

Court of Appeals of Indiana OJL QRP, LLC, Appellant-Defendant

v.

IN 123 Rentals LLC, Appellee-Plaintiff

July 15, 2026 Court of Appeals Case No. 25A-CE-3217 Appeal from the Lake Superior Court The Honorable John M. Sedia, Judge Trial Court Cause No. 45D01-2508-CE-59

Opinion by Chief Judge Tavitas Judges Bradford and Felix concur.

Court of Appeals of Indiana | Opinion 25A-CE-3217 | July 15, 2026 Page 1 of 17 Tavitas, Chief Judge.

Case Summary [1] IN 123 Rentals, LLC (“IN 123”) filed a complaint against OJL QRP, LLC

(“OJL”), seeking specific performance of a lease-to-purchase option agreement

(“Agreement”). OJL’s attorney entered an appearance five days after the

deadline to answer IN 123’s complaint, and IN 123 moved for default

judgment. OJL opposed the motion and sought an enlargement of time,

arguing excusable neglect based on a breakdown in communication. The trial

court granted default judgment to IN 123. OJL appeals, and we reverse and

remand.

Issue [2] OJL raises one issue, which we restate as whether the trial court abused its

discretion by granting IN 123’s motion for default judgment and effectively

denying OJL’s motion for enlargement of time. 1

Facts [3] OJL and IN 123 were parties to the Agreement dated October 20, 2020,

concerning real property located in Gary. Under the Agreement, IN 123 was

1 In its order, the trial court granted only the relief requested by IN 123, including default judgment, and did not expressly rule on OJL’s motion for enlargement of time. The trial court, however, expressly rejected OJL’s argument of excusable neglect that the delayed pleading resulted from a breakdown in communication between OJL and its attorney. We, therefore, construe the order as denying OJL’s motion for enlargement of time.

Court of Appeals of Indiana | Opinion 25A-CE-3217 | July 15, 2026 Page 2 of 17 the lessee with an option to purchase, and OJL was the lessor. On August 20,

2025, IN 123 filed a complaint against OJL seeking specific performance of the

Agreement to purchase the real property. IN 123 served the complaint and

summons on OJL by certified mail on August 26, 2025. A responsive pleading

was due on or before September 18, 2025.

[4] OJL had previously been represented in Indiana real estate litigation by

Attorney Tramel Raggs. At the time of those prior representations, Attorney

Raggs was associated with Harris Law Firm, P.C., and used an email address at

that firm. On August 30, 2025, however, Attorney Raggs separated from Harris

Law Firm, P.C., to begin his own practice. After OJL was served with the

complaint, OJL forwarded correspondence regarding the lawsuit to Attorney

Raggs at the firm email address it had on file, as it had done in prior matters.

That email address, however, was no longer in use or actively monitored. 2 OJL

subsequently made contact with Attorney Raggs and retained him in the

matter, and Attorney Raggs entered his appearance for OJL on September 23,

2025, which was five days after the deadline to file a responsive pleading.

[5] On September 24, 2025, the day after Attorney Raggs entered his appearance,

IN 123 filed a motion for default judgment, asserting that OJL had failed to file

a timely responsive pleading. On October 9, 2025, OJL filed a response in

2 The record does not contain the specific date on which OJL successfully contacted Attorney Raggs and retained him in this matter. In OJL’s unverified motion in opposition to default judgment, OJL asserted that its initial contact with Attorney Raggs was made “[p]rior to that [] due date, but after service of the Complaint.” Appellant’s App. Vol. II p. 22. IN 123 did not dispute this fact.

Court of Appeals of Indiana | Opinion 25A-CE-3217 | July 15, 2026 Page 3 of 17 opposition to the motion for default judgment and a motion for enlargement of

time to file a responsive pleading pursuant to Indiana Trial Rule 6(C)(2). See

Appellant’s App. Vol. II p. 3. OJL argued that its failure to timely respond

resulted from “excusable neglect,” namely, a “breakdown in communication”

between OJL and Attorney Raggs after he departed from his prior firm. Tr.

Vol. II pp. 6-7.

[6] On December 11, 2025, the trial court held a hearing on the motions, at which

both parties appeared by counsel and presented argument. On December 12,

2025, the trial court entered an order granting IN 123’s motion for default

judgment, which effectively denied OJL’s motion for enlargement of time. The

trial court’s order expressly rejected OJL’s excusable neglect argument, and

stated in its written order, “[i]f being a CPA during tax season and COVID-19

concerns or being a doctor and failing to read email are insufficient to overcome

the burden to demonstrate entitlement to relief from judgment . . . so too is

OJL’s lack of diligence in ascertaining its counsel’s whereabouts and timely

contacting him.” Appellant’s App. Vol. II p. 7. IN 123 did not challenge

Attorney Raggs’s statements regarding the delay at the hearing, and the trial

court accepted those facts as true in its written order. See id. at 3 n.1.

[7] The trial court’s order required OJL to close on the property within ten days,

awarded IN 123 court costs, and preserved IN 123’s ability to seek additional

damages, including attorney fees, after closing. Id. at 7-8. On December 18,

Court of Appeals of Indiana | Opinion 25A-CE-3217 | July 15, 2026 Page 4 of 17 2025, OJL filed a Motion to Stay Judgment Pending Appeal. 3 Id. at 4. OJL

filed its Notice of Appeal on December 19, 2025. Id. IN 123 represents on

appeal that the parties closed on the property on December 22, 2025, within the

ten-day period allowed by the default judgment for completing the transaction,

and that the deed was recorded on January 29, 2026. 4 See Appellee’s Br. p. 13.

Discussion and Decision Standard of Review

[8] The parties dispute the standard of review governing this appeal. OJL argues

that we should review this appeal de novo because the trial court reached its

decision on a paper record and without evidentiary hearing. IN 123 argues that

the trial court held a hearing at which OJL presented its argument and that,

thus, the proper standard is abuse of discretion. We agree with IN 123. “Our

standard of review for a trial court’s decision regarding a default judgment is

well-settled.” Whetstine v. Menard, Inc., 161 N.E.3d 1274, 1279 (Ind. Ct. App.

2020). “We review a trial court’s decision to enter a default judgment for an

abuse of discretion.” Expert Pool Builders, LLC v. Vangundy, 224 N.E.3d 309, 312

(Ind. 2024).

3 The trial court granted OJL’s Motion to Stay the Default Judgment on March 24, 2026, more than three months after OJL filed its Notice of Appeal. 4 These events are not reflected in the record on appeal. We recount IN 123’s representations only to frame its mootness argument.

Court of Appeals of Indiana | Opinion 25A-CE-3217 | July 15, 2026 Page 5 of 17 [9] Here, the trial court held a hearing at which both parties, through counsel, had

the opportunity to present their arguments. OJL argued that the belated

pleading resulted from a breakdown in communication between OJL and

Attorney Raggs and argued that this breakdown constituted excusable neglect

under Indiana law. OJL explained that Attorney Raggs was associated with his

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