Cuyahoga County Court of Common Pleas, General Division Pre-Motion Conference Requirements

Responses to motions in limine are due under Civil Rule 6(c), and reply briefs are not permitted.

Responses due pursuant to Civ. R. 6(c). No replies are permitted.

Parties must confer with the court before filing any discovery motion.

Parties are required to confer with the Court prior to filing any discovery motions (see Discovery Disputes, below).

Before filing a discovery motion, parties must contact the staff attorney and initiate a telephone conference.

Parties are required to contact the staff attorney and initiate a telephone conference prior to filing any discovery motions (motion to compel, motion to quash, motion for protective order, etc.)

Parties must contact the staff attorney before filing a motion to compel.

Parties must contact the staff attorney prior to filing a motion to compel.

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

Prior to any party filing any Discovery Motion, the parties shall contact Judge Russo’s Staff Attorney to set an Attorney Conference either via telephone or in-person with the Court as soon as possible.

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

In accordance with the Court’s Discovery practices, the parties are to contact Judge Russo’s Staff Attorney prior to the filing of any Discovery Motion to set the matter for an Attorney Conference either via telephone or in-person with the Court as soon as possible.

Before filing a Motion to Compel, attorneys must attempt to resolve the discovery dispute and, if unsuccessful, contact the court.

Attorneys shall make all efforts to resolve discovery disputes amongst themselves. If those attempts are unsuccessful, the parties shall contact the court prior to filing a Motion to Compel to help timely resolve any issues.

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

Parties are to contact the Court to schedule a telephone conference prior to filing any motion to compel.

Parties must confer before filing a non-dispositive motion and indicate agreement where possible.

Parties are to confer regarding non-dispositive motions before filing and indicate the parties' agreement where possible.

A motion lacking unanimous consent will be denied if it does not leave sufficient time for a response under Civil Rule 6(c).

Any motion filed without the consent of all other parties will be denied if the motion does not leave time for the other parties to respond pursuant to Civ.R. 6(c).

Counsel seeking a protective order must first make a reasonable effort to resolve the discovery dispute with the requesting attorney or unrepresented party.

Any counsel seeking a protective order must first make a reasonable effort to resolve the matter with the attorney or unrepresented party seeking discovery.

For a motion for summary judgment, the opposition brief is due 28 days after filing and the reply brief is due seven days after the opposition brief, without leave of court.

A Brief in Opposition is due twenty-eight (28) days after the filing of a Motion for Summary Judgment. A Reply Brief is due within seven (7) days after the filing of the Brief in Opposition. No leave of court is required when filing a Reply Brief.

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

A Brief in Opposition is due fourteen (14) days after the filing of a Motion. A Reply Brief is due seven (7) days after the filing of a Brief in Opposition.

Before filing a discovery motion, the parties must contact the Staff Attorney and hold a telephone conference with all other parties.

Parties are required to contact the Staff Attorney and initiate a telephone conference with all other parties prior to filing any discovery motions (motion to compel, motion to quash, motion for protective order, etc.)

For summary judgment, opposition is due within 28 days and reply within 7 days after opposition; oral argument is available upon request, with disposition posted on the docket absent another arrangement.

Pursuant to Civ.R. 6, a brief in opposition is due 28 days after the filing of a motion for summary judgment. A reply brief is due 7 days after the filing of a brief in opposition. An oral hearing on the motion will be set upon request. The Court will try to rule on the motion prior to the final pretrial, if possible. The ruling will be made on the docket unless other arrangements have been made by the parties with the Court.

A motion in limine must be filed at least 28 days before trial, opposition is due 14 days later, and no reply is permitted.

Pursuant to Civ.R. 6, the Court orders that any motion in limine be filed at least 28 days before trial. Any brief in opposition is due 14 days thereafter. No reply shall be permitted.

For motions other than those separately addressed, any opposition is due within 14 days and a reply is due within 7 days after the opposition is filed.

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 a discovery motion, the parties must promptly contact Linda Herman at (216) 443-8580 to arrange a Zoom, telephone, or in-person attorney conference with the court.

Before any party files a discovery motion, the parties shall contact Judge Vodrey’s judicial staff attorney, Linda Herman, at (216) 443-8580 to set an attorney conference either via Zoom, telephone or in-person with the Court as soon as possible.

A motion in limine must be filed at least 28 days before trial, opposition is due 14 days later, and no reply is permitted.

In accordance with Civ.R. 6, the Court orders that any motion in limine be filed at least 28 days before trial. Any brief in opposition is due 14 days thereafter. No reply shall be permitted.

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

If those attempts are unsuccessful, the parties shall contact the court prior to filing a Motion to Compel to help timely resolve any issues.

Parties must confer before filing a nondispositive motion and should indicate their agreement where possible.

Parties are to confer regarding non-dispositive motions before filing and indicate the parties' agreement where possible.

No reply brief is permitted for motions in limine.

No Reply shall be permitted.

The Court will hear merits oral argument if requested; otherwise, it will schedule oral hearings as it deems appropriate.

If requested, the Court will hear oral arguments on the merits of the motion. Otherwise, the Court will schedule oral hearings as it sees fit.

Parties are encouraged, but not required, to resolve discovery disputes themselves before filing a motion.

The parties are encouraged to settle any discovery dispute amongst themselves before filling a motion with the court (motions to compel, motions for a protective order, etc.)

The Court will schedule a settlement or pretrial conference when requested by the parties.

The Court will schedule a settlement conference or pretrial conference upon the request of the parties.

An oral hearing on a motion for summary judgment is available if requested.

An oral hearing on the Motion is available upon request.

The court will attempt to rule on the summary-judgment motion before the final pretrial, ordinarily placing the ruling on the docket unless the parties make other arrangements with the court.

The Court shall make all attempts to issue a ruling on the Motion prior to the Final Pretrial. The ruling will be made on the docket unless other arrangements have been made by the parties with the Court.