Common Pleas Court Judges
Judge Carolyn B. Friedland
Matthew D. Greenwell
Ten years of private practice in the civil area.
For all court conferences: appear on time and present a completed pre-trial statement. Generally promotes mediation in all circumstances.
Staff Attorney conducts case management and final pretrial conferences. At case management conference lead counsel required. At final pre-trial conference lead counsel and an individual with authority required. Does not allow phone conferences except in extenuating circumstances, such as when counsel for a party is located outside of Cuyahoga County. Discuss only deadlines at case management conferences.
Staff Attorney handles filing deadlines, pending motions, discovery disputes. Must file a motion to address scheduling conflicts. Provide copies of filings to court only when matters need immediate attention. Allows oral arguments only as allowed by Civil Rules. Allows reply briefs on a case-by-case basis. Does not usually allow sur-reply briefs, depending upon complexity of issues. Motions in limine may be written or oral and must be submitted 10-14 days before trial.
Requires a scheduling order. Discovery deadlines allow as much time as needed, within reason.
Holds settlement conference when requested by counsel who feels that court intervention will facilitate settlement. Requires lead counsel, parties, and individual with authority to be present. Court sometimes participates in settlement. Does not allow settlement conferences by phone-except under extenuating circumstances.
Calendaring and Continuances
To extend discovery requires motion by party or joint motion. First continuance of trial requires motion by party with client approval. Does not allow parties to extend discovery without court consent.
The following are due at least 10 days before trial: trial briefs, witness lists, jury instructions, jury interrogatories, and motions in limine. Jury instructions and interrogatories shall be stipulated to by the parties and filed as well as emailed in a Word Document format to the Staff Attorney at: MGreenwell@cuyahogacounty.us. Exhibits may be presented on the day of trial. For videotape matters see Superintendence Rule 12. Requires filing of index of objections morning of trial. Will rule on objections to video tape morning of trial or as it comes up in trial. Allows exhibits in opening statement within reason and considering objections. Will not allow anyone but client and counsel to sit at trial table. During voir dire, no instructions of law, no promises extracted from jury, question should aim at determining who is fair and impartial. Pass original around to show exhibits. Does not permit jurors to speak to counsel after case. Requires counsel to stand to address court and witness-counsel may otherwise stand when they wish.
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