IN THE COURT OF COMMON PLEAS

CUYAHOGA COUNTY, OHIO

JUANITA BRENT, ) CASE NO. CV-23-988870

)
Petitioner, ) JUDGE NANCY MARGARET RUSSO
)
v. )
) PETITIONER JUANITA BRENT’S FIRST
ELLIOT FORHAN, ) SET OF INTERROGATORIES TO
) RESPONDENT ELLIOT FORHAN
Respondent. )
)

Petitioner Juanita Brent (“Petitioner”), by and through undersigned counsel, and

pursuant to Civil Rules 26 and 33, hereby requests that Respondent Elliot Forhan

(“Respondent”), answer the following written Interrogatories under oath, and serve a copy

of his answers no later than February 20, 2024 on counsel for Petitioner at the offices of

Tucker Ellis LLP, 950 Main Avenue, Suite 1100, Cleveland, Ohio 44113-7213, or via email to

undersigned counsel.

INSTRUCTIONS

A. General Instructions

1. With respect to any of the following answers to interrogatories as to which

you, after answering, acquire additional knowledge or information, Petitioner asks that you

serve on the undersigned further answers to such interrogatories within five days after

acquiring such additional knowledge or information. In the event that you acquire

additional knowledge or information less than five days prior to the hearing in this matter,

Petitioner asks that you serve on the undersigned further answers to such interrogatories

immediately upon acquiring such additional knowledge or information.

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 2. In responding to these interrogatories, furnish all information, however

obtained, including any information that is available to you and information known by or in

possession of yourself, your agents and your attorneys, or appearing in your records. If a

claim of privilege, immunity or otherwise is asserted, please support the claimed privilege

with a statement of particulars sufficient to enable the Court to assess its validity. In the

case of a document, such a statement should identify each such document by specifying its

date, author(s), recipient(s), subject matter, all persons to whom such document has been

provided, and set forth the grounds upon which its production is being withheld. In the case

of a communication, the statement should include the date, place, subject, and purpose of

the communication, as well as the names, addresses, and positions of all persons present.

3. Whenever an interrogatory is framed in the disjunctive, it shall also be

construed to be in the conjunctive and vice versa. Whenever an interrogatory is framed in

the singular, it shall also be construed to be in the plural and vice versa. If any document

relevant to a response to an interrogatory has been in your possession or subject to your

custody or control but is not at the present time, or is known to you to have been in

existence, but is not at the present time, state what disposition was made of it or what

became of it.

B. Relevant Time Period

Unless otherwise stated, the Relevant Time Period for each of the following

interrogatories is May 1, 2023 through the present.

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 DEFINITIONS

For purposes of this First Set of Interrogatories, the following terms shall be defined

as follows:

1. “Petition” means the Petition for Civil Stalking Protection Order filed by

Petitioner on or around November 20, 2023 in the Cuyahoga County Court of Common

Pleas, Case No. CV-23-988870.

2. “Automobile” means any vehicle designed for operation on ordinary roads,

including but not limited to cars, trucks, and SUVs, without regard to body type.

3. “Ex Parte Order” means the Order of Protection issued on November 21, 2023

in the Cuyahoga County Court of Common Pleas, Case No. CV-23-988870.

4. “Document” and “documents” as used herein are both singular and plural and

shall be defined to the broadest extent permitted by Ohio Rule of Civil Procedure 34, and

shall include, without limitation, any written, printed, recorded, electronically stored,

typed, handwritten, transcribed, punched, taped, filmed or graphic matter of every kind or

description, whether produced, recorded, reproduced or stored on paper, film, video, other

multimedia formats, or electronic storage devices, and whether draft or final, original or

reproduction, in the custody or control of Respondent, his agents or counsel, or known to

any of them to have been created or reproduced, or within the your right to obtain upon

request or demand, including, without limitation, all data, letters, correspondence,

electronic mail (and attachments to electronic mail), memoranda, notes (handwritten,

typewritten or stenographic), text messages, instant message logs, online chat logs,

notebooks, books, pamphlets, brochures, periodicals, studies, diaries, calendars, planners,

schedules, ledgers, accounting records, invoices, vouchers, checks, estimates, work papers,

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sketches, prints, diagrams, drawings, plans, pictures, tables, lists, maps, data sheets,

memoranda or minutes of meetings, interoffice documents, conversations (written,

personal or telephone), telegrams, mailgrams, telex communications, cables, statements,

instruments, contracts, agreements, transcripts, records, reports, photographs, films, tape-

recordings, videos, drawings, graphs, charts, data processing results, printouts, file and

index cards, computations, electronic recordings, computer tapes, discs and cards, and all

other data compilations from which intelligence can be perceived with or without the use

of detection devices.

5. “Identify” or “describe,” when referring to an individual or person, means to

state the full legal name, present or last known mailing address, telephone number, and

occupation or job title of that person.

6. “Refer,” “reflect,” and “relate” shall mean referring to, or having any

relationship with whatsoever, or regarding or pertaining to, or comprising, or indicating, or

supporting, or constituting evidence of, in whole or in part.

7. “Petitioner” or “Juanita Brent” refers to Petitioner Juanita Brent.

8. “Respondent,” “Elliot Forhan,” “you,” or “your” means Respondent Elliot

Forhan, or any other person, attorney, agent, employee, subsidiary, or other individual or

entity acting or purporting to act on his behalf.

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 INTERROGATORIES

INTERROGATORY NO. 1: Identify each person whom you expect to call as a witness at

the full hearing in this matter, stating the subject matter of the expected testimony for each.

ANSWER:

INTERROGATORY NO. 2: Identify each person who has knowledge of the allegations in

the Petition, which is attached hereto as Exhibit A, to the extent not identified in response

to Interrogatory No. 1.

INTERROGATORY NO. 3: Identify each document you expect to proffer as evidence at the

full hearing in this matter.

ANSWER:

INTERROGATORY NO. 4: Identify all social media or similar websites including, but not

limited to, Facebook, Twitter or X, Instagram, Snapchat, Tumblr, Reddit, TikTok, Myspace,

LinkedIn, Google Plus, YouTube, you have used during the relevant period of time, including

your account name or handle you have used on those websites.

ANSWER:

INTERROGATORY NO. 5: Identify by make, model, year, color, and license plate all

Automobiles you have driven during the Relevant Time Period.

ANSWER:

INTERROGATORY NO. 6: Identify by make, model, year, color, and license plate all

Automobiles registered in your name or in the name of any individuals who reside with

you.

ANSWER:

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 Respectfully submitted,

/s/ Melissa Z. Kelly

Melissa Z. Kelly (0077441)
Taylor L. Gill (0102513)
Tucker Ellis LLP
950 Main Avenue, Suite 1100
Cleveland, OH 44113
Tel: 216.592.5000
Fax: 216.592.5009
E-mail: [email protected]
[email protected]

Attorneys for Petitioner Juanita Brent

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 PROOF OF SERVICE

A copy of the foregoing was served on February 5, 2024 pursuant to Civ.R.

5(B)(2)(f) by sending it by electronic means to the e-mail address(es) provided by the

parties in accordance with Civ.R. 11 as follows:

Elliot P. Forhan
Ohio House of Representatives
Vern Riffe State Office Tower
77 South High Street, Floor 12
Columbus, OH 43215
[email protected]

Respondent

/s/ Melissa Z. Kelly

Melissa Z. Kelly (0077441)
One of the Attorneys for Petitioner
Juanita Brent

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 VERIFICATION

STATE OF OHIO )
) ss:
COUNTY OF _______________________ )

Elliot P. Forhan, being duly sworn, says that the foregoing responses to Petitioner

Juanita Brent’s First Set of Interrogatories are true and correct to the best of my knowledge,

information, and belief.

Elliot P. Forhan

Sworn to before me and subscribed in my presence on this ____ day of__________________, 2024.

Notary Public

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