Judge Andrew J. Santoli
Individual Rules, Standing Orders & Policies
Limits & Logistics
Courtesy Copies
Motion
- Upon Filing
Adjournments
- Continuances and extensions are granted only when good cause is shown.
- Extensions of court-ordered deadlines should be requested by joint or unopposed motion when possible.
- Before filing an extension motion, counsel must consult opposing counsel and state that position in the motion.
Request must include
Communication
Phone
Court-wideClerk
Document Format Requirements3 rules
In addition to hard copies, proposed jury instructions, including the stipulated statement of the case, jury interrogatories, and verdict forms are to be provided to the Court in a Microsoft Word document via email sent to the court’s staff attorney.
- File type
- Word
- Jury instructions
- Stipulated statement of case
- Interrogatories
- Verdict forms
Jury instructions must conform to Ohio Judicial Instructions or cite published Ohio cases, address the issues at trial, and be short, concise, understandable, and neutral.
- Jury instructions
Formatting
- •Instructions must be relevant to the specific issues presented at trial
Court's wording
Counsel shall provide jury instructions that conform to OJI or cite to published Ohio cases. Counsel shall provide jury instructions that are relevant to the specific issues to be presented at trial. All instructions should be short, concise, understandable and neutral statements of law.
Trial exhibits shall be pre-marked with exhibit stickers and exchanged. Plaintiffs shall mark their exhibits using numbers; defendants shall mark their exhibits using letters.
- Exhibits
Formatting
- •Plaintiffs shall mark exhibits using numbers
- •Defendants shall mark exhibits using letters
Document Filing Requirements8 rules
The parties shall exchange, serve, and file witness lists which shall include the witnesses' names and a very brief statement outlining the substance of each witness' expected testimony.
At the default hearing, the movant must bring an affidavit of damages, a prepared journal entry, and proof of a mailed hearing notice.
Court's wording
The movant must bring to the hearing the following: affidavit of damages, a prepared journal entry, and a copy of the letter sent regular and certified mail 7 days prior to the hearing date notifying all parties of the hearing and that failure to appear will result in judgment against them.
The parties shall exchange, serve, and file a list of trial exhibits.
Each party must serve and file a trial brief containing the specified claims, facts, issues, stipulations, damages, and trial-time estimate.
Court's wording
All parties are required to serve and file a trial brief which shall contain: a succinct statement of their claims (as presented in the pleadings); a brief statement of the essential and material facts; the legal issues involved; the stipulations agreed upon by the parties; the type and amount of damages they are seeking; and an estimate of how long it will take to put on their case in chief.
In its objection, counsel shall highlight the objectionable language and include a concise argument as to why the proposed language is improper.
Attorneys must confer before the CMC to discuss claims and defenses, settlement possibilities, discovery, and a proposed schedule.
Court's wording
In accordance with Civ.R. 26(F), the attorneys shall confer prior to a scheduled Case Management Conference (“CMC”) to discuss claims and possible defenses, the possibilities for resolving and/or settling the case, create a discovery plan, and establish a proposed case schedule.
The Court will not consider proposed jury instructions that are deemed argumentative or which otherwise do not conform to the above requirements.
The parties should then confer in order to agree on a single set of instructions to the extent possible.
Filing & Service rules
Filing Timing and Cure Windows
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.
Page 1 | Jury Instructions, Interrogatories, Verdict Forms
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.
Page 1 | Motion Practice
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.
Page 1 | Witness and Exhibit Lists
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.
Page 1 | Settlement Conference
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.
Page 1 | Civil Case Management Order
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.
Page 1 | Motion Practice
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.
Page 1 | Jury Instructions, Interrogatories, Verdict Forms
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.
Page 1 | Settlement Conference
The Court may strike motions or briefs that are untimely.
Untimely motions and/or briefs may be stricken by the Court.
Page 1 | Motion Practice
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.
Page 1 | Default Judgment
Service and Proof of Service Rules
Trial briefs must be served and filed at least seven days before trial.
Trial briefs shall be delivered seven (7) days before trial.
Page 1 | Trial Briefs
Proposed jury instructions, interrogatories, and verdict forms must be served on the other parties at least 14 days before trial.
The parties must serve their proposed jury instructions, interrogatories, and verdict forms on each other at least fourteen (14) days before trial.
Page 1 | Jury Instructions, Interrogatories, Verdict Forms
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.
The movant must bring to the hearing the following: affidavit of damages, a prepared journal entry, and a copy of the letter sent regular and certified mail 7 days prior to the hearing date notifying all parties of the hearing and that failure to appear will result in judgment against them.
Page 1 | Default Judgment
Courtesy Copy Requirements
Counsel must provide the Court with a courtesy copy whenever a motion is filed.
When a motion is filed, counsel is required to provide the Court with a courtesy copy of the motion.
Page 1 | Motion Practice
Pre-Motion Conference Requirements
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.
Page 1 | Motion Practice
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.)
Page 1 | Motion Practice
Adjournment & Extension Requirements
Continuances and extensions are granted only when good cause is shown.
Continuances and extensions may be granted only for good cause shown.
Page 1 | Civil Case Management Order
Before filing an extension motion, counsel must consult opposing counsel and state that position in the motion.
Prior to filing a motion seeking an extension, you are required to consult with your opposing counsel and state in your motion your opposing counsel's position on the extension request.
Page 1 | Civil Case Management Order
Extensions of court-ordered deadlines should be requested by joint or unopposed motion when possible.
Extensions of court-ordered deadlines may be requested by motion, preferably in the form of a joint or unopposed motion.
Page 1 | Civil Case Management Order