Cuyahoga County Court of Common Pleas, General Division Filing Rules

When directed by the Court, counsel must prepare and submit a journal entry within ten days unless the court extends the time, and opposing counsel must approve or reject it within three days after receipt.

In specified foreclosure cases, the plaintiff must complete the court-prescribed Residential Property Status Report with a recent color photograph and file and hand-deliver it to courtroom 18-C on the filing date.

Before the default-judgment hearing, plaintiff’s counsel must provide the Court with the correspondence sent to the defendant stating the hearing’s date and time.

All parties and their chosen representatives must attend the final pretrial with full, final, and immediate settlement authority.

Each party must serve and file a trial brief at least one week before the scheduled trial date, with specified required content.

The clerk rejects electronic filings exceeding the size limit, which must instead be filed in paper format.

A jury-waiver request must be filed and served on opposing counsel and the court at least 14 days before trial.

Plaintiff’s counsel is responsible for submitting the joint proposed jury document no later than two weeks before trial.

The parties must file their proposed discovery plan at least seven days before the CMC.

Seven days before a settlement conference, each party must provide a statement covering the claims for discussion, factual basis of disputes, and prior offers or settlement discussions.

The security deposit is $1,100 for the first order of sale in a case and $600 for each subsequent order.

A filing fee is required for a debtor-examination submission.

A continuance must be granted when a party, counsel, or subpoenaed witness is scheduled to appear on the same date at a specified Supreme Court disciplinary proceeding in one of the listed capacities.

The court will not consider untimely requests to continue or excuse appearance absent an exigent circumstance or unforeseen emergency.

Requests to modify the case-management schedule must be made by joint or unopposed motion and include proposed dates.

By mutual agreement, parties may extend a discovery deadline, but the extension may not alter any other court-scheduled event, deadline, or mediation.

An extension of another case-management date or deadline must be requested by motion stating the requested continuance length and reason.

When the court requires a client to attend a withdrawal hearing, counsel must notify the client of the hearing date and time by certified mail with return receipt requested.

The motion must be served on the Court and opposing counsel when it is filed.

The movant must bring the affidavit of damages, prepared journal entry, and copy of the hearing notice letter sent by regular and certified mail 7 days before the hearing.

A plaintiff must give written notice of the default hearing to all opposing parties by regular mail and certified mail, return receipt requested, at least five days before the hearing.

Service on a nonresident pro hac vice attorney must also be made on local counsel, and service on local counsel is deemed service on the nonresident attorney.

All pleadings, motions, and other filings must use letter-sized white paper, with typed documents double-spaced in 12-point font, subject to stylistic variation in block quotations and footnotes.

An electronic Excel copy of every Excel attachment to a filing or trial exhibit must be emailed to the staff attorney.

Trial exhibits must be pre-marked with exhibit stickers; plaintiffs use numbers and defendants use letters.

Exhibits must be marked before trial using party-specific numbering or lettering conventions and the applicable exhibit stickers.

Counsel should place exhibits in three-ring binders with marked divider tabs, and each binder must include a table of contents.

A litigant unable to access e-filing may contact the clerk at 217-558-4400.

For a deposition dispute requiring immediate court assistance, the parties may call the staff attorney only jointly.

Criminal-case questions should be directed to the bailiff during business hours.

Initial case management conferences in Commercial Docket cases are conducted in person with Judge Russo.

Before filing a motion to compel or motion to quash, the parties must contact the staff attorney at 216-443-7326 to schedule a telephone conference.

Counsel must submit every entry of appearance in writing through electronic filing.

Paper copies of pleadings may be submitted to the clerk's office when e-filing is unavailable.

Civil and criminal motions must be filed electronically and appear on the court’s filing queue.

Proposed orders may optionally be submitted through the Clerk of Court’s electronic filing system.

One courtesy copy of every pleading must be delivered to Chambers in room 18C on its filing date, and e-filing does not replace that requirement.

Courtesy copies of dispositive motions must be delivered to the judge’s chambers on the filing date.

Courtesy copies must be provided to the court for every motion exceeding 10 pages.

A courtesy copy of the listed jury-trial submissions should be delivered to the court with the filings.

Counsel must provide the Court with a courtesy copy whenever a motion is filed.

Before filing a Motion to Compel, parties must contact the court if their efforts to resolve the discovery dispute were unsuccessful.

Pursuant to Civ.R. 6, a response and brief in opposition, if any, is due 14 days after the filing of a motion. A reply brief is due 7 days after the filing of a brief in opposition.

Before filing any discovery motion, the parties must promptly contact the Staff Attorney to arrange a telephone or in-person attorney conference.

When discovery disputes reach an impasse, a judge may require a court hearing before the parties may file a motion to compel.

Parties must schedule a telephone conference with the court before filing a motion to compel.

Social security numbers and all other personal identifying information must be redacted before filing, including from attached exhibits and addenda.

A party seeking to file an agreed confidential document must move for sealing, and the court will decide the request case by case.

Every criminal motion other than a discovery motion must be delivered to the court on its filing date.

The investigator’s bill must be filed with assigned counsel’s attorney-fee application and paid as part of counsel’s expenses.

When an opposing party responds to a motion, the Court will rule only after the matter is fully briefed.

Trial briefs may not exceed 10 pages unless good cause is shown and the court grants leave.

Trial briefs may not exceed three pages.

Final pretrial statements, including exhibits, may not exceed 10 pages.

The Court encourages active participation by less-experienced lawyers and may allow bifurcated oral argument or relax the one-lawyer-per-witness rule to facilitate it.