Judge Daniel E. Haughey
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Motion
Court-wideMotion to Seal
Court-wide- Upon Filing
Suggestion of Complex Litigation
Court-wideDocument Format Requirements2 rules
Joint jury instructions are required to be submitted in writing and electronically in Microsoft Word, at least two (2) weeks before trial.
- File type
- Word
- Jury instructions
Each party’s set of materials shall be placed in a binder or cover.
- Trial materials
Formatting
- •Place each party’s set of trial materials in a binder or cover
Document Filing Requirements12 rules
Each party shall prepare a pretrial statement which shall contain the following: (1) A concise statement of its claims and defenses;
Each party’s pretrial statement must include specified facts and issues, witness and expert information, an exhibit list using designated numbering, previously unfiled motions in limine, alleged special damages, and the expected trial time.
Court's wording
(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.
If there is a particular legal or evidentiary issue which any party wishes to bring to the court’s attention, a short memorandum with pertinent cases attached is expected.
The court expects the parties, before the trial, to have briefed the court on all legal issues related to the trial.
Filing & Service rules
Filing Timing and Cure Windows
Proposed findings of fact and conclusions of law must be submitted electronically at least one week before a bench 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.
Civil cases
Page 3 | F. ISSUES TRIED TO THE COURT
Joint jury instructions must use the Microsoft Word file format and be submitted electronically at least two weeks before trial.
Joint jury instructions are required to be submitted in writing and electronically in Microsoft Word, at least two (2) weeks before trial.
Civil cases
Page 3 | E. JURY INSTRUCTIONS
The elements-to-be-proved memorandum for each bench-trial claim must be submitted electronically at least one week before trial.
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.
Civil cases
Page 3 | F. ISSUES TRIED TO THE COURT
The pretrial-statement deadline may be extended only with leave of court.
This deadline cannot be extended except by leave of court.
Civil cases
Page 3 | D. PRETRIAL STATEMENTS
An objection to the admission or use of trial material must be filed before 4:00 p.m. on the indicated date, and a copy must be contemporaneously delivered to the court’s chambers.
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.
Civil cases
Page 4 | H. TRIAL MATERIALS EXCHANGE
Transcripts and video depositions are due to the Clerk’s office before trial begins.
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.
Civil cases
Page 5 | J. TRIAL
Service and Proof of Service Rules
A separate set of trial materials must be delivered to opposing parties or their attorneys and to the court before 4:00 p.m. on the date specified in the pretrial order.
Separate sets of materials shall be delivered to opposing parties, or their attorneys, and to the court before 4:00 p.m. on the date indicated in the pretrial order.
Civil cases
Page 4 | H. TRIAL MATERIALS EXCHANGE
A contemporaneous copy of each written objection must be delivered to the court’s chambers.
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.
Civil cases
Page 4 | H. TRIAL MATERIALS EXCHANGE