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, ) REQUESTS FOR PRODUCTION OF
) DOCUMENTS TO RESPONDENT ELLIOT
Respondent. ) FORHAN
)

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

pursuant to Civil Rules 26 and 34, hereby requests that Respondent Elliot Forhan

(“Respondent”), serve a written response to the following requests for production of

documents and make available for inspection and copying the specified documents no later

than February 20, 2024. The requested documents should be available at the offices of

Tucker Ellis LLP, 950 Main Avenue, Suite 1100, Cleveland, Ohio 44113-7213, or copies of

said documents should be delivered to counsel for Petitioner at that address, via email to

undersigned counsel or some other mutually agreeable method.

INSTRUCTIONS

A. General Instructions

1. With respect to any of the following requests for production as to which you,

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

serve on the undersigned further answers to such requests 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

6323674.1
asks that you serve on the undersigned further answers to such requests immediately upon

acquiring such additional knowledge or information.

2. In responding to these requests for production, 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 a request for production is framed in the disjunctive, it shall also

be construed to be in the conjunctive and vice versa. Whenever a request for production is

framed in the singular, it shall also be construed to be in the plural and vice versa.

4. If any document responsive to a request for production 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 requests

for production is May 1, 2023 through the present.

2
6323674.1
 DEFINITIONS

For purposes of this First Set of Requests for production, 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. “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.

3. “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,

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

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

3
6323674.1
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.

4. “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.

5. “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.

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

7. “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.

4
6323674.1
 REQUESTS FOR PRODUCTION OF DOCUMENTS

REQUEST NO. 1: Produce all Documents that you expect to proffer as evidence at the

full hearing in this matter.

RESPONSE:

REQUEST NO. 2: Produce all Documents identified in your answers to Petitioner’s

Interrogatories.

RESPONSE:

REQUEST NO. 3: Produce all Documents that reflect or contain correspondence from

you to Juanita Brent, including, without limitation, text messages, emails, and instant

messages.

RESPONSE:

REQUEST NO. 4: Produce all Documents that reflect or contain correspondence from

Juanita Brent to you, including, without limitation, text messages, emails, and instant

messages.

RESPONSE:

REQUEST NO. 5: Produce downloads of all data from the social media websites as

instructed by Attachment 1 to Petitioner’s Requests for Production of Documents.

RESPONSE:

REQUEST NO. 6: To the extent that Request for Production No. 5 and Attachment 1 did

not instruct you to collect data from a social media or similar website that you otherwise

identified in response to Interrogatory No. 4 of Petitioner’s Interrogatories, please provide

downloads of all data from your remaining social media or similar websites.

5
6323674.1
 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: melissa.kelly@tuckerellis.com
Taylor.gill@tuckerellis.com

Attorneys for Petitioner Juanita Brent

6
6323674.1
 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
Elliot.Forhan@OhioHouse.gov

Respondent

/s/ Melissa Z. Kelly

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

7
6323674.1
 ATTACHMENT 1:
SOCIAL MEDIA DOWNLOAD PROTOCOL
 FACEBOOK “DOWNLOAD YOUR DATA” PROTOCOL

Facebook allows users to obtain copies of their Facebook information by using the

“Download Your Information” tool. There is no cost associated with this process.

How to download a copy of your Facebook data for your profile:1

Step 1: Click account in the top right of Facebook.

Step 2: Select Settings & privacy, then click Settings.

Step 3: In the left column, click Privacy, then click Your Facebook
information.

Step 4: Next to Download profile information, click View.

Step 5: To add categories of data from your request, click the boxes on the right
side of Facebook. Select all categories of data.

Step 6: Select other options, including:

• Set the format of the download as “JSON.”

• Select the highest possible quality of photos, videos and

other media.

• Set the date range of information to the date range

specified in the Red Roof Defendants’ discovery request.

Step 7: Click Request download to confirm the download request.

Step 8: After you've made a download request, it will appear as Pending in

the Available Copies section of the Download Your Information tool.
It may take several days for Facebook to finish preparing your download
request.

Once Facebook has finished preparing your download request, it will

send a notification letting you know it's ready.

Step 9: Go to the Available Copies section of the Download Your Information

tool.

Step 10: Click Download and enter your password.

1
Instructions on how to download your Facebook data are also available here:
https://www.facebook.com/help/1701730696756992
 INSTAGRAM “DOWNLOAD YOUR DATA” PROTOCOL

Instagram allows users to obtain copies of their data. There is no cost associated with this

process.

How to download a copy of Instagram data for your profile:2

Step 1: Select and log into the profile that you would like to download information
from.

Step 2: Click the “More” button in the bottom left. The “More” button may be
represented by the following symbol:

Step 3: Click the “Settings” button. The “Settings” button may be represented by
the following symbol:

Step 4: Scroll down to “Data download” and click “Request download.”

Step 5: Enter the email address where you would like to receive a link to your data.

Step 6: Set the format of the download request as “JSON” and click “Next.”

Step 7: Enter your Instagram account password and click “Request download.”

Step 8: Upon receipt of the email link containing your data to the email address
entered, click “Download data.”

2
Instructions on how to download Instagram data are also available here:
https://help.instagram.com/181231772500920.
 TWITTER “DOWNLOAD YOUR DATA” PROTOCOL

Twitter allows users to obtain copies of their data. There is no cost associated with this

process.

How to download a copy of Twitter data for your profile:3

Step 1: Select and log into the profile that you would like to download information
from.

Step 2: Click the “More” button in the navigation bar. The “More” button may be
represented by the following symbol:

Step 3: Select “Your account” from the menu.

Step 4: Enter your password under “Download an archive of your data.”

Step 5: Click “Confirm.”

Step 6: Verify your identity by clicking “Send code” to your email address and/or
phone number associated with your Twitter account.

Step 7: Enter the code received to your email address and/or phone number
associated with your Twitter account.

Step 8: Click “Request data.”

Step 9: You will receive an email with the download link (to the email address
associated with your Twitter account) or a push notification where
accessing Twitter via an app.

Step 10: Download your data via the email/notification provided.

3
Instructions on how to download Twitter data are also available here:
https://help.twitter.com/en/managing-your-account/how-to-download-your-twitter-archive.
 TIKTOK “DOWNLOAD YOUR DATA” PROTOCOL

TikTok allows users to obtain copies of their data. There is no cost associated with this

process.

How to download a copy of TikTok data for your profile:4

Step 1: Open the TikTok app and select the profile that you would like to download
information from.

Step 2: Click the “Profile” button at the bottom.

Step 3: Select the “Menu” button at the top.

Step 4: Select “Settings and privacy.”

Step 5: Select “Manage Account.”

Step 6: Select “Download your data.”

Step 7: Follow the instructions as provided.

Step 8: Once your data has been prepared, you will be able to download the data
from the “Download your data” tab:

a) Select “Profile.”

b) Select “Menu.”

c) Select “Settings and Privacy.”

d) Select “Manage Account.”

e) Select “Download your data.”

f) Select “Download data.”

4
Instructions on how to download TikTok data are also available here:
https://support.tiktok.com/en/account-and-privacy/personalized-ads-and-data/requesting-your-data.
 LINKEDIN “DOWNLOAD YOUR DATA” PROTOCOL

LinkedIn allows users to obtain copies of their data. There is no cost associated with this

process.

How to download a copy of LinkedIn data for your profile:5

Step 1: Select and log into the profile that you would like to download information
from.

Step 2: Click the “Me” button in the navigation bar. The “Me” button may be
represented by the following symbol:

Step 3: Select “Settings & Privacy” from the dropdown menu.

Step 4: Select “Data Privacy” from the left-rail menu.

Step 5: Scroll to the “How LinkedIn uses your data section” and click on “Get a
copy of your data.”

Step 6: Select all available data and click “Request archive.”

Step 7: Upon receipt of an email notifying you that your data is available for
download, follow the link in the email and download your data.

5
Instructions on how to download LinkedIn data are also available here:
https://www.linkedin.com/help/linkedin/answer/a1339364.