Party Discovery: ANA L. ROMERO vs. EMILY OQUENDO-MALDONADO, ET AL

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                                152200133
                                            152200133

                     IN THE COURT OF COMMON PLEAK                                  %
                         CUYAHOGA COUNTY, OHIO J                                  7    &
                                                        Case No: ^-23-978^2)^-^
ANA L. ROMERO
      Plaintiff
                                                        Judge: SHIRLEY STRICKLAND SAEKOLD
                                                                                    '‘'ZL
EMILY OQUENDO-MALDONADO, ET AL
     Defendant

                                                        JOURNALENTRY


CASE MANAGEMENT CONFERENCE HELD 07/13/23. ALL PARTIES PRESENT THROUGH COUNSEL. THE FOLLOWING
DATES ARE TO APPLY TO THIS MATTER.

ALL PAPER DISCOVERY TO BE COMPLETED BY 11/10/23.
AFFIRMATIVE EXPERT REPORT DUE BY 11/10/23.
REBUTTAL EXPERT REPORT DUE BY 12/11/23.
DISPOSITIVE MOTIONS DUE BY 12/18/23. RESPONSES AND REPLIES DUE BY RULE.
FINAL PRETRIAL SET FOR 02/29/24 AT 10:00AM.
FINAL PRETRIAL STATEMENTS DUE 7 DAYS PRIOR. FPT STATEMENTS SHOULD BE E-MAILED TO THE STAFF
ATTORNEY AT ILOVING@CUYAHOGACOUNTY.US. ALL PARTIES, INCLUDING PARTIES WITH ULTIMATE
SETTLEMENT AUTHORITY, ARE TO BE PRESENT, IN PERSON. TELEPHONE APPEARANCE IS NOT PERMITTED.
TRIAL SET FOR 04/01/24 AT 10:00 AM.
AN AGREED UPON SET OF JURY INSTRUCTIONS, INTERROGATORIES, VERDICT FORMS, AND STATEMENT OF THE
CASE TO BE READ TO PROSPECTIVE JURORS ARE DUE 7 DAYS PRIOR TO TRIAL. ANY INSTRUCTIONS THAT THE
PARTIES CANNOT AGREE UPON SHALL BE SUBMITTED SEPARATELY. COPIES SHALL BE SUBMITTED IN
MICROSOFT WORD FORMAT BY EMAIL TO THE STAFF ATTORNEY AT ILOVING@CUYAHOGACOUNTY.US. TRIAL
BRIEFS, WITNESS LISTS, AND EXHIBIT LISTS ARE DUE 7 DAYS PRIOR TO TRIAL. EXHIBITS SHALL BE LABELED
AND MARKED BEFORE TRIAL. COURTESY COPIES OF EXHIBITS TO BE GIVEN TO THE COURT ON THE DAY OF
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 COURT. ANY PARTY
WISHING TO PROFFER DEPOSITION TESTIMONY (VIDEOTAPE AND WRITTEN) AT TRIAL SHALL FILE A LIST OF
ALL DEPOSITION TRANSCRIPTS THAT ARE TO BE UTILIZED AT TRIAL AT LEAST FOURTEEN (14) DAYS BEFORE
TRIAL. OBJECTIONS TO TESTIMONIAL DEPOSITIONS THAT REQUIRE RULINGS FROM THE COURT SHALL BE
SUBMITTED AT LEAST SEVEN (7) DAYS PRIOR TO TRIAL. COUNSEL PROPOSING TO USE SAID DEPOSITION SHALL
FILE A RESPONSE TO THE OBJECTIONS OR INDICATE THEIR AGREEMENT TO DELETE THE PORTION OF THE
DEPOSITION FOR WHICH THERE IS AN OBJECTION THREE (3) DAYS BEFORE TRIAL. THE COURT MUST BE
PROVIDED WITH A COMPLETE WRITTEN TRANSCRIPT OF THE DISPUTED DEPOSITIONS. FAILURE OF ANY PARTY
TO SUBMIT OBJECTIONS SHALL RESULT IN WAIVER OF ALL OBJECTIONS. MOTIONS IN LIMINE MUST BE FILED
NO LATER THAN 14 DAYS PRIOR TO TRIAL. ANY BRIEFS IN OPPOSITION TO MOTIONS IN LIMINE ARE DUE 7 DAYS
PRIOR TO TRIAL. REPLY BRIEFS IN SUPPORT OF MOTIONS IN LIMINE BY LEAVE OF COURT ONLY. UNTIMELY
MOTIONS WILL NOT BE CONSIDERED OR ACCEPTED. ALL PARTIES ARE TO NOTE THAT A PERSON WITH
ULTIMATE SETTLEMENT AUTHORITY MUST BE PRESENT, IN PERSON, FOR ALL SET DATES. NO EXCEPTIONS AND
NO TELEPHONE APPEARANCE PERMITTED FOR ANY REASON. FAILURE TO APPEAR AT ANY SET DATE WILL
RESULT IN JUDGMENT BEING RENDERED OR DISMISSAL WITH PREJUDICE PURSUANT TO CIV. R. 41(B) AS WELL
AS POSSIBLE SANCTIONS.

IT IS SO ORDERED.


                                                    Judge Signature           Date


07/13/2023
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