Court Rules
Judge Shannon M. Gallagher
Judge

Judge Shannon M. Gallagher

Individual Rules, Standing Orders & Policies

Cuyahoga County Court of Common Pleas, General Division

Limits & Logistics

Courtesy Copies

Filings > 10 pages

  • Hand Delivery • After Submission

Adjournments

  • Requests to modify the case-management schedule must be made by joint or unopposed motion and include proposed dates.
  • Every continuance request must be made by motion.
  • The parties may mutually extend the discovery-completion deadline, but the extension may not alter any other scheduled event, deadline, or mediation.
  • +3 more

Request must include

Proposed New DatesReason For Request

Communication

Email

Chambers

kdavenport@cuyahogacounty.us
Status Inquiries
Phone
Scheduling
Phone
Court-wide

Clerk

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

Document Filing Requirements8 rules

Filing RequirementsCivil cases

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

At least one week before trial, parties must file the listed trial materials, serve opposing counsel, and provide the Court with copies.

No later than one week prior to trial parties should file, serve on opposing counsel and provide the Court with a copy of trial briefs, witness lists, exhibit lists, a list of stipulations to be presented, all expert reports, deposition transcripts of expert witnesses and a list of all objections to videotape and deposition testimony with a copy of the applicable transcript and videotape.

Document Type

Trial Materials

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

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

Discovery motions will not be considered unless the parties follow the standing discovery-dispute procedure.

The Court will not consider any discovery motion, i.e., motion to compel, motion for protective order, motion to quash, etc., unless the parties follow the procedure outlined below regarding discovery disputes.

Document Type

Discovery Motion

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

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

In a civil case without a jury demand, each party must prepare proposed findings of fact and conclusions of law and file and serve them no later than one week before the bench trial.

In all civil cases were a jury demand is not made, counsel for each of the parties shall prepare proposed Findings of Fact and Conclusions of Law, which shall be filed with the Court and served upon opposing counsel no later than one week prior to the scheduled bench trial.

Document Type

Proposed Findings Conclusions

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

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

Counsel and unrepresented parties must submit the required settlement, mediation, or pretrial statement at least one week before the settlement conference.

Counsel and unrepresented parties are required to comply with Loc.R. 21, Parts II and III(E), which includes submitting a settlement/mediation or pretrial statement at least one week prior to the scheduled settlement conference.

Document Type

Settlement Mediation Or Pretrial Statement

Specific requirements detailed in rule text.
Cuyahoga Oh:5c4d93aa752e07570644726e
|SecSettlement Conference
Filing RequirementsCivil cases

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

Prior court leave is required before filing any motion not already permitted by rule or a prior court order.

Leave of the Court is required prior to filing any motion not otherwise permitted by rule or prior order of the Court.

Document Type

Motion

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

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

A default-judgment motion seeking damages must be accompanied by an affidavit documenting the plaintiff’s expenses or losses caused by the defendant.

Before the Court will consider awarding damages pursuant to a Motion for Default Judgment, Plaintiff must provide an affidavit with documentation of expenses/losses incurred as a result of the Defendant’s conduct.

Document Type

Motion For Default Judgment

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

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

The parties must jointly file agreed-upon, case-specific jury instructions no later than one week before trial.

No later than one week prior to trial the parties shall jointly file agreed-upon, case specific jury instructions.

Document Type

Jury Instructions

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

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

Proposed Orders for the Court's signature must be delivered to the Bailiff or Staff Attorney, accompanied by a time-stamped copy of a properly filed motion, which includes a copy of the proposed order as an exhibit.

Summary: A proposed order must be delivered to the Bailiff or Staff Attorney with a time-stamped copy of the properly filed motion, with the proposed order included as an exhibit.

Document Type

Proposed Order

Content & Formatting
Proposed Order
Exhibit List

Filing & Service rules

Electronic Filing Rules

Proposed orders may optionally be submitted through the Clerk of Court’s electronic filing system.

Proposed orders may also be submitted to the Court through the Clerk of Court's electronic filing system.

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

Page 1 | Motion Practice

Filing Timing and Cure Windows

All time requirements for civil case filings were suspended and tolled beginning March 9, 2020.

Pursuant to the Ohio Supreme Court’s 03/27/2020 Administrative Actions Order, all time requirements for civil case filings have been suspended and tolled as of 03/09/2020.

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

Page 1 | Policies Related to COVID-19

A motion in limine must be filed no later than ten days before trial.

Any motions in limine shall be filed no later than ten days prior to trial.

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

Page 1 | Trials

Responses to a motion in limine are due seven days after filing, or three days before trial.

Pursuant to Loc.R.11(C), all responses are due seven thereafter, or three days prior to trial.

Not confirmed. Read the court's wording below. · Civil cases

Page 1 | Trials

The Court will not rule on an unopposed motion until both the tolling period and the opposing party’s response period have expired.

The Court will not rule on any unopposed motions, unless the motion is otherwise designated as unopposed, until after both the tolling period and the opposing party’s response time have expired.

Not confirmed. Read the court's wording below. · Civil cases

Page 1 | Policies Related to COVID-19

A default-judgment motion tied to a responsive pleading due before March 9, 2020 will not be ruled on or scheduled for hearing until tolling and the opposing party’s response period expire.

If a Plaintiff proceeds forward in filing a Motion for Default Judgment in a case in which an Answer or responsive pleading was due prior to 03/09/2020, the Court shall hold its ruling in abeyance and will not schedule the matter for a hearing until the tolling period and the opposing party’s response time have expired.

Not confirmed. Read the court's wording below. · Civil cases

Page 1 | Policies Related to COVID-19

Service and Proof of Service Rules

The plaintiff must serve written notice of the default hearing and provide a certified-mail receipt, an ordinary-mail service affidavit, a military-status affidavit, and a proposed journal entry.

The Plaintiff is required to send written notice of the date and time of the hearing to the party against whom action is taken and shall provide the Court with proof that the notification letter was sent by virtue of a certified mail receipt and an affidavit of service via ordinary mail, an affidavit that a search has been conducted and that defendant is not a current member of the military, and a proposed journal entry.

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

Page 1 | Default Judgments

In a civil case without a jury demand, the proposed findings of fact and conclusions of law must be served on opposing counsel no later than one week before the bench trial.

In all civil cases were a jury demand is not made, counsel for each of the parties shall prepare proposed Findings of Fact and Conclusions of Law, which shall be filed with the Court and served upon opposing counsel no later than one week prior to the scheduled bench trial.

Not confirmed. Read the court's wording below. · Civil cases

Page 1 | Bench Trials

Courtesy Copy Requirements

A hard copy of an e-filed motion or brief exceeding 10 pages, including exhibits, must reach the Bailiff or Staff Attorney within three days of e-filing.

A hard copy of any e-filed motion or brief in excess of ten (10) pages (including exhibits) must be delivered to the Bailiff or Staff Attorney within three (3) days of e-filing.

Not confirmed. Read the court's wording below. · Civil cases

Page 1 | Motion Practice

Pre-Motion Conference Requirements

Before filing a discovery motion, the parties must contact the Staff Attorney and hold a telephone conference with all other parties.

Parties are required to contact the Staff Attorney and initiate a telephone conference with all other parties prior to filing any discovery motions (motion to compel, motion to quash, motion for protective order, etc.)

Not confirmed. Read the court's wording below. · Civil cases

Page 1 | Discovery

Adjournment & Extension Requirements

Every continuance request must be made by motion.

All requests for continuances must be made via motion.

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

Page 1 | Calendaring and Continuances

Requests to modify the case-management schedule must be made by joint or unopposed motion and include proposed dates.

The Court requires joint or unopposed motions with proposed dates included.

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

Page 1 | Policies Related to COVID-19

A motion to continue trial must be written, state the reason for the request, and be endorsed in writing by the parties and counsel.

Motions to continue trial must be in writing, state the reason for the request, and be endorsed in writing by the parties as well as counsel.

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

Page 1 | Calendaring and Continuances

The parties may mutually extend the discovery-completion deadline, but the extension may not alter any other scheduled event, deadline, or mediation.

Parties may, by mutual agreement, extend the deadline for completing discovery; provided, any such extension shall not, under any circumstances, alter any other court-scheduled events, deadlines, or mediation.

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

Page 1 | Discovery

A trial continuance may be granted when good cause is shown.

Consistent with Local Rule 17, continuances of trial may be granted for good cause shown.

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

Page 1 | Calendaring and Continuances

An agreed motion signed by all parties and counsel will be granted unless unusual circumstances or undue delays exist.

Agreed motions, signed by all parties and counsel, will be granted absent unusual circumstances or undue delays.

Not confirmed. Read the court's wording below. · Civil cases

Page 1 | Calendaring and Continuances

Chambers Communication Rules

The parties must email the Staff Attorney a Word document containing the joint proposed jury instructions.

Parties are to email a word document of the joint proposed jury instructions to the Staff Attorney at kdavenport@cuyahogacounty.us.

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

Page 1 | Trials

Parties may email Staff Attorney Kimberly Davenport about civil matters, copying all opposing counsel and pro se parties.

Any party may address questions about a civil matter to Judge Gallagher’s Staff Attorney Kimberly Davenport by email at kdavenport@cuyahogacounty.us, with all opposing counsel and/or pro se parties copied on the email.

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

Page 1 | Policies Related to COVID-19

An out-of-town party excused from appearing in person must remain available by telephone during the settlement conference or final pretrial.

All out of town parties who have been excused from making an in person appearance shall be available by telephone during the scheduled settlement conference or final pretrial.

Not confirmed. Read the court's wording below. · Civil cases

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 Shannon M. Gallagher

- On the Common Pleas bench since: 1/10/2015 - Admitted to the bar: May 2004 - Legal experience: Judicial Attorney, State Court of Appeals, Eighth Appellate District, 2005-2007, 2011-2014; Labor Relations Advisor/Director of Legal and Government Affairs, 2008-2011; Civil Staff Attorney, 2004.

- Courtroom: 22-D - Courthouse: 1200 Ontario Street, Cleveland, Ohio 44113 - Fax: (216) 348-4037 - Bailiff: Lisa M. Schill (216) 443-2025 - Staff attorney: Kimberly N. Davenport (216) 443-8874

Common questions about Judge Shannon M. Gallagher's rules

Are courtesy copies required for Judge Shannon M. Gallagher?

Courtesy-copy rule applies when a filing is > 10 pages. Details: delivery after submission, by hand delivery. A hard copy of an e-filed motion or brief exceeding 10 pages, including exhibits, must reach the Bailiff or Staff Attorney within three days of e-filing.

View ruleSource: page 1, section Motion Practice

Does Judge Shannon M. Gallagher require a pre-motion conference or letter before filing a motion?

Judge Shannon M. Gallagher's rules set a pre-motion procedure for discovery. Before filing a discovery motion, the parties must contact the Staff Attorney and hold a telephone conference with all other parties.

View ruleSource: page 1, section Discovery

What must be included with motion filings before Judge Shannon M. Gallagher?

The rule identifies required filing content or certificates. Prior court leave is required before filing any motion not already permitted by rule or a prior court order.

View ruleSource: page 1, section Motion Practice

What must be included with discovery motion filings before Judge Shannon M. Gallagher?

The rule identifies required filing content or certificates. Discovery motions will not be considered unless the parties follow the standing discovery-dispute procedure.

View ruleSource: page 1, section Motion Practice

How may parties contact Judge Shannon M. Gallagher's chambers?

The rule addresses phone communications. An out-of-town party excused from appearing in person must remain available by telephone during the settlement conference or final pretrial.

View ruleSource: page 1, section Settlement Conference

How do I request an adjournment or extension before Judge Shannon M. Gallagher?

Advance notice is not fully stated in the structured details. The request must include proposed new dates. Requests to modify the case-management schedule must be made by joint or unopposed motion and include proposed dates.

View ruleSource: page 1, section Policies Related to COVID-19

Is electronic filing required before Judge Shannon M. Gallagher?

Electronic filing is optional for the covered filings. Proposed orders may optionally be submitted through the Clerk of Court’s electronic filing system.

View ruleSource: page 1, section Motion Practice

What filing deadlines does Judge Shannon M. Gallagher set?

All time requirements for civil case filings were suspended and tolled beginning March 9, 2020.

View ruleSource: page 1, section Policies Related to COVID-19

What rule applies to service for notice of default hearing before Judge Shannon M. Gallagher?

Proof of service is required for the covered service rule. Details: method: service by mail, recipient: the opposing party. The plaintiff must serve written notice of the default hearing and provide a certified-mail receipt, an ordinary-mail service affidavit, a military-status affidavit, and a proposed journal entry.

View ruleSource: page 1, section Default Judgments
Complete rules summary for Judge Shannon M. Gallagher

All time requirements for civil case filings were suspended and tolled beginning March 9, 2020.

Requests to modify the case-management schedule must be made by joint or unopposed motion and include proposed dates.

Every continuance request must be made by motion.

The Court will not rule on an unopposed motion until both the tolling period and the opposing party’s response period have expired.

A default-judgment motion tied to a responsive pleading due before March 9, 2020 will not be ruled on or scheduled for hearing until tolling and the opposing party’s response period expire.

Parties may email Staff Attorney Kimberly Davenport about civil matters, copying all opposing counsel and pro se parties.

Prior court leave is required before filing any motion not already permitted by rule or a prior court order.

Discovery motions will not be considered unless the parties follow the standing discovery-dispute procedure.

A hard copy of an e-filed motion or brief exceeding 10 pages, including exhibits, must reach the Bailiff or Staff Attorney within three days of e-filing.

A proposed order must be delivered to the Bailiff or Staff Attorney with a time-stamped copy of the properly filed motion, with the proposed order included as an exhibit.

Counsel and unrepresented parties must submit the required settlement, mediation, or pretrial statement at least one week before the settlement conference.

Proposed orders may optionally be submitted through the Clerk of Court’s electronic filing system.

A default-judgment motion seeking damages must be accompanied by an affidavit documenting the plaintiff’s expenses or losses caused by the defendant.

The plaintiff must serve written notice of the default hearing and provide a certified-mail receipt, an ordinary-mail service affidavit, a military-status affidavit, and a proposed journal entry.

The parties may mutually extend the discovery-completion deadline, but the extension may not alter any other scheduled event, deadline, or mediation.

Before filing a discovery motion, the parties must contact the Staff Attorney and hold a telephone conference with all other parties.

An out-of-town party excused from appearing in person must remain available by telephone during the settlement conference or final pretrial.

A trial continuance may be granted when good cause is shown.

A motion to continue trial must be written, state the reason for the request, and be endorsed in writing by the parties and counsel.

An agreed motion signed by all parties and counsel will be granted unless unusual circumstances or undue delays exist.

At least one week before trial, parties must file the listed trial materials, serve opposing counsel, and provide the Court with copies.

The parties must jointly file agreed-upon, case-specific jury instructions no later than one week before trial.

The parties must email the Staff Attorney a Word document containing the joint proposed jury instructions.

A motion in limine must be filed no later than ten days before trial.

Responses to a motion in limine are due seven days after filing, or three days before trial.

In a civil case without a jury demand, each party must prepare proposed findings of fact and conclusions of law and file and serve them no later than one week before the bench trial.

In a civil case without a jury demand, the proposed findings of fact and conclusions of law must be served on opposing counsel no later than one week before the bench trial.

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