Judge Cassandra Collier-Williams
Individual Rules, Standing Orders & Policies
Limits & Logistics
Courtesy Copies
Case Dispositive Motion
- Chambers Drop Off • Upon Filing
Motion
- Hand Delivery
Required Trial Document, Trial Brief
- Chambers Drop Off
Trial Brief, Proposed Stipulation, Exhibits, Jury Instructions, Jury Interrogatories, Motion in Limine
- Chambers Drop Off
Communication
Phone
Phone
Chambers
Phone
Court-wideClerk
Document Format Requirements2 rules
Exhibits must be bound, marked, and submitted at least two weeks before trial, and each party must include the curriculum vitae of each potential trial expert as an exhibit.
- Binding
- Securely bound
- Exhibits
Court's wording
Exhibits shall be bound and marked before trial and submitted to the court no later than two weeks prior to trial. Each party shall include as one of their exhibits the curriculum vitae of any expert(s) that may be called to present evidence or testimony at trial for the use of the court.
In addition to filing proposed jury instructions with the court, counsel shall email proposed jury instructions in Word format to doprian@cuyahogacounty.gov.
- File type
- Word
- Proposed jury instructions
Document Filing Requirements8 rules
Witnesses or exhibits not listed in the trial brief shall not testify or be introduced at trial absent a showing of good cause.
ALL REQUESTS REGARDING SUBSTANTIVE MATTERS IN PENDING CASES MUST BE FILED AS A MOTION ON THE PUBLIC DOCKET.
A complete trial brief must state the facts, discuss controlling law and anticipated evidentiary issues, list proposed witnesses and the subjects of their testimony, index and describe proposed exhibits, and include unique or sensitive proposed voir dire questions.
- Document
- Trial brief
Must include
- •Exhibit list
- •Statement of facts
Court's wording
A complete trial brief includes: -A statement of the facts; -A discussion of the controlling law; -A list of proposed witnesses along with a brief description of the subject matter of the testimony of each witness; -An index of all proposed exhibits containing a brief description of each exhibit; and -A discussion of any evidentiary issues likely to arise at trial. -Trial briefs shall also include any unique or sensitive proposed voir dire questions (traditional or boilerplate voir dire questions need not be provided).
Final-pre-trial briefs should be served and filed at least three days before the pretrial and should summarize the case, settlement status, trial length and witnesses, and anticipated special trial needs.
Court's wording
Parties shall serve and file pretrial briefs no less than three days prior to the final pretrial. The final pretrial brief should provide the Court with a brief synopsis of the case, the status of any settlement negotiations, the expected length of trial including the number of potential witnesses, and any special issues of trial needs anticipated.
All witness lists shall be filed with the court. If a person or entity is not listed on the witness list filed with the Court, that person or representative of the entity shall not testify.
Where leave has been granted for an attorney to appear pro hac vice (“nonresident attorney”), local counsel of this state shall examine and cosign all motions, pleadings and other papers prepared by the nonresident attorney.
Counsel shall submit joint proposed jury instructions for each claim, counterclaim and/or cross-claim contained in the pleadings with applicable O.J.I. or case citations, as well as verdict forms and any interrogatories. In addition to jointly filing the above documents, parties shall file a joint list of stipulated facts.
A party seeking to have videotaped testimony utilized at trial must retain a videographer for the playback at trial.
Filing & Service rules
Filing Timing and Cure Windows
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.
Page 1 | Motion Practice
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.
Page 1 | Calendaring and Continuances
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.
Page 1 | Discovery
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.
Page 1 | Trials
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.
Page 1 | Motion Practice
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.
Page 1 | Trials
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.
Page 1 | Trials
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.
Page 1 | Trials
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.
Page 1 | Trials
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.
Page 1 | Discovery
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.
Page 1 | Trials
Service and Proof of Service Rules
Service on a nonresident pro hac vice attorney must also be made on local counsel, and service on local counsel is deemed service on the nonresident attorney.
Service of orders, motions, pleadings and any other papers upon the nonresident attorney shall also be served upon local counsel. Service of orders, motions, pleadings and any other papers upon local counsel shall be deemed service on the nonresident attorney.
Page 1 | Admission of Out-of-State Attorneys
Every continuance request must be served on all parties.
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.
Page 1 | Calendaring and Continuances
Each criminal-motion filer is responsible for serving opposing counsel with a copy of the filed motion.
Each counsel is responsible for serving opposing counsel a copy of their filed motion.
Page 1 | CRIMINAL CASES - MOTION PRACTICE
Courtesy Copy Requirements
Courtesy copies of dispositive motions must be delivered to the judge’s chambers on the filing date.
Courtesy copies of Dispositive Motions must be walked up to the Judge’s chambers on the date of filing.
Page 1 | Motion Practice
Courtesy copies of the required trial briefs, stipulations, exhibits, jury instructions, jury interrogatories, and motions in limine must be 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.
Page 1 | Trials
For cases tried by a visiting judge, the assigned judge retains jurisdiction over post-trial motions, and motion copies must be hand-delivered to her office on the filing date.
The assigned judge, Cassandra Collier-Williams, retains jurisdiction on all post-trial motions. Copies of motions are to be hand-delivered to Judge Collier-Williams' office on the day of filing.
Page 1 | Trials
Trial counsel must deliver courtesy copies of all required documents and trial briefs to the staff attorney or chambers no later than two weeks before trial.
Trial counsel shall walk courtesy copies of all required documents and their trial briefs to the Judge's staff attorney on the 11th floor of the Justice Center or directly to the Judge's Chambers by no later than two (2) weeks prior to trial.
Page 1 | Trials
Sealing & Redaction Procedures
A party seeking to file an agreed confidential document must move for sealing, and the court will decide the request case by case.
If seeking to file an agreed upon confidential document, a party must file a motion to determine if the document may be filed under seal. A ruling on that motion will be determined on a case-by-case- basis.
Page 1 | Protection Orders
Filing Bundling Requirements
Every criminal motion other than a discovery motion must be delivered to the court on its filing date.
All motions, except discovery motions, must be walked up to the court on the day of filing.
Page 1 | CRIMINAL CASES - MOTION PRACTICE
Civil reply briefs may be filed without prior court approval, but responses to them will not be accepted.
Reply Briefs can be filed without prior court approval. No responses to the Reply Briefs will be accepted.
Page 1 | Motion Practice
Adjournment & Extension Requirements
A continuance request must be filed as a motion, delivered to court on its filing date, served on every party, and filed no later than the existing 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.
Page 1 | Calendaring and Continuances
Chambers Communication Rules
Substantive criminal issues must be addressed with all parties at a pretrial, through group communications, or by motion on the public docket.
ALL QUESTIONS REGARDING SUBSTANTIVE MATTERS IN PENDING CASES MUST BE DISCUSSED DURING PRE-TRIALS WITH ALL PARTIES PRESENT, OR VIA GROUP TEXT, GROUP EMAILS, AND/OR RAISED IN MOTIONS FILED ON THE PUBLIC DOCKET.
Page 1 | Criminal Matters
Routine civil scheduling and dial-in requests may be made by telephone, but ex parte guidance on deadlines, briefing, or pending-motion status is prohibited.
COUNSEL AND THE PARTIES ARE HEREBY ADVISED THAT THIS COURT WILL NOT ACCEPT EX PARTE TELEPHONE CALLS TO THE STAFF ATTORNEY REGARDING SUBSTANTIVE ISSUES IN PENDING CIVIL MATTERS. THE COURT SPEAKS THROUGH ITS DOCKET. WHILE IT MAY BE APPROPRIATE TO CALL THE STAFF ATTORNEY REGARDING ROUTINE, NON-SUBSTANTIVE MATTERS (SUCH AS REQUESTS FOR THE DIAL-IN INFORMATION FOR AN UPCOMING STATUS CONFERENCE, ETC.), IT IS NOT APPROPRIATE UNDER ANY CIRCUMSTANCES FOR COUNSEL TO CALL EX PARTE FOR GUIDANCE OR CLARIFICATION REGARDING SUBSTANTIVE MATTERS, INCLUDING MATTERS RELATING TO EXISTING CASE MANAGEMENT DEADLINES, REQUESTS TO FILE BRIEFING, AND/OR INQUIRIES REGARDING THE STATUS OF PENDING MOTIONS.
Page 1 | Civil Matters
Counsel must email proposed jury instructions in Word format to doprian@cuyahogacounty.gov in addition to filing them with the court.
In addition to filing proposed jury instructions with the court, counsel shall email proposed jury instructions in Word format to doprian@cuyahogacounty.gov.
Page 1 | Trials
Routine, non-substantive criminal scheduling matters may be handled by telephone, but substantive ex parte requests for guidance or clarification are prohibited.
COUNSEL AND THE PARTIES ARE HEREBY ADVISED THAT THIS COURT WILL NOT ACCEPT EX PARTE TELEPHONE CALLS TO CHAMBERS REGARDING SUBSTANTIVE ISSUES IN PENDING CRIMINAL MATTERS. THE COURT SPEAKS THROUGH ITS DOCKET. WHILE IT MAY BE APPROPRIATE TO CALL CHAMBERS REGARDING ROUTINE, NON-SUBSTANTIVE MATTERS (SUCH AS SCHEDULING OF PRETRIALS, ACCEPTANCE OF ASSIGNED CASES, ETC.), IT IS NOT APPROPRIATE UNDER ANY CIRCUMSTANCES FOR COUNSEL TO CALL CHAMBERS EX PARTE FOR GUIDANCE OR CLARIFICATION REGARDING SUBSTANTIVE MATTERS.
Page 1 | Criminal Matters
For a deposition dispute requiring immediate court assistance, the parties may call the staff attorney only jointly.
IF A DISPUTE ARISES DURING A DEPOSITION THAT REQUIRES THIS COURT’S IMMEDIATE ASSISTANCE, THE PARTIES MAY CALL THE STAFF ATTORNEY FOR ASSISTANCE, BUT MUST DO SO JOINTLY (AND NOT ON AN EX PARTE BASIS).
Page 1 | Civil Matters
PARTIES MAY CALL JOINTLY TO THE STAFF ATTORNEY OR CONTACT THE STAFF ATTORNEY VIA JOINT EMAIL REGARDING THOSE MATTERS.
PARTIES MAY CALL JOINTLY TO THE STAFF ATTORNEY OR CONTACT THE STAFF ATTORNEY VIA JOINT EMAIL REGARDING THOSE MATTERS.
Page 1 | Civil Matters