Cuyahoga County Court of Common Pleas, General Division Filing Timing and Cure Windows

Deadline

7 calendar days

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

The parties shall file their proposed discovery plan in accordance with Civ.R. 26(F)(3) seven (7) days prior to the CMC.

Deadline

10 calendar days

Written motions in limine must be filed ten days before trial.

Motions in Limine must be in writing and filed ten (10) days before trial.

Deadline

7 calendar days

An opposition brief is due seven days after the motion in limine is filed and at least three days before trial.

A brief in opposition is due seven (7) days after the motion in limine is filed, but no later than three days prior to trial.

Deadline

30 calendar days

Within 30 days after settlement, the parties must submit a joint notice of dismissal identifying who will pay the court costs.

The parties are to submit a joint Notice of Dismissal indicating which party will bear the court costs of the action within 30 days of the settlement agreement.

Deadline

7 calendar days

The court must receive copies of the witness and exhibit lists at least seven days before trial.

The parties are required to provide the court with a copy of all of the above items seven (7) days before trial.

Deadline

7 calendar days

Joint and disputed proposed jury instructions, interrogatories, and verdict forms must be filed at least seven days before trial.

The joint proposed instructions (along with the proposed instructions upon which the parties have been unable to agree), interrogatories, and verdict forms must be filed with the court at least seven (7) days before trial.

Deadline

2 calendar days

Applies to

Objections to jury instructions interrogatories and verdict forms

Any objections to opposing counsel's proposed jury instructions, interrogatories, or verdict forms must be filed at least two days before trial.

Further, counsel must file its objections, if any, to jury instructions, interrogatories, and verdict forms proposed by opposing counsel at least two (2) days before trial.

Deadline

45 calendar days

A Daubert or expert-related motion must be filed by the Court’s deadline or, when no deadline was set, at least 45 days before trial.

Any motion challenging purported expert testimony shall be filed by the Expert Motion deadline set by the Court. If no Expert Motion deadline was set, then any motion challenging purposed expert testimony shall be filed at least forty-five (45) days before trial.

Deadline

7 calendar days

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.

Seven days before the settlement conference, each party shall provide the court with a brief statement outlining the claims to be discussed, the factual support of any disputes, and any offers or settlement discussion had to date.

Deadline

7 calendar days

The parties must exchange trial exhibits no later than seven days before trial.

The parties shall exchange trial exhibits no later than seven (7) days before trial.

Deadline

21 calendar days

motions in limine must be filed 21 days before trial begins.

Motions in limine shall be filed twenty-one (21) days before the start of trial.

Deadline

3 calendar days

The joint notice on unresolved motions in limine must be filed at least three days before trial.

at least (3) days prior to trial, the parties shall file a joint notice informing the Court which motions in limine are unopposed or resolved, and which remain opposed.

Deadline

30 calendar days

Deposition testimony offered instead of a deponent’s attendance must be exchanged by counsel at least 30 days before trial.

Any party wishing to proffer deposition testimony at trial in lieu of the deponent's attendance shall exchange such deposition testimony by counsel at least thirty (30) days in advance of trial.

Deadline

14 calendar days

Any remaining disputed deposition-testimony designations must be sent to the staff attorney at least 14 days before trial.

If any disputes relating to the testimony remain after the good faith conference, the parties shall send hard copies of their respective designations with objections either annotated in the margins or outlined in a separate document to the Court's staff attorney at least fourteen (14) days in advance of trial.

Deadline

7 calendar days

Proposed jury instructions and jury interrogatories are due seven days before trial.

Proposed jury instructions and jury interrogatories are due seven (7) days before trial.

Deadline

1 calendar days

The joint proposed jury instructions must be submitted to the staff attorney at least one day before trial.

The parties shall submit a joint proposed set of jury instructions to the Court's staff attorney at least one (1) day before trial.

After settlement, parties must notify the court as soon as practicable and submit a joint notice of dismissal identifying the party bearing costs within 30 days.

In the event that a case has settled, the parties are to notify the Court as soon as practicable after a settlement agreement has been reached. The parties are to submit a joint Notice of Dismissal indicating which party will bear the court costs of the action within 30 days of the settlement agreement.

Trial briefs are due 14 days before trial and may not exceed three pages.

Trial briefs shall be submitted fourteen (14) days before trial, and shall be no longer than three (3) pages in length.

A motion in limine must be filed at least 14 days before trial.

Motions in Limine must be in writing and filed at least fourteen (14) days before trial.

The opposition brief is due seven days after the motion in limine is filed.

A brief in opposition is due seven (7) days after the motion in limine is filed.

Joint jury instructions, interrogatories, and verdict forms must be filed 14 days before trial.

Fourteen (14) days prior to trial, the parties shall file joint jury instructions, interrogatories, and verdict forms.

Civil motion and pleading deadlines are strictly enforced and calculated in calendar days.

This court strictly construes time allowed on motions/pleadings. All time limitations are calculated on a calendar-day basis.

If a served defendant does not answer or respond, the plaintiff must timely move for default judgment or risk dismissal for want of prosecution.

If the Defendant is served but does not answer or respond to the Complaint, Plaintiff must timely file the Motion for Default Judgment or the Complaint will be dismissed for want of prosecution.

A party must make initial disclosures by the parties’ first pre-trial or case management conference, unless the parties stipulate or the court orders a different time, or a party objects.

A party must make the initial disclosures no later than the parties’ first pre-trial or case management conference, unless a different time is set by stipulation or court order, or unless a party objects.

A party first served or joined after the initial pretrial or case-management conference must make initial disclosures within 30 days unless a different time is stipulated or ordered.

A party that is first served or otherwise joined after the first pre-trial or case management conference must make the initial disclosures within 30 days after being served or joined, unless a different time is set by stipulation or court order.

A continuance motion must be filed on or before the currently applicable deadline.

All requests for continuances must be in the form of a motion, walked up to the 23A on the date of filing, and served on all parties.  Additionally, the request must be filed on or before the date of the existing deadline.

Trial briefs and the listed supporting trial submissions are due no later than two weeks before trial, with courtesy copies provided to the court.

All trial briefs; Proposed Stipulations as to undisputed facts, reserving any objections as to relevance; Exhibits; Jury Instructions; Jury Interrogatories; and Motions in Limine are due no later than two (2) weeks prior to trial and courtesy copies shall be provided to the court.

All exhibits must be submitted to the court no later than two weeks before trial.

Exhibits shall be bound and marked before trial and submitted to the court no later than two weeks prior to trial.

Complete trial briefs must be filed and delivered to the court’s chambers no later than two weeks before trial.

Complete trial briefs shall be filed and delivered to the Court's chambers by no later than two weeks prior to trial.

By two weeks before trial, counsel must identify deposition transcripts to be used and, absent good cause, confer and submit lists of objections requiring rulings and withdrawn objections; failure waives objections.

Counsel must file a list of all filed deposition transcripts that are to be utilized at trial by no later than two (2) weeks prior to trial.  Absent a showing of good cause, counsel must confer and present a list of all objections for which a ruling is desired as well as a list of withdrawn objections on said date.  Failure to submit said list shall result in waiver of all objections.

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

It is the responsibility of plaintiff's counsel to submit the joint document by no later than two (2) weeks prior to trial.

If the parties disagree, each must file separate proposed instructions, stipulations, interrogatories, and verdict forms two weeks before trial and attend the trial-preparation hearing.

If the document is not filed jointly due to disagreement of the parties, each party shall file their proposed instructions, stipulations, interrogatories, and verdict forms two weeks prior to trial, and appear at the trial preparation hearing.

Pleadings, discovery deadlines, dispositive motions, motion responses, and expert deadlines due during the tolling period are tolled.

all pleadings, discovery deadlines, dispositive motions, motion responses, expert deadlines, etc. that are due between March 9, 2020 and the lifting of this order are tolled.

Tolled deadlines resume according to their originally scheduled expiration date after the order is lifted.

All deadlines will resume once the order is lifted in accordance with the date the original deadline was set to expire.

All motions must be filed before the tolled deadline expires.

All motions shall be filed prior to the expiration of the tolled deadline.

Applies to

Motion

A motion in limine must be filed and presented to the judge at least ten days before trial or it will not be entertained.

Motions in limine will not be entertained unless filed and walked up to Judge ten days prior to trial.

All parties must submit a pretrial statement describing settlement discussions to the staff attorney at least seven days before the final pretrial.

All parties must submit a pretrial statement that includes the status of settlement discussions to the staff attorney at least 7 days before the final pretrial.

All pretrial motions, including motions in limine, must be filed at least fourteen days before trial.

Parties must file any pretrial motions, including motions in limine, at least 14 days prior to trial.

Opposition briefs are due seven days before trial.

Briefs in opposition are due 7 days before trial.

The agreed jury instructions, interrogatories, verdict forms, and statement of facts for voir dire must be filed no later than fourteen days before trial.

Parties must file agreed jury instructions, agreed jury interrogatories and verdict forms, and an agreed statement of the facts for voir dire no later than 14 days prior to trial.

Objections to deposition testimony intended for trial, except limited impeachment objections, must be filed ten days before trial with transcript copies.

All objections to deposition testimony to be used at trial, other than for limited impeachment purposes, must be filed 10 days prior to trial with a copy of the transcripts.

Trial briefs with witness and exhibit lists must be filed at least fourteen days before trial.

Trial briefs with witness and exhibit lists must be filed 14 days prior to trial.

Each party must submit the specified pretrial statement at least seven days before the final pretrial.

At least seven (7) days in advance of the Final Pretrial, each party shall submit a statement containing the following: statement of facts, statement of disputed legal issues, stipulations (if any), list of fact witnesses, list of expert witnesses, estimated length of trial, pretrial motions anticipated, and equipment needs at trial.

Counsel and parties must appear at 9:00 a.m. on the first day of trial.

Counsel and parties are to be present at 9:00 am on the first day of trial.

All motions in limine must be filed fourteen days before trial.

Fourteen (14) days before the trial date, all motions in limine are to be filed.

The specified trial filings must be submitted seven days before the trial date.

Seven (7) days before the trial date, the following items are to be filed: responses to any motions in limine, trial briefs, witness lists, exhibit Lists, trial deposition transcripts with a log of objections (if any) and the reason(s) for the objection, stipulations, as well as proposed jury instructions, interrogatories, and verdict forms.

The listed trial-preparation documents must be filed no later than 14 days before trial.

The Court additionally orders that at least 14 days prior to Trial, the parties are to file the following: (1) Trial Briefs, (2) Witness Lists, (3) Exhibit Lists, (4) Joint Jury Instructions, Jury Interrogatories, and /or Jury Verdict Forms if applicable, (5) Stipulations, and (6) an agreed upon State of the Case to be read to the Jury.

A motion in limine must be filed at least 28 days before trial.

In accordance with Civ.R. 6, the Court orders that any Motion in Limine is to be filed at least 28 days before Trial.

An opposition brief to a motion in limine is due 14 days after the motion is filed.

Any Brief in Opposition is due 14 days thereafter.

No reply brief is permitted in response to a motion in limine.

No Reply shall be permitted.

For motions other than summary judgment or in limine, the opposition brief is due 14 days after filing.

Pursuant to Civ.R. 6, a Brief in Opposition is due 14 days after the filing of a Motion.

A summary-judgment opposition brief is due 28 days after the summary-judgment motion is filed.

Pursuant to Civ.R. 6, a Brief in Opposition is due 28 days after the filing of a Motion for Summary Judgment.

A summary-judgment reply brief is due seven days after the opposition brief is filed.

A Reply Brief is due 7 days after the filing of a Brief in Opposition.

A motion in limine must be filed at least 28 days before trial.

Pursuant to Civ.R. 6, the Court orders that any Motion in Limine is to be filed at least 28 days before Trial.

Final pretrial statements must be filed seven days before the settlement conference.

Final pretrial statements to be filed seven days prior to the conference.

A motion in limine is due 28 days before trial, and a response may be served within 14 days after service of the motion.

Motions in Limine are due 28 days prior to the start of trial; any response may be served within 14 days after service of the motion.

Trial briefs, jury instructions, jury interrogatories, jury verdict forms, and stipulations must be received by the court no later than seven days before trial.

No later than 7 days before the trial date, the court must receive from the parties: trial briefs, proposed/agreed jury instructions, jury interrogatories, jury verdict forms, and stipulations.

The parties must exchange proposed exhibits three days before trial.

The parties are to also exchange proposed exhibits 3 days prior to trial.

Objections to testimonial depositions requiring a court ruling must be submitted to the court three days before trial.

Objections for testimonial depositions that require rulings from the Court are to be given to the Court 3 days before the day of trial.

At least seven days before trial, parties must file witness lists, exhibit lists, proposed jury instructions, applicable jury interrogatories or verdict forms, motions in limine, stipulations, and an agreed statement of the case.

At least 7 days prior to trial, the parties are to file the following: Witness lists Exhibit lists Proposed jury instructions Jury interrogatories, and/or verdict forms if applicable Motions in limine Stipulations A concise, mutually-agreed-upon statement of the case to be read to the jury at the outset of trial

A motion in limine must be written and filed ten days before trial.

Motions in limine must be in writing and filed ten (10) days before trial.

Deadline

5 business days

The joint proposed instructions, disputed proposed instructions, interrogatories, and verdict forms must be filed at least five business days before trial.

The joint proposed instructions (along with the proposed instructions upon which the parties have been unable to agree), interrogatories, and verdict forms must be filed with the court at least five (5) business days before trial.

A brief opposing a motion in limine is due seven days after filing, and in all events no later than three days before trial.

A brief in opposition is due seven (7) days after the motion in limine is filed, but not later than three days prior to trial.

All parties must file the listed trial submissions before the final pretrial.

Prior to the final pretrial, all parties are to file the following:

The parties must meet and confer no later than 21 days before the case management conference.

Pursuant to Civ.R. 26, the parties must meet and confer no later than 21 days before the CMC.

The discovery plan must be filed within 14 days after the parties’ conference.

The parties must file a discovery plan within 14 days of their conference.

Initial disclosures must be provided by the case management conference unless the parties agree to a later date.

Each party must provide initial disclosures to the other parties by the date of the CMC unless the parties stipulate to a later date.

A response to a summary-judgment motion is due within 28 days after service, and the reply is due within 7 days after service of the response.

Pursuant to Civ.R. 6(c), amended as of July 1, 2019, responses to motions for summary judgment are due within 28 days of service of the motion for summary judgment, and replies are due within 7 days after service of the response.

Responses to non-summary-judgment motions other than motions in limine are due within 14 days after service.

Responses to all non-summary judgment motions, except motions in limine, are due within 14 days of service of the motion.

Replies to non-summary-judgment motions are due within 7 days.

Any replies are due within 7 days.

Trial briefs, witness and exhibit lists, stipulated jury instructions, motions in limine, and interrogatories must be submitted to the court at least 10 days before trial.

All parties are to submit trial briefs, witness and exhibit lists, stipulated jury instructions, motions in limine, and interrogatories to the Court at least 10 days before trial.

The Notice of Compliance is due within 7 days after the debtor examination or satisfaction of the judgment.

Plaintiff’s counsel is ordered to file a Notice of Compliance within 7 days of the debtor examination or satisfaction of the judgment in order to remove the warrant.

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

Any request for a jury waiver must be filed and served upon opposing counsel and the court no less than 14 days before trial.

Complete trial briefs must be filed with and delivered to the court by noon on the date specified in the order.

Complete trial briefs shall be filed and delivered to the Court by noon on ____________________________________.

Motions in limine and motions to admit must be filed at least seven days before trial and hand-delivered to the court and opposing counsel on the filing date.

Motions in Limine or Motions to Admit must be filed with the Court no less than seven (7) days before trial, and service copies are to be hand-delivered to the Court and opposing counsel on the day of filing.

Any response to a motion in limine or motion to admit must be filed and hand-delivered to the court and opposing counsel at least four days before trial.

Responses, if any, must be filed, and hand-delivered to the Court and opposing counsel no less than 4 days before trial.

Deadline

3 working days

The deposition transcript underlying intended videotaped testimony must be filed with the court at least three working days before trial.

If any party intends to use videotaped testimony at trial, the corresponding deposition transcript upon which this videotaped testimony is based must be filed with the Court at least three (3) working days before trial.

Deadline

3 working days

A party asserting an intention to use videotaped testimony must file any index of objections at least three working days before trial.

Further, when a party timely asserts its intention to use videotaped testimony at trial, this Court requires the filing of an index of objections, if any, at least three (3) working days before trial.

The court must be notified of dismissal or settlement before 3:00 P.M. on the date trial briefs are due if the briefs are not filed.

If trial briefs are not filed on date due, and this Court is not notified of dismissal or settlement before 3:00 P.M. on the date trial briefs are due, fines and sanctions may be imposed pursuant to an Order to Show Cause and subsequent finding of contempt.

The criminal discovery cutoff is seven days before the final pretrial, and all parties must exchange all related discovery by that date.

The court sets the discovery cutoff date 7 days prior to the final pre-trial date. All parties are ordered that they are to exchange all discovery related to this case by this date

Deadline

3 working days

A party that did not timely receive discovery must move to exclude the evidence within three working days after the discovery cutoff.

Any party who has not timely received discovery, within the confines of this order is ordered to file the appropriate motion with the court to exclude evidence, and said motion is to be made within 3 working days of the passage of the cutoff.

Deadline

3 working days

A written motion to extend the criminal discovery deadline must be filed at least three working days before the cutoff.

Any motion to extend the discovery deadline is to be made in writing no less than 3 working days before the discovery cutoff.

All criminal discovery must be completed before the final pretrial date.

All discovery is to be completed before the final pretrial date.

A motion to excuse in-person attendance or request appearance by phone must be filed at least seven days before the scheduled event and state a valid reason.

Failure of any party’s counsel or pro se party to appear in person at a court date, without prior permission of the court excusing attendance, may result in the court dismissing one’s claims with or without prejudice or rendering judgment against a party or sanctions including contempt. Motions excusing attendance or to appear by phone must be filed at least 7 days in advance of the scheduled event and must clearly state a valid reason for the request.

The plaintiff must notify the court within 14 days after entering a forbearance agreement, loan modification, payment plan, or similar settlement, whether before or after judgment.

In the event the debtor enters into a forbearance agreement, loan modification, payment plan or any other similar settlement with the plaintiff, whether it is before judgment or after judgment, the plaintiff must notify the court of said agreement within 14 days of entering such an agreement.

After a foreclosure judgment or decree, the plaintiff must provide the clerk or sheriff with all documents necessary to trigger the property sale within 30 days after judgment.

In the event the court awards plaintiff with a judgment and/or decree of foreclosure, plaintiff is ordered to provide the clerk and/or sheriff with all necessary documents to trigger the sale of the within property within 30 days of the date of the court's judgment.

If the property remains unsold, the plaintiff must file a subsequent praecipe for sale within 30 days after the sheriff reports the property unsold, repeating the process until sale, good cause, and docketed entry.

If the property is unsold, plaintiff will be required to file a subsequent praecipe for sale, within 30 days after the sheriff’s return reporting the property as unsold, until the property is sold or good cause is shown and the court dockets such an entry.

A bankruptcy notice must include a copy of the bankruptcy docket, and the court must be notified within 15 days after the automatic stay is lifted through a properly filed reactivation motion stating the lift date.

Notices of Bankruptcy filed with the court must have attached to them a copy of the bankruptcy docket. Cases stayed due to bankruptcy may be returned to the active docket only upon a properly filed motion that states the date on which the automatic stay was lifted. Court to be notified of the lifting of a bankruptcy stay within 15 days of same.

A defendant intending to pursue loss mitigation must submit a complete loss mitigation packet to the plaintiff or loan servicer within 60 days after the complaint is filed.

17. In the event the defendant intends to pursue loss mitigation, he or she must submit a complete loss mitigation packet to the plaintiff or loan servicer within 60 days of the filing of the complaint.

For all default hearings, the Plaintiff’s attorney must file the listed materials with the Clerk at least seven days before the hearing.

For all default hearings, the Plaintiff’s attorney is required to file the following with the Clerk no less than 7 days before the scheduled hearing date:

Deadline

7 calendar days

Required

Always

A filer must correct and refile a rejected filing within seven calendar days.

Whenever a filing is rejected, the filer has seven (7) calendar days to correct the error and refile.

All pleading-filing deadlines were suspended as of March 9, 2020, with the tolling period ending when the COVID-19 Emergency ended or July 30, 2020, whichever occurred first, after which the remaining time under the Civil Rules applied.

"Pursuant to the Ohio Supreme Court’s 03/27/2020 Administrative Actions Order, all time requirements for filing all pleadings (including answers, motions, responsive briefing, etc.) have been suspended and tolled as of 03/09/2020. (2020-Ohio-1166, https://www.supremecourt.ohio.gov/rod/docs/pdf/0/2020/2020-Ohio-1166.pdf). The tolling period shall expire on the date the COVID-19 Emergency ends or 07/30/2020, whichever is sooner. At that time, the parties shall have the remaining time applicable under the Civil Rules in which to file their pleading.

The COVID-19 tolling order does not apply to specific court orders issued on or after March 9, 2020.

The Court notes that the tolling order does not apply to specific orders of this Court that were issued on or after 03/09/2020

For cases involving pro se defendants, an answer due after March 9, 2020 was tolled through the duration of the order.

For cases especially involving pro se Defendants, the Court notes that any Answer that was/is due after 03/09/2020 through the duration of the Order is tolled.

When a defendant’s answer was due before March 9, 2020 but the plaintiff files a default-judgment motion, the Court will hold its ruling pending the defendant’s response or until the tolling and response periods have expired.

If a Plaintiff proceeds forward in filing a Motion for Default Judgment in a case in which the Defendant’s Answer was due prior to 03/09/2020, the Court shall hold its ruling in abeyance pending any response to the Motion by Defendant or until the tolling period has expired and the Defendant’s response time has expired.

Plaintiff must communicate its demand to defendant at least 14 days before the final pretrial conference.

Plaintiff shall communicate a demand to the defendant at least fourteen (14) days prior to the final pretrial conference.

The parties must provide the listed proposed or agreed trial materials to the court no later than 14 days before trial.

No later than fourteen (14) days before the trial date, the court must receive from the parties proposed/agreed jury instructions, jury interrogatories, jury verdict forms, trial briefs, witness lists, and stipulations.

The parties must exchange proposed exhibits seven days before trial.

The parties are also to exchange proposed exhibits seven (7) days prior to trial.

Deadline

3 business days

Objections to testimonial depositions requiring a court ruling must be submitted to the court at least three business days before trial.

Objections to testimonial depositions that require rulings from the court are to be given to the court at least three (3) business days before the scheduled trial date.

Deadline

2 business days

Within two business days after objections are filed, counsel must either file a brief supporting use of the deposition testimony or indicate agreement to delete the objected-to portion.

Counsel proposing to use the deposition testimony shall file a brief in support within two (2) business days after the objections are filed or indicate an agreement to delete the portion for which there is an objection.

Motions in limine must be filed 28 days before trial, and responses must be served within 14 days after service of the motion.

Motions in limine are due twenty-eight (28) days prior to the start of trial and responses must be served within fourteen (14) days after service of the motions.

Responses to motions in limine must be served within 14 days after service of the motion.

Responses must be served within fourteen (14) days after service of the motions.

All time requirements for civil case filings were suspended and tolled beginning March 9, 2020.

Pursuant to the Ohio Supreme Court’s 03/27/2020 Administrative Actions Order, all time requirements for civil case filings have been suspended and tolled as of 03/09/2020.

The Court will not rule on an unopposed motion until both the tolling period and the opposing party’s response period have expired.

The Court will not rule on any unopposed motions, unless the motion is otherwise designated as unopposed, until after both the tolling period and the opposing party’s response time have expired.

A default-judgment motion tied to a responsive pleading due before March 9, 2020 will not be ruled on or scheduled for hearing until tolling and the opposing party’s response period expire.

If a Plaintiff proceeds forward in filing a Motion for Default Judgment in a case in which an Answer or responsive pleading was due prior to 03/09/2020, the Court shall hold its ruling in abeyance and will not schedule the matter for a hearing until the tolling period and the opposing party’s response time have expired.

A motion in limine must be filed no later than ten days before trial.

Any motions in limine shall be filed no later than ten days prior to trial.

Responses to a motion in limine are due seven days after filing, or three days before trial.

Pursuant to Loc.R.11(C), all responses are due seven thereafter, or three days prior to trial.

A motion in limine must be filed seven days before trial.

Motions in Limine: Motions in Limine must be filed 7 days prior to trial.

An emergency motion and its filing must be telephoned to the court and opposing party or counsel as soon as possible, and avoidable delay may reduce the likelihood of success.

The filing of an emergency motion shall be brought to the attention of the Court and of the opposing party or counsel as soon as possible by telephone. Avoidable delays in filing the motion, or in the proponent’s drawing attention to its filing, may make it less likely that the motion will be granted.

The parties must file a discovery plan no later than 14 days after their conference.

The parties shall file a discovery plan within 14 days of their conference.

Deadline

14 calendar days

The required trial-preparation filings must be submitted at least 14 days before trial.

The Court additionally orders that at least 14 days prior to trial, the parties are to file the following: (1) trial briefs, (2) witness lists, (3) exhibit lists, (4) joint jury instructions, jury interrogatories, and/or jury verdict forms if applicable, (5) stipulations, and (6) a concise, mutually-agreed-upon statement of the case to be read to the trial jury at the outset of trial.

The Court schedules a default hearing after a motion for default judgment is filed.

Upon filing of a motion for default judgment, the Court will schedule a default hearing.

The Court may strike motions or briefs that are untimely.

Untimely motions and/or briefs may be stricken by the Court.

The parties must notify the Court as soon as practicable after reaching a settlement.

In the event that a case has settled, the parties are to notify the Court as soon as practicable after a settlement agreement has been reached.

A motion for default judgment should be filed within fourteen days after the defendant’s answer period expires.

Motions seeking default judgment should be filed within 14 days of the expiration of the defendant’s answer time.

Deadline

2 business days

A party should file any objections to another party’s proposed jury instructions, interrogatories, or verdict forms no later than two business days before trial.

Each party should file its objections, if any, to jury instructions, interrogatories, and verdict forms proposed by any other party no later than two (2) business days before trial.

The Court will process submitted cognovit documents as soon as possible, within seven days.

The Court shall process the documents as soon as possible within 7 days.

Trial briefs, witness lists, proposed jury instructions, motions in limine, deposition-objection rulings, and stipulations should be filed seven days before trial with a courtesy copy delivered to the court.

Trial briefs, witness lists, proposed jury instructions, motions in limine, requests for rulings on deposition objections and stipulations should be filed 7 days before trial with a courtesy copy delivered to the court

Trial briefs, witness lists, and motions in limine should be filed seven days before a court trial, while proposed findings of fact and conclusions of law must be submitted as ordered at the conclusion of the bench trial or hearing.

Trial briefs, witness lists and motions in limine should be filed 7 days before trial; proposed findings of fact and conclusions of law are to be submitted in conformance with court order at the conclusion of a bench trial or hearing.

If the opposing party does not respond during the tolling period, the Court will hold the motion in abeyance until both the tolling period and the opposing party's response period have expired.

However, if the opposing party does not respond in electing to have the matter tolled, then the Court shall hold the Motion in abeyance until the tolling period has expired and the opposing party’s response time has expired.

The Court may schedule and conduct oral argument on pending summary-judgment motions, with argument time parameters set by Judge Kelley.

The Court may schedule and conduct an oral argument on pending motions for summary judgment. The time parameters for argument shall be set by Judge Kelley.

A party may file a brief written reply supporting its proposed jury instructions on the day of trial.

Any party may, if it chooses, submit a brief written reply in support of its proposed instructions on the day of trial.