Common Pleas Court Judges
Judge Cassandra Collier-Williams
Anthony T. Parker
DeAngelo A. LaVette
Private Practice (both civil and criminal) since 1991
All Case Management Conferences are conducted by telephone. Failure of the Plaintiff to appear at the CMC will result in a dismissal without prejudice. At that time all dates and deadlines will be established. Alternate Dispute Resolution is looked at in all appropriate cases. Failure to appear at any court hearing or event may result in the dismissal of Plaintiff’s complaint for want of prosecution or judgment rendered against the Defendant. All requests to the Court must be in the form of a motion and served upon all parties. Service must be obtained on all parties pursuant to Civil Rule 4(e) or the case will be dismissed as to that party for lack of service.
Admission of Out-of-State Attorneys
Where leave has been granted for an attorney to appear pro hac vice (“nonresident attorney”), local counsel of this state shall examine and cosign all motions, pleadings and other papers prepared by the nonresident attorney. Local counsel must appear at oral hearings with the nonresident attorney. Service of orders, motions, pleadings and any other papers upon the nonresident attorney shall also be served upon local counsel.
Parties are encouraged to confer among themselves and to come to an agreement regarding the confidentiality of documents during the exchange of discovery.
If seeking to file an agreed upon confidential document, a party must file a motion to determine if the document may be filed under seal. A ruling on that motion will be determined on a case-by-case- basis.
Most pre-trials are conducted in person with all parties present.
This court strictly construes time allowed on motions/pleadings. All time limitations are calculated on a calendar-day basis. Reply Briefs can be filed without prior court approval. No responses to the Reply Briefs will be accepted.
Courtesy copies of Dispositive Motions must be walked up to the Judge’s chambers on the date of filing.
If the Defendant is served but does not answer or respond to the Complaint, Plaintiff must timely file the Motion for Default Judgment or the Complaint will be dismissed for want of prosecution.
This court expects all parties to participate in discovery in good faith and cooperate with each other prior to the submission of any discovery motions.
This court adheres to Civil Rule 26(3) regarding initial disclosures by a party. Without awaiting a discovery request, a party must provide to the other parties, except as exempted by Civ. R. 26(B)(3)(b) or as otherwise stipulated, or ordered by the court:
(i) the name and, if known, the address and telephone number of each individual likely to have discoverable information - along with the subjects of that information - that the disclosing party may use to support its claims or defenses, unless the use would be solely for impeachment;
(ii) a copy - or a description by category and location - of all documents, electronically stored information, and tangible things that the disclosing party has in its possession, custody, or control and may use to support its claims or defenses, unless the use would be solely for impeachment;
(iii) a computation of each category of damages claimed by the disclosing party - who must also make available for inspection and copying as under Civ. R. 34 the documents or other evidentiary material, unless privileged or protected from disclosure, on which each computation is based, including materials bearing on the nature and extent of injuries suffered; and
(iv) for inspection and copying as under Civ. R. 34, any insurance agreement under which an insurance business may be liable to satisfy all or part of a possible judgment in the action or to indemnify or reimburse for payments made to satisfy the judgment.
A party must make the initial disclosures no later than the parties’ first pre-trial or case management conference, unless a different time is set by stipulation or court order, or unless a party objects. In ruling on the objection, the court must determine what disclosures, if any, are to be made and must set the time for disclosure.
A party that is first served or otherwise joined after the first pre-trial or case management conference must make the initial disclosures within 30 days after being served or joined, unless a different time is set by stipulation or court order.
Settlement conferences will be set by the court at the court’s discretion or upon the request of the parties.
Calendaring and Continuances
All requests for continuances must be in the form of a motion, walked up to the 23A on the date of filing, and served on all parties. Additionally, the request must be filed on or before the date of the existing deadline.
The trial orders will be given to the parties thirty days before trial.
All trial briefs; Proposed Stipulations as to undisputed facts, reserving any objections as to relevance; Exhibits; Jury Instructions; Jury Interrogatories; and Motions in Limine are due no later than two (2) weeks prior to trial and courtesy copies shall be provided to the Court.
Stipulations as to the authenticity of all documents/exhibits shall be agreed upon unless credible evidence to the contrary exists.
The Court shall not grant leave to conduct depositions after the above deadline for any reason, including continuance of trial, even if said continuance is due to the Court’s engagement in another trial. Objections to “unavailability” are not waived by participation in videotaped depositions.
All parties, counsel of record, and adjusters to be present in person with full settlement authority for final settlement conference one-half hour before trial.
Exhibits shall be bound and marked before trial and submitted to the Court no later than two (2) weeks prior to trial. Each party shall include as one of their exhibits the curriculum vitae of any expert(s) that may be called to present evidence or testimony at trial for the use of the Court.
Witnesses or exhibits not listed in the trial brief shall not testify or be introduced at trial absent a showing of good cause.
Complete trial briefs shall be filed and delivered to the Court’s chambers by not later than two (2) weeks prior to trial. A complete trial brief includes:
-A statement of the facts;
-A discussion of the controlling law;
-A list of proposed witnesses along with a brief description of the subject matter of the testimony of each witness;
-An index of all proposed exhibits containing a brief description of each exhibit; and
-A discussion of any evidentiary issues likely to arise at trial.
Trial Briefs shall also include any unique or sensitive proposed voir dire questions (Traditional or boilerplate voir dire questions need not be provided).
Counsel must file a list of all filed deposition transcripts that are to be utilized at trial by no later than two (2) weeks prior to trial. Counsel must confer and present a list of all objections for which a ruling is desired as well as a list of withdrawn objections on said date. Failure to submit said list shall result in waiver of all objections.
A party seeking to have videotaped testimony utilized at trial must retain a videographer for the playback at trial.
In a Jury case, counsel shall submit proposed jury Instructions for each claim, counterclaim and/or cross-claim contained in the pleadings with applicable O.J.I. or case citations, as well as verdict forms and any interrogatories. Failure to submit Proposed Jury Instructions and/or Interrogatories may be deemed a violation of this Order and sanctions may issue.
In the event the Court is engaged in trial and this matter is referred to a visiting judge, the case is referred for purposes of trial only. The assigned Judge, Cassandra Collier-Williams, retains jurisdiction on all post-trial motions. Copies of motions are to be hand-delivered to Judge Collier-Williams’ office on the day of filing.
Trial counsel shall walk courtesy copies of all stipulations and their trial briefs to the Judge’s staff attorney on the 11th floor of the Justice Center or directly to the Judge’s chambers by no later than two (2) weeks prior to trial.
Failure to comply with any portion of this Court’s orders may result in sanctions, including dismissal or judgment.
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