Judge Daniel E. Haughey

Joint jury instructions are required to be submitted in writing and electronically in Microsoft Word, at least two (2) weeks before trial.

Each party’s set of materials shall be placed in a binder or cover.

Each party shall prepare a pretrial statement which shall contain the following: (1) A concise statement of its claims and defenses;

(2) Those facts established by admissions in the pleadings, admissions by discovery, and stipulations of counsel; (3) The contested issues of fact; (4) The contested issues of law, with citations of authority for the party’s position; (5) The names and addresses of fact witnesses, together with a brief statement of the subject matter of each witness’s testimony and a brief summary of the anticipated testimony; (6) The names, addresses, and qualifications of expert witnesses expected to testify, together with a brief statement of the subject matter of each witness’s testimony and a brief summary of the anticipated testimony; (7) A list of exhibits which each party intends to offer into evidence, marked as follows: (a) Joint exhibits with Roman numerals, (b) Plaintiff’s exhibits with Arabic numerals, (c) Defendant’s exhibits with letters; NOTE: Each list of exhibits shall be set forth on an “Itemized Evidence Inventory Form.” This form can be obtained on the internet at www.commonpleascourt.bcohio.gov , under the heading “Court Forms/Evidence.” (8) Motions in limine not previously filed; (9) A list of all special damages being alleged; (10) Each party’s expectation of the trial time needed to present its side of the case;

Joint jury instructions are required to be submitted in writing and electronically in Microsoft Word, at least two (2) weeks before trial.

In lieu of jury instructions, for any issue to be tried to the court, each party shall submit to the court, in writing and electronically, at least one week before trial, proposed findings of fact and conclusions law.

The pretrial statements shall be delivered to the court’s chambers no later than 4:00 p.m. on the date indicated.

For each claim to be tried to the court, each party shall submit to the court, in writing and electronically, at least one week before trial, a memorandum setting forth the elements to be proved to establish such claim.

If the parties cannot agree on jury instructions, then each party must submit its proposed jury instructions as described above.

Objections to the admission of exhibits or to the use of other material must be made in writing and filed before 4:00 p.m. on the date indicated, and a copy of the objection shall be contemporaneously delivered to the court in chambers.

Each objection shall include both the grounds for the objection and a brief citation of authority.

The parties, or their attorneys, are responsible for insuring that all transcripts and video depositions are filed with the Clerk’s office prior to trial.