Hamilton County Court of Common Pleas, General Division Pre-Motion Conference Requirements

CRITICAL

Parties must attempt to resolve a discovery dispute before seeking court involvement.

If a discovery dispute arises, parties must attempt to work it out before seeking Court involvement.

CRITICAL

Before filing a motion to compel discovery in a civil case, parties must arrange and attend a Discovery Conference with the Court; the Court will not hear the motion before that conference.

In civil cases, prior to any party filing a Motion to Compel Discovery, parties must first reach out to the staff attorney to schedule a Discovery Conference. The Court will not hear any motion to compel until the parties have met with the Court for a Discovery Conference.

CRITICAL

Before filing a motion to compel, counsel must confer in good faith and, if the dispute remains unresolved, contact the staff attorney to arrange an informal court conference.

In the event of a discovery dispute, counsel are expected to comply with Rule 37(A)(1) by conferring in good faith to attempt to resolve the dispute. The Court expects all counsel to cooperate in such efforts through actual discussion. If a dispute cannot be resolved, counsel are expected to contact the Court’s staff attorney to arrange an informal conference with the Court. No motions to compel should be filed without first following this process.

CRITICAL

Before filing a discovery motion, the parties must contact the Staff Attorney as soon as possible to set an Attorney Conference with the Court.

Prior to any party filing any Discovery Motion, the parties shall contact Judge Wagner’s Staff Attorney to set an Attorney Conference either via telephone, video, or in-person with the Court as soon as possible.

CRITICAL

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

Disputes arising after the discovery deadline shall not be heard.

CRITICAL

Before filing a motion to compel discovery, the parties must meet and confer, make a good-faith resolution effort, and contact the Court; the motion should be a last resort.

Motions to compel discovery shall not be filed until the parties have met and conferred, and made a good faith effort to resolve any discovery disputes. A motion to compel shall be a last resort and filed only after first contacting the Court to discuss the matter.

CRITICAL

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.

Prior to any party filing any Discovery Motion, the parties shall contact Judge Wagner’s Staff Attorney to set an Attorney Conference either via telephone, video, or in-person with the Court as soon as possible.

CRITICAL

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

Motions in limine must be filed no later than two weeks before trial. Any responses to those motions are due one week before trial unless otherwise ordered.

CRITICAL

Criminal bench-trial motions in limine are due 14 days before trial, responses are due 7 days before trial unless otherwise ordered, and replies are prohibited unless directed by the Court.

Motions in Limine must be filed 14 days before trial. Responses due 7 days before trial, unless otherwise ordered. No replies are permitted unless directed by the Court.

CRITICAL

Bench-trial motions in limine are due 14 days before trial, opposition responses are due 7 days later, and replies require leave of Court.

File 14 days before trial. Opposition responses are due 7 days later. Replies are not permitted without leave of Court.

CRITICAL

After a good-faith conferral fails to resolve a discovery dispute, contact the Staff Attorney for an informal court conference before filing a motion to compel.

If a discovery dispute remains unresolved after conferral, contact the Staff Attorney to schedule an informal conference with the Court. No motions to compel may be filed without first following this process.

CRITICAL

Counsel must confer in good faith and, if a discovery issue remains unresolved, contact the Bailiff for a discovery conference before seeking a discovery-related motion to compel or sanctions.

Discovery disputes must be addressed promptly and professionally. Counsel must confer in good faith to resolve any issues before involving the Court. If unresolved, counsel should contact the Court’s Bailiff to request a discovery conference. Motions to compel or motions for sanctions related to discovery will not be entertained unless this process is followed.

CRITICAL

Civil motions in limine are due 14 days before trial, responses are due 7 days later, and replies are prohibited unless ordered.

Motions in Limine must be filed 14 days before trial. Responses are due 7 days later. No replies are permitted unless ordered.

CRITICAL

Criminal jury-trial motions in limine are due 14 days before trial, oppositions are due 7 days before trial, and replies are prohibited unless specifically ordered.

All motions in limine must be filed no later than 14 days before trial. Responses or memoranda in opposition are due no later than 7 days before trial. No replies are permitted unless specifically ordered by the Court.

CRITICAL

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.

If discovery disputes remain, the parties are to contact Judge Cross’s Staff Attorney (civil) or Bailiff (criminal) prior to filing any motions to compel. A conference with the Court will be scheduled either via telephone, video, or in-person.

WARNING

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

The Court generally discourages discovery motions and expects counsel to resolve discovery issues short of court intervention.

WARNING

Oral argument is allowed only by court order or request after conferring with opposing counsel.

Oral argument is permitted only by Court order or upon request, after first conferring with opposing counsel.

INFO

Before filing a motion to compel, counsel may call Court staff to schedule a telephone conference with the Judge.

Counsel may, prior to filing a motion to compel, call Court staff to schedule a telephone conference with the Judge.

INFO

The Court sets the discovery and trial schedules during CMCs.

The Court shall set a discovery schedule and Trial schedule during the CMCs.

INFO

Civil motions are generally decided on the papers after briefing is complete, without oral argument.

Motions filed in civil cases are generally taken under submission without oral argument after briefing is complete.

INFO

The parties are encouraged to work together to resolve discovery disputes.

The parties are encouraged to work together to resolve all discovery disputes.