Court Rules
Judge John J. Russo
Judge

Judge John J. Russo

Individual Rules, Standing Orders & Policies

Cuyahoga County Court of Common Pleas, General Division

Limits & Logistics

Courtesy Copies

Jury Instructions, Jury Interrogatories, Jury Verdict Form

  • Email

Adjournments

  • Discovery deadlines and court events may be continued without court consent only when all parties agree and the extension will not interfere with the trial date.

Request must include

Adversary PositionAffects Other Dates

Communication

Phone
216-443-8588
Scheduling
Phone
Court-wide

Clerk

Technical Issues
Hours: 8:30 a.m. to 4:30 p.m. each business day
Filters:AllMandatoryDiscoveryJuryConferencesMemorandaExhibitsEvidence/WitnessesProposed Orders

Document Filing Requirements6 rules

Filing Requirements

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

Requests for production of documents and interrogatories must be served before the case management conference together with the required Generative Artificial Intelligence certificate.

Requests for production of documents and interrogatories must be served prior to the Case Management Conference, as well as the Certificate regarding Generative Artificial Intelligence (click here for PDF).

Document Type

Discovery Requests

Content & Formatting
Ai Disclosure
Cuyahoga Oh:f17643c504f4b42731938215
|SecCase Management Conferences
Filing Requirements

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

The parties must provide one consolidated set of jury instructions, interrogatories, and verdict forms that identifies both agreed and disputed items.

With respect to Jury Instructions, Jury Interrogatories, and Jury Verdict Forms, the Parties are to provide the Court with one consolidated set of Instructions/Interrogatories/Verdict Forms that includes all the Instructions/Interrogatories/Verdict Forms to which the Parties agree and that identifies all the Instructions/Interrogatories/Verdict Forms to which the Parties disagree.

Document Type

Jury Instructions Interrogatories And Verdict Forms

Specific requirements detailed in rule text.
Filing Requirements

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

At least 14 days before trial, the parties must file trial briefs, witness and exhibit lists, applicable joint jury materials, stipulations, and an agreed statement of the case for the jury.

The Court additionally orders that at least 14 days prior to Trial, the parties are to file the following: (1) Trial Briefs, (2) Witness Lists, (3) Exhibit Lists, (4) Joint Jury Instructions, Jury Interrogatories, and /or Jury Verdict Forms if applicable, (5) Stipulations, and (6) an agreed upon State of the Case to be read to the Jury.

Document Type

Trial Preparation Documents

Specific requirements detailed in rule text.
Filing Requirements

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

A motion for default judgment must be accompanied by the relevant written instruments, affidavits of service and damages, a military affidavit, and a proposed judgment entry.

When provided by Civ.R. 55, the Plaintiff may file a Motion for Default Judgment and provide to the Court the following documents: (1) the contract(s), assignment(s), account statement(s), or written instrument(s) upon which Plaintiff seeks judgment; (2) an affidavit of service of the Complaint; (3) an affidavit of damages; (4) a military affidavit; and (5) a proposed judgment entry.

Document Type

Motion For Default Judgment

Content & Formatting
Proposed Order
Cuyahoga Oh:f17643c504f4b42731938215
|SecMotions for Default Judgment
Filing Requirements

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

Evidence supporting the amount of damages, such as bills or account statements, must be filed before default judgment is rendered.

Evidence of damages, such as bills or account statements, must be included in the file before default judgment can be rendered.

Document Type

Damages Evidence

Specific requirements detailed in rule text.
Cuyahoga Oh:f17643c504f4b42731938215
|SecMotions for Default Judgment
Filing Requirements

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

I further certify that no portion of any filing in this case will be drafted by generative artificial intelligence or that any language drafted by generative artificial intelligence—including quotations, citations, paraphrased assertions, and legal analysis—will be checked for accuracy, using print reporters or traditional legal databases, by a human being before it is submitted to the Court.

Summary: No portion of a filing may be drafted by generative artificial intelligence, and any generative-AI-drafted language must be checked for accuracy by a human using print reporters or traditional legal databases before submission.

Document Type

Filing

Specific requirements detailed in rule text.
jjr-certificate-re-generative-artificial-intelligence · p. 1
|SecCERTIFICATE REGARDING JUDGE-SPECIFIC REQUIREMENTS

Filing & Service rules

Filing Timing and Cure Windows

A motion in limine must be filed at least 28 days before trial.

In accordance with Civ.R. 6, the Court orders that any Motion in Limine is to be filed at least 28 days before Trial.

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

Page 1 | Trials

The listed trial-preparation documents must be filed no later than 14 days before trial.

The Court additionally orders that at least 14 days prior to Trial, the parties are to file the following: (1) Trial Briefs, (2) Witness Lists, (3) Exhibit Lists, (4) Joint Jury Instructions, Jury Interrogatories, and /or Jury Verdict Forms if applicable, (5) Stipulations, and (6) an agreed upon State of the Case to be read to the Jury.

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

Page 1 | Trials

A summary-judgment opposition brief is due 28 days after the summary-judgment motion is filed.

Pursuant to Civ.R. 6, a Brief in Opposition is due 28 days after the filing of a Motion for Summary Judgment.

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

Page 1 | Motions for Summary Judgment

A motion in limine must be filed at least 28 days before trial.

Pursuant to Civ.R. 6, the Court orders that any Motion in Limine is to be filed at least 28 days before Trial.

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

Page 1 | Motions in Limine

For motions other than summary judgment or in limine, the opposition brief is due 14 days after filing.

Pursuant to Civ.R. 6, a Brief in Opposition is due 14 days after the filing of a Motion.

Not confirmed. Read the court's wording below.

Page 1 | Any Motions other than a Motion for Summary Judgment or a Motion in Limine

An opposition brief to a motion in limine is due 14 days after the motion is filed.

Any Brief in Opposition is due 14 days thereafter.

Not confirmed. Read the court's wording below.

Page 1 | Trials

A summary-judgment reply brief is due seven days after the opposition brief is filed.

A Reply Brief is due 7 days after the filing of a Brief in Opposition.

Not confirmed. Read the court's wording below.

Page 1 | Motions for Summary Judgment

No reply brief is permitted in response to a motion in limine.

No Reply shall be permitted.

Not confirmed. Read the court's wording below.

Page 1 | Trials

Courtesy Copy Requirements

The parties should email the Staff Attorney a Word-format courtesy copy of their jury instructions, interrogatories, and verdict forms.

A courtesy copy of the Parties’ Instructions/Interrogatories/Verdict Forms in a Word format should be emailed to the Court’s Staff Attorney.

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

Page 1 | Trials

Pre-Motion Conference Requirements

Before filing any discovery motion, the parties must promptly contact the Staff Attorney and arrange a telephone or in-person attorney conference.

In accordance with the Court’s Discovery practices, the parties are to contact Judge Russo’s Staff Attorney prior to the filing of any Discovery Motion to set the matter for an Attorney Conference either via telephone or in-person with the Court as soon as possible.

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

Page 1 | Motion Practice — Discovery Motions

Before filing any discovery motion, the parties must promptly contact the Staff Attorney to arrange a telephone or in-person attorney conference.

Prior to any party filing any Discovery Motion, the parties shall contact Judge Russo’s Staff Attorney to set an Attorney Conference either via telephone or in-person with the Court as soon as possible.

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

Page 1 | Discovery

An oral hearing on a motion for summary judgment is available if requested.

An oral hearing on the Motion is available upon request.

Not confirmed. Read the court's wording below.

Page 1 | Motions for Summary Judgment

The court will attempt to rule on the summary-judgment motion before the final pretrial, ordinarily placing the ruling on the docket unless the parties make other arrangements with the court.

The Court shall make all attempts to issue a ruling on the Motion prior to the Final Pretrial. The ruling will be made on the docket unless other arrangements have been made by the parties with the Court.

Not confirmed. Read the court's wording below.

Page 1 | Motions for Summary Judgment

Adjournment & Extension Requirements

Discovery deadlines and court events may be continued without court consent only when all parties agree and the extension will not interfere with the trial date.

Continuances of discovery deadlines or court events without Court consent shall be permitted as long as (1) all the parties agree and (2) the extension does not interfere with the Trial date.

Not confirmed. Read the court's wording below.

Page 1 | Calendaring and Continuances

Chambers Communication Rules

Plaintiff’s counsel must initiate the case management telephone conference with defense counsel and then Judge Russo’s Staff Attorney at the stated number.

Plaintiff's counsel is to initiate the telephone conference to Defendant's counsel and then to Judge Russo’s Staff Attorney at 216-443-8588.

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

Page 1 | Case Management Conferences

The initial case management conference ordinarily occurs by telephone with the Staff Attorney unless the parties request that Judge Russo conduct it.

The CMC will be conducted by phone with the Court’s Staff Attorney, unless the parties request it be held by Judge Russo.

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

Page 1 | General

If settlement is no longer possible, the parties should contact the Staff Attorney to cancel the settlement conference rather than appear in court.

If the parties believe settlement is not possible prior to the Settlement Conference, please contact Judge Russo’s Staff Attorney to cancel the Settlement Conference instead of coming to Court.

Not confirmed. Read the court's wording below.

Page 1 | Settlement Conference

Initial case management conferences in Commercial Docket cases are conducted in person with Judge Russo.

However, the initial Case Management Conference for Commercial Docket cases will be conducted in-person with Judge Russo.

Not confirmed. Read the court's wording below.

Page 1 | General

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 John J. Russo

- On the Common Pleas bench since: 01/09/2005 - Admitted to the bar: 1992 - Legal experience: THE HONORABLE JOHN J. RUSSO is the immediate Past Administrative and Presiding Judge of the Court of Common Pleas of Ohio in Cuyahoga County. Unanimously elected by his colleagues to lead the Court from 2014-2019, he was responsible for coordinating the development of Court policies and overseeing the administration of the General Division, the highest-level trial court in the state. Judge Russo manages his civil and criminal dockets, as well as, managed from 2018-2022, Cuyahoga County’s Veteran Treatment Court/Specialty Docket. In addition, he has chaired or participated in numerous justice system boards and committees since beginning his judicial career in 2005 on the Common Pleas Court. Some include: Chair-Elect and Co-Chair of the Court Administration Committee of the Ohio Judicial Conference; President of the Cleveland Metropolitan Bar Association; Cleveland State University Law Alumni Association where in 2018 was inducted into CSU/Law Hall of Fame and in 2019 was CSU College of Law Alumni of the year; Member of the Public Health, Death Penalty and Bail Bond Reform Task Force (all appointed by the Ohio Chief Justice); Past President and Man of The Year recipient of the Legal Eagles St. Edward High School. He served as president of the National Association for Presiding Judges and Court Executive Officers (NAPCO), a national organization of court chief judges and court executives, from 2015-2016. In 2019, he was elected to, and currently serves as, NAPCO’s Chair of the Board of Directors. In addition, he has taught at numerous court conclaves, judges’ conferences, community programs, and bar association CLE programs. Judge is a member of the Ohio State Bar Association, Cuyahoga Metropolitan Bar Association, Westshore Bar Association, and CSU College of Law Alumni Association. Prior to the bench, Judge Russo was a civil and criminal litigator in his private practice for 12 years. After earning a Bachelor of Science in Business Administration, he received his Juris Doctor degree at CSU College of Law, where he currently serves as an Adjunct Professor.

- Courtroom: 16-B - Courthouse: 1200 Ontario Street, Cleveland, Ohio 44113 - Fax: (216) 348-4038 - Bailiff: Kathleen M. Dunham (216) 443-8676 - Staff attorney: Marie Banks (216) 443-8588

Common questions about Judge John J. Russo's rules

Are courtesy copies required for Judge John J. Russo?

Courtesy-copy rule applies for jury instructions, jury interrogatories, and jury verdict forms. Details: by email. The parties should email the Staff Attorney a Word-format courtesy copy of their jury instructions, interrogatories, and verdict forms.

View ruleSource: page 1, section Trials

Does Judge John J. Russo require a pre-motion conference or letter before filing a motion?

Judge John J. Russo's rules set a pre-motion procedure for discovery. Before filing any discovery motion, the parties must promptly contact the Staff Attorney to arrange a telephone or in-person attorney conference.

View ruleSource: page 1, section Discovery

What must be included with filing filings before Judge John J. Russo?

The rule identifies required filing content or certificates. No portion of a filing may be drafted by generative artificial intelligence, and any generative-AI-drafted language must be checked for accuracy by a human using print reporters or traditional legal databases before submission.

View ruleSource: page 1, section CERTIFICATE REGARDING JUDGE-SPECIFIC REQUIREMENTS

What must be included with discovery requests filings before Judge John J. Russo?

The rule requires ai disclosure. Requests for production of documents and interrogatories must be served before the case management conference together with the required Generative Artificial Intelligence certificate.

View ruleSource: page 1, section Case Management Conferences

How may parties contact Judge John J. Russo's chambers?

The rule addresses phone communications. The rule lists phone 216-443-8588. Plaintiff’s counsel must initiate the case management telephone conference with defense counsel and then Judge Russo’s Staff Attorney at the stated number.

View ruleSource: page 1, section Case Management Conferences

How do I request an adjournment or extension before Judge John J. Russo?

Advance notice is not fully stated in the structured details. The request must include adversary position and affects other dates. Discovery deadlines and court events may be continued without court consent only when all parties agree and the extension will not interfere with the trial date.

View ruleSource: page 1, section Calendaring and Continuances

What filing deadlines does Judge John J. Russo set?

The listed trial-preparation documents must be filed no later than 14 days before trial.

View ruleSource: page 1, section Trials
Complete rules summary for Judge John J. Russo

No portion of a filing may be drafted by generative artificial intelligence, and any generative-AI-drafted language must be checked for accuracy by a human using print reporters or traditional legal databases before submission.

The initial case management conference ordinarily occurs by telephone with the Staff Attorney unless the parties request that Judge Russo conduct it.

Initial case management conferences in Commercial Docket cases are conducted in person with Judge Russo.

Plaintiff’s counsel must initiate the case management telephone conference with defense counsel and then Judge Russo’s Staff Attorney at the stated number.

Requests for production of documents and interrogatories must be served before the case management conference together with the required Generative Artificial Intelligence certificate.

Before filing any discovery motion, the parties must promptly contact the Staff Attorney to arrange a telephone or in-person attorney conference.

If settlement is no longer possible, the parties should contact the Staff Attorney to cancel the settlement conference rather than appear in court.

Discovery deadlines and court events may be continued without court consent only when all parties agree and the extension will not interfere with the trial date.

At least 14 days before trial, the parties must file trial briefs, witness and exhibit lists, applicable joint jury materials, stipulations, and an agreed statement of the case for the jury.

The listed trial-preparation documents must be filed no later than 14 days before trial.

The parties must provide one consolidated set of jury instructions, interrogatories, and verdict forms that identifies both agreed and disputed items.

The parties should email the Staff Attorney a Word-format courtesy copy of their jury instructions, interrogatories, and verdict forms.

A motion in limine must be filed at least 28 days before trial.

An opposition brief to a motion in limine is due 14 days after the motion is filed.

No reply brief is permitted in response to a motion in limine.

Before filing any discovery motion, the parties must promptly contact the Staff Attorney and arrange a telephone or in-person attorney conference.

A motion for default judgment must be accompanied by the relevant written instruments, affidavits of service and damages, a military affidavit, and a proposed judgment entry.

For motions other than summary judgment or in limine, the opposition brief is due 14 days after filing.

Evidence supporting the amount of damages, such as bills or account statements, must be filed before default judgment is rendered.

A summary-judgment opposition brief is due 28 days after the summary-judgment motion is filed.

A summary-judgment reply brief is due seven days after the opposition brief is filed.

An oral hearing on a motion for summary judgment is available if requested.

The court will attempt to rule on the summary-judgment motion before the final pretrial, ordinarily placing the ruling on the docket unless the parties make other arrangements with the court.

A motion in limine must be filed at least 28 days before trial.

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