Judge John J. Russo
Individual Rules, Standing Orders & Policies
Limits & Logistics
Courtesy Copies
Jury Instructions, Jury Interrogatories, Jury Verdict Form
Communication
Phone
Phone
Court-wideClerk
Document Filing Requirements6 rules
I further certify that no portion of any filing in this case will be drafted by generative artificial intelligence or that any language drafted by generative artificial intelligence—including quotations, citations, paraphrased assertions, and legal analysis—will be checked for accuracy, using print reporters or traditional legal databases, by a human being before it is submitted to the Court.
Requests for production of documents and interrogatories must be served prior to the Case Management Conference, as well as the Certificate regarding Generative Artificial Intelligence (click here for PDF).
- Document
- Discovery requests
- Placement
- Certificate section
Must include
- •AI disclosure
The parties must provide one consolidated set of jury instructions, interrogatories, and verdict forms that identifies both agreed and disputed items.
Court's wording
With respect to Jury Instructions, Jury Interrogatories, and Jury Verdict Forms, the Parties are to provide the Court with one consolidated set of Instructions/Interrogatories/Verdict Forms that includes all the Instructions/Interrogatories/Verdict Forms to which the Parties agree and that identifies all the Instructions/Interrogatories/Verdict Forms to which the Parties disagree.
At least 14 days before trial, the parties must file trial briefs, witness and exhibit lists, applicable joint jury materials, stipulations, and an agreed statement of the case for the jury.
Court's wording
The Court additionally orders that at least 14 days prior to Trial, the parties are to file the following: (1) Trial Briefs, (2) Witness Lists, (3) Exhibit Lists, (4) Joint Jury Instructions, Jury Interrogatories, and /or Jury Verdict Forms if applicable, (5) Stipulations, and (6) an agreed upon State of the Case to be read to the Jury.
A motion for default judgment must be accompanied by the relevant written instruments, affidavits of service and damages, a military affidavit, and a proposed judgment entry.
- Document
- Motion for default judgment
May include
- •Proposed order
Court's wording
When provided by Civ.R. 55, the Plaintiff may file a Motion for Default Judgment and provide to the Court the following documents: (1) the contract(s), assignment(s), account statement(s), or written instrument(s) upon which Plaintiff seeks judgment; (2) an affidavit of service of the Complaint; (3) an affidavit of damages; (4) a military affidavit; and (5) a proposed judgment entry.
Evidence of damages, such as bills or account statements, must be included in the file before default judgment can be rendered.
Filing & Service rules
Filing Timing and Cure Windows
For motions other than summary judgment or in limine, the opposition brief is due 14 days after filing.
Pursuant to Civ.R. 6, a Brief in Opposition is due 14 days after the filing of a Motion.
Page 1 | Any Motions other than a Motion for Summary Judgment or a Motion in Limine
A motion in limine must be filed at least 28 days before trial.
In accordance with Civ.R. 6, the Court orders that any Motion in Limine is to be filed at least 28 days before Trial.
Page 1 | Trials
The listed trial-preparation documents must be filed no later than 14 days before trial.
The Court additionally orders that at least 14 days prior to Trial, the parties are to file the following: (1) Trial Briefs, (2) Witness Lists, (3) Exhibit Lists, (4) Joint Jury Instructions, Jury Interrogatories, and /or Jury Verdict Forms if applicable, (5) Stipulations, and (6) an agreed upon State of the Case to be read to the Jury.
Page 1 | Trials
A summary-judgment opposition brief is due 28 days after the summary-judgment motion is filed.
Pursuant to Civ.R. 6, a Brief in Opposition is due 28 days after the filing of a Motion for Summary Judgment.
Page 1 | Motions for Summary Judgment
An opposition brief to a motion in limine is due 14 days after the motion is filed.
Any Brief in Opposition is due 14 days thereafter.
Page 1 | Trials
A summary-judgment reply brief is due seven days after the opposition brief is filed.
A Reply Brief is due 7 days after the filing of a Brief in Opposition.
Page 1 | Motions for Summary Judgment
No reply brief is permitted in response to a motion in limine.
No Reply shall be permitted.
Page 1 | Trials
A motion in limine must be filed at least 28 days before trial.
Pursuant to Civ.R. 6, the Court orders that any Motion in Limine is to be filed at least 28 days before Trial.
Page 1 | Motions in Limine
Courtesy Copy Requirements
The parties should email the Staff Attorney a Word-format courtesy copy of their jury instructions, interrogatories, and verdict forms.
A courtesy copy of the Parties’ Instructions/Interrogatories/Verdict Forms in a Word format should be emailed to the Court’s Staff Attorney.
Page 1 | Trials
Pre-Motion Conference Requirements
Before filing any discovery motion, the parties must promptly contact the Staff Attorney and arrange a telephone or in-person attorney conference.
In accordance with the Court’s Discovery practices, the parties are to contact Judge Russo’s Staff Attorney prior to the filing of any Discovery Motion to set the matter for an Attorney Conference either via telephone or in-person with the Court as soon as possible.
Page 1 | Motion Practice — Discovery Motions
Before filing any discovery motion, the parties must promptly contact the Staff Attorney to arrange a telephone or in-person attorney conference.
Prior to any party filing any Discovery Motion, the parties shall contact Judge Russo’s Staff Attorney to set an Attorney Conference either via telephone or in-person with the Court as soon as possible.
Page 1 | Discovery
An oral hearing on a motion for summary judgment is available if requested.
An oral hearing on the Motion is available upon request.
Page 1 | Motions for Summary Judgment
The court will attempt to rule on the summary-judgment motion before the final pretrial, ordinarily placing the ruling on the docket unless the parties make other arrangements with the court.
The Court shall make all attempts to issue a ruling on the Motion prior to the Final Pretrial. The ruling will be made on the docket unless other arrangements have been made by the parties with the Court.
Page 1 | Motions for Summary Judgment
Adjournment & Extension Requirements
Discovery deadlines and court events may be continued without court consent only when all parties agree and the extension will not interfere with the trial date.
Continuances of discovery deadlines or court events without Court consent shall be permitted as long as (1) all the parties agree and (2) the extension does not interfere with the Trial date.
Page 1 | Calendaring and Continuances
Chambers Communication Rules
Plaintiff’s counsel must initiate the case management telephone conference with defense counsel and then Judge Russo’s Staff Attorney at the stated number.
Plaintiff's counsel is to initiate the telephone conference to Defendant's counsel and then to Judge Russo’s Staff Attorney at 216-443-8588.
Page 1 | Case Management Conferences
If settlement is no longer possible, the parties should contact the Staff Attorney to cancel the settlement conference rather than appear in court.
If the parties believe settlement is not possible prior to the Settlement Conference, please contact Judge Russo’s Staff Attorney to cancel the Settlement Conference instead of coming to Court.
Page 1 | Settlement Conference
The initial case management conference ordinarily occurs by telephone with the Staff Attorney unless the parties request that Judge Russo conduct it.
The CMC will be conducted by phone with the Court’s Staff Attorney, unless the parties request it be held by Judge Russo.
Page 1 | General
Initial case management conferences in Commercial Docket cases are conducted in person with Judge Russo.
However, the initial Case Management Conference for Commercial Docket cases will be conducted in-person with Judge Russo.
Page 1 | General