Court Rules
Judge Andrew J. Santoli
Judge

Judge Andrew J. Santoli

Individual Rules, Standing Orders & Policies

Cuyahoga County Court of Common Pleas, General Division

Limits & Logistics

Courtesy Copies

Motion

  • Upon Filing

Adjournments

  • Continuances and extensions are granted only when good cause is shown.
  • Extensions of court-ordered deadlines should be requested by joint or unopposed motion when possible.
  • Before filing an extension motion, counsel must consult opposing counsel and state that position in the motion.

Request must include

Reason For RequestAdversary Position

Communication

Phone
Court-wide

Clerk

Technical Issues
Hours: 8:30 a.m. to 4:30 p.m. each business day
Filters:AllMandatoryImportantFormattingJuryDiscoveryLettersExhibitsMemorandaEvidence/WitnessesSettlement

Document Format Requirements3 rules

Formatting

Checked against the court's document on Oct 1, 2026Mandatory

In addition to hard copies, proposed jury instructions, stipulated statements, interrogatories, and verdict forms must be emailed to the court's staff attorney as Microsoft Word documents.

In addition to hard copies, proposed jury instructions, including the stipulated statement of the case, jury interrogatories, and verdict forms are to be provided to the Court in a Microsoft Word document via email sent to the court’s staff attorney.

Required Format

DOCX

Cuyahoga Oh:84c3b267ba26e5c69ac40e6d
|SecJury Instructions, Interrogatories, Verdict Forms
Formatting

Checked against the court's document on Oct 1, 2026Important

Jury instructions must conform to Ohio Judicial Instructions or cite published Ohio cases, address the issues at trial, and be short, concise, understandable, and neutral.

Counsel shall provide jury instructions that conform to OJI or cite to published Ohio cases. Counsel shall provide jury instructions that are relevant to the specific issues to be presented at trial. All instructions should be short, concise, understandable and neutral statements of law.

Cuyahoga Oh:84c3b267ba26e5c69ac40e6d
|SecJury Instructions, Interrogatories, Verdict Forms
Formatting

Checked against the court's document on Oct 1, 2026Important

Trial exhibits must be pre-marked with exhibit stickers; plaintiffs use numbers and defendants use letters.

Trial exhibits shall be pre-marked with exhibit stickers and exchanged. Plaintiffs shall mark their exhibits using numbers; defendants shall mark their exhibits using letters.

Cuyahoga Oh:84c3b267ba26e5c69ac40e6d
|SecWitness and Exhibit Lists

Document Filing Requirements8 rules

Filing Requirements

Checked against the court's document on Oct 1, 2026Mandatory

The parties must exchange, serve, and file witness lists containing each witness's name and a brief description of expected testimony.

The parties shall exchange, serve, and file witness lists which shall include the witnesses' names and a very brief statement outlining the substance of each witness' expected testimony.

Document Type

Witness List

Specific requirements detailed in rule text.
Cuyahoga Oh:84c3b267ba26e5c69ac40e6d
|SecWitness and Exhibit Lists
Filing Requirements

Checked against the court's document on Oct 1, 2026Mandatory

At the default hearing, the movant must bring an affidavit of damages, a prepared journal entry, and proof of a mailed hearing notice.

The movant must bring to the hearing the following: affidavit of damages, a prepared journal entry, and a copy of the letter sent regular and certified mail 7 days prior to the hearing date notifying all parties of the hearing and that failure to appear will result in judgment against them.

Document Type

Default Judgment Hearing Submission

Content & Formatting
Proposed Order
Filing Requirements

Checked against the court's document on Oct 1, 2026Mandatory

The parties must exchange, serve, and file a list of trial exhibits.

The parties shall exchange, serve, and file a list of trial exhibits.

Document Type

Trial Exhibit List

Specific requirements detailed in rule text.
Cuyahoga Oh:84c3b267ba26e5c69ac40e6d
|SecWitness and Exhibit Lists
Filing Requirements

Checked against the court's document on Oct 1, 2026Mandatory

Each party must serve and file a trial brief containing the specified claims, facts, issues, stipulations, damages, and trial-time estimate.

All parties are required to serve and file a trial brief which shall contain: a succinct statement of their claims (as presented in the pleadings); a brief statement of the essential and material facts; the legal issues involved; the stipulations agreed upon by the parties; the type and amount of damages they are seeking; and an estimate of how long it will take to put on their case in chief.

Document Type

Trial Brief

Specific requirements detailed in rule text.
Filing Requirements

Checked against the court's document on Oct 1, 2026Mandatory

Attorneys must confer before the CMC to discuss claims and defenses, settlement possibilities, discovery, and a proposed schedule.

In accordance with Civ.R. 26(F), the attorneys shall confer prior to a scheduled Case Management Conference (“CMC”) to discuss claims and possible defenses, the possibilities for resolving and/or settling the case, create a discovery plan, and establish a proposed case schedule.

Document Type

Proposed Case Schedule And Discovery Plan

Specific requirements detailed in rule text.
Cuyahoga Oh:84c3b267ba26e5c69ac40e6d
|SecCivil Case Management Order
Filing Requirements

Checked against the court's document on Oct 1, 2026Important

The Court will not consider proposed jury instructions that are argumentative or otherwise nonconforming.

The Court will not consider proposed jury instructions that are deemed argumentative or which otherwise do not conform to the above requirements.

Document Type

Jury Instructions

Specific requirements detailed in rule text.
Cuyahoga Oh:84c3b267ba26e5c69ac40e6d
|SecJury Instructions, Interrogatories, Verdict Forms
Filing Requirements

Not confirmed. Read the court's wording below.Mandatory?

In its objection, counsel shall highlight the objectionable language and include a concise argument as to why the proposed language is improper.

Summary: An objection must identify and highlight the objectionable language and include a concise explanation of why it is improper.

Document Type

Objections To Jury Instructions Interrogatories And Verdict Forms

Specific requirements detailed in rule text.
Cuyahoga Oh:84c3b267ba26e5c69ac40e6d
|SecJury Instructions, Interrogatories, Verdict Forms
Filing Requirements

Not confirmed. Read the court's wording below.Note?

The parties should then confer in order to agree on a single set of instructions to the extent possible.

Summary: After serving their proposed jury materials, the parties should confer and seek agreement on a single set of instructions to the extent possible.

Document Type

Jury Instructions

Specific requirements detailed in rule text.
Cuyahoga Oh:84c3b267ba26e5c69ac40e6d
|SecJury Instructions, Interrogatories, Verdict Forms

Filing & Service rules

Filing Timing and Cure Windows

Joint and disputed proposed jury instructions, interrogatories, and verdict forms must be filed at least seven days before trial.

The joint proposed instructions (along with the proposed instructions upon which the parties have been unable to agree), interrogatories, and verdict forms must be filed with the court at least seven (7) days before trial.

Checked against the court's document on Oct 1, 2026

Page 1 | Jury Instructions, Interrogatories, Verdict Forms

An opposition brief is due seven days after the motion in limine is filed and at least three days before trial.

A brief in opposition is due seven (7) days after the motion in limine is filed, but no later than three days prior to trial.

Checked against the court's document on Oct 1, 2026

Page 1 | Motion Practice

The parties must file their proposed discovery plan at least seven days before the CMC.

The parties shall file their proposed discovery plan in accordance with Civ.R. 26(F)(3) seven (7) days prior to the CMC.

Checked against the court's document on Oct 1, 2026

Page 1 | Civil Case Management Order

Written motions in limine must be filed ten days before trial.

Motions in Limine must be in writing and filed ten (10) days before trial.

Checked and corrected to match the court's document on Oct 1, 2026

Page 1 | Motion Practice

Any objections to opposing counsel's proposed jury instructions, interrogatories, or verdict forms must be filed at least two days before trial.

Further, counsel must file its objections, if any, to jury instructions, interrogatories, and verdict forms proposed by opposing counsel at least two (2) days before trial.

Checked against the court's document on Oct 1, 2026

Page 1 | Jury Instructions, Interrogatories, Verdict Forms

The parties must notify the Court as soon as practicable after reaching a settlement.

In the event that a case has settled, the parties are to notify the Court as soon as practicable after a settlement agreement has been reached.

Checked against the court's document on Oct 1, 2026

Page 1 | Settlement Conference

The Court may strike motions or briefs that are untimely.

Untimely motions and/or briefs may be stricken by the Court.

Checked against the court's document on Oct 1, 2026

Page 1 | Motion Practice

The court must receive copies of the witness and exhibit lists at least seven days before trial.

The parties are required to provide the court with a copy of all of the above items seven (7) days before trial.

Not confirmed. Read the court's wording below.

Page 1 | Witness and Exhibit Lists

Within 30 days after settlement, the parties must submit a joint notice of dismissal identifying who will pay the court costs.

The parties are to submit a joint Notice of Dismissal indicating which party will bear the court costs of the action within 30 days of the settlement agreement.

Not confirmed. Read the court's wording below.

Page 1 | Settlement Conference

The Court schedules a default hearing after a motion for default judgment is filed.

Upon filing of a motion for default judgment, the Court will schedule a default hearing.

Not confirmed. Read the court's wording below.

Page 1 | Default Judgment

Service and Proof of Service Rules

Proposed jury instructions, interrogatories, and verdict forms must be served on the other parties at least 14 days before trial.

The parties must serve their proposed jury instructions, interrogatories, and verdict forms on each other at least fourteen (14) days before trial.

Checked against the court's document on Oct 1, 2026

Page 1 | Jury Instructions, Interrogatories, Verdict Forms

The movant must bring the affidavit of damages, prepared journal entry, and copy of the hearing notice letter sent by regular and certified mail 7 days before the hearing.

The movant must bring to the hearing the following: affidavit of damages, a prepared journal entry, and a copy of the letter sent regular and certified mail 7 days prior to the hearing date notifying all parties of the hearing and that failure to appear will result in judgment against them.

Checked and corrected to match the court's document on Oct 1, 2026

Page 1 | Default Judgment

Trial briefs must be served and filed at least seven days before trial.

Trial briefs shall be delivered seven (7) days before trial.

Not confirmed. Read the court's wording below.

Page 1 | Trial Briefs

Courtesy Copy Requirements

Counsel must provide the Court with a courtesy copy whenever a motion is filed.

When a motion is filed, counsel is required to provide the Court with a courtesy copy of the motion.

Checked against the court's document on Oct 1, 2026

Page 1 | Motion Practice

Pre-Motion Conference Requirements

The Court will hear merits oral argument if requested; otherwise, it will schedule oral hearings as it deems appropriate.

If requested, the Court will hear oral arguments on the merits of the motion. Otherwise, the Court will schedule oral hearings as it sees fit.

Checked against the court's document on Oct 1, 2026

Page 1 | Motion Practice

Parties are encouraged, but not required, to resolve discovery disputes themselves before filing a motion.

The parties are encouraged to settle any discovery dispute amongst themselves before filling a motion with the court (motions to compel, motions for a protective order, etc.)

Checked against the court's document on Oct 1, 2026

Page 1 | Motion Practice

Adjournment & Extension Requirements

Continuances and extensions are granted only when good cause is shown.

Continuances and extensions may be granted only for good cause shown.

Checked against the court's document on Oct 1, 2026

Page 1 | Civil Case Management Order

Extensions of court-ordered deadlines should be requested by joint or unopposed motion when possible.

Extensions of court-ordered deadlines may be requested by motion, preferably in the form of a joint or unopposed motion.

Checked against the court's document on Oct 1, 2026

Page 1 | Civil Case Management Order

Before filing an extension motion, counsel must consult opposing counsel and state that position in the motion.

Prior to filing a motion seeking an extension, you are required to consult with your opposing counsel and state in your motion your opposing counsel's position on the extension request.

Not confirmed. Read the court's wording below.

Page 1 | Civil Case Management Order

Court-wide rules

Applies court-wide

These 421 rules apply across Cuyahoga County Court of Common Pleas, General Division. Where this judge's own standing orders above address the same topic, the judge's requirement controls.

  • Applies to
    Mediation

    No mediation fees are charged for civil cases referred to the court's dispute resolution department.

  • Applies to
    Mediation

    When a case is referred to a mediator outside the court's dispute resolution department, the parties share the mediation cost in proportions they agree upon.

  • Fee
    $66
    Applies to
    Special process server application

    Filing a Special Process Server application costs $66.00 plus any applicable Special Project Fees.

Filing Timing

All 85
  • A motion for extraordinary assigned-counsel compensation must be filed with the usual affidavit and entry requesting assigned-counsel fees.

  • A Guardian Ad Litem may request fees above the schedule by using the extraordinary-compensation procedure.

  • Assigned counsel must apply in writing for an investigator at least 30 days before trial.

Filing Requirements

All 56
  • Applies to
    Notice of appearance

    A notice of limited appearance must use the prescribed title, describe the representation’s scope and justification, and state that the limited representation was communicated to the client in writing.

  • Applies to
    Special process server application
    Must include
    local rule certificate

    An application for a standing order designating a Special Process Server must be supported by an affidavit containing the stated applicant information and agreements.

  • Applies to
    Proposed standing order

    The applicant must submit a proposed standing order with the specified caption and language designating the applicant to serve process and subpoenas for the stated one-year term or until further court order.

Adjournments

All 39
  • Mediation continuances require good cause, generally cannot be based solely on pending motions, and will not be granted unless mediation can be scheduled before the next court event.

  • If the Court cannot rule by the scheduled ruling date for any reason, the trial date must be continued for at least 60 days.

  • An automatic trial-date continuance does not apply when a party obtains an extension of the briefing schedule that requires extending the ruling date, although the Court may continue the trial date in its discretion.

About Judge Andrew J. Santoli

- On the Common Pleas bench since: January 2021 - Admitted to the bar: 2006 - Legal experience: Assistant Prosecuting Attorney-Major Trial Unit, Cuyahoga County Prosecutor’s Office (2007-2020) Civil Litigation Attorney, Schraff Thomas Law, LLC

- Courtroom: 21-A - Courthouse: 1200 Ontario Street, Cleveland, Ohio 44113 - Fax: 216-348-4033 - Bailiff: Thomas Lynch (216) 443-8686 - Staff attorney: Shannon Raley (216) 443-8604

Common questions about Judge Andrew J. Santoli's rules

Are courtesy copies required for Judge Andrew J. Santoli?

Courtesy-copy rule applies for motions. Details: delivery upon filing. Counsel must provide the Court with a courtesy copy whenever a motion is filed.

View ruleSource: page 1, section Motion Practice

Does Judge Andrew J. Santoli require a pre-motion conference or letter before filing a motion?

Judge Andrew J. Santoli's rules set a pre-motion procedure for covered motions. The Court will hear merits oral argument if requested; otherwise, it will schedule oral hearings as it deems appropriate.

View ruleSource: page 1, section Motion Practice

What formatting rules apply to filings before Judge Andrew J. Santoli?

Judge Andrew J. Santoli's formatting rule includes file format docx and in addition to hard copies, provide the document to the court by emailing the court's staff attorney.. In addition to hard copies, proposed jury instructions, stipulated statements, interrogatories, and verdict forms must be emailed to the court's staff attorney as Microsoft Word documents.

View ruleSource: page 1, section Jury Instructions, Interrogatories, Verdict Forms

What must be included with proposed case schedule and discovery plan filings before Judge Andrew J. Santoli?

The rule identifies required filing content or certificates. Attorneys must confer before the CMC to discuss claims and defenses, settlement possibilities, discovery, and a proposed schedule.

View ruleSource: page 1, section Civil Case Management Order

What must be included with default judgment hearing submission filings before Judge Andrew J. Santoli?

The rule requires proposed order. At the default hearing, the movant must bring an affidavit of damages, a prepared journal entry, and proof of a mailed hearing notice.

View ruleSource: page 1, section Default Judgment

How do I request an adjournment or extension before Judge Andrew J. Santoli?

Advance notice is not fully stated in the structured details. Continuances and extensions are granted only when good cause is shown.

View ruleSource: page 1, section Civil Case Management Order

What filing deadlines does Judge Andrew J. Santoli set?

The parties must file their proposed discovery plan at least seven days before the CMC.

View ruleSource: page 1, section Civil Case Management Order

What rule applies to service for notice of default hearing before Judge Andrew J. Santoli?

The rule addresses service method, recipient, or timing requirements. Details: method: service by mail, recipient: all parties, timing: 7 calendar days before hearing. The movant must bring the affidavit of damages, prepared journal entry, and copy of the hearing notice letter sent by regular and certified mail 7 days before the hearing.

View ruleSource: page 1, section Default Judgment
Complete rules summary for Judge Andrew J. Santoli

Counsel must provide the Court with a courtesy copy whenever a motion is filed.

The Court will hear merits oral argument if requested; otherwise, it will schedule oral hearings as it deems appropriate.

Attorneys must confer before the CMC to discuss claims and defenses, settlement possibilities, discovery, and a proposed schedule.

The parties must file their proposed discovery plan at least seven days before the CMC.

Continuances and extensions are granted only when good cause is shown.

Written motions in limine must be filed ten days before trial.

Extensions of court-ordered deadlines should be requested by joint or unopposed motion when possible.

Before filing an extension motion, counsel must consult opposing counsel and state that position in the motion.

The Court schedules a default hearing after a motion for default judgment is filed.

At the default hearing, the movant must bring an affidavit of damages, a prepared journal entry, and proof of a mailed hearing notice.

The movant must bring the affidavit of damages, prepared journal entry, and copy of the hearing notice letter sent by regular and certified mail 7 days before the hearing.

Parties are encouraged, but not required, to resolve discovery disputes themselves before filing a motion.

An opposition brief is due seven days after the motion in limine is filed and at least three days before trial.

The Court may strike motions or briefs that are untimely.

The parties must notify the Court as soon as practicable after reaching a settlement.

Within 30 days after settlement, the parties must submit a joint notice of dismissal identifying who will pay the court costs.

Each party must serve and file a trial brief containing the specified claims, facts, issues, stipulations, damages, and trial-time estimate.

Trial briefs must be served and filed at least seven days before trial.

An objection must identify and highlight the objectionable language and include a concise explanation of why it is improper.

The parties must exchange, serve, and file witness lists containing each witness's name and a brief description of expected testimony.

The parties must exchange, serve, and file a list of trial exhibits.

Trial exhibits must be pre-marked with exhibit stickers; plaintiffs use numbers and defendants use letters.

The court must receive copies of the witness and exhibit lists at least seven days before trial.

Jury instructions must conform to Ohio Judicial Instructions or cite published Ohio cases, address the issues at trial, and be short, concise, understandable, and neutral.

The Court will not consider proposed jury instructions that are argumentative or otherwise nonconforming.

Proposed jury instructions, interrogatories, and verdict forms must be served on the other parties at least 14 days before trial.

After serving their proposed jury materials, the parties should confer and seek agreement on a single set of instructions to the extent possible.

Joint and disputed proposed jury instructions, interrogatories, and verdict forms must be filed at least seven days before trial.

Any objections to opposing counsel's proposed jury instructions, interrogatories, or verdict forms must be filed at least two days before trial.

In addition to hard copies, proposed jury instructions, stipulated statements, interrogatories, and verdict forms must be emailed to the court's staff attorney as Microsoft Word documents.

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