Donald Brooks Vs. Department Of Youth Services Cuyahoga, Et Al.

CASE FILED: NOTICE OF APPEAL WORK. COMP ADMIN APPEAL

NOTICE FILED BY D2 OHIO BUREAU OF WORKERS' COMPENSATION ATTORNEY GEOFFREY H TUROFF 0039641 NOTICE OF EXPERT WITNESS

COMPLAINT W/ NO SUMS(49153333) SENT BY CERTIFIED MAIL. TO: OHIO BUREAU OF WORKERS' COMPENSATION 30 W. SPRING STREET, 7TH FLOOR COLUMBUS, OH 43215

ANSWER FILED BY D1 DEPARTMENT OF YOUTH SERVICES CUYAHOGA HILLS JUVENILE CORRECTIONAL ATTORNEY MICHAEL P GERMANO 0040031 ANSWER OF DEFENDANT, DEPARTMENT OF YOUTH SERVICES CUYAHOGA HILLS JUVENILE CORRECTIONAL FACILITY

COMPLAINT W/ NO SUMS(49153332) SENT BY CERTIFIED MAIL. TO: DEPARTMENT OF YOUTH SERVICES CUYAHOGA HILLS JUVENILE CORRECTIONAL 4545 FISHER ROAD, STE. D COLUMBUS, OH 43228

MOTION FOR LEAVE TO FILE ANSWER INSTANTER MOTION OF DEFENDANT, DEPARTMENT OF YOUTH SERVICES CUYAHOGA HILLS JUVENILE CORRECTIONAL FACILITY, TO FILE ANSWER INSTANTER 02/15/2023 - GRANTED

CMC BY PHONE HELD ON 02/22/2023. THE PARTIES APPEARED THROUGH COUNSEL OF RECORD. STATUS OF CASE DISCUSSED AND THE FOLLOWING DEADLINES SET: ALL DISCOVERY TO BE COMPLETED BY 05/31/2023. IF A DISCOVERY DISPUTE ARISES, THE PARTIES SHALL CONFER TELEPHONICALLY OR IN-PERSON. IF AFTER A GOOD-FAITH ATTEMPT TO RESOLVE THE ISSUES A DISPUTE REMAINS, THE PARTIES SHOULD CONTACT THE COURT'S STAFF ATTORNEY BY EMAIL WITH A SUGGESTED DATE AND TIME FOR A ZOOM CONFERENCE WITH THE COURT, AND INCLUDE A BRIEF DESCRIPTION OF THE ISSUES TO BE DISCUSSED. THEREAFTER, THE COURT MAY ORDER BRIEFING. PLAINTIFF'S EXPERT REPORT DUE 05/31/2023. DEFENDANT'S EXPERT REPORT DUE 06/30/2023. FINAL PRETRIAL SET FOR 08/31/2023 AT 01:00 PM. THE PARTIES SHALL EACH FILE A FINAL PRETRIAL STATEMENT SEVEN DAYS BEFORE THE FINAL PRETRIAL AND SHALL INCLUDE THE FOLLOWING: - A BRIEF STATEMENT OF FACTS AND LEGAL ISSUES; - STIPULATIONS; - LIST OF WITNESSES WITH BRIEF SUMMARY OF EXPECTED TESTIMONY; - LIST OF EXHIBITS EXPECTED TO BE USED A TRIAL; - ANY ANTICIPATED UNIQUE LEGAL ISSUES; - AN ESTIMATED LENGTH OF TRIAL; - ANY CONTEMPLATED PRETRIAL MOTIONS; AND - SPECIAL EQUIPMENT OR POTENTIAL LOGISTICAL REQUESTS. THE PARTIES SHALL EXCHANGE TRIAL EXHIBITS NO LATER THAN SEVEN (7) DAYS BEFORE TRIAL. JURY TRIAL SET FOR 09/27/2023 AT 09:00 AM. COUNSEL AND PRO SE PARTIES ARE DIRECTED TO SUP.R. 41 AND LOC.R. 17 REGARDING CONTINUANCE OF TRIAL. TRIAL BRIEFS DUE ONE DAY BEFORE TRIAL. DAUBERT OR EXPERT-RELATED MOTIONS IN LIMINE: ANY MOTION CHALLENGING PURPORTED EXPERT TESTIMONY SHALL BE FILED BY THE EXPERT MOTION DEADLINE SET BY THE COURT. IF NO EXPERT MOTION DEADLINE WAS SET, THEN ANY MOTION CHALLENGING PURPOSED EXPERT TESTIMONY SHALL BE FILED AT LEAST FORTY-FIVE (45) DAYS BEFORE TRIAL. THE PARTY CHALLENGING THE PROPOSED EXPERT TESTIMONY SHALL FILE A COMPLETE COPY OF THE EXPERT'S REPORT(S) AND COMPLETE DEPOSITION TRANSCRIPTS, IF THE EXPERT WAS DEPOSED. MOTIONS IN LIMINE SHALL BE FILED TWENTY-ONE (21) DAYS BEFORE THE START OF TRIAL. RESPONSES DUE PURSUANT TO CIV. R. 6(C). NO REPLIES ARE PERMITTED. AFTER THE DEADLINE FOR RESPONSES, COUNSEL AND PRO SE PARTIES SHALL CONFER TO RESOLVE THE MOTIONS IN LIMINE, AND, AT LEAST (3) DAYS PRIOR TO TRIAL, THE PARTIES SHALL FILE A JOINT NOTICE INFORMING THE COURT WHICH MOTIONS IN LIMINE ARE UNOPPOSED OR RESOLVED, AND WHICH REMAIN OPPOSED. DEPOSITIONS, AUDIOVISUAL OR TRANSCRIPTS, TO BE PROFFERED AT TRIAL. ANY PARTY WISHING TO PROFFER DEPOSITION TESTIMONY AT TRIAL IN LIEU OF THE DEPONENT'S ATTENDANCE SHALL EXCHANGE SUCH DEPOSITION TESTIMONY BY COUNSEL AT LEAST THIRTY (30) DAYS IN ADVANCE OF TRIAL. THE PARTIES SHALL MEET TELEPHONICALLY OR IN PERSON TO DISCUSS ANY OBJECTIONS TO THE PROFFERED TESTIMONY. IF ANY DISPUTES RELATING TO THE TESTIMONY REMAIN AFTER THE GOOD FAITH CONFERENCE, THE PARTIES SHALL SEND HARD COPIES OF THEIR RESPECTIVE DESIGNATIONS WITH OBJECTIONS EITHER ANNOTATED IN THE MARGINS OR OUTLINED IN A SEPARATE DOCUMENT TO THE COURT'S STAFF ATTORNEY AT LEAST FOURTEEN (14) DAYS IN ADVANCE OF TRIAL. THE PARTIES MAY INCLUDE A BRIEF STATEMENT FOR CONTEXT FOR THE OBJECTIONS IF NECESSARY. JURY INSTRUCTIONS AND INTERROGATORIES. PROPOSED JURY INSTRUCTIONS AND JURY INTERROGATORIES ARE DUE SEVEN (7) DAYS BEFORE TRIAL. COUNSEL AND PRO SE PARTIES SHALL CONFER REGARDING JURY INSTRUCTIONS AND INTERROGATORIES IN ORDER TO SUBMIT A JOINT PROPOSED SET OF JURY INSTRUCTIONS AND INTERROGATORIES. THE PARTIES SHALL SUBMIT A JOINT PROPOSED SET OF JURY INSTRUCTIONS TO THE COURT'S STAFF ATTORNEY AT LEAST ONE (1) DAY BEFORE TRIAL. IF ANY DISAGREEMENT REMAINS, THE PARTIES SHALL HIGHLIGHT DISAGREEMENTS TO THE COURT. THE PROPOSED JURY INSTRUCTIONS AND INTERROGATORIES SHALL BE SUBMITTED IN MICROSOFT WORD FORMAT TO THE COURT'S STAFF ATTORNEY. FURTHER, THE PARTIES ARE ENCOURAGED TO SUBMIT A JOINT STATEMENT OF THE CASE TO BE READ TO THE JURY. ALL PARTIES AND COUNSEL OF RECORD TO BE PRESENT AT BOTH THE SETTLEMENT CONFERENCE AND THE FINAL PRETRIAL OR APPROPRIATE SANCTIONS WILL BE IMPOSED, INCLUDING DISMISSAL PURSUANT TO CIV. RULE 41(B)(1) OR DEFAULT JUDGMENT (AS APPLICABLE). THE COURT HOLDS SETTLEMENT CONFERENCES AND FINAL PRETRIALS BY ZOOM, UNLESS THE ORDERED OTHERWISE OR THE PARTIES REQUEST IN-PERSON SETTLEMENT CONFERENCE AND/OR FINAL PRETRIAL AT LEAST TWO WEEKS IN ADVANCE. COUNSEL AND PRO SE PARTIES ARE EXPECTED TO BE FAMILIAR WITH THE OHIO RULES OF CIVIL PROCEDURE, THE LOCAL RULES, THIS COURT'S STANDING CIVIL ORDER, WHICH CAN BE FOUND ON THE COURT'S WEBSITE, AND ANY OTHER ORDERS OF THIS COURT. NOTICE ISSUED

ANSWER FILED BY D2 OHIO BUREAU OF WORKERS' COMPENSATION ATTORNEY GEOFFREY H TUROFF 0039641 ANSWER OF DEFENDANT- ADMINISTRATOR, BUREAU OF WORKERS' COMPENSATION

MOTION OF DEFENDANT, DEPARTMENT OF YOUTH SERVICES CUYAHOGA HILLS JUVENILE CORRECTIONAL FACILITY, TO FILE ANSWER INSTANTER, FILED 02/13/2023, IS GRANTED. ANSWER OF DEFENDANT, DEPARTMENT OF YOUTH SERVICES CUYAHOGA HILLS JUVENILE CORRECTIONAL FACILITY, IS DEEMED FILED ON 02/13/2023. NOTICE ISSUED

ON 08/31/2023, THE PARTIES ADVISED THE COURT THAT THE MATTER SETTLED. THE COURT ORDERED THE PARTIES TO FILE A CONSENT JUDGMENT ENTRY, NOTICE, OR STIPULATION OF DISMISSAL WITHIN 30 DAYS OF THE ORDER. THE PARTIES HAVE FAILED TO DO SO. THEREFORE, THE PARTIES SHALL FILE A CONSENT JUDGMENT ENTRY, NOTICE, OR STIPULATION OF DISMISSAL WITHIN SEVEN (7) DAYS OF ENTRY OF THIS ORDER. FAILURE TO DO WILL RESULT IN DISMISSAL OF THE MATTER FOR WANT OF PROSECUTION. NOTICE ISSUED

THE COURT HAS BEEN ADVISED BY COUNSEL THAT CASE IS SETTLED. COUNSEL TO FILE A CONSENT JUDGMENT ENTRY, NOTICE, OR STIPULATION OF DISMISSAL WITHIN 30 DAYS OF JOURNALIZATION OF THIS ENTRY. COUNSEL TO ADDRESS MATTER OF COSTS. NOTICE ISSUED

BY STIPULATION OF THE PARTIES, CASE DISMISSED WITH PREJUDICE. COURT COST ASSESSED TO THE PLAINTIFF(S). NOTICE ISSUED