IN THE COURT OF COMMON PLEAS

DOMESTIC RELATIONS DIVISION

HAMILTON COUNTY, OHIO

:	Case No:
Plaintiff	:
:	Judge:
v.	:
:	Magistrate:
:
Defendant	:	Joint Discovery Plan
:	(MANDATORY FORM)

Initial disclosures Check all that apply

The parties have exchanged initial mandatory disclosures.

The parties will provide initial mandatory disclosures no later than .

The parties have stipulated that the following will not be included in initial disclosures: List Items Not Included.

The parties have stipulated not to provide any initial disclosures.

The following party objects to providing initial disclosures on the following grounds: Identify the party and state all applicable grounds.

Discovery

The parties have held a discovery conference as required by Ohio Rule of Civil Procedure 26(F)(1).

All written discovery will be served no later than 90 days before trial. All depositions will be completed no later than 60 days before trial. Or, all discovery will be completed by:

Check all that apply

The parties have agreed to a discovery plan, and their agreement is set forth in Attachment .

The parties have agreed to deviate from the limits on discovery otherwise applicable to this action, and their agreement is set forth in Attachment .

The parties have agreed to conduct discovery in phases, and their agreement is set forth in Attachment .

The parties have reached an agreement under Ohio Rule of Civil Procedure 26(C) as set forth in Attachment .

The parties have conferred about a discovery plan and have been unable to reach agreement on the issues set forth in Attachment .

Expert Witnesses

A party who intends to call, or proposes the possibility of calling, an expert witness, including rebuttal expert witnesses, shall certify to the court and all other parties the expert’s name, subject matter of expertise, and qualifications, within the following time period:

Expert Report: 60 days before trial or by .

Rebuttal: 30 days before trial or by .

Pretrial Submissions

At least 14 or (the parties may enter another number but not less than 7) days before trial, counsel for the parties and self-represented litigants must:

File a witness and exhibit list with the clerk of court, serve a copy on opposing counsel and self-represented litigants, and exchange exhibits. Plaintiff shall label their exhibits with numbers. Defendant shall label their exhibits with letters. Exhibits must be marked before trial. Each party shall provide the original set of all exhibits to the Court at the hearing/trial.

File and serve motions in limine, with supporting legal authority.

Deliver to the judge and serve a concise trial brief addressing factual, legal, and evidentiary issues, with citation to legal authorities.

Deliver to the judge any written stipulations or agreed entries between the parties.

Motions

All pre-trial motions except motions in limine, must be filed with the clerk of court’s office or electronically filed at least 30 days before trial, with copies to the assigned judge. Any motion filed after this deadline is deemed to be waived, unless good cause shown.

Settlement Conference Note to parties: If A or B is checked, leave any date blank; the court will fill in the settlement conference date after the trial-setting conference.

A settlement conference will be held on Month, Day, Year, at Time AM PM at 800 Broadway, Cincinnati OH 45202 Room .

A settlement conference will be held on Month, Day, Year, at Time AM PM at the following location: .

A settlement conference will occur at a date, time, and location arranged by the parties.

A settlement conference will be held upon request.

The parties are encouraged to consider alternative dispute resolution including mediation or neutral evaluation.

Settlements

The parties are responsible for immediately notifying the court of settlement.

Continuances

Continuances are discouraged and will only be granted for good cause. Motions to continue are governed by Local Rule 1.2. In the event the trial date is continued, all time deadlines in this Plan and any Stipulated Amendments remain in effect relative to the new trial date unless the court approves new deadlines.

Notice

Failure to comply with any of the provisions of this Plan or Stipulated Amendments to this Plan may result in the court imposing sanctions pursuant to Ohio Rule of Civil Procedure 37, including limitation and exclusion of evidence and witnesses and payment of costs or attorney fees. The court will resolve disputes regarding oral agreements on scheduling by reference to this Plan or any Stipulated Amendments to this Plan.

Other List additional agreements of the parties for the Discovery Plan

At least one signature to the Discovery Plan is required. The signer certifies that all listed parties have joined in this Discovery Plan, subject to any objections noted.

I certify that all parties and attorneys to this action have agreed to this Discovery Plan and have been served with a copy.

/s
Date	Party’s or attorney’s signature
Printed Name	Attorney’s law firm, if applicable
Mailing address	City, State, Zip Code
Phone Number	Email Address	Additional Email Address, if available

/s
Date	Party’s or attorney’s signature
Printed Name	Attorney’s law firm, if applicable
Mailing address	City, State, Zip Code
Phone Number	Email Address	Additional Email Address, if available

Copies to: counsel of record and self-represented litigants.

Upon review, the Court hereby accepts and adopts the above Discovery

Plan as an order of the Court.

Judge/Magistrate	Date