Court Rules
Judge Kevin Kelley
Judge

Judge Kevin Kelley

Individual Rules, Standing Orders & Policies

Cuyahoga County Court of Common Pleas, General Division

Adjournments

Court-wide

Request must include

Reason For Request
Reason For Request
7Court Daysnotice
30Court Daysnotice

Communication

Phone

Chambers

216-443-7326
Scheduling
Phone
Court-wide

Clerk

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

Document Format Requirements1 rule

Formatting

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

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

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

Document Filing Requirements18 rules

Filing Requirements

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

Before the default-judgment hearing, plaintiff’s counsel must provide an affidavit establishing that the defendant is not an active member of the military.

Prior to the scheduled hearing, Plaintiff’s counsel shall provide the Court with the following: 1) a copy of the correspondence sent to the defendant advising of the date and time of the default hearing. 2) an affidavit that establishes that the defendant is not an active member of the military

Document Type

Default Judgment Hearing Submission

Specific requirements detailed in rule text.
Cuyahoga Oh:8ab4dd92563241050d90572c
|SecMotion Practice - Motions for Default Judgment
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

Exhibit List

Content & Formatting
Exhibit List
Filing Requirements

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

Before jury selection begins, the parties must deliver the Court an agreed statement of the case to be read to prospective jurors.

Prior to the start of jury selection, the parties are to deliver to the Court a brief agreed statement of the case to be read to the prospective jurors.

Document Type

Agreed Statement Of The Case

Specific requirements detailed in rule text.
Filing Requirements

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

Before the default-judgment hearing, plaintiff’s counsel must provide a copy of the contract, assignment, or written instrument supporting the requested judgment.

Prior to the scheduled hearing, Plaintiff’s counsel shall provide the Court with the following: 1) a copy of the correspondence sent to the defendant advising of the date and time of the default hearing. 2) an affidavit that establishes that the defendant is not an active member of the military 3) an affidavit signed by the Plaintiff, or Plaintiff’s representative, proving damages 4) a copy of the contract, assignment, or written instrument upon which plaintiff seeks judgment

Document Type

Default Judgment Hearing Submission

Specific requirements detailed in rule text.
Cuyahoga Oh:8ab4dd92563241050d90572c
|SecMotion Practice - Motions for Default Judgment
Filing Requirements

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

Before the default-judgment hearing, plaintiff’s counsel must provide a proposed judgment entry.

Prior to the scheduled hearing, Plaintiff’s counsel shall provide the Court with the following: 1) a copy of the correspondence sent to the defendant advising of the date and time of the default hearing. 2) an affidavit that establishes that the defendant is not an active member of the military 3) an affidavit signed by the Plaintiff, or Plaintiff’s representative, proving damages 4) a copy of the contract, assignment, or written instrument upon which plaintiff seeks judgment and 5) a proposed judgment entry.

Document Type

Default Judgment Motion

Content & Formatting
Proposed Order
Cuyahoga Oh:8ab4dd92563241050d90572c
|SecMotion Practice - Motions for Default Judgment
Filing Requirements

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

The parties must file any stipulations.

The parties are to file any stipulations.

Document Type

Stipulation

Specific requirements detailed in rule text.
Filing Requirements

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

Every party must serve and file a trial brief containing a succinct statement of claims, essential material facts, legal issues, the type and amount of damages sought, and an estimate of the time needed to present the party’s case in chief.

All parties are required to serve and file a trial brief which shall contain a succinct statement of their claims; a brief statement of the essential and material fact; the legal issues involved; 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

Content & Formatting
Statement Of Facts
Legal Argument
Filing Requirements

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

When applicable, the objecting party must submit an alternative instruction addressing the relevant subject matter or legal principle.

Where applicable, the objecting party must submit an alternative instruction covering the pertinent subject matter or principle of law.

Document Type

Jury Instruction Objection

Specific requirements detailed in rule text.
Filing Requirements

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

An objection must quote the proposed instruction in full, identify the objectionable language, concisely explain why it is improper, and cite relevant legal authority.

Any such objections must recite the proposed instruction in its entirety and specifically highlight the objectionable language. The objection should contain both a concise argument why the proposed language is improper and citation to relevant legal authority.

Document Type

Jury Instruction Objection

Specific requirements detailed in rule text.
Filing Requirements

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

The Court will not consider proposed jury instructions that are argumentative or otherwise fail to conform to the stated requirements.

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.
Filing Requirements

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

Before the default-judgment hearing, plaintiff’s counsel must provide an affidavit signed by the plaintiff or plaintiff’s representative proving damages.

Prior to the scheduled hearing, Plaintiff’s counsel shall provide the Court with the following: 1) a copy of the correspondence sent to the defendant advising of the date and time of the default hearing. 2) an affidavit that establishes that the defendant is not an active member of the military 3) an affidavit signed by the Plaintiff, or Plaintiff’s representative, proving damages

Document Type

Default Judgment Hearing Submission

Specific requirements detailed in rule text.
Cuyahoga Oh:8ab4dd92563241050d90572c
|SecMotion Practice - Motions for Default Judgment
Filing Requirements

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

The parties must exchange, serve, and file witness lists identifying each witness and briefly describing the expected testimony.

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

Document Type

Witness List

Specific requirements detailed in rule text.
Filing Requirements

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

Counsel must provide relevant jury instructions that conform to Ohio Jury Instructions or cite published Ohio cases and are short, concise, understandable, and neutral statements of law.

Counsel shall provide jury instructions which 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 the law.

Document Type

Jury Instructions

Specific requirements detailed in rule text.
Filing Requirements

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

All parties and representatives must attend settlement conferences and final pretrials with full, final, and immediate settlement authority.

For settlement conferences and final pretrials, all parties and representatives must be present with full, final, and immediate settlement authority.

Document Type

Settlement Conference And Final Pretrial

Specific requirements detailed in rule text.
Cuyahoga Oh:8ab4dd92563241050d90572c
|SecSettlement Conference
Filing Requirements

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

Before the default-judgment hearing, plaintiff’s counsel must provide the Court with the correspondence sent to the defendant stating the hearing’s date and time.

Prior to the scheduled hearing, Plaintiff’s counsel shall provide the Court with the following: 1) a copy of the correspondence sent to the defendant advising of the date and time of the default hearing.

Document Type

Default Judgment Hearing Submission

Specific requirements detailed in rule text.
Cuyahoga Oh:8ab4dd92563241050d90572c
|SecMotion Practice - Motions for Default Judgment
Filing Requirements

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

Motions in limine must be submitted in writing.

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

Document Type

Motion In Limine

Specific requirements detailed in rule text.
Filing Requirements

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

The parties should confer and try to agree on a single set of jury instructions to the extent possible.

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

Document Type

Jury Instructions

Specific requirements detailed in rule text.
Filing Requirements

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

The parties are required to provide the Court with a file-stamped copy of the above items.

Summary: The parties must provide the Court with file-stamped copies of the witness list, exhibit list, and stipulations.

Document Type

Trial Submissions

Specific requirements detailed in rule text.

Filing & Service rules

Filing Timing and Cure Windows

The joint proposed instructions, disputed proposed instructions, interrogatories, and verdict forms must be filed at least five business 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 five (5) business days before trial.

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

Page 1 | Trials

All parties must file the listed trial submissions before the final pretrial.

Prior to the final pretrial, all parties are to file the following:

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

Page 1 | Trials

A brief opposing a motion in limine is due seven days after filing, and in all events no later than three days before trial.

A brief in opposition is due seven (7) days after the motion in limine is filed, but not later than three days prior to trial.

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

Page 1 | Trials

A motion in limine must be written and filed ten days before trial.

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

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

Page 1 | Trials

A party should file any objections to another party’s proposed jury instructions, interrogatories, or verdict forms no later than two business days before trial.

Each party should file its objections, if any, to jury instructions, interrogatories, and verdict forms proposed by any other party no later than two (2) business days before trial.

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

Page 1 | Trials

A party may file a brief written reply supporting its proposed jury instructions on the day of trial.

Any party may, if it chooses, submit a brief written reply in support of its proposed instructions on the day of trial.

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

Page 1 | Trials

The Court may schedule and conduct oral argument on pending summary-judgment motions, with argument time parameters set by Judge Kelley.

The Court may schedule and conduct an oral argument on pending motions for summary judgment. The time parameters for argument shall be set by Judge Kelley.

Not confirmed. Read the court's wording below.

Page 1 | Motion Practice - Motions for Summary Judgment

Service and Proof of Service Rules

The parties must serve their proposed jury instructions, interrogatories, and verdict forms on one another.

The parties must serve their proposed jury instructions, interrogatories, and verdict forms on each other.

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

Page 1 | Trials

Chambers Communication Rules

Plaintiff’s counsel must initiate the telephone hearing for default judgment.

Plaintiff’s counsel is to initiate the telephonic hearing for default judgment.

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

Page 1 | Motion Practice - Motions for Default Judgment

Before filing a motion to compel or motion to quash, the parties must contact the staff attorney at 216-443-7326 to schedule a telephone conference.

The parties are to contact the staff attorney at 216-443-7326 in order to schedule a telephone conference prior to filing any discovery motion (motion to compel, motion to quash).

Not confirmed. Read the court's wording below.

Page 1 | Discovery

Pretrials will be held in person when time permits, but may also be held by telephone with the staff attorney.

Time permitting, pretrials will be conducted in person with Judge Kelley. Pretrials may also be held by telephone with the staff attorney.

Not confirmed. Read the court's wording below.

Page 1 | Pre-Trials

A party may request a settlement conference by motion or by contacting the staff attorney.

The parties may request a settlement conference by motion or by contacting the staff attorney.

Not confirmed. Read the court's wording below.

Page 1 | Settlement Conference

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 Kevin Kelley

- On the Common Pleas bench since: December 2022 - Admitted to the bar: 2004

- Courtroom: 22-A - Courthouse: 1200 Ontario Street, Cleveland, Ohio 44113 - Fax: (216) 348-4032 - Bailiff: Shirlee Moss (216) 443-8746 - Staff attorney: Kevin Hippley (216) 443-7326

Common questions about Judge Kevin Kelley's rules

What must be included with default judgment hearing submission filings before Judge Kevin Kelley?

The rule identifies required filing content or certificates. Before the default-judgment hearing, plaintiff’s counsel must provide the Court with the correspondence sent to the defendant stating the hearing’s date and time.

View ruleSource: page 1, section Motion Practice - Motions for Default Judgment

What must be included with default judgment motion filings before Judge Kevin Kelley?

The rule requires proposed order. Before the default-judgment hearing, plaintiff’s counsel must provide a proposed judgment entry.

View ruleSource: page 1, section Motion Practice - Motions for Default Judgment

How may parties contact Judge Kevin Kelley's chambers?

The rule addresses phone communications. Plaintiff’s counsel must initiate the telephone hearing for default judgment.

View ruleSource: page 1, section Motion Practice - Motions for Default Judgment

What filing deadlines does Judge Kevin Kelley set?

A motion in limine must be written and filed ten days before trial.

View ruleSource: page 1, section Trials

What rule applies to serving the opposing party before Judge Kevin Kelley?

The rule addresses service method, recipient, or timing requirements. Details: recipient: the opposing party. The parties must serve their proposed jury instructions, interrogatories, and verdict forms on one another.

View ruleSource: page 1, section Trials
Complete rules summary for Judge Kevin Kelley

Pretrials will be held in person when time permits, but may also be held by telephone with the staff attorney.

Plaintiff’s counsel must initiate the telephone hearing for default judgment.

Before the default-judgment hearing, plaintiff’s counsel must provide the Court with the correspondence sent to the defendant stating the hearing’s date and time.

Before the default-judgment hearing, plaintiff’s counsel must provide an affidavit establishing that the defendant is not an active member of the military.

Before the default-judgment hearing, plaintiff’s counsel must provide an affidavit signed by the plaintiff or plaintiff’s representative proving damages.

Before the default-judgment hearing, plaintiff’s counsel must provide a copy of the contract, assignment, or written instrument supporting the requested judgment.

Before the default-judgment hearing, plaintiff’s counsel must provide a proposed judgment entry.

The Court may schedule and conduct oral argument on pending summary-judgment motions, with argument time parameters set by Judge Kelley.

Before filing a motion to compel or motion to quash, the parties must contact the staff attorney at 216-443-7326 to schedule a telephone conference.

A party may request a settlement conference by motion or by contacting the staff attorney.

All parties and representatives must attend settlement conferences and final pretrials with full, final, and immediate settlement authority.

A motion in limine must be written and filed ten days before trial.

The joint proposed instructions, disputed proposed instructions, interrogatories, and verdict forms must be filed at least five business days before trial.

Motions in limine must be submitted in writing.

A brief opposing a motion in limine is due seven days after filing, and in all events no later than three days before trial.

Before jury selection begins, the parties must deliver the Court an agreed statement of the case to be read to prospective jurors.

All parties must file the listed trial submissions before the final pretrial.

Every party must serve and file a trial brief containing a succinct statement of claims, essential material facts, legal issues, the type and amount of damages sought, and an estimate of the time needed to present the party’s case in chief.

A party should file any objections to another party’s proposed jury instructions, interrogatories, or verdict forms no later than two business days before trial.

The parties must exchange, serve, and file witness lists identifying each witness and briefly describing the expected testimony.

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

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

The parties must provide the Court with file-stamped copies of the witness list, exhibit list, and stipulations.

An objection must quote the proposed instruction in full, identify the objectionable language, concisely explain why it is improper, and cite relevant legal authority.

The parties must file any stipulations.

Counsel must provide relevant jury instructions that conform to Ohio Jury Instructions or cite published Ohio cases and are short, concise, understandable, and neutral statements of law.

The Court will not consider proposed jury instructions that are argumentative or otherwise fail to conform to the stated requirements.

The parties must serve their proposed jury instructions, interrogatories, and verdict forms on one another.

The parties should confer and try to agree on a single set of jury instructions to the extent possible.

When applicable, the objecting party must submit an alternative instruction addressing the relevant subject matter or legal principle.

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