Professional Documents
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Forhan Set - Rogs (1st) 2024 X
Forhan Set - Rogs (1st) 2024 X
JUANITA BRENT,
Petitioner, Case No. 2023 CV 988870
v. Judge Nancy Margaret Russo
ELLIOT FORHAN,
Respondent.
Respondent Elliot Forhan (“Respondent”) hereby propounds, pursuant to Ohio Rules of Civil
Procedure 26 and 33, on Petitioner Juanita Brent (“Petitioner”) the following First Set of
Interrogatories (“Interrogatories”). Respondent requests that Petitioner answer by February 20, 2024,
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Definitions and Instructions
exchange of oral or written information (in the form of promises, facts, ideas, inquiries,
estimates, solicitations, or otherwise) between anyone, including, but not limited to, writings,
5. “Document” means any written, recorded, or graphic material of any kind, whether prepared
by you or by any other person, that is in your possession, custody, or control. The term
descriptions; drafts, whether or not they resulted in a final document; minutes of meetings,
6. The term “document” also includes electronically stored data from which information can be
obtained either directly or by translation through detection devices or readers; any such
document is to be produced in a reasonably legible and usable form. The term "document"
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includes all drafts of a document and all copies that differ in any respect from the original,
including any notation, underlining, marking, or information not on the original. The term
also includes information stored in, or accessible through, computer or other information
retrieval systems (including any computer archives or back-up systems), together with
instructions and all other materials necessary to use or interpret such data compilations A
document can take the form of any medium on which information can be stored, including
without limitation, computer memory, computer disk, film, paper, tape recordings, video
tapes, and video disks, hard drives, servers, CDs, DVDs, zip discs, jump drives, iPods, iPads,
MP3 players, CD-ROM disks, magnetic tapes, and back-up tapes. A document also includes
computerized data, i.e., a data compilation from which information can be obtained and
translated by the responding party, if necessary, through detection devices in reasonably usable
form, and meta data, system data, backup data, files deleted by a computer user, residual data,
a. in the case of a person other than a natural person, its name, the address of its principal
place of business (including zip code), its telephone number, and the name of its chief
executive officer, as well as, if it has a person other than a natural person that ultimately
controls it, that other person's name, the address of that person's principal place of
business (including zip code), that other person's telephone number, and the name of
b. in the case of a natural person, his or her name, business address and telephone
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c. in the case of a communication, its date, type (e.g., in-person conversation, by phone,
by email, by text message), the place where it occurred, the identity of the person who
made the communication, the identity of the person who received the communication,
the identity of each other person when it was made, and the subject matter discussed;
d. in the case of a document, the title of the document, the author, the title or position
of the author, the addressee, each recipient, the type of document, the subject matter,
e. in the case of an agreement, its date, the place where it occurred, the identity of all
persons who were parties to the agreement, the identity of each person who has
knowledge of the agreement and all other persons present when it was made, and the
10. The “Minority Leader” means House Minority Leader Allison Russo.
13. “Person” means any natural person, corporation, company, partnership, joint venture, firm,
14. The “Petition” means the Petition for Civil Stalking Protection Order, filed on November 20,
16. “Relating to” means containing, constituting, considering, comprising, concerning, discussing,
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17. “Respondent” means Respondent Elliot Forhan.
21. “You” or “Your” means Petitioner, as well as her agents, affiliates, representatives, employees,
22. Unless otherwise stated in a particular Interrogatory, the time period applicable to these
23. The singular of any word shall include the plural, and the plural of any word shall include the
singular.
24. Under Civ.R. 26, there is a continuing duty to seasonably supplement or amend the answers
to these Interrogatories.
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Interrogatories
communication, with respect to which you were a party either relating to the filing of the Petition or
any transaction or occurrence (including each communication in which you told Respondent that you
did not want to hear from him) mentioned in the Petition or in which you told anyone, including but
not limited to David Brock, that you would not mind or that you would not call the police if
Respondent attended in person the meeting on January 6, 2024, in Independence, Ohio, of the
executive committee of the Cuyahoga County Democratic Party (the “County Party”).
ANSWER:
INTERROGATORY NO. 2: With respect to the “video surveillance” alleged in the third paragraph
of the narrative of the report, filed on November 21, 2023 (the “Nov.-21 CDP Report”), by you with
the Cleveland Division of Police (the “CDP”), alleging the commission by Respondent of certain
conduct, describe how you viewed the video surveillance, how you learned of the existence of the
ANSWER:
INTERROGATORY NO. 3: With respect to the “letter” alleged in the third paragraph of the
narrative of the Nov.-21 CDP Report, describe the contents of the letter and how you learned of the
ANSWER:
INTERROGATORY NO. 4: Identify each person (including the person who allegedly observed at
or about 9:15 a.m. on November 21, 2023, the black F-150 driving down your street and the person
who answered the door of your house on June 26, 2023, when Respondent knocked on it) mentioned
in any of the Petition, the Nov.-21 CDP Report or the report, filed on November 20, 2023, by you
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ANSWER:
INTERROGATORY NO. 5: Describe the steps that you took to satisfy the requests by law
enforcement, in connection with the filing of the Nov.-21 CDP Report, that you produce the “video
surveillance” and “letter,” or copies thereof, mentioned in the third paragraph of the narrative of the
ANSWER:
INTERROGATORY NO. 6: Describe how you came to believe that Respondent asked David Brock
three times during November 16 to 19, 2023, to meet with you or for your schedule.
ANSWER:
INTERROGATORY NO. 7: Describe the interactions with Respondent that you alleged in
paragraph 7) of the Petition were “inappropriate” and how they were inappropriate.
ANSWER:
INTERROGATORY NO. 8: With respect to each text and phone call that Respondent allegedly sent
or made, as applicable, to you after you allegedly told Respondent that you did not want to hear from
him, describe how the communication was outside of the working relationship between you and
Respondent.
ANSWER:
INTERROGATORY NO. 9: With respect to each text message that you sent on or about October
11, 2023, and on or about September 12 and 13, 2023, to Respondent, describe why you made the
communication.
ANSWER:
INTERROGATORY NO. 10: With respect to the event at or about 1:00 p.m. on September 10,
2023, at Trellis Rooftop Bar at Studio West 117 in Lakewood organized by the Cleveland Stonewall
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Democrats organization, describe your interactions at the event with Respondent’s parents and with
Respondent.
ANSWER:
INTERROGATORY NO. 11: With respect to the conversation that occurred between at or about
12:53 p.m. and at or about 12:57 p.m. on November 15, 2023 (the “Munira-Respondent
Conversation”), in Statehouse Hearing Room 121 between Ohio State Representative Munira
Abdullahi and Respondent, estimate how much of the conversation you witnessed and describe what
you witnessed.
ANSWER:
INTERROGATORY NO. 12: With respect to the Munira-Respondent Conversation, describe the
actions that you took during the period starting one minute before you started to witness the Munira-
Respondent Conversation and ending one minute after you stopped witnessing the Munira-
Respondent Conversation.
ANSWER:
INTERROGATORY NO. 13: Describe how you learned about the knocking on June 26, 2023, by
ANSWER:
INTERROGATORY NO. 14: With respect to the knocking on June 26, 2023, by Respondent on
the door of your house, describe how you came to believe that Respondent pounded on the door
aggressively, that the person who answered the door ever opened the main door in connection with
the conversation between the person and Respondent and that Respondent repeated over and over at
ANSWER:
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INTERROGATORY NO. 15: Describe how you learned about the rumor that you were recruiting
ANSWER:
INTERROGATORY NO. 16: With respect to the meeting that occurred at or about 9:00 a.m. on
June 27, 2023 (the “Jun.-27 Meeting”), in the Riffe Tower office of the Minority Leader, the
participants of which meeting included Petitioner, Respondent, the Minority Leader and Ohio State
Representative Phil Robinson, describe the purpose or purposes of the Jun.-27 Meeting.
ANSWER:
INTERROGATORY NO. 17: Estimate the frequency at which you ask, in connection with your
service as an officer of the County Party and as a state representative, people to knock doors.
ANSWER:
INTERROGATORY NO. 18: Describe what you meant when you said during the Jun.-27 Meeting
to Respondent words to the effect that knocking on your door without advance notice wouldn’t have
ANSWER:
INTERROGATORY NO. 19: Describe your thoughts and reaction when the Minority Leader said
during the Jun.-27 Meeting words to the effect of, “Rep. Forhan, if you knock my door without giving
advance notice, then I might answer the door without wearing a bra.”
ANSWER:
INTERROGATORY NO. 20: Describe how you initiated the conversation that occurred from at or
about 1:52 p.m. to at or about 2:00 p.m. on May 23, 2023 (the “Wright-Respondent Conversation”),
in Statehouse Hearing Room 113 between Ms. Ladosha Wright and Respondent.
ANSWER:
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INTERROGATORY NO. 21: Describe all evidence, documents or communications upon which
ANSWER:
INTERROGATORY NO. 22: Identify each person having personal knowledge of the events
ANSWER:
INTERROGATORY NO. 23: With respect to any request for admission propounded by Respondent
on you to which you answered anything other than admitting fully, describe why you did not so admit.
ANSWER:
INTERROGATORY NO. 24: Identify each person whom you plan to call as a witness at the trial in
ANSWER:
INTERROGATORY NO. 25: Identify who served as the “security detail” mentioned in the third
paragraph of the narrative of the Nov.-21 CDP Report and who paid for the detail.
ANSWER:
INTERROGATORY NO. 26: Identify who advised you to file the Petition, who advised you to say
that I drove a black F150-style truck and who advised you that you or someone you hired should say
ANSWER:
INTERROGATORY NO. 27: Describe why you included in the email, time-stamped at or about
9:30 p.m. on June 26, 2023, by you to Respondent, mention of the Cleveland.com reporter.
ANSWER:
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STATE OF OHIO )
) ss: VERIFICATION
COUNTY OF _________________ )
__________________________, being first duly sworn according to law, deposes and states
that she/he has read the foregoing and that it is true and accurate to the best of her/his knowledge.
______________________________
Name:
______________________________
NOTARY PUBLIC
/s/Elliot P. Forhan
Representative Elliot P. Forhan
Ohio House of Representatives
Vern Riffe State Office Tower
77 South High Street, Floor 12
Columbus, OH 43215
Tel: (216) 352-3867
[email protected]
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Certificate of Service
I certify that I served on February 5, 2024, as provided by Ohio Civ. R. 5(B)(2) on opposing
counsel a copy of the foregoing document.
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