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 INTERROGATORIES PROPOUNDED ON

PETITIONER JUANITA BRENT

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,

under oath, each Interrogatory. 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

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 Definitions and Instructions

1. The “CDP” is defined herein.

2. “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.

3. The “County Party” is defined herein.

4. “Describe” means to represent or give an account of in words.

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

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orders; bills of lading; recordings; published or unpublished speeches or articles; publications;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

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,

online storage media, and near line storage media.

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

8. “Identify” or “identity” means to state or a statement of:

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

that other person's chief executive officer;

b. in the case of a natural person, his or her name, business address and telephone

number, employer, and title or position;

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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,

the date of preparation, and its number of pages; and

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

subject matter of the agreement.

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

10. The “Minority Leader” means House Minority Leader Allison Russo.

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

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

13. “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.

14. The “Petition” means the Petition for Civil Stalking Protection Order, filed on November 20,

2023, by Petitioner in the above-captioned case.

15. “Petitioner” means Petitioner Juanita Brent.

16. “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.

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17. “Respondent” means Respondent Elliot Forhan.

18. “Statehouse” means the Ohio Statehouse.

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

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

21. “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.

22. Unless otherwise stated in a particular Interrogatory, the time period applicable to these

Interrogatories shall be from January 1, 2023, to the present.

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

INTERROGATORY NO. 1: Identify each communication, excluding any privileged

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

video surveillance and how the video surveillance was recorded.

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

existence of the letter.

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

with the CDP, alleging the commission by Respondent of certain conduct.

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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

Nov.-21 CDP Report.

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

Respondent on the door of your house.

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

the door the statement “I just want to talk to her.”

ANSWER:

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INTERROGATORY NO. 15: Describe how you learned about the rumor that you were recruiting

one or more candidates to compete against Respondent in a future election.

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

been a problem “if you were my man.”

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

you intend to rely in support of your request for a protection order.

ANSWER:

INTERROGATORY NO. 22: Identify each person having personal knowledge of the events

described in your Petition.

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

the above-captioned case.

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

that I drove by your house.

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:

SWORN TO BEFORE ME and subscribed in my presence this __ day of February, 2024.

______________________________
NOTARY PUBLIC

Date: February 5, 2024 Respectfully submitted,

/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
Elliot.Forhan@OhioHouse.gov

Respondent Elliot P. Forhan

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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.

_/s/ Elliot P. Forhan_________________

Respondent Elliot P. Forhan

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