Hamilton County Court of Common Pleas, General Division Filing Rules

Provide a proposed entry in Word format when filing.

Unless the Court orders otherwise, counsel, all parties, and persons with authority must attend the FPTC.

The parties must confer to identify agreed and disputed jury instructions and label proposed instructions as such in their filings.

Trial briefs must include facts, controlling law, stipulations, a witness list with testimony descriptions, and an exhibit list with descriptions.

A new-media applicant must submit one of three specified forms of documentation identifying the applicant and media outlet.

Attorneys with specific concerns should call before their trial date.

Once a motion has been ripe for more than 60 days, please email Court staff that a motion remains pending and copy all parties.

Direct criminal questions to the Bailiff and civil or non-case-related inquiries to the Staff Attorney.

The Staff Attorney should be informed as soon as practical when a civil case settles.

To set a hearing in a civil case, contact the law clerk.

A motion in limine must be filed at least 21 days before trial.

Pretrial Statements must be filed two weeks before the FPTC.

For deposition or video testimony, objections must be filed and ruled on at least 7 business days before trial, and the testimony must be reviewed and edited beforehand.

Counsel must file a joint plan before the initial case management conference.

Sentencing memorandums are encouraged and should be filed no later than three days before the sentencing hearing.

If no defendant has been served 21 days before the CMC, Plaintiff must move to postpone it and explain the planned service efforts and expected service timeframe.

Contact the Staff Attorney in advance to reschedule the initial case management conference.

Court-set discovery deadlines may not be extended without prior approval.

Counsel should contact opposing counsel before filing a continuance or extension motion to determine whether it will be opposed.

The discovery deadline in the case management order may not be extended without prior Court approval.

Criminal jury-trial exhibits must be pre-marked, paginated, tabbed, and bound, with three hard copies submitted at least three business days before trial and the CV of each potential expert witness included.

A proposed entry should be emailed to the Court’s staff attorney in Word format when a civil motion is filed.

Counsel must submit complete proposed jury instructions in Word format before the pretrial conference.

A motion to continue a set civil trial date must be made in writing even if both parties agree.

The Court does not require a particular exhibit-labeling system, but requests that opposing parties use different types of symbols, such as numbers for one party and letters for the other.

Special criminal instructions and requested civil instructions should be emailed to the Staff Attorney before trial.

A file-stamped courtesy copy of each civil motion and brief should be provided to the Court.

A courtesy copy of the motion, opposition, and reply must be provided to the Staff Attorney as a hard copy or by email.

One copy of civil jury instructions, in complete and final form, should be submitted by e-mail to the staff attorney one week before trial. Counsel must work together to submit one final version of jury instructions. Only if parties disagree on portions of the jury instructions may you submit different versions of those portions only.

A file-stamped courtesy copy of the motion should be provided to the Court in advance.

Criminal motions in limine are due no later than two weeks before trial, and responses are due one week before trial unless otherwise ordered.

Before filing a motion to compel over an unresolved discovery dispute, the parties must contact the Staff Attorney in civil cases or the Bailiff in criminal cases; the court will schedule a conference by telephone, video, or in person.

The Court generally discourages discovery motions and expects counsel to resolve discovery issues without court intervention.

The Court will not hear disputes that arise after the discovery deadline.

Before filing a discovery motion, the parties must contact Judge Wagner’s Staff Attorney as soon as possible to arrange an attorney conference with the Court by telephone, video, or in person.

Motion hearing exhibits must be provided to the opposing party and the Court before the hearing.

The plaintiff must complete service on at least one defendant within six months or the case may be dismissed sua sponte for lack of prosecution.

Motion hearing exhibits must be provided to the opposing party.

Requests for production and interrogatories must be served before the CMC.

Motion briefs are limited to 20 pages, and the motion submission with exhibits is limited to 60 pages total.

Attorneys may request leave of court to exceed the motion-brief page limits.

Rule 26(B) disclosures must not be filed with the Court.

Rule 26(B) disclosures must not be filed with the Court.

Proposed civil jury instructions must be emailed to the law clerk one week before trial.

Since Trial Briefs shall be submitted simultaneously, parties should anticipate the opposing party’s legal issues.

Bench-trial briefs are filed simultaneously, and each party is expected to anticipate and respond to the opposing arguments.