IN THE UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF OHIO 

WESTERN DIVISION – CINCINNATI 

MICHAEL SLOCUM, 

 Plaintiff, 

v. 

SGT. S. BEAR, et al., 

Defendants. 

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Case No. 1:18-cv-423 

Judge Douglas R. Cole 

Magistrate Judge Karen L. Litkovitz 

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JOINT MOTION TO SCHEDULE A STATUS CALL TO DISCUSS REFERRING 

THIS CASE FOR MEDIATION 

______________________________________________________________________________ 

The parties jointly request that the Court schedule a telephonic status conference 

to discuss the possibility of referring this case for mediation. This motion is supported 

by the attached memorandum. 

Respectfully submitted, 

/s/ David P. Dornette

David P. Dornette (0098903) 

TAFT STETTINIUS & HOLLISTER LLP 

425 Walnut Street, Suite 1800 

Cincinnati, Ohio 45202 

Phone: (513) 357-9666 

Fax: (513) 381-0205 

ddornette@taftlaw.com 

Counsel for Plaintiff Michael Slocum

Granted. [ 9:10 AM, Dec 15, 2021] ~ zx~ United States Magistrate Judge 

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DAVE YOST (0056290) 

Ohio Attorney General 

/s/ William Case

William Case (0090684) 

Assistant Attorney General 

Criminal Justice Sect. Corrections Unit

30 E. Broad St., 23rd Floor 

Columbus, Ohio 43215

Phone: (614)-728-8445 

Fax: (844) 255-4358 

William.case@ohioattorneygeneral.gov 

Counsel For Defendants 

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MEMORANDUM IN SUPPORT 

In October 2017, Plaintiff Michael Slocum was assaulted by multiple prison guards 

while serving an unrelated sentence at the Southern Ohio Correctional Facility in 

Lucasville (“Lucasville”). Mr. Slocum filed this case pro se in June 2018, initial discovery 

concluded in August 2020, and summary judgment was granted in part and denied in 

part in August 2021. The Court then appointed Plaintiff’s counsel on October 19, 2021. 

On October 27, 2021, Mr. Slocum, through counsel, offered Defendants a settlement offer. 

But since all settlement offers must go through the Director of Ohio’s Department of 

Rehabilitation & Correction, defense counsel has not yet been able to provide an 

affirmative response or counter-proposal. 

Thereafter, Mr. Slocum moved to reopen discovery and establish a trial calendar. 

The Court granted the motion, and this case is now set for a jury trial on May 9, 2022. 

However, last week, Mr. Slocum notified counsel of an incident that occurred involving 

two prison guards at Lucasville. Although these two guards are not presently named as 

Defendants in this case, Mr. Slocum takes the position that their actions constitute a claim 

for retaliation. Mr. Slocum is thus inclined to seek leave from the Court to file an 

amended complaint. But doing so would delay the established trial calendar and, if 

granted, lead to a new round of pleadings, service of process, motions, and discovery. 

So, before Mr. Slocum pursues this route (and in hopes of reaching a quick, 

amenable resolution to this matter), he requests that the Court schedule a status call to 

discuss the possibility of referring this case for mediation. Doing so will hopefully help 

expedite settlement negotiations and avoid any further delays in this nearly four-yearCase: 1:18-cv-00423-DRC-KLL Doc #: 109 Filed: 12/15/21 Page: 3 of 5 PAGEID #: 628
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old case. Plaintiff’s counsel discussed this matter with defense counsel, who agrees that 

a mediation attempt is a good idea and thus joins in Mr. Slocum’s request. 

For the reasons above, the parties jointly requests that the Court schedule a 

telephonic status conference to discuss this matter and refer this case for mediation. 

Respectfully submitted, 

/s/ David P. Dornette

David P. Dornette (0098903) 

TAFT STETTINIUS & HOLLISTER LLP 

425 Walnut Street, Suite 1800 

Cincinnati, Ohio 45202 

Phone: (513) 357-9666 

Fax: (513) 381-0205 

ddornette@taftlaw.com 

Counsel for Plaintiff Michael Slocum

DAVE YOST (0056290) 

Ohio Attorney General 

/s/ William Case

William Case (0090684) 

Assistant Attorney General 

Criminal Justice Sect., Corrections Unit

30 E. Broad St., 23rd Floor 

Columbus, Ohio 43215

Phone: (614)-728-8445 

Fax: (844) 255-4358 

William.case@ohioattorneygeneral.gov 

Counsel For Defendants

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CERTIFICATE OF SERVICE

I hereby certify that a true and accurate copy of the above was filed electronically 

on December 14, 2021. Notice of this filing will be sent to all parties through the Court’s 

electronic filing system. 

/s/ David P. Dornette

Case: 1:18-cv-00423-DRC-KLL Doc #: 109 Filed: 12/15/21 Page: 5 of 5 PAGEID #: 630