In Phillips v. Rayburn (1996), 113 Ohio App.3d 374, 680 N.E.2d 1279, the trial court took judicial notice of the plaintiff's judgment of conviction in a criminal case, and applied collateral estoppel to preclude the plaintiff from relitigating the issue in subsequent civil case. The appellate court held that the trial court erred in taking judicial notice of its judgment in another case; instead, the criminal judgment of conviction should have been incorporated into the motion for summary judgment by way of affidavit was required by Civ.R. 56(C). Phillips.