Common Pleas Court Judges

Ohio Rules of Civil and Criminal Procedure; Local Rules of Civil and Criminal Procedure

Opportunities for Less-Experienced Lawyers

The Court strongly encourages parties to allow less-experienced lawyers the opportunity to participate actively in cases by presenting arguments at motion hearings, appearing at pretrial conferences, or examining witnesses at trial. Therefore, the Court may alter its practices to afford opportunities to less-experienced lawyers. For example, the Court may allow a bifurcated oral argument in which a senior attorney presents one portion of the argument, and a newer lawyer who has worked on the case presents the other portion. Similarly, at trial or evidentiary hearings, the Court may relax the usual one-lawyer-per-witness rule to allow less-experienced lawyers an opportunity to examine witnesses. Counsel seeking permission to bifurcate arguments or witness examinations should raise the issue at the final pretrial conference or by contacting the Court’s staff attorney.

Counsel only need to appear by telephone or in person, as set by the Court.

As provided in the rules.

As provided in the rules and with any deadlines established at a pretrial or case management conference.

All parties with authority to be present with the exception of out-of-town parties who may be excused only with leave of court.

Requests made at conferences or by motion will be considered.

At least 7 days prior to trial, the parties are to file the following:

• Witness lists
• Exhibit lists
• Proposed jury instructions
• Jury interrogatories, and/or verdict forms if applicable
• Motions in limine
• Stipulations
• A concise, mutually-agreed-upon statement of the case to be read to the jury at the outset of trial

Jury instructions, interrogatories and verdict forms shall be submitted to the Court by email in word format to staff attorney Patsy Coughlin at pcoughlin@cuyahogacounty.us

Voir Dire:  Voir dire is conducted by the Court and counsel. Counsel shall address questions to the entire panel of prospective jurors.  

Opening Statements:  Counsel shall not use “exhibits” unless opposing counsel has agreed or the Court gives approval.

Video Depositions:  Objections transcripts shall be delivered to the Court at least one day prior to the trial.

Trial Conduct:

• No speaking objections. If a record is required, ask for permission to approach the bench.

• Counsel shall mark their exhibits and exchange the same with opposing counsel prior to the start of trial. Counsel who intend to use poster boards should have photos of the boards available to substitute for the record. Court reporters will not be keeping the poster boards as part of the record.

• Counsel may bring beverages into the courtroom.

• If counsel uses a discovery deposition for impeachment purposes, a page reference should always be given to opposing counsel.

• During deliberations, counsel should make sure the staff attorney and/or bailiff know where counsel can be reached in case of questions or a verdict. Counsel and parties should be within 5 minutes of the courthouse.

• Counsel are responsible for conferring with the court reporter to be sure the exhibits that are admitted into evidence properly go back to the jury.

Jurors will be permitted to take notes. All other trial matters as governed by the Rules of Procedure.