Forhan Set - RFAs (1st) 2024 X

IN THE COURT OF COMMON PLEAS
CUYAHOGA COUNTY, OHIO
JUANITA BRENT,
Petitioner, Case No. 2023 CV 988870
v. Judge Nancy Margaret Russo
ELLIOT FORHAN,
Respondent.
RESPONDENT ELLIOT FORHAN’S FIRST SET OF REQUESTS FOR ADMISSION PROPOUNDED ON

PETITIONER JUANITA BRENT
Respondent Elliot Forhan (“Respondent”) hereby propounds, pursuant to Ohio Rules of Civil
Procedure 26 and 36, on Petitioner Juanita Brent (“Petitioner”) the following First Set of Requests for
Admission (“RFAs”). Respondent requests that Petitioner answer by February 20, 2024, under oath,
each RFA. Please forward to Respondent via email at Elliot.Forhan@OhioHouse.gov or at the
following address the answers:
Representative Elliot P. Forhan

Ohio House of Representatives
Vern Riffe State Office Tower
77 South High Street, Floor 12
Columbus, Ohio 43215
Page 1 of 23
Definitions and Instructions
1. The “Caucus” means the Democratic Caucus in the House.
2. The “CDP” is defined herein.
3. “Communication(s)” means and includes every manner or means of disclosure, transfer, or
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,
documents, interoffice and intra-office memoranda, written agreements, oral agreements,
correspondence, reports, notes of meetings, conferences, and oral conversations, whether
such communication is face-to-face, by telephone, by text message, by email, by mail, by
telecopier, by telex, by computer, or otherwise.
4. The “County Party” means the Cuyahoga County Democratic Party.
5. The “CSPO Ex Parte” means the Civil Stalking Protection Order Ex Parte, issued on
November 21, 2023, in the above-captioned case.
6. “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
includes agreements; contracts; letters; telegrams; inter-office communications; memoranda;
reports; records; instructions; specifications; notes; notebooks; scrapbooks; diaries; plans;
drawings; sketches; blueprints; diagrams; photographs; photocopies; charts; graphs;
descriptions; drafts, whether or not they resulted in a final document; minutes of meetings,
conferences, and telephone or other conversations or communications; invoices; purchase
orders; bills of lading; recordings; published or unpublished speeches or articles; publications;
transcripts of telephone conversations; phone mail; electronic-mail; ledgers; financial
statements; microfilm; microfiche; tape or disc recordings; and computer printouts.
Page 2 of 23
7. 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"
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,
online storage media, and near line storage media.
8. The “House” means the Ohio House of Representatives.
9. The “Jun.-27 Meeting” is defined herein.
10. The “Minority Leader” means Ohio House Minority Leader Allison Russo.
11. The “Munira-Respondent Conversation” is defined herein.
12. The “Nov.-18 Video” is defined herein.
13. The “Nov.-18-20 Videos” is defined herein.
15. The “Nov.-20 CDP Report” is defined herein.
Page 3 of 23
17. The “Nov.-21 CDP Report” is defined herein.
18. “Person” means any natural person, corporation, company, partnership, joint venture, firm,
association, proprietorship, agency, board, authority, commission, office or other business or
legal entity, whether private or governmental.
19. The “Petition” means the Petition for Civil Stalking Protection Order, filed on November 20,
2023, by Petitioner in the above-captioned case.
20. “Petitioner” means Petitioner Juanita Brent.
21. The “Petitioner Press Release” is defined herein.
22. The “Petitioner Email” is defined herein.
23. The “Petitioner Quotes” is defined herein.
24. “Relating to” means containing, constituting, considering, comprising, concerning, discussing,
regarding, describing, reflecting, studying, commenting or reporting on, mentioning, analyzing,
or referring, alluding, or pertaining to, in whole or in part.
25. “Respondent” means Respondent Elliot Forhan.
26. The “Respondent Campaign Facebook Page” means the page available at
https://www.facebook.com/ForhanForOhio.
27. The “Respondent Campaign Instagram Account” means the account available at
https://www.instagram.com/forhanforohio/.
28. The “Respondent Personal Facebook Account” means the account available at
https://www.facebook.com/elliot.forhan.
29. The “Respondent Personal Instagram Account” means the account available at
https://www.instagram.com/elliotforhan/.
Page 4 of 23
30. The “Respondent Social-Media Accounts” means (1) the Respondent Campaign Facebook
Page, (2) the Respondent Campaign Instagram Account, (3) the Respondent Personal
Facebook Account, (4) the Respondent Personal Instagram Account, (5) the Respondent
TikTok Account and (6) the Respondent Twitter Account.
31. The “Respondent TikTok Account” means the account available at
https://www.tiktok.com/@elliotforhan.
32. The “Respondent Twitter Account” means the account available at
https://twitter.com/ForhanForOhio.
33. The “Rumor” is defined herein.
34. “Statehouse” means the Ohio Statehouse.
35. The “Wright-Respondent Conversation” is defined herein.
36. The “Wright-Respondent Meeting” is defined herein.
37. “You” or “Your” means Petitioner, as well as her agents, affiliates, representatives, employees,
or any other person or entity acting or purporting to act on her behalf.
38. Unless otherwise stated in a particular RFA, the time period applicable to these RFAs shall be
from January 1, 2023, to the present.
39. The singular of any word shall include the plural, and the plural of any word shall include the
singular.
40. Under Civ.R. 26, there is a continuing duty to seasonably supplement or amend the answers
to these RFAs.
Page 5 of 23
Requests for Admission
REQUEST FOR ADMISSION NO. 1: Admit that, with respect to the meeting on January 6, 2024
(the “Jan.-6 Meeting”), in Independence, Ohio, of the executive committee of the Cuyahoga County
Democratic Party, you told David Brock before the start of the Jan.-6 Meeting either that you did not
mind or that you would not call the police if Respondent attended in person the Jan.-6 Meeting.
ANSWER:
REQUEST FOR ADMISSION NO. 2: Admit that you filed on or about November 21, 2023, with
the Cleveland Division of Police (the “CDP”) a report (the “Nov.-21 CDP Report”) alleging the
commission by Respondent of certain conduct.
ANSWER:
REQUEST FOR ADMISSION NO. 3: Admit that you filed on or about November 20, 2023, with
the Cleveland Division of Police (the “CDP”) a report (the “Nov.-20 CDP Report”) alleging the
commission by Respondent of certain conduct.
ANSWER:
REQUEST FOR ADMISSION NO. 4: Admit that, in connection with the filing of the Nov.-21
CDP Report, you told law enforcement that you had video surveillance that showed Respondent
approaching your home on November 20, 2023.
ANSWER:
CDP Report, you told law enforcement that Respondent left a letter on your property.
ANSWER:
CDP Report, you told law enforcement that someone who resembled Respondent drove at 9:15 a.m.
on November 21, 2023, past your house in a black Ford F-150 truck.
Page 6 of 23
ANSWER:
REQUEST FOR ADMISSION NO. 7: Admit that to your knowledge, Respondent only visited your
home one time, on June 26, 2023.
ANSWER:
REQUEST FOR ADMISSION NO. 8: Admit that you do not have any video surveillance that shows
Respondent approaching your home on or about November 20, 2023.
ANSWER:
REQUEST FOR ADMISSION NO. 9: Admit that you have no evidence that Respondent left a
letter on your property.
ANSWER:
REQUEST FOR ADMISSION NO. 10: Admit that you have no reason to believe that Respondent
drives a black truck.
ANSWER:
REQUEST FOR ADMISSION NO. 11: Admit that you thought that Respondent drove a Ford F-
150-style truck because you saw the photograph included in the post, dated on or about February 18,
2023, on Respondent’s campaign social-media accounts, of Respondent posing with another Ohio
State Representative and her husband and their dark-colored pickup truck.
ANSWER:
CDP Report, law enforcement asked you to produce the video surveillance that showed Respondent
approaching your home on November 20, 2023, or a copy thereof.
ANSWER:
Page 7 of 23
CDP Report, law enforcement asked you to produce the letter that Respondent left on your property
or a copy thereof.
ANSWER:
CDP Report, you did not produce the video surveillance that you alleged showed Respondent
approaching your home on November 20, 2023, or a copy thereof.
ANSWER:
CDP Report, you did not produce the letter that you alleged that Respondent left on your property or
a copy thereof.
ANSWER:
and Nov.-21 CDP Reports, despite not receiving from you any responsive records, law enforcement
investigated.
ANSWER:
and Nov.-21 CDP Reports, law enforcement declined, after concluding the investigation, to prosecute.
ANSWER:
REQUEST FOR ADMISSION NO. 18: Admit that you never told Respondent not to contact you.
ANSWER:
REQUEST FOR ADMISSION NO. 19: Admit that you have no documents showing that you told
Respondent not to contact you.
ANSWER:
Page 8 of 23
REQUEST FOR ADMISSION NO. 20: Admit that you sent on or about October 11, 2023, to
Respondent a text message in which you wrote, “Thank you.”
ANSWER:
REQUEST FOR ADMISSION NO. 21: Admit that the reason that you sent on or about October
11, 2023, to Respondent a text message was in response to receiving on the same day a text message
from Respondent.
ANSWER:
REQUEST FOR ADMISSION NO. 22: Admit that you sent on or about September 12 and 13,
2023, twice, to Respondent two text messages in which you wrote, “text me.”
ANSWER:
REQUEST FOR ADMISSION NO. 23: Admit that Respondent has not called you since September
18, 2023.
ANSWER:
REQUEST FOR ADMISSION NO. 24: Admit that, since May 23, 2023, except for a week-long
period in September when Respondent was trying to organize a group letter, Respondent has called
you no more than three times.
ANSWER:
REQUEST FOR ADMISSION NO. 25: Admit that, since May 23, 2023, except for a week-long
period in September when Respondent was trying to organize a group letter, Respondent called you
three times: once on May 25, 2023, during which you and Respondent talked for approximately ten
minutes, and once on June 9, 2023, to each of two phones of yours, neither of which call was answered.
ANSWER:
Page 9 of 23
REQUEST FOR ADMISSION NO. 26: Admit that, except for the week-long period in September
when Respondent was trying to organize a group letter, Respondent has sent to you a text message
no more than four times, ever.
ANSWER:
REQUEST FOR ADMISSION NO. 27: Admit that Respondent has not sent to you a Signal message
since April 2023.
ANSWER:
REQUEST FOR ADMISSION NO. 28: Admit that Respondent has sent to you a Signal message
no more than four times, ever.
ANSWER:
REQUEST FOR ADMISSION NO. 29: Admit that each communication by Respondent to you was
related to political or government activities or activities otherwise in connection with the Ohio General
Assembly or the Ohio or Cuyahoga County Democratic Party organization.
ANSWER:
REQUEST FOR ADMISSION NO. 30: Admit that you posed on or about September 10, 2023, for
a photograph with Respondent and Respondent’s parents.
ANSWER:
REQUEST FOR ADMISSION NO. 31: Admit that you said on or about September 10, 2023, to
one of Respondent’s mothers, “Can I call you Mom?”
ANSWER:
REQUEST FOR ADMISSION NO. 32: Admit that you issued on or about November 21, 2023, a
press release (the “Petitioner Press Release”) announcing that you obtained the CSPO Ex Parte.
ANSWER:
Page 10 of 23
REQUEST FOR ADMISSION NO. 33: Admit that you included in the Petitioner Press Release that
you “file[d] a temporary restraining order.”
ANSWER:
REQUEST FOR ADMISSION NO. 34: Admit that, with respect to the three videos, dated
November 18 (the “Nov.-18 Video”), 19 (the “Nov.-19 Video”) and 20 (the “Nov.-20 Video” and,
together with the Nov.-18 Video and the Nov.-19 Video, the “Nov.-18-20 Videos”), 2023, by
Respondent, mentioned in paragraphs 5) through 7) of the Petition, Respondent said nothing
threatening.
ANSWER:
REQUEST FOR ADMISSION NO. 35: Admit that, other than to one or more of the Respondent
Social-Media Accounts, Respondent did not publish any of the Nov.-18-20 Videos.
ANSWER:
REQUEST FOR ADMISSION NO. 36: Admit that, to the extent that Respondent published any of
the Nov.-18-20 Videos, Respondent did not tag any account owned by you.
ANSWER:
REQUEST FOR ADMISSION NO. 37: Admit that, with respect to each of the Respondent Social-
Media Accounts, the Nov.-18-20 Videos are deleted therefrom.
ANSWER:
REQUEST FOR ADMISSION NO. 38: Admit that, with respect to each of the Respondent Social-
Media Accounts, the Nov.-18-20 Videos were before the time of the filing of the Petition deleted
therefrom.
ANSWER:
Page 11 of 23
REQUEST FOR ADMISSION NO. 39: Admit that you have no reason to believe that the post,
time-stamped at or about 10:26 a.m. on November 15, 2023, by Respondent on Twitter, tagging the
account of Ohio Lieutenant Governor Jon Husted, is anything other than a post about deer-hunting.
ANSWER:
REQUEST FOR ADMISSION NO. 40: Admit that you gave on or about November 16, 2023, to a
Cleveland.com reporter, in connection with the prospective publication of an article about Respondent,
quotes (the “Petitioner Quotes”).
ANSWER:
REQUEST FOR ADMISSION NO. 41: Admit that you included in the Petitioner Quotes a
suggestion that Respondent should resign or be removed from his position as an Ohio state
representative.
ANSWER:
REQUEST FOR ADMISSION NO. 42: Admit that you included in the Petitioner Quotes statements
to the effect of “We can’t have people in office who are having manic moments. . . . [Respondent has]
had a lot of manic moments.”
ANSWER:
REQUEST FOR ADMISSION NO. 43: Admit that you are not qualified to make clinical diagnoses
regarding mental health.
ANSWER:
REQUEST FOR ADMISSION NO. 44: Admit that you do not know of any diagnosis of
Respondent.
ANSWER:
Page 12 of 23
REQUEST FOR ADMISSION NO. 45: Admit that you included in the Petitioner Quotes, in
addition to the suggestion that Respondent should resign or be removed, other remarks disparaging
to Respondent.
ANSWER:
REQUEST FOR ADMISSION NO. 46: Admit that you included in the Petitioner Quotes the
statement, with respect to the Munira-Respondent Conversation, “Rep. Abdullahi came out of the
room crying super hard.”
ANSWER:
REQUEST FOR ADMISSION NO. 47: Admit that Cleveland.com published on or about November
16, 2023, an article that included at least some of the Petitioner Quotes, including (a) the suggestion
by you that Respondent should resign or be removed from his position as an Ohio state representative,
(b) statements to the effect of “We can’t have people in office who are having manic moments. . . .
[Respondent has] had a lot of manic moments, (c) other remarks by you disparaging to Respondent
and (d) the statement, with respect to the Munira-Respondent Conversation, by you that “Rep.
Abdullahi came out of the room crying super hard.”
ANSWER:
REQUEST FOR ADMISSION NO. 48: Admit that you serve as the Executive Vice Chair of the
County Party.
ANSWER:
REQUEST FOR ADMISSION NO. 49: Admit that the Executive Vice Chair position is the second-
highest-ranking officer position of the County Party.
ANSWER:
REQUEST FOR ADMISSION NO. 50: Admit that the County Party is, with respect to politics in
Cuyahoga County, one of the most influential organizations.
Page 13 of 23
ANSWER:
REQUEST FOR ADMISSION NO. 51: Admit that you saw no more than ten seconds of a
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.
ANSWER:
REQUEST FOR ADMISSION NO. 52: Admit that you looked into Statehouse Hearing Room 121
for no more than ten seconds from the hallway outside of the room during the Munira-Respondent
Conversation.
ANSWER:
REQUEST FOR ADMISSION NO. 53: Admit that you never entered with all your body Statehouse
Hearing Room 121 during the Munira-Respondent Conversation.
ANSWER:
REQUEST FOR ADMISSION NO. 54: Admit that, with respect to the Munira-Respondent
Conversation, the statement “Rep. Abdullahi came out of the room crying super hard” is false.
ANSWER:
REQUEST FOR ADMISSION NO. 55: Admit that Rep. Munira accepted Respondent’s apology in
connection with the Munira-Respondent Conversation.
ANSWER:
REQUEST FOR ADMISSION NO. 56: Admit that Rep. Munira said that she got angry during the
Munira-Respondent Conversation.
ANSWER:
REQUEST FOR ADMISSION NO. 57: Admit that Respondent gave you flowers once, on or about
July 3, 2023.
Page 14 of 23
ANSWER:
REQUEST FOR ADMISSION NO. 58: Admit that Respondent told you, when he gave you the
flowers, that he was doing so at the suggestion of Rep. Munira.
ANSWER:
REQUEST FOR ADMISSION NO. 59: Admit that you do not have personal knowledge that
Respondent pounded aggressively on June 26, 2023, on the door of your home.
ANSWER:
REQUEST FOR ADMISSION NO. 60: Admit that you do not have personal knowledge that the
person who answered the door of your house on June 26, 2023, when Respondent knocked on it ever
opened the main door during the conversation between the person and Respondent.
ANSWER:
Respondent repeated over and over on June 26, 2023, at your door the statement “I just want to talk
to her.”
ANSWER:
Respondent badgered on June 26, 2023, the person at your door.
ANSWER:
REQUEST FOR ADMISSION NO. 63: Admit that you sent at or about 9:30 p.m. on June 26, 2023,
to Respondent, copying, among other people, the Minority Leader, an email (the “Petitioner Email”).
ANSWER:
REQUEST FOR ADMISSION NO. 64: Admit that you wrote in the Petitioner Email that
Respondent “knock[ed]” on your door.
ANSWER:
Page 15 of 23
REQUEST FOR ADMISSION NO. 65: Admit that you did not include in the Petitioner Email any
mention of Respondent yelling at the person who answered the door.
ANSWER:
REQUEST FOR ADMISSION NO. 66: Admit that you included in the Petitioner Email a request
that Respondent disclose the identity of the person who had told Respondent a rumor (the “Rumor”)
that you were recruiting one or more candidates to compete against Respondent in a future election.
ANSWER:
REQUEST FOR ADMISSION NO. 67: Admit that you included in the Petitioner Email that a Plain
Dealer reporter called you on May 30 and asked you for an interview relating to Respondent and that
you “refused.”
ANSWER:
REQUEST FOR ADMISSION NO. 68: Admit that the number of words that you devoted in the
Petitioner Email to the topics of (a) the identity of the person who had told Respondent the Rumor
and (b) the Plain Dealer reporter is no fewer than 89.
ANSWER:
REQUEST FOR ADMISSION NO. 69: Admit that the number of words that you devoted in the
Petitioner Email to the topic of Respondent knocking on your door is no more than 91.
ANSWER:
REQUEST FOR ADMISSION NO. 70: Admit that you included in the Petitioner Email as a threat
to Respondent mention of the Plain Dealer reporter.
ANSWER:
REQUEST FOR ADMISSION NO. 71: Admit that you included in the Petitioner Email that you
were not sure how Respondent got your address.
ANSWER:
Page 16 of 23
REQUEST FOR ADMISSION NO. 72: Admit that the County Party makes publicly available on its
website the street address of the residence of each member of the leadership of the organization,
including each of the hundreds of members of the executive and central committees.
ANSWER:
REQUEST FOR ADMISSION NO. 73: Admit that, with respect to the leadership of the County
Party, the residential street address is the only form of contact information that the organization makes
publicly available.
ANSWER:
REQUEST FOR ADMISSION NO. 74: Admit that, during the meeting that occurred at or about
9:00 a.m. on June 27, 2023 (the “Jun.-27 Meeting”), in the Vern Riffe State Office Tower office of the
Minority Leader, the participants of which meeting included you, Respondent, the Minority Leader
and Ohio State Representative Phil Robinson, you asked that Respondent disclose the identity of the
person who had told Respondent the Rumor.
ANSWER:
REQUEST FOR ADMISSION NO. 75: Admit that the purpose of the Jun.-27 Meeting was to obtain
from Respondent the identity of the person who had told Respondent the Rumor.
ANSWER:
REQUEST FOR ADMISSION NO. 76: Admit that in connection with your service as an officer of
the County Party and as a state representative you ask on a regular basis people to knock doors.
ANSWER:
REQUEST FOR ADMISSION NO. 77: Admit that you said during the Jun.-27 Meeting to
Respondent that knocking on your door without advance notice wouldn’t have been a problem “if
you were my man.”
ANSWER:
Page 17 of 23
REQUEST FOR ADMISSION NO. 78: Admit that 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:
REQUEST FOR ADMISSION NO. 79: Admit that you initiated the conversation that occurred
from at or about 1:52 p.m. to at or about 1:57 p.m. on May 23, 2023 (the “Wright-Respondent
Conversation”), in Statehouse Hearing Room 113 between Ms. Ladosha Wright and Respondent by
indicating at Respondent and telling Ms. Wright that Respondent was the Democrat who was co-
sponsoring the bill that Ms. Wright opposed.
ANSWER:
REQUEST FOR ADMISSION NO. 80: With respect to the Wright-Respondent Conversation,
admit that Respondent gesticulated with his hand in connection with the content of the conversation
by (a) pointing to the ceiling as he was saying words to the effect of “to the highest level” and (b)
snapping his fingers as he was saying words to the effect of, “If I could snap my fingers and make this
change, then I would.”
ANSWER:
admit that Respondent did not scream.
ANSWER:
admit that Respondent did not say “I know better because I went to Yale Law School.”
ANSWER:
Page 18 of 23
admit that at the end of the conversation Ms. Wright extended to Respondent her hand and said,
“Thank you,” and Respondent and Ms. Wright shook hands.
ANSWER:
admit that approximately two days later you and Respondent spoke by phone (the “Petitioner-
Respondent Call”).
ANSWER:
REQUEST FOR ADMISSION NO. 85: With respect to the Petitioner-Respondent Call, admit that
Respondent apologized to you, and you accepted his apology.
ANSWER:
REQUEST FOR ADMISSION NO. 86: With respect to the Petitioner-Respondent Call, admit that
you expressed surprise that the Minority Leader said that she might remove Respondent from a House
committee leadership position.
ANSWER:
admit that David Brock invited you to attend a meeting that occurred at or about 8:00 a.m. on June 1,
2023 (the “Wright-Respondent Meeting”).
ANSWER:
REQUEST FOR ADMISSION NO. 88: Admit that you did not attend the Wright-Respondent
Meeting.
ANSWER:
Page 19 of 23
REQUEST FOR ADMISSION NO. 89: Admit that you have not participated in the ongoing
discussions from June 2023 through February 2024 between Respondent and Ms. Wright in
connection with their work together on new Black-hairstyling-education legislation.
ANSWER:
REQUEST FOR ADMISSION NO. 90: Admit that, during a meeting that occurred on or about
November 20, 2022, at the headquarter office of the County Party, the participants of which meeting
included the delegation from Cuyahoga County to the House of Democratic state representatives, you
encouraged Respondent to seek an open position on the leadership team of the Caucus.
ANSWER:
Respondent asked David Brock three times during November 16 to 19, 2023, to meet with you or for
your schedule.
ANSWER:
REQUEST FOR ADMISSION NO. 92: Admit that contacts between you and other state
representatives occur routinely when you are not in Columbus.
ANSWER:
REQUEST FOR ADMISSION NO. 93: Admit that Respondent did not engage in a pattern of
conduct that knowingly caused you to believe that Respondent will cause physical harm to you or a
family or household member of yours or cause mental distress to you or a family or household member
of yours.
ANSWER:
REQUEST FOR ADMISSION NO. 94: Admit that Mallory McMaster advised you to file the
Petition.
ANSWER:
Page 20 of 23
REQUEST FOR ADMISSION NO. 95: Admit that Mallory McMaster told you that I drove a black
F150-style truck.
ANSWER:
REQUEST FOR ADMISSION NO. 96: Admit that Mallory McMaster advised you that you or an
agent of yours should say that I drove by your house.
ANSWER:
Page 21 of 23
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:
SWORN TO BEFORE ME and subscribed in my presence this __ day of February, 2024.
______________________________
NOTARY PUBLIC
Page 22 of 23
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.
_/s/ Elliot P. Forhan_________________

Respondent Elliot P. Forhan
Page 23 of 23

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IN THE COURT OF COMMON PLEAS

CUYAHOGA COUNTY, OHIO

RESPONDENT ELLIOT FORHAN’S FIRST SET OF REQUESTS FOR ADMISSION PROPOUNDED ON

each RFA. Please forward to Respondent via email at Elliot.Forhan@OhioHouse.gov or at the

following address the answers:

Representative Elliot P. Forhan

1. The “Caucus” means the Democratic Caucus in the House.

2. The “CDP” is defined herein.

3. “Communication(s)” means and includes every manner or means of disclosure, transfer, or

documents, interoffice and intra-office memoranda, written agreements, oral agreements,

correspondence, reports, notes of meetings, conferences, and oral conversations, whether

such communication is face-to-face, by telephone, by text message, by email, by mail, by

telecopier, by telex, by computer, or otherwise.

4. The “County Party” means the Cuyahoga County Democratic Party.

November 21, 2023, in the above-captioned case.

includes agreements; contracts; letters; telegrams; inter-office communications; memoranda;

reports; records; instructions; specifications; notes; notebooks; scrapbooks; diaries; plans;

drawings; sketches; blueprints; diagrams; photographs; photocopies; charts; graphs;

conferences, and telephone or other conversations or communications; invoices; purchase

orders; bills of lading; recordings; published or unpublished speeches or articles; publications;

transcripts of telephone conversations; phone mail; electronic-mail; ledgers; financial

statements; microfilm; microfiche; tape or disc recordings; and computer printouts.

online storage media, and near line storage media.

8. The “House” means the Ohio House of Representatives.

9. The “Jun.-27 Meeting” is defined herein.

11. The “Munira-Respondent Conversation” is defined herein.

12. The “Nov.-18 Video” is defined herein.

13. The “Nov.-18-20 Videos” is defined herein.

14. The “Nov.-19 Video” is defined herein.

15. The “Nov.-20 CDP Report” is defined herein.

17. The “Nov.-21 CDP Report” is defined herein.

association, proprietorship, agency, board, authority, commission, office or other business or

legal entity, whether private or governmental.

2023, by Petitioner in the above-captioned case.

20. “Petitioner” means Petitioner Juanita Brent.

21. The “Petitioner Press Release” is defined herein.

22. The “Petitioner Email” is defined herein.

23. The “Petitioner Quotes” is defined herein.

regarding, describing, reflecting, studying, commenting or reporting on, mentioning, analyzing,

or referring, alluding, or pertaining to, in whole or in part.

25. “Respondent” means Respondent Elliot Forhan.

TikTok Account and (6) the Respondent Twitter Account.

31. The “Respondent TikTok Account” means the account available at

32. The “Respondent Twitter Account” means the account available at

33. The “Rumor” is defined herein.

34. “Statehouse” means the Ohio Statehouse.

35. The “Wright-Respondent Conversation” is defined herein.

36. The “Wright-Respondent Meeting” is defined herein.

or any other person or entity acting or purporting to act on her behalf.

from January 1, 2023, to the present.

commission by Respondent of certain conduct.

commission by Respondent of certain conduct.

approaching your home on November 20, 2023.

home one time, on June 26, 2023.

Respondent approaching your home on or about November 20, 2023.

letter on your property.

drives a black truck.

approaching your home on November 20, 2023, or a copy thereof.

approaching your home on November 20, 2023, or a copy thereof.

Respondent not to contact you.

Respondent a text message in which you wrote, “Thank you.”

you no more than three times.

no more than four times, ever.