State Rep.

Elliot Forhan (he/him)

Ohio House District 21 – Hillcrest, Euclid & Collinwood
June 25, 2024

Re: Memo re perjury committed by Juanita Brent.

To whom it may concern,

Please find attached a memorandum re perjury committed by Juanita Brent in her civil
stalking protection order case (case no. 2023 CV 988870, Cuyahoga County Common Pleas
Court) against me.1

Please also note that on March 28, 2024, I filed at the Fourth District Cleveland Division
of Police office a report (case no. 2024-00083355) against J. Brent for filing a false CDP report
and violating Ohio’s prohibition of making false alarms (R.C. 2917.32).2

Please let me know if you have any questions as you investigate this matter. I am
available by phone at (216) 352-3867 and by email at [email protected].

Sincerely,

Elliot Forhan
State Representative, Ohio House District 21

1
The memo, together with all supporting documentation, is also available in the folder at the following link:
https://drive.google.com/drive/u/0/folders/1uu_GsCE1SPUq1ecpr0ri4P61iL49ZaEF.
2
See report, filed on March 28, 2024, in case no. 2024-00083355, by E. Forhan with the CDP (copy available at
https://drive.google.com/file/d/1rqyv7Nslel3cnNh3DnWMyR6U5ZYUgYLG/view?usp=drive_link).

www.ohiohouse.gov office: (614) 644-5079

77 South High Street, Floor 12 mobile: (216) 352-3867
Columbus, OH 43215-6111 fax: (614) 719-0009
email: [email protected]
 Examples of false statements by J. Brent

Example What happened: What J. Brent said happened:

no.
1 J. Brent told police that I left a letter She admitted on the stand at trial that I never left a
at her house when I did not. letter and denied ever telling police that I did.
2 J. Brent told police that she had She said under oath first that she had video and had
video of me going to her home when viewed it, then admitted that she didn’t have a
she did not. video, then said on the stand at trial that she never
said that she viewed a video.
3 Police asked J. Brent for a copy of She denied under oath that police asked her for the
each of the letter and the video that letter or video.
she falsely alleged existed.
4 J. Brent never told me not to contact She said under oath that she told me not to contact
her. In any event, she and I contacted her, then implied on the stand that she had told me
each other minimally and only about nonverbally, with “body language.”
work matters.
She said under oath that I called and texted her
more than I had and when phone records show that
I did not.
5 J. Brent approached my parents at She said on the stand at trial that she only spoke to
the Stonewall Dems event. They did my parents at that event because they were waiting
not approach her, and there was no in a receiving line for her.
receiving line.

www.ohiohouse.gov office: (614) 644-5079

77 South High Street, Floor 12 mobile: (216) 352-3867
Columbus, OH 43215-6111 fax: (614) 719-0009
email: [email protected]
 Rep. Elliot P. Forhan (he/him)
Ohio’s 21st House District – Hillcrest, Euclid & Collinwood
Memorandum
TO: Michael C. O’Malley, Cuyahoga County Prosecutor
CC: Aqueelah Jordan, Chief Prosecutor, City of Cleveland
DATE: Jun. 25, 2024
RE: Perjury committed by Juanita Brent in her CSPO case against Rep. Forhan
____________________________________________________________________________________________________________________________________________________________

On November 20, 2023, Juanita Brent filed (case no. 2023 CV 988870) with the Cuyahoga
County Common Pleas Court a petition for a civil stalking protection order against Elliot Forhan.1
On April 5, 2024, the court held the trial.2 On April 10, 2024, the court ruled in favor of E. Forhan
and denied J. Brent’s petition.3

Throughout the CSPO case, including at trial, J. Brent committed multiple acts of perjury
(violations of R.C. 2921.11), each of which is a felony of the third degree, punishable by the
imposition of a sentence of a prison term of a definite term of between nine and 36 months.4

I. PERJURY COUNTS

J. Brent, in the CSPO case, knowingly made material false statements under oath re the
following:

1. Claims that she did not allege to law enforcement that E. Forhan left a letter on her
property;
2. Claims that she had video of E. Forhan approaching her home on November 20, 2023;
3. Certain details of certain events on November 15, 2023, at the Ohio Statehouse
involving her, Munira Abdullahi and Andrew DiPalma;
4. Claims that she told E. Forhan not to contact her;

1
See Petition for a Civil Stalking Protection Order, filed November 20, 2023, by J. Brent (copy available at
https://drive.google.com/file/d/1S7Qrn2VYi8bWYX76_THIvWpIBQe9l1uk/view?usp=drive_link).
2
See Transcript of Proceedings, dated April 5, 2024 (copy available at
https://drive.google.com/file/d/1XptfP1my_6bfDq0Ej9wCL0TnObjJP8eW/view?usp=drive_link).
3
See Order, filed April 10, 2024, by the court in the CSPO case at p. 7 (copy available at
https://drive.google.com/file/d/1Jacil-mAmFGd4LtG5pSk9rsztgdu-byX/view?usp=drive_link).
4
See R.C. 2921.11 (available at https://codes.ohio.gov/ohio-revised-code/section-2921.11); R.C. 2929.14(A)(3)(b)
(available at https://codes.ohio.gov/ohio-revised-code/section-2929.14).
 5. Claims that there was a receiving line for her at an event in September 2023, that the
parents of E. Forhan were standing in that receiving line and that the interactions
between her and Forhan’s parents were in connection with them standing in the line;
6. Claims that Mallory McMaster was not involved in the CSPO case;
7. Claims that law enforcement never asked her to substantiate certain allegations she
made against E. Forhan;
8. Certain details re the scope of contacts between E. Forhan and her;
9. Claims that she was not able to access Signal messages after making multiple claims
that she never deleted anything from her phone;
10. Claims that she does not in connection with her positions ask people on a regular basis
to knock doors; and
11. Claims that the position within the county Democratic party organization that she holds
is not the second-highest-ranking position in the organization.

A. Brent perjured herself re the letter allegation.

On November 21, 2023, J. Brent alleged falsely to the Cleveland Division of Police that E.
Forhan left a letter on her property.

According to CDP body-cam video, on that day, at or about 6:54 p.m., J. Brent said to CDP
Officer Sergeant Wells at the Fourth District office of the CDP, “There was an envelope left.”5
Immediately before J. Brent made that statement, David Brock, a colleague who accompanied J.
Brent to the CDP office, said, “[Y]esterday . . . there was just a package left.”6

Approximately eight minutes earlier, in the immediate presence of Sergeant Wells, D.

Brock had said to J. Brent, “Did [E. Forhan] come by yesterday too?”7 J. Brent had replied,
“[S]omething got left.”8

Later, when Sergeant Wells was outside of the room, D. Brock asked J. Brent, “Did you
open what [E. Forhan] left you in the envelope?”9 J. Brent replied, “We can talk about it later.”10

The purpose of the conversation with Sergeant Wells was for J. Brent to file a report, which
she did (case no. 2023-00352531), accusing E. Forhan of violating Ohio’s prohibition of menacing

5
See video, dated November 21, 2023, by the CDP at 18:54:03-06 (according to the timestamp in the upper-right
corner of the frame of the video) (copy available at https://drive.google.com/file/d/1W1iFy6XoNMS5b-
akArQxs0XDyGKxCbgp/view?usp=drive_link).
6
See CDP video at 18:54:00-04.
7
See Id. at 18:46:22-24.
8
See Id. at 18:46:24-33.
9
See Id. at 18:55:51-55.
10
See Id. at 18:55:54-57.

2
by stalking (R.C. 2903.211).11 Menacing by stalking is also the crime that in the CSPO case J.
Brent accused E. Forhan of committing.12

The Nov.-21 CDP report contains the following statement: “[E. Forhan] left a letter for [J.
Brent] on her property.”13

E. Forhan did not go to J. Brent’s home on November 20, 2023, or at any time about then
and never left a letter, envelope, package or anything like that on J. Brent’s property or anywhere
else. The statements by J. Brent to Sergeant Wells suggesting that E. Forhan drove by her home,
went to her home and left a letter or anything on her property were false.14

a. Testimony at trial in the CSPO case

Despite what the CDP video shows, J. Brent testified falsely under oath at trial on April 5,
2024, in the CSPO case re the letter allegation the following:

1. “I never implied . . . that [E. Forhan] left a letter to the police.”15

2. “[T]here was a letter that was left on my property and -- but I did not mention that
during the time they were doing the police report.”16
3. “I [did not] bring up the letter to the police when I did my police report.”17
4. “[Re ‘Did you try to correct M. McMaster when you heard her say the letter
allegation?’:] I did.”18
5. “[The police officer] put [the letter allegation] in the report even though I did not say
it.”19
6. “I did not say [the letter allegation] to the officer.”20
7. “I didn’t know that [the police officer] was gonna put [the letter allegation] in the report,
so, because I was only giving him my statement. [M. McMaster] just happened to be
sitting in the room.”21
8. “[Re ‘Who made the statement “E. Forhan left a letter for J. Brent on her property?”’:]
That was my friend, Mallory.”22

11
See report, filed on November 21, 2023, in case no. 2023-00352531, by J. Brent with the CDP (copy available at
https://drive.google.com/file/d/1yFHage-Cu0ADaSDmHNpcOY8p52U5f_VQ/view?usp=drive_link).
12
See CSPO petition; see also R.C. 2903.214(C) (“The petition shall contain or state . . . [a]n allegation that the
respondent . . . engaged in a violation of section 2903.211 of the Revised Code against the person to be protected by
the protection order.”).
13
See Nov.-21 CDP report at p. 5.
14
On March 28, 2024, E. Forhan filed at the Fourth District CDP office a report (case no. 2024-00083355) against J.
Brent for filing the false Nov.-21 CDP report and violating Ohio’s prohibition of making false alarms (R.C.
2917.32). See report, filed on March 28, 2024, in case no. 2024-00083355, by E. Forhan with the CDP (copy
available at https://drive.google.com/file/d/1rqyv7Nslel3cnNh3DnWMyR6U5ZYUgYLG/view?usp=drive_link).
15
Trial transcript at p. 91.
16
Id.
17
Id. at p. 93.
18
Id. at p. 88.
19
Id. at p. 89.
20
Id. at p. 87.
21
Id. at p. 90.
22
Id. at pp. 87-88 (omitting page number).

3
 9. “I did not make any allegations in the police report about you leaving a letter at my
home.”23
10. “[Re ‘Isn’t it true that in connection with the filing of that police report you told law
enforcement that I left a letter on your property?’]: No.”24
11. “[Re ‘Did you make the statement “E. Forhan left a letter for J. Brent on her
property?”’:] No, I didn’t.”25

b. Testimony at deposition in the CSPO case

J. Brent testified falsely under oath at deposition on March 1, 2024, in the CSPO case re
the letter allegation the following:

1. “I never stated that you left a package at my house.”26

2. “I never said that you left a package or anything like that.”27
3. “[Re ‘Did you ever say that I left a letter at your house?’:] No.”28
4. “[Re ‘Did you ever say I left a paper at your house?’:] No. No.”29

c. Attestations in written discovery responses in the CSPO case

J. Brent attested falsely under oath on February 20, 2024, in responses to written discovery
requests in the CSPO case re the letter allegation the following:

1. “[Re ‘Produce a copy of the “letter” that you alleged in the Nov.-21 CDP report that
E. Forhan left on your property’:] None. [J. Brent] did not tell police officers that [E.
Forhan] left a letter at her home.”30
2. “[Re ‘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’:] [J. Brent] has never alleged that [E. Forhan] left a letter at her
home.”31

d. The statements under oath by J. Brent re M. McMaster are also false.

J. Brent already perjured herself by, for example, testifying under oath at trial that (1) she
did not imply to the police that E. Forhan left a letter and (2) she did not mention a letter while

23
Id. at p. 92.
24
Id. at p. 83.
25
Id. at p. 87.
26
Transcript of the Testimony of Juanita O. Brent, dated March 1, 2024, at p. 70 (copy available at
https://drive.google.com/file/d/1tu1lgnmQ_4kWfXvabUvku5ho-yKQSRRx/view?usp=drive_link).
27
Brent deposition transcript at p. 70.
28
Id.
29
Id.
30
Petitioner J. Brent’s Responses to Respondent E. Forhan’s First Set of Requests for Production of Documents,
dated February 20, 2023, at p. 2 (copy available at
https://drive.google.com/file/d/13XPKQm0khr8Fi1JMRjGPfBKCGbWKX1--/view?usp=drive_link).
31
Petitioner J. Brent’s Responses to Respondent E. Forhan’s First Set of Interrogatories, dated February 20, 2023, at
p. 2 (copy available at https://drive.google.com/file/d/1TGfc3q9VtL0815Yo8GGXUW4d_-
lF6Jcv/view?usp=drive_link).

4
she was filing the police report.32 She did so imply and mention.33 But the statements under oath
by J. Brent that M. McMaster made the letter allegation are also false.

On November 20, 2023, the day before J. Brent filed the Nov.-21 CDP report, J. Brent
filed an earlier CDP report (case no. 2023-00351508) against E. Forhan at the Third District
office with CDP Officer Delvonte Scott, in the company of M. McMaster.34 That report includes
no mention of any allegation like that E. Forhan left a letter on J. Brent’s property.35

M. McMaster testified under oath at her own deposition on March 26, 2024, that M.
McMaster did not know about the letter allegation until the next day, November 21, 2023.36 M.
McMaster also testified that, even though she was present at the time of the filing the Nov.-20
CDP report, M. McMaster did not know what was included in the statement that J. Brent gave to
Officer Scott in connection therewith.37

M. McMaster also testified under oath at trial that she believed that J. Brent made the
letter allegation in a police report.38

M. McMaster never made the letter allegation.39 J. Brent lied about that too.

e. The false statements made, under oath, by J. Brent could have affected the
course or outcome of the CSPO case.

In a CSPO case, whether the respondent visited the petitioner’s home, before or after the
filing of the petition, or left a letter for the petitioner would be important, even critical, facts for
the court to determine the outcome of the case.

E. Forhan did not go to J. Brent’s home on November 20, 2023, or at any time about
then, and never left a letter, envelope, package or anything like that on J. Brent’s property or
anywhere else. Yet J. Brent filed a false police report alleging that he did.40 The false statements
could have affected the course or outcome of the CSPO case.

32
See Trial transcript at p. 91.
33
See, e.g., CDP video at 18:54:03-06 (“There was an envelope left.”),
34
See the report, filed November 20, 2023, in case no. 2023-00351508, by J. Brent with the CDP (copy available at
https://drive.google.com/file/d/1BJ9I0h9618C_QbH5F8pb0NEJtlBDRPU3/view?usp=drive_link).
35
See Nov.-20 CDP report.
36
See Transcript of the Testimony of Mallory McMaster, dated March 26, 2024, at p. 40 (“[Re ‘When did you first
hear about E. Forhan dropping off a letter at J. Brent’s house?’:] When [D.] Brock told me [that he and J. Brent]
were at the police station filing a report.”) (copy available at
https://drive.google.com/file/d/1ezV3djlY8WoVOx8kCc2BG0TxSZ4x6aP1/view?usp=drive_link).
37
See McMaster deposition transcript at p. 32 (“I was on the other side of the room, and I don’t know what was
included. . . . [J. Brent] wrote part of the statement, and the officer was asking her questions.”).
38
See Trial transcript at p. 186 (“[Re ‘Whom did J. Brent tell that E. Forhan left something at her house?’] I believe
she discussed that in a police report.”).
39
On June 15, 2024, E. Forhan submitted on the Cleveland Public Records Center website a request (ref. no.
P012619-061524) to obtain any and all audio and video records that capture the making of the Nov.-20 CDP report.
On the same date, E. Forhan sent to Sergeant John Ball (badge no. 9190) with the CDP mobile-support unit an email
notifying Sgt. Ball of the submission that day by E. Forhan of the public-records request. E. Forhan has yet to
receive a response to his records request.
40
See Nov.-21 CDP report at p. 5.

5
 Also, facts that affect the credibility of a party to a court case can and do affect the course
and outcome of the case.

The statements by J. Brent to Sergeant Wells suggesting that E. Forhan left a letter on her
property were false. If J. Brent had testified and attested truthfully that she had made the letter
allegation to the police, then she would have had to admit to the court that she filed a false police
report against E. Forhan. That admission would have damaged her credibility before the court
and hurt her chances of winning the CSPO case. To avoid suffering the damage to her credibility,
she lied under oath.

B. Brent perjured herself re the video-surveillance allegation.

E. Forhan did not go to J. Brent’s home on November 20, 2023, or at any time about then.
J. Brent cannot have video of E. Forhan doing that because he did not do that.

On November 21, 2023, J. Brent alleged falsely to the CDP that she had video surveillance
that showed E. Forhan approaching her home the previous day, on November 20, 2023.41

Again, E. Forhan did not go to J. Brent’s home on November 20, 2023, or at any time about
then. No video could exist of him doing that. J. Brent did not even allege in her case in chief at
trial on April 5, 2024, in the CSPO case that E. Forhan went to her home then.42 The statement by
J. Brent in the Nov.-21 CDP report that she had video of him doing so was false.43

a. Attestations in written discovery responses in the CSPO case

Despite the impossibility of the existence of any such video, J. Brent attested falsely under
oath on February 20, 2024, or, as applicable, February 28, 2024, in responses or, as applicable,
supplemental responses to written discovery requests in the CSPO case the following:

1. “[Re ‘Admit that you do not have any video surveillance that shows E. Forhan
approaching your home on or about November 20, 2023’:] [D]enied.”44
2. “[Re ‘With respect to the “video surveillance” alleged in the Nov.-21 CDP report,
describe how you viewed the video surveillance and how you learned of the existence
of the video surveillance:] [J. Brent] became aware that [E. Forhan] was in video
surveillance from her home after she was informed by her cousin . . . that [E. Forhan]
had been at [J. Brent’s] home. [J. Brent] viewed the video on her computer.”45
3. “[J. Brent] became aware of video surveillance of a vehicle driven by [E. Forhan]
passing slowly by her home on November 20, 2023 when a member of her security

41
See Id. (“[O]n November 20, 2023, [J. Brent] states that she has video surveillance that shows [E. Forhan]
approaching her home.”); Petitioner J. Brent’s Responses to Respondent E. Forhan’s First Set of Requests For
Admission, dated February 20, 2023, at p. 2 (admitting that, in connection with the filing of the Nov.-21 CDP report,
J. Brent told law enforcement that she had video of E. Forhan approaching her home on November 20, 2023) (copy
available at https://drive.google.com/file/d/1L53Ea2OSCSdrIqv0ZTfkj6dI6wTG-GgG/view?usp=drive_link).
42
See Trial transcript at pp. 13-201.
43
See, e.g., Mar.-28 CDP report by E. Forhan against J. Brent for filing the false Nov.-21 CDP report.
44
RFA responses at p. 2.
45
Interrogatory responses at p. 2.

6
 detail informed her of that occurrence. . . . [J. Brent] viewed the video on her home
computer.”46
4. “[Re ‘Produce a copy of the “video surveillance” that you alleged in the Nov.-21
CDP report that you have that shows E. Forhan approaching your home on November
20, 2023’’:] [N]one.”47

b. Testimony at trial in the CSPO case

Despite the attestations under oath by J. Brent that she viewed video showing E. Forhan
coming to her home on November 20, 2023, J. Brent testified under oath at trial on April 5, 2024,
in the CSPO case the following:

1. “I never said that I saw you stop by my house, just it was secondhand information.”48
2. “[Re ‘Did you ever allege that I drove by your house at 9:15 a.m. on the 21st of
November?’:] [T]he only thing I put out there was what the security team told me.”49

c. The false statements made, under oath, by J. Brent could have affected the
course or outcome of the CSPO case.

In a CSPO case, if the respondent visited the petitioner’s home again, after the filing of
the CSPO petition, would be an important, even critical, fact for the court to determine the
outcome of the case.

E. Forhan did not go to J. Brent’s home on November 20, 2023, or at any time about
then. Yet J. Brent filed a false police report alleging that he did.50 She also attested under oath
falsely that she had, and had viewed, video that captured E. Forhan doing that.51 She then
testified under oath falsely that she never said that she saw him stop by her house.52 The false
statements could have affected the course or outcome of the CSPO case.

46
Petitioner J. Brent’s Second Supplemental Answers to Respondent’s Discovery Requests, dated February 28,
2024, at pp. 1-2 (omitting page number) (copy available at https://drive.google.com/file/d/1TRE4-
M6QRwMa5LZn525-8Cw1N7IfSFe9/view?usp=drive_link).
47
Petitioner J. Brent’s Supplemental Answers to Respondent’s Discovery Requests, dated February 28, 2024, at p. 2
(copy available at
https://drive.google.com/file/d/1ygpMbVTZYOBzbj7MqK7iHO5uN_1P2u0d/view?usp=drive_link).
48
Trial transcript at p. 112.
49
Id.
50
See Nov.-21 CDP report; see also Mar.-28 CDP report by E. Forhan against J. Brent for filing the false Nov.-21
CDP report.
51
See RFA responses at p. 2 (denying that J. Brent does not have any video surveillance that shows Respondent
approaching her home on or about November 20, 2023); Interrogatory responses at p. 2 (suggesting that J. Brent
viewed video that recorded E. Forhan at her home on November 20, 2023); Supplemental (2nd) discovery answers
at pp. 1-2 (suggesting that J. Brent viewed video that recorded E. Forhan at her home on November 20, 2023).
52
See Trial transcript at p. 112 (“I never said that I saw you stop by my house.”).

7
 C. Brent perjured herself re the Munira interaction.

On November 15, 2023, E. Forhan and Munira A. had a conversation in Hearing Room
121 in the Ohio Statehouse in downtown Columbus. J. Brent witnessed from the hallway a couple
of seconds of the conversation.53

According to video captured by a Statehouse security camera in the hallway outside of

Room 121, after J. Brent stopped looking into the room from the hallway, she walked down the
hallway and sat on a bench at the end of the hallway.54 She remained seated for approximately one
and one-half minutes.55 Then, Munira A. exited Room 121 and walked down the hallway in the
direction toward where J. Brent was seated.56 As Munira A. walked by J. Brent, J. Brent rose,
reached out and grasped Munira A.’s arm.57 Munira A. and J. Brent talked to each other for less
than one minute.58 Then A. DiPalma appeared and embraced Munira A.59 The three of them
conversed together for more than two minutes.60

J. Brent later included in the CSPO petition certain allegations against E. Forhan regarding
the Munira-Forhan conversation.61

a. Testimony at trial in the CSPO case

J. Brent testified truthfully under oath at trial on April 5, 2024, in the CSPO case re the
Munira interaction the following:

1. “[Re ‘For how long did you view the conversation between Munira A. and E.
Forhan?’:] [A] couple seconds.”62

b. Testimony at deposition in the CSPO case

Despite what the Statehouse hallway video shows, J. Brent testified falsely under oath at
deposition on March 1, 2024, in the CSPO case re the Munira interaction the following:

1. “[Re ‘Did you talk with Munira A.?’:] She wasn’t talking.”63
2. “[Re ‘Munira A. wasn’t talking at all?’:] No. She was crying very hard.”64

53
See video, dated November 15, 2023, by the Capitol Square Review and Advisory Board, at 12:55:05-07
(according to the timestamp in the bottom-center of the frame of the video) (copy available at
https://drive.google.com/file/d/1LqrQIRNNPqLTLeNs9ofs6hc7g4JjBQ6x/view?usp=drive_link); Trial transcript at
p. 100 (“[I]t was a couple seconds.”).
54
See Statehouse hallway video at 12:55:08-44.
55
See Id. at 12:55:44-57:13.
56
See Id. at 12:57:13-17.
57
See Id. at 12:57:17-19.
58
See Id. at 12:57:19-58:04.
59
See Id. at 12:58:04-06.
60
See Id. at 12:58:06-01:00:15.
61
See CSPO petition at p. 3.
62
Trial transcript at p. 100.
63
Brent deposition transcript at p. 56.
64
Id.

8
 3. “[Re ‘Didn’t A. DiPalma interact with you then?’:] No.”65
4. “[Re ‘A. DiPalma and Munira A. did not hug each other?’:] The only person that was
hugging [Munira A.] at that time was me. She . . . wasn’t talking.”66
5. “[Re ‘After Munira A. exited Room 121, did you interact with her?’:] [Munira A.] ran
out of the room, and she came and embraced me.”67
6. “[Re ‘Could you have looked into Room 121 for more than a minute?’:] I didn’t
count.”68
7. “[Re ‘Could it have been more than 10 minutes?’:] I didn’t count.”69
8. “[Re ‘Could it have been more than an hour and one minute?’:] I was not counting.”70

c. Attestations in written discovery responses in the CSPO case

J. Brent attested falsely under oath on February 20, 2024, in responses to written discovery
requests in the CSPO case re the Munira interaction the following:

1. “When [J. Brent] returned to [Room 121], Representative Abdullahi ran . . . into [J.
Brent’s] arms.”71
2. “[Re ‘Admit that you never entered with all your body Statehouse Hearing Room 121
during the Munira-Forhan conversation’:] Denied.”72
3. “[Re ‘Admit that you saw no more than ten seconds of the Munira-Forhan
conversation’:] Denied.”73
4. “[Re ‘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-Forhan
conversation’:] Denied.”74

d. The false statements made, under oath, by J. Brent could have affected the
course or outcome of the CSPO case.

Facts that affect the impression held by a court of a party to a case before the court can
and do affect the course and outcome of the case.

J. Brent misrepresented, under oath, the events of November 15, 2023. She exaggerated
falsely to the court the role that she played in them. She also described falsely to the court the
distress shown by Munira A.

65
Id.
66
Id.
67
Id. at p. 56.
68
Id. at p. 53.
69
Id.
70
Id. at p. 54.
71
Interrogatory responses at p. 6.
72
RFA responses at p. 11.
73
Id. at p. 10.
74
Id. at p. 11.

9
 J. Brent only witnessed the Munira-Forhan conversation for a couple of seconds.75 She
ultimately admitted that fact under oath at trial.76 Yet she suggested under oath, falsely, that she
witnessed more, even much more, than that.77 She stuck her head into Room 121; she never
entered the room with her whole body.78 Yet she denied that fact under oath, falsely.79

After Munira A. exited Room 121, Munira A. walked down the hallway and by J. Brent,
who was seated, and J. Brent rose and grasped Munira A.’s arm.80 Munira A. did not “r[u]n . . .
into [J. Brent’s] arms,” as J. Brent attested under oath, falsely.81

Then, J. Brent and Munira A. talked to each other.82 The testimony under oath by J. Brent
that Munira A. did not talk is false.83 Then, A. DiPalma joined the conversation.84 He and
Munira A. embraced each other immediately in front of J. Brent.85 The testimony under oath by
J. Brent that A. DiPalma did not interact with them then and that he and Munira A. did not
embrace each other is false.86 J. Brent must know that it’s false because A. DiPalma and Munira
A. embraced right in front of J. Brent, and all three of them conversed with one another for more
than two minutes.87

J. Brent, by testifying and attesting falsely about these events as she did, portrayed (1)
Munira A. as more distressed than she was, (2) A. DiPalma as absent from the scene, which he
was not, and (3) herself as more involved than she was. J. Brent misrepresented, under oath,
these events to try to portray herself to the court as more important and heroic than the truth
might otherwise suggest. Also, by misrepresenting Munira A. as more distressed than she was, J.
Brent tried to portray E. Forhan to the court as a villain. Public statements by Munira A. also
show the falsity of J. Brent’s statements.88

J. Brent included in the CSPO petition a description this event and relied on it in asking
the court to grant to her a CSPO against E. Forhan. These falsehoods tended to improve J.
Brent’s chances of winning the CSPO case. They could have affected the course or outcome of
the case.

75
See Statehouse hallway video at 12:55:05-07; Trial transcript at p. 100 (“[I]t was a couple seconds.”).
76
See Trial transcript at p. 100.
77
See RFA responses at pp. 10-11 (denying that the amount of time was less than 10 seconds); Brent Deposition
Transcript at p. 54 (declining to answer if the amount of time could have exceeded one hour and one minute).
78
See Statehouse hallway video at 12:55:05-07.
79
See RFA responses at p. 11.
80
See Statehouse hallway video at 12:57:13-19.
81
See Interrogatory responses at p. 6; see also Brent deposition transcript at p. 56 (“[Munira A.] ran out of the room,
and she came and embraced me.”).
82
See Statehouse hallway video at 12:57:19-01:00:15.
83
See Brent deposition transcript at p. 56 (denying that Munira A. was talking “at all”).
84
See Statehouse hallway video at 12:58:04-06.
85
See Id.
86
See Brent deposition transcript at p. 56.
87
See Statehouse hallway video at 12:58:04-01:00:15.
88
See, e.g., post, dated November 15, 2023, by Munira A. to her Twitter account (available at
https://x.com/muniraforohio/status/1725333642598060191) (stating that she was “angry,” not afraid).

10
 D. Brent perjured herself re telling E. Forhan not to contact her.

J. Brent never told E. Forhan not to contact her.89

a. Testimony at trial in the CSPO case

Even though J. Brent never told E. Forhan not to contact her, she testified under oath at
trial on April 5, 2024, in the CSPO case the following:

1. “[Re ‘Did you ever instruct E. Forhan about contacting you?’:] I just told him when I
saw him in person, I don’t want to be around you.”90
2. “[E. Forhan] didn’t seem like he could read body language. If someone moves away
from me, I’m not gonna try to sit next to them next time, I’m just gonna leave you
alone. He doesn’t seem like he can read body language.”91
3. “[S]aying no doesn’t always particularly mean with words, but also with actions.”92

b. Testimony at deposition in the CSPO case

J. Brent testified under oath at deposition on March 1, 2024, in the CSPO case the
following:

1. “[Re ‘Identify when you told E. Forhan not to contact you’:] There were multiple
times.”93
2. “[Re ‘Identify when you told E. Forhan not to contact you’:] I don’t have a specific
date.”94
3. “[Re ‘How did you tell E. Forhan to not contact you?’:] I told [E. Forhan] in-person.”95

c. Attestations in written discovery responses in the CSPO case

J. Brent attested under oath on February 20, 2024, in responses to written discovery
requests in the CSPO case the following:

1. “[Re ‘Admit that you never told E. Forhan not to contact you.’:] Denied.”96

J. Brent also omitted, in attesting under oath on February 20, 2024, to identify any
communication in which she told E. Forhan that she did not want to hear from him.97 She so

89
E. Forhan will testify under oath that J. Brent never told him not to contact her.
90
Trial transcript at p. 44.
91
Id. at p. 27.
92
Id.
93
Brent deposition transcript at p. 110.
94
Id.
95
Id.
96
RFA responses at p. 4.
97
See Interrogatory responses at pp. 1-2 (omitting, in answering Interrogatory No. 1, to identify any communication
in which she told E. Forhan that she did not want to hear from him); see also Respondent E. Forhan’s First Set of
Interrogatories Propounded on Petitioner J. Brent, dated February 5, 2024, at p. 2 (defining the term

11
omitted in answering an interrogatory that asked her to identify, among other things, each
communication in which she told E. Forhan that she did not want to hear from him.98 She omitted
to so identify.99

d. Attestations in the CSPO petition

J. Brent attested under oath on November 20, 2023, in the CSPO petition the following:

1. “[I told E. Forhan] emphatically that I do not want to hear from him.”100

e. The false statements made, under oath, by J. Brent could have affected the
course or outcome of the CSPO case.

In a CSPO case, whether the petitioner did or did not tell the respondent not to contact
them is an important, even critical, fact for the court to determine the outcome of the case.

During the discovery phase of the CSPO case, E. Forhan asked J. Brent to disclose details
re when she allegedly asked him not to contact her. Each time, she answered falsely, evaded the
question or answered incompletely.101 Ultimately, she changed her story on the stand: she stated
and implied that she had communicated to E. Forhan that message nonverbally.102

J. Brent never told E. Forhan not to contact her.103 Yet she testified and attested under
oath falsely multiple times that she did.104 The false statements could have affected the course or
outcome of the CSPO case.

E. Brent perjured herself re the Sep.-2023 Stonewall event.

On September 10, 2023, E. Forhan and his parents attended an event at a bar in Lakewood
organized by the Cleveland Stonewall Democrats organization. During the event program, the
organization gave an award to each of four honorees. One of the honorees was J. Brent, who

“communication” to include “oral conversations, whether such communication is face-to-face . . . or otherwise”)

(copy available at https://drive.google.com/file/d/1QvB7lp8ZTjIgr5hUB_9UOeb0oUbWYj_l/view?usp=drive_link).
98
Id.
99
Id.
100
CSPO petition at p. 4.
101
See, e.g., Interrogatory responses at pp. 1-2 (omitting to identify any communication in which J. Brent told E.
Forhan that she did not want to hear from him); Brent deposition transcript at p. 110 (“[Re ‘Identify when you told
E. Forhan not to contact you’:] I don’t have a specific date.”); see also Interrogatory set at p. 2 (defining the term
“communication” to include “oral conversations, whether such communication is face-to-face . . . or otherwise”).
102
See Trial transcript at pp. 27 (“He doesn’t seem like he can read body language. . . . [S]aying no doesn’t always
particularly mean with words, but also with actions.”), 44.
103
E. Forhan will testify under oath that J. Brent never told him not to contact her.
104
See Trial transcript at p. 44; Brent deposition transcript at p. 110; RFA responses at p. 4; CSPO petition at p. 4
(including stating that J. Brent told E. Forhan “emphatically” that she did not want to hear from him).

12
received the “Cleveland Stonewall Democrats Leadership Award.”105 The other honorees won the
“Stephanie Tubbs Jones Freedom Award” and the “Dave Ream Standing OUT Award.”106

After the event program ended, J. Brent approached the parents of E. Forhan, whom she
had met before at another event, and they chatted briefly.107 One, Linn Forhan, of the parents of E.
Forhan attested in a court document that the interaction was warm and affectionate.108 They and J.
Brent, together with E. Forhan, posed together for a photograph.109

a. Testimony at trial in the CSPO case

Even though J. Brent approached the parents of E. Forhan, J. Brent testified falsely under
oath at trial on April 5, 2024, in the CSPO case re the Stonewall event the following:

1. “[Re ‘Do you recognize the Sep.-10-event photograph?’:] It was a line of people who
were taking pictures with me, because I received the Democrat of the Year award. So
it was a processional line of people, and everybody that wanted a picture, I took a
picture with them.”110
2. “[T]here was a receiving line of people who were congratulating me . . . . [W]hen I
saw [the parents of E. Forhan] at the event, they came and they congratulated me on
it, and I . . . had very small-talk with them and they moved on their way, the next
person came.”111

b. Attestations in written discovery responses in the CSPO case

J. Brent attested falsely under oath on February 20, 2024, in responses to written discovery
requests in the CSPO case re the Stonewall event the following:

1. “[E. Forhan] and his parents were in a long line of people waiting to take photographs
with [J. Brent].”112

c. The false statements made, under oath, by J. Brent could have affected the
course or outcome of the CSPO case.

Evidence re the events of September 10, 2023, played an important role in resolving, as
the court did, the CSPO case in favor of E. Forhan. The court noted in its order that “[J. Brent]

105
See email, dated September 9, 2023, by Brooks Boron, at p. 3 (copy available at
https://drive.google.com/file/d/1PujyZ918UCCDp8mVav3Gbn0ELjyV-4p8/view?usp=drive_link).
106
See Boron email at p. 3.
107
See affidavit, dated April 9, 2024, by Linn Forhan (copy available at
https://drive.google.com/file/d/1D0xKlFGnFIgbqdrEAXeCvHLFMHQl0mUi/view?usp=drive_link). E. Forhan and
the parents of E. Forhan will testify under oath to the events of September 10, 2023.
108
See Linn Forhan affidavit.
109
E. Forhan and the parents of E. Forhan will testify under oath to the events of September 10, 2023.
110
Trial transcript at p. 82.
111
Id. at pp. 51-52 (omitting page number).
112
Interrogatory responses at p. 4.

13
was willing to smile and pose with [E. Forhan] and his family at a political event on September
10, 2023. . . . A picture can be worth a thousand words. Here, it is quite telling.”113

J. Brent misrepresented, under oath, these events. She minimized falsely to the court the
significance of them.

The parents of E. Forhan interacted with J. Brent at the Sep.-10 event because J. Brent
approached them.114 They did not, as J. Brent testified and attested under oath falsely, approach
J. Brent or stand in a line to congratulate her.115 Nor did E. Forhan stand in any such line, as J.
Brent attested under oath falsely.116 No such line existed for J. Brent at the Sep.-10 event. J.
Brent’s testimony and attestations about the existence of such a line are false.117

J. Brent, by testifying and attesting falsely about these events as she did, portrayed the
interaction between herself and the parents of E. Forhan as empty of any meaning. J. Brent made
false statements, under oath, about these events to try to minimize their significance.

These falsehoods tended to improve J. Brent’s chances of winning the CSPO case. They
could have affected the course or outcome of the case.

F. Brent perjured herself re the involvement in the CSPO case of M. McMaster.

M. McMaster helped J. Brent complete and file the CSPO petition.118 M. McMaster spent
the day of November 20, 2023, with J. Brent, helping J. Brent complete the CSPO petition.119 The
help by M. McMaster included producing for and delivering to J. Brent for inclusion in the CSPO
petition a transcription of a video.120 J. Brent included in the CSPO petition the video transcription
by McMaster.121 J. Brent also appears to have included in the CSPO petition at least one other
passage produced and delivered to her by M. McMaster.122

113
Order at p. 4.
114
See Linn Forhan affidavit.
115
See Trial transcript at pp. 51-52 (describing a “receiving line” for J. Brent and stating that the parents of E.
Forhan “came and congratulated” her), 82 (describing a “processional line” for J. Brent); Interrogatory responses at
p. 4 (stating that E. Forhan and his parents were in a “long line of people waiting to take photographs with” J.
Brent).
116
See Interrogatory responses at p. 4.
117
E. Forhan and the parents of E. Forhan will testify under oath to the events of September 10, 2023.
118
See McMaster deposition transcript at pp. 29-31.
119
See Id. at pp. 30 (“[T]hroughout the day, I helped Juanita fill out the application for the protection order. . . . I’d .
. . help her figure out which box to fill out.”), 84 (“[Re ‘Did you transcribe the video so that J. Brent would include
that transcript in the petition?’:] She asked me to do that for her. . . . I’m good at those tasks, so I offered to help.”).
120
See Id. at p. 84 (stating that J. Brent asked M. McMaster to transcribe a video for her and that M. McMaster
offered to do it).
121
CSPO petition at p. 4 (including as paragraph 6 the video transcript produced by M. McMaster).
122
See document production by Petitioner J. Brent in the CSPO case at p. 50 (displaying a screenshot of a text
message, dated November 20, 2023, by M. McMaster to J. Brent that is verbatim part of paragraph 8 of the CSPO
petition) (copy available at
https://drive.google.com/file/d/1GAyt5puvuwvXxw4YfBzkEyW5xLAZcnAH/view?usp=drive_link).

14
 On that day, in the afternoon, M. McMaster accompanied J. Brent to the Justice Center.123
There J. Brent filed, in the company of M. McMaster, the CSPO petition.124 Then they traveled
together to the Third District office of the CDP.125 There J. Brent filed, in the company of M.
McMaster, the Nov.-20 CDP report.126

The evening of the day before, November 19, 2023, J. Brent and M. McMaster had spoken
by phone about filing the CSPO petition.127 M. McMaster also arranged a security detail that J.
Brent used starting on November 20, 2023.128

At trial, J. Brent called M. McMaster as a witness and relied on her testimony in support
of her case in chief.129

a. Testimony at deposition in the CSPO case

Even though M. McMaster helped J. Brent complete and file the CSPO petition, J. Brent
testified falsely under oath at deposition on March 1, 2024, in the CSPO case the following:

1. “[Re ‘How was M. McMaster involved with any of the allegations in the CSPO
petition?’:] None of it.”130
2. “[M. McMaster is] not directly involved with the [CSPO] case.”131

b. Attestations in written discovery responses in the CSPO case

J. Brent attested faselely under oath on February 20, 2024, in responses to written discovery
requests in the CSPO case the following:

1. “No one provided any input with respect to the contents of the [CSPO] [p]etition.”132

c. The false statements made, under oath, by J. Brent could have affected the
course or outcome of the CSPO case.

Evidence re M. McMaster played a role in resolving, as the court did, the CSPO case in
favor of E. Forhan. As the court wrote in its order, “[T]he most disturbing thing that happened in
the entire case was [done] by Ms. McMaster, when she testified, in open court, under oath, that

123
See McMaster deposition transcript (“[A]t about 3:30, we were finally ready to go downtown. . . . It was after 5
by the time we were done.”).
124
See Id.
125
See Id. (“We went straight from [filing] the petition to the Third District . . . to file a police report.”).
126
See Id.
127
See Id. at p. 29 (“We had a conversation late one night. The following day . . . we talked early in the morning . . .
and she said, ‘I'm ready to do it. I want to do it today.’”).
128
See Id. at p. 30 (“I arranged for security.”).
129
See Trial transcript at pp. 164-73.
130
Brent deposition transcript at p. 103.
131
Id.
132
Interrogatory responses at p. 10.

15
she wanted to ‘shoot’ Mr. Forhan.”133 The reason that M. McMaster so testified at trial is that she
had testified similarly at her deposition.134

M. McMaster also provided to E. Forhan in the CSPO case other valuable testimony at
her deposition and materials and information via the production by her of certain documents.135
These documents included materials that showed a lack of candor by J. Brent with the court.136

M. McMaster helped J. Brent complete the CSPO petition.137 The help by McMaster
included producing for and delivering to J. Brent for inclusion in the CSPO petition a
transcription of a video.138 J. Brent included in the CSPO petition the video transcription by
McMaster.139 J. Brent also appears to have included in the CSPO petition at least one other
passage produced and delivered to her by M. McMaster.140

The testimony or, as applicable, attestation by J. Brent under oath that (1) M. McMaster
involved with none of the allegations in the CSPO petition, (2) M. McMaster was not directly
involved with the CSPO case and (3) no one provided any input with respect to the contents of
the Petition was, in each case, false.141

J. Brent testified and attested under oath falsely re M. McMaster to conceal the
involvement in the CSPO case of M. McMaster. The connection by E. Forhan of M. McMaster
to the CSPO case, and the resulting testimony and production of documents by M. McMaster,
damaged J. Brent’s chances of winning the case. J. Brent tried to conceal M. McMaster’s
involvement to avoid that damage.

These falsehoods tended to improve J. Brent’s chances of winning the CSPO case. They
could have affected the course or outcome of the case.

G. Brent perjured herself re requests by the CDP.

According to an email sent on or before January 2, 2024, by a communications strategist

for the City of Cleveland to a Cleveland.com reporter, CDP officers “asked for but ultimately never

133
See Order at p. 7.
134
See Trial transcript at p. 183 (“[Re ‘Did you tell E. Forhan that you wanted an excuse to shoot him?’:] I did.”);
McMaster deposition transcript at pp. 75 (“I wanted an excuse to shoot [E. Forhan].”).
135
See, generally, McMaster deposition transcript; Respondent’s Motion to Compel, filed on March 27, 2024, by E.
Forhan at pp. 11-17 (copy available at
https://drive.google.com/file/d/1IHEhPWfJ874LosKhXt5DbPrUWXp5ZJBK/view?usp=drive_link).
136
See Respondent’s motion to compel at pp. 11-17; see also Journal Entry, filed on April 4, 2024, by the court,
granting Respondent’s motion to compel (copy available at
https://drive.google.com/file/d/1IHEhPWfJ874LosKhXt5DbPrUWXp5ZJBK/view?usp=drive_link).
137
See McMaster deposition transcript at pp. 30 (stating that M. McMaster helped J. Brent complete the CSPO
petition throughout the day of November 20, 2023), 84 (suggesting that J. Brent asked M. McMaster to transcribe a
video and that M. McMaster offered to do so).
138
Id. at p. 84 (suggesting that J. Brent asked M. McMaster to transcribe a video and that M. McMaster offered to do
so).
139
CSPO petition at p. 4 (including as paragraph 6 the video transcript produced by M. McMaster).
140
See Brent document production at p. 50 (including a screenshot of a text message, dated November 20, 2023, by
M. McMaster to J. Brent that is verbatim part of paragraph 8 of the CSPO petition).
141
See Brent deposition transcript at p. 103; Interrogatory responses at p. 10.

16
received” a copy of each of the letter and the video alleged falsely in the Nov.-21 CDP report by
J. Brent.142 “Despite not receiving copies, detectives utilized other methods to investigate the
case.”143

a. Attestations in written discovery responses in the CSPO case

Even though CDP officers asked J. Brent for copies of the video and letter that she alleged
existed, J. Brent attested under oath on February 20, 2024, in responses to written discovery
requests in the CSPO case the following:

1. “[Re ‘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’:] [J. Brent] is not aware of any request that she
produce anything in relation to the police reports.”144
2. “[Re ‘Admit that, in connection with the filing of the Nov.-21 CDP report, law
enforcement asked you to produce the video surveillance that showed E. Forhan
approaching your home on November 20, 2023, or a copy thereof’:] Denied.”145
3. “[Re ‘Admit that, in connection with the filing of the Nov.-21 CDP report, law
enforcement asked you to produce the letter that E. Forhan left on your property or a
copy thereof’:] Denied.”146
4. “[Re ‘Admit that, in connection with the filing of the Nov.-20 and Nov.-21 CDP
reports, despite not receiving from you any responsive records, law enforcement
investigated’:] Denied.”147

b. The false statements made, under oath, by J. Brent could have affected the
course or outcome of the CSPO case.

Facts that affect the credibility of a party to a court case can and do affect the course and
outcome of the case.

The allegations by J. Brent in the Nov.-21 CDP report that she had video surveillance that
showed E. Forhan approaching her home on November 20, 2023, and that E. Forhan left a letter
for J. Brent on her property were false. J. Brent did not deliver to the CDP officers, as they
requested, a copy of either the video or letter because no video or letter ever existed. They never
existed because E. Forhan did not visit J. Brent’s home on November 20, 2023, or anytime about
that date and never left her a letter or anything like that.

142
See email, dated on or before January 2, 2024, by Tyler Sinclair to Andrew Tobias (copy available at
https://drive.google.com/file/d/1CAbErgKO-2hctx_1agDU9dSiRaZ0Sno1/view?usp=drive_link); see also Nov.-21
CDP report at p. 5 (stating that J. Brent told the CDP that she had video that showed E. Forhan approaching her
home on November 20, 2023, and that E. Forhan left a letter for J. Brent on her property).
143
See Sinclair email.
144
Interrogatory responses at p. 3.
145
RFA responses at p. 3.
146
Id.
147
Id. at p. 4.

17
 If J. Brent had attested truthfully that the CDP asked her to substantiate the allegations
she made in the Nov.-21 CDP report and that she did not do so, then would have had to admit to
the court that she filed a false police report against E. Forhan. That admission would have
damaged her credibility before the court and hurt her chances of winning the CSPO case. To
avoid suffering the damage to her credibility, she lied under oath.

H. Brent perjured herself re the scope of contacts between Forhan and Brent.

The last time E. Forhan called J. Brent was on September 18, 2023.148 Since May 23, 2023,
except for a week-long period in September 2023 when E. Forhan was trying to organize a group
letter, E. Forhan has called J. Brent no more than three times total.149 Except for that week in
September 2023, E. Forhan has sent to J. Brent a text message no more than four times, ever.150

Each communication by E. Forhan to J. Brent 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.151 E. Forhan never tried to entice anyone to
contact J. Brent on his behalf.152

a. Attestations in written discovery responses in the CSPO case

Even though the contacts between E. Forhan and J. Brent were minimal and only work-
related, J. Brent attested falsely under oath on February 20, 2024, or, as applicable, on November
20, 2023, in responses to written discovery requests in the CSPO case or, as applicable, in the
CSPO petition the following:

1. “Since the initial . . . interactions, Mr. Forhan has continued to contact me via text
and phone call - despite me telling him emphatically that I do not want to hear from
him. These contacts have been happening outside of our working relationship.”153
2. “Mr. Forhan has tried to entice others to contact me on his behalf. He contacted
several people.”154
3. “[Re ‘Admit that, except for the week-long period in September when E. Forhan was
trying to organize a group letter, E. Forhan has sent to you a text message no more
than four times, ever.’:] Denied.”155

148
See records of all phone calls, since May 21, 2023, between J. Brent and E. Forhan (copy available at
https://drive.google.com/file/d/1siuYde6Gk8_uYRPkBagjli8idxwMt67o/view?usp=drive_link). E. Forhan will
testify under oath to the authenticity and completeness of the records.
149
See Brent-Forhan phone records.
150
See all text messages, ever, between J. Brent and E. Forhan (copy available at
https://drive.google.com/file/d/1no-yXOj9omCoKlwp8kTN68tKca2WfOs9/view?usp=drive_link). E. Forhan will
testify under oath to their authenticity and completeness.
151
See Brent-Forhan text messages; all Signal messages, ever, between J. Brent and E. Forhan (copy available at
https://drive.google.com/file/d/1h6ufzU5FX5V0vlk67HUWDerVYYppW-ki/view?usp=drive_link). E. Forhan will
testify under oath to the authenticity and completeness of the Signal messages and to the scope of contacts between
him and J. Brent.
152
E. Forhan will testify under oath to the scope, including the absence of any such enticement, of contacts between
him and J. Brent.
153
CSPO petition at p. 4.
154
Id.
155
RFA responses at p. 5.

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 4. “[Re ‘Admit that each communication by E. Forhan 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.’:]
[D]enied.”156

b. The false statements made, under oath, by J. Brent could have affected the
course or outcome of the CSPO case.

In a CSPO case, the scope of contacts by the respondent of the petitioner is an important,
even critical, fact for the court to determine the outcome of the case.

The contacts between E. Forhan and J. Brent were minimal and only work-related.157 Yet
J. Brent attested under oath falsely multiple times that they were otherwise.158 The false
statements could have affected the course or outcome of the CSPO case.

I. Brent perjured herself re her ability to access Signal messages.

J. Brent can access her Signal-application messages. She served on E. Forhan in the CSPO
case a production of documents that included screenshots of Signal messages between her and
another person.159 She also testified under oath multiple times that she never deleted anything from
her phone.160

E. Forhan has not sent to J. Brent a Signal message since April 2023.161 E. Forhan has sent
to J. Brent a Signal message no more than four times, ever.162

a. Attestations in written discovery responses in the CSPO case

Even though J. Brent showed that she could access her Signal messages, she attested under
oath on February 20, 2024, in responses to written discovery requests in the CSPO case the
following:

1. “[Re ‘Admit that E. Forhan has not sent to you a Signal message since April 2023.’:]
[J. Brent] does not have access to records that reflect [E. Forhan’s] Signal use. Thus,
denied for lack of knowledge.”163
2. “[Re ‘Admit that E. Forhan has sent to you a Signal message no more than four times,
ever.’:] [J. Brent] does not have access to records that reflect [E. Forhan’s] Signal use.
Thus, denied for lack of knowledge.”164

156
Id. at p. 7.
157
E. Forhan will testify under oath to the scope of contacts between him and J. Brent.
158
See CSPO petition at p. 4; RFA responses at pp. 5, 7.
159
See Brent document production at pp. 114-25.
160
See Trial transcript at pp. 126-27 (“I don’t delete anything. You can find stuff from the first time I ever had a
iPhone in my phone.”); Brent deposition transcript at pp. 30-31 (“Nothing’s been deleted off my phone.”).
161
See Brent-Forhan Signal messages.
162
Id.
163
RFA responses at p. 6.
164
Id.

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 b. The false statements made, under oath, by J. Brent could have affected the
course or outcome of the CSPO case.

In a CSPO case, the scope of contacts by the respondent of the petitioner is an important,
even critical, fact for the court to determine the outcome of the case.

The contacts between E. Forhan and J. Brent via the Signal application were minimal.165
J. Brent showed that she could access her Signal messages.166 Yet she attested falsely that she
could not access her Signal messages with E. Forhan.167 By doing so she prevented E. Forhan
from confirming the minimal scope of Signal contacts between them.

The false statements could have affected the course or outcome of the CSPO case.

J. Brent perjured herself re door-knocking.

J. Brent serves as an Ohio state representative and as the Executive Vice Chair of the
Cuyahoga County Democratic Party. In connection with those positions, she asks people on a
regular basis to do political canvassing, i.e. to “knock doors” and talk to voters.

On June 26, 2023, E. Forhan visited the home of J. Brent and knocked on her door. He
wanted to have a brief conversation with her. A family member of J. Brent answered the door and
told E. Forhan that J. Brent was not home, and he left.168

J. Brent included in the CSPO petition a description of the Jun.-2023 visit and claimed that
it terrified her.169

a. Attestation in written discovery responses in the CSPO case

Even though J. Brent asks people on a regular basis to knock doors, she attested under oath
on February 20, 2024, in responses to written discovery requests in the CSPO case the following:

1. “[Re ‘Admit that in connection with your service as an officer of the County Party
and as a state representative you ask people on a regular basis to knock doors’:]
[D]enied.”170

b. The false statement made, under oath, by J. Brent could have affected the
course or outcome of the CSPO case.

The context of allegations made in a court case can and does affect the course and
outcome of the case.

165
See Brent-Forhan Signal messages.
166
See Brent document production at pp. 114-25.
167
See RFA responses at p. 6 (denying that she has access to her Signal messages with E. Forhan).
168
See Order at p. 3 (“[E. Forhan] came over unannounced, knocked on a door and left after two minutes having
learned [J. Brent] was not at home.”).
169
See CSPO petition at p. 3.
170
RFA responses at p. 15.

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 J. Brent is familiar with knocking on people’s doors. She does it herself on a regular basis
in connection with political campaigns. A colleague knocking on her door one time and leaving
upon learning that she’s not home should not terrify her, as she claimed in the CSPO petition.
The addition of those contextual details damages J. Brent’s credibility and makes her less likely
to win the case.

J. Brent, because of the positions that she holds, even asks other people to knock doors,
also on a regular basis. Yet she attested falsely to the contrary.171 By doing so she prevented E.
Forhan from confirming a detail that formed a relevant part of the context of the allegations that
she made in the CSPO case.

The false statement could have affected the course or outcome of the CSPO case.

K. Brent perjured herself re the county Democratic party organization.

J. Brent serves as the Executive Vice Chair of the Cuyahoga County Democratic Party.
The Executive Vice Chair position is the second-highest-ranking officer position of the county-
party organization. The chair leads the organization. No vice-chair position exists other than the
Executive Vice Chair position, which J. Brent holds.172

E. Forhan serves as an Ohio state representative. He represents a House district located

within Cuyahoga County. He is a Democrat. He won his first election ever in 2022 and was at the
time serving his first term of office in any elected position.

The Cuyahoga County Democratic Party organization is the most important actor in
Democratic politics in Cuyahoga County. The support of the county party is, with respect to more
or less every Democratic candidate in Cuyahoga County—especially one who is new to politics
like E. Forhan is—extremely important for the prospects of future electoral success.

On June 26, 2023, E. Forhan visited the home of J. Brent and knocked on her door. He
wanted to discuss with her an issue that seemed to him to be affecting their working relationship.

J. Brent included in the CSPO petition a description of the Jun.-2023 visit by E. Forhan to
her home and relied on it in asking the court to grant to her a civil stalking protection order against
E. Forhan.173

a. Attestation in written discovery responses in the CSPO case

Even though the Executive Vice Chair position is the second-highest-ranking officer
position of the county-party organization, J. Brent attested under oath on February 20, 2024, in
responses to written discovery requests in the CSPO case the following:

171
See Id.
172
See the webpage, titled “Leadership,” on the website of the county party (available at
https://cuydem.com/leadership/).
173
See CSPO petition at p. 3.

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 1. “[Re ‘Admit that the Executive Vice Chair position is the second-highest-ranking
officer position of the Cuyahoga County Democratic Party.’:] [D]enied.”174

b. The false statement made, under oath, by J. Brent could have affected the
course or outcome of the CSPO case.

The context of allegations made in a court case can and does affect the course and
outcome of the case.

E. Forhan perceived in June 2023 that something was wrong with the working
relationship between him and J. Brent. That was a problem for him because J. Brent is influential
within the county Democratic party organization, the most important actor in Democratic politics
in Cuyahoga County. She even holds an important officer position in the organization.

A problem with J. Brent could result in difficulty in retaining the support of the county
party in a future election cycle and, as a result, difficulty in obtaining re-election. That’s why E.
Forhan visited on June 26, 2023, her home and knocked on her door. He wanted to identify and
repair whatever issue might be affecting their working relationship.

J. Brent serves as the second-highest-ranking officer of the county party. Yet she attested
falsely to the contrary.175 By doing so she prevented E. Forhan from confirming a detail that
formed a relevant part of the context of the allegations that she made in the CSPO case.

The false statement could have affected the course or outcome of the CSPO case.

II. CONTINUED SHOWINGS THAT J. BRENT IS REMORSELESS

On June 8, 2024, J. Brent published to her Twitter account a post, stating, “From court
cases . . . to Election Day shenanigans; there is no other person I rather get into ‘Good Trouble
With’ ‼ … Happy National Best Friend Day,” and tagged the Twitter account of M. McMaster.176
M. McMaster reposted approvingly J. Brent’s post.177

The documents produced by M. McMaster to E. Forhan in the CSPO case include a

screenshot of a text message, dated November 22, 2023, by M. McMaster stating, “[T]he judge is
desperate for the Dem Party endorsement this cycle so she’s going to be nice to [J. Brent].”178

J. Brent remains remorseless and unchecked. When she breaks the law, she expects no
consequences. Her best friend and witness even suggested that they could use their political power

174
RFA responses at p. 10.
175
See Id.
176
See post, timestamped 5:46 p.m. on June 8, 2024, by J. Brent to her Twitter account (available at
https://x.com/Juanita_Brent/status/1799558714346618982).
177
See post, timestamped 6:07 p.m. on June 8, 2024, by M. McMaster to her Twitter account (“Love you boo!”)
(available at https://x.com/MK_McMaster/status/1799563848829018225).
178
See text messages, dated November 22, 2023, by M. McMaster to Robert Cummings at p. 2 (copy available at
https://drive.google.com/file/d/1efLQWSPMMxprxNDTJY5Je-vwuotKjekE/view?usp=drive_link).

22
to influence the judge and control the outcome of the CSPO case. These actions should cause
everyone to feel concern about what they will do next.

23