Paulding County Court of Common Pleas, Ohio Pre-Motion Conference Requirements

CRITICAL

Outside domestic-relations matters, motion responses may be filed by day 14 and replies by day 21 after filing; the motion is then submitted without oral argument unless counsel requests argument in writing, and summary-judgment motions are excluded.

The opposing counsel or a party may file a response by the fourteenth day after the day on which the motion was filed. The moving party may file a reply brief by the twenty-first day following the day on which such motion was filed. On the twenty-first calendar day after the motion was filed, the motion shall be deemed submitted without oral argument unless requested in writing by counsel. This rule shall apply to all motions including motions for new trial, motions for judgment notwithstanding the verdict, and motions for reconsideration but shall not apply to motions for summary judgment.

CRITICAL

Counsel must confer in good faith with opposing counsel before serving a discovery motion to determine whether informal discussion can resolve the issue.

Before a party may serve any discovery motion, counsel must confer in good faith with opposing counsel to determine if informal discussion may resolve the discovery issue before filing said motion.

CRITICAL

Counsel must exhaust extrajudicial means to resolve discovery disputes before filing discovery-related papers under Civil Rules 27 through 37.

No objections, interrogatories, motions, applications or requests related to discovery shall be filed under provision of Civil Rules 27 to 37 in the Court unless counsel have exhausted all extrajudicial means for the resolution of differences.

WARNING

Discovery interrogatories and requests should not be filed unless informal out-of-court discovery efforts are ineffective and a motion to compel is necessary.

It is also intended that Interrogatories and Requests shall not be filed with the Court except in those cases where informal, out-of-court attempts at discovery are ineffective and it becomes necessary to file a Motion to Compel Discovery under the provisions of Rule 37(A), Ohio Rules of Civil Procedure.