
Judge Deborah M. Turner
Individual Rules, Standing Orders & Policies

Limits & Logistics
Courtesy Copies
Filings > 20 pages

Adjournments
- Counsel are encouraged to contact opposing counsel before filing a continuance motion to determine whether the motion will be opposed.
- All continuance and extension requests must be made in writing.
- A continuance request should identify a specific requested date, preferably supported by opposing counsel's concurrence.
Request must include

Communication
Phone
Court-wideClerk
Document Format Requirements1 rule
Exhibits shall be bound and marked before trial and submitted to the court prior to trial.
- Binding
- Securely bound
Formatting
- •Marked before trial
- •Submitted to the court prior to trial
Document Filing Requirements14 rules
Opposing briefs to motions in limine shall be filed no later than seven (7) days before trial.
Witnesses or exhibits not listed in the trial brief shall not testify or be introduced at trial absent a showing of good cause.
Parties shall prepare a stipulated statement of the case for the court to read to the jury pursuant to Civ. R. 47(a).
Parties shall submit trial briefs, motions in limine, no later than fourteen (14) days before trial.
Parties to serve and file pretrial statement no less than one week prior to the final pretrial.
All parties and chosen representatives must be present at the final pretrial with full, final, and immediate settlement authority.
Parties shall submit trial briefs, motions in limine, jury interrogatories and jury instructions, no later than fourteen (14) days before trial.
Trial briefs are to include: a statement of the facts; a discussion of the controlling law; any stipulations; witness list along with a brief description of the subject matter of the testimony of each witness; exhibit list containing a brief description of each exhibit.
- Document
- Trial brief
Include
- •Exhibit list
- •Statement of facts
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.
If the real party in interest is an insurance company, corporation, common carrier, or other artificial entity, then the chosen representative must be the person with full, final, and immediate authority to negotiate and enter into a binding settlement agreement as to all claims.
Counsel must confer about proposed jury interrogatories and instructions and attempt to reach agreement.
Court's wording
Counsel for the parties are required to confer with one another with respect to the proposed jury interrogatories/instructions, with a view to reaching agreement on interrogatories/instructions to be requested.
All possible stipulations are to be made prior to trial.
The final pretrial statement 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 or trial needs anticipated.
The interrogatories/instructions agreed upon by all counsel shall be identified. Disputed interrogatories/instructions shall likewise be identified along with separate citation to legal authority for each.
Filing & Service rules
Courtesy Copy Requirements
A hard copy of any motion exceeding 20 pages, including exhibits in the page count, must be delivered to the Court, either to the staff attorney on the 11th floor of the Justice Center or to the bailiff in Courtroom 20-D.
Parties are required to deliver a hard copy of all motions which exceed twenty (20) pages to the Court. Exhibits are included in the page count. Hard copies may be delivered to the staff attorney on the 11th floor of the Justice Center, or to the bailiff in Courtroom 20-D.
Page 1 | Motion Practice
Pre-Motion Conference Requirements
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.
Page 1 | Settlement Conference
Adjournment & Extension Requirements
All continuance and extension requests must be made in writing.
All requests for continuances or extensions of time must be made in writing.
Page 1 | Calendaring and Continuances
A continuance request should identify a specific requested date, preferably supported by opposing counsel's concurrence.
When requesting a continuance, parties should provide the Court with a specific date for the continuance, preferably with the concurrence of opposing counsel.
Page 1 | Calendaring and Continuances
Counsel are encouraged to contact opposing counsel before filing a continuance motion to determine whether the motion will be opposed.
Counsel are encouraged to contact opposing counsel prior to filing the motion so that they can see if the motion will be opposed.
Page 1 | Calendaring and Continuances
Chambers Communication Rules
Plaintiff's counsel must email the proposed jury instructions, interrogatories, and verdict forms in Word format to the staff attorney at least 14 days before trial.
Counsel for the plaintiff shall be responsible for ensuring that a copy of the proposed jury instructions, interrogatories and verdict forms are emailed in word format to the staff attorney at doakley@cuyahogacounty.us at least fourteen (14) days before the scheduled trial date.
Page 1 | Trials — Jury Trials
Parties must contact the staff attorney by phone before filing a motion to compel when discovery disputes remain unresolved.
If discovery disputes remain, the parties are to contact the staff attorney at (216) 443-8602 prior to filing any motions to compel.
Page 1 | Discovery