Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
Court-wide- 1 copy
Motion, Supporting Brief, Opposing Brief
Court-wide- Upon Filing
Motion, Supporting Brief, Opposition Brief
Court-wide- Upon Filing
Proposed Instructions
Court-wideDocument Filing Requirements19 rules
The parties shall file and serve on all other parties, a preliminary list of witnesses and exhibits on or before the 11th day of May, 2012.
Each expert-witness designation must identify each expert and provide the specified testimony, facts, opinions, and grounds.
Court's wording
Such designation must include the name and business address of each expert witness. In addition, the designation must state the subject matter on which each designated expert is expected to testify, the substance of the facts and opinions of the expert and a summary of the grounds for each opinion.
Along with the designation, counsel for plaintiff must provide at least two dates that each expert is available to have his/her deposition taken within 30 days of the service of the expert designation.
An expert designation must identify the expert and provide the expected testimony, opinions, and grounds for each opinion.
Court's wording
include the name and business address of each expert witness. In addition, the designation must state the subject matter on which each designated expert is expected to testify, the substance of the facts and opinions of the expert and a summary of the grounds for each opinion.
Along with the designation, counsel for defendant(s) must provide at least two dates that each expert is available to have his/her deposition taken within 30 days of the service of the expert designation.
A treating physician must be designated as an expert if a party intends to elicit opinions about standard-of-care deviations, causation, or future events.
Court's wording
If any party wishes to call plaintiff’s treating physician(s) to render opinions regarding deviations from the standard of care, causation or future events (i.e. future medical treatment, future medical expenses, future disability, future pain and suffering, etc.,) such treating physician must be designated as an expert witness as provided in subparagraph A above.
Any such motion must recite with particularity, the communications or attempted communications aimed at resolving the discovery dispute prior to the filing of the motion, or it will not be considered. The Motion must also recite the date of the conference call above-referenced.
Such motion and any response thereto, must be in compliance with Kansas Supreme Court Rule 141, or it will not be considered.
Except for the listed motions, a motion must state counsel’s efforts to consult opposing counsel, the results, and whether opposing counsel agrees with the requested relief.
Court's wording
Any motion (other than a motion to dismiss, motion for judgment on the pleadings, motion for summary judgment or motion to compel) must contain a statement that counsel for the moving party has attempted to consult with opposing counsel, the result of those attempts, and whether or not opposing counsel agree(s) to the relief sought in the motion.
A moving party may provide a proposed journal entry only if all counsel of record sign it or the motion states that all counsel were consulted and agree to its relief.
Court's wording
The moving party shall not provide a proposed journal entry relating to the motion filed, unless the journal entry is signed by all counsel of record in the case, or, the motion recites specifically that all counsel of record have been consulted, and that they agree to the relief granted in the proposed journal entry.
The parties shall file and serve on all other parties, a preliminary list of witnesses and exhibits on or before the 3rd day of August, 2012.
Each expert designation must identify each expert and state the expected testimony, opinions, facts, and grounds for those opinions.
Court's wording
Such designation must include the name and business address of each expert witness. In addition, the designation must state the subject matter on which each designated expert is expected to testify, the substance of the facts and opinions of the expert and a summary of the grounds for each opinion.
Along with the designation, counsel for plaintiff must provide at least two dates that each expert is available to have his/her deposition taken within 30 days of the service of the expert designation.
Along with the designation, counsel for defendant(s) must provide at least two dates that each expert is available to have his/her deposition taken within 30 days of the service of the expert designation.
An expert designation must identify each expert and provide the expected subject matter, facts and opinions, and grounds for each opinion.
Court's wording
include the name and business address of each expert witness. In addition, the designation must state the subject matter on which each designated expert is expected to testify, the substance of the facts and opinions of the expert and a summary of the grounds for each opinion.
Such motion and any response thereto, must be in compliance with Kansas Supreme Court Rule 141, or it will not be considered.
Any motion (other than a motion to dismiss, motion for judgment on the pleadings, motion for summary judgment or motion to compel) must contain a statement that counsel for the moving party has attempted to consult with opposing
Any such motion must recite with particularity, the communications or attempted communications aimed at resolving the discovery dispute prior to the filing of the motion. The motion must also recite the date of the conference call above-referenced.
A moving party may provide a proposed journal entry only if all counsel of record sign it or the motion states that all counsel were consulted and agree to the relief.
Court's wording
E. The moving party shall not provide a proposed journal entry relating to the motion filed, unless the journal entry is signed by all counsel of record in the case, or, the motion recites specifically that all counsel of record have been consulted, and that they agree to the relief granted in the proposed journal entry.
Filing & Service rules
Filing Timing and Cure Windows
The preliminary witness and exhibit list must be filed by May 11, 2012.
The parties shall file and serve on all other parties, a preliminary list of witnesses and exhibits on or before the 11th day of May, 2012.
Civil cases
Page 1 | PRELIMINARY WITNESS AND EXHIBIT LIST
The defendant must file an expert-witness designation by April 10, 2012.
The defendant must file and serve on all other parties, a designation of expert witnesses on or before the 10th day of April, 2012.
Civil cases
Page 2 | EXPERT WITNESSES
The plaintiff must file an expert-witness designation by February 20, 2012.
The plaintiff must file and serve on all other parties, a designation of expert witnesses on or before the 20th day of February, 2012.
Civil cases
Page 2 | EXPERT WITNESSES
An objection to the form of an expert designation must be filed within 10 days of receipt or it is waived.
Any party who has an objection to the form of another party’s expert designation, must file such objection with the Court within ten (10) days of receipt of such expert designation. If the objection is not timely filed, it is waived.
Civil cases
Page 3 | EXPERT WITNESSES
A motion to compel discovery must be filed within 45 days of the relevant default, service of a response, answer, or objection, or it will not be considered.
Any motion to compel discovery must be filed within 45 days of the default, service of response, answer or objection that is the subject of the motion. If the motion is not filed within this time, the motion will not be considered.
Civil cases
Page 4 | MOTIONS
Motions to amend pleadings or join parties must be filed by April 24, 2012, and will not be granted after that date absent party agreement.
Any motions to amend the pleadings and/or join parties must be filed on or before the 24th day of April, 2012. Absent agreement of the parties, no such motions will be granted after this date.
Civil cases
Page 4 | MOTIONS TO AMEND
Dispositive motions must be filed by May 1, 2012.
Any dispositive motion must be filed no later than the 1st day of May, 2012.
Civil cases
Page 4 | MOTIONS
If no deadline is set by statute or Kansas Supreme Court Rule, a response to a motion is due 14 calendar days after service.
Other motions: If a motion is filed, and neither the Kansas Statutes, nor the Kansas Supreme Court Rules clearly set forth a deadline for a response to such motion, the deadline shall be 14 calendar days after service of the motion.
Civil cases
Page 5 | MOTIONS
The parties must file a preliminary witness and exhibit list by August 3, 2012.
The parties shall file and serve on all other parties, a preliminary list of witnesses and exhibits on or before the 3rd day of August, 2012.
Civil cases
Page 1 | PRELIMINARY WITNESS AND EXHIBIT LIST
The plaintiff must file an expert-witness designation by June 19, 2012.
The plaintiff must file and serve on all other parties, a designation of expert witnesses on or before the 19th day of June, 2012.
Civil cases
Page 2 | EXPERT WITNESSES
The defendants must file an expert-witness designation by August 3, 2012.
The defendants must file and serve on all other parties, a designation of expert witnesses on or before the 3rd day of August, 2012.
Civil cases
Page 2 | EXPERT WITNESSES
An objection to the form of an expert designation must be filed within 10 days of receipt or it is waived.
Any party who has an objection to the form of another party’s expert designation, must file such objection with the Court within ten (10) days of receipt of such expert designation. If the objection is not timely filed, it is waived.
Civil cases
Page 3 | EXPERT WITNESSES
Motions to amend the pleadings must be filed by May 4, 2012, and will not be granted after that date absent the parties’ agreement.
Any motions to amend the pleadings must be filed on or before the 4th day of May, 2012. Absent agreement of the parties, no such motions will be granted after this date.
Civil cases
Page 3 | MOTIONS TO AMEND
When no deadline is clearly provided by Kansas law or rules, a response to a motion is due 14 calendar days after service.
If a motion is filed, and neither the Kansas Statutes, nor the Kansas Supreme Court Rules clearly set forth a deadline for a response to such motion, the deadline shall be 14 calendar days after service of the motion.
Civil cases
Page 4 | MOTIONS
Dispositive motions must be filed by September 14, 2012.
Any dispositive motion must be filed no later than the 14th day of September, 2012.
Civil cases
Page 4 | MOTIONS
A motion to compel discovery must be filed within 45 days of the relevant default, service of response, answer, or objection, or it will not be considered.
Any motion to compel discovery must be filed within 45 days of the default, service of response, answer or objection that is the subject of the motion. If the motion is not filed within this time, the motion will not be considered.
Civil cases
Page 4 | MOTIONS
Service and Proof of Service Rules
The preliminary witness and exhibit list must be served on all other parties by May 11, 2012.
The parties shall file and serve on all other parties, a preliminary list of witnesses and exhibits on or before the 11th day of May, 2012.
Civil cases
Page 1 | PRELIMINARY WITNESS AND EXHIBIT LIST
Written discovery may not be served after May 11, 2012, unless the parties agree or the Court orders otherwise.
No written discovery may be served by any party after the 11th day of May, 2012, absent agreement of the parties or order of this Court.
Civil cases
Page 1 | DISCOVERY DEADLINE
The plaintiff must serve the expert-witness designation on all other parties by February 20, 2012.
The plaintiff must file and serve on all other parties, a designation of expert witnesses on or before the 20th day of February, 2012.
Civil cases
Page 2 | EXPERT WITNESSES
The defendant must serve the expert-witness designation on all other parties by April 10, 2012.
The defendant must file and serve on all other parties, a designation of expert witnesses on or before the 10th day of April, 2012.
Civil cases
Page 2 | EXPERT WITNESSES
After scheduling an oral-argument hearing, the party who requested it must send written notice to all other parties.
Such party must then send written notice of the hearing to all other parties.
Civil cases
Page 5 | MOTIONS
If defendants elect to conduct an independent medical examination, they must complete it and provide the report to counsel for all other parties by the expert-designation deadline.
If the defendants wish to conduct an independent medical examination, such examination must be completed, and a report provided to counsel for all other parties, on or before the date defendants’ expert witness designations are due.
Civil cases
Page 6 | INDEPENDENT MEDICAL EXAMINATION
The parties must serve the preliminary witness and exhibit list on all other parties by August 3, 2012.
The parties shall file and serve on all other parties, a preliminary list of witnesses and exhibits on or before the 3rd day of August, 2012.
Civil cases
Page 1 | PRELIMINARY WITNESS AND EXHIBIT LIST
Written discovery may not be served after August 3, 2012, unless the parties agree or the Court orders otherwise.
No written discovery may be served by any party after the 3rd day of August, 2012, absent agreement of the parties or order of this Court.
Civil cases
Page 1 | DISCOVERY DEADLINE
The defendants must serve the expert-witness designation on all other parties by August 3, 2012.
The defendants must file and serve on all other parties, a designation of expert witnesses on or before the 3rd day of August, 2012.
Civil cases
Page 2 | EXPERT WITNESSES
The plaintiff must serve the expert-witness designation on all other parties by June 19, 2012.
The plaintiff must file and serve on all other parties, a designation of expert witnesses on or before the 19th day of June, 2012.
Civil cases
Page 2 | EXPERT WITNESSES
After scheduling an oral-argument hearing, the party seeking it must send written notice to all other parties.
Such party must then send written notice of the hearing to all other parties.
Civil cases
Page 5 | MOTIONS
Pre-Motion Conference Requirements
Before filing a motion to compel discovery, moving counsel must contact the Court to schedule a conference call to discuss the issues with all parties' counsel.
Prior to filing the motion, counsel for the moving party must contact the Court to schedule a conference call so that the Court can discuss with counsel for all parties, the issues that will be addressed in the motion.
Civil cases
Page 4 | MOTIONS
Before filing a motion to compel discovery, moving counsel must contact the Court to schedule a conference call to discuss the motion’s issues with all parties’ counsel.
Prior to filing the motion, counsel for the moving party must contact the Court to schedule a conference call so that the Court can discuss with counsel for all parties, the issues that will be addressed in the motion.
Civil cases
Page 4 | MOTIONS
Adjournment & Extension Requirements
A motion to extend the deadline for amending pleadings or joining parties must be filed before the deadline.
Any motion to extend this deadline must be filed prior to this deadline.
Civil cases
Page 4 | MOTIONS TO AMEND
A motion to extend the deadline for amending pleadings must be filed before the existing deadline.
Any motion to extend this deadline must be filed prior to this deadline.
Civil cases
Page 3 | MOTIONS TO AMEND
Chambers Communication Rules
The parties must contact the Court to arrange a hearing on an objection to an expert designation.
The parties are mutually responsible for contacting the Court to set a hearing on the objection.
Civil cases
Page 3 | EXPERT WITNESSES
Moving counsel must contact the Court to arrange the required pre-filing conference call for a motion to compel discovery.
Prior to filing the motion, counsel for the moving party must contact the Court to schedule a conference call so that the Court can discuss with counsel for all parties, the issues that will be addressed in the motion.
Civil cases
Page 4 | MOTIONS
The parties must contact the Court to schedule a hearing on an objection to an expert designation.
The parties are mutually responsible for contacting the Court to set a hearing on the objection.
Civil cases
Page 3 | EXPERT WITNESSES
Moving counsel must contact the Court by conference call scheduling before filing a motion to compel discovery.
Prior to filing the motion, counsel for the moving party must contact the Court to schedule a conference call so that the Court can discuss with counsel for all parties, the issues that will be addressed in the motion.
Civil cases
Page 4 | MOTIONS
A party seeking oral argument on a filed motion must contact the Administrative Assistant for Division 3 to schedule the hearing.
G. Scheduling motions: Any party who desires a hearing for oral argument on any motion filed is responsible for contacting the Administrative Assistant for Division 3 to schedule such hearing.
Civil cases
Page 5 | MOTIONS
If the parties cannot agree on an expert’s deposition date within 30 days of service of the designation, counsel must contact the Court for a conference call to set it.
If for some reason, the parties cannot agree upon a date for the deposition of an expert witness within 30 days of the service of the expert designation, counsel must contact the Court for a conference call to set a deposition date for the expert witness.
Civil cases
Page 2 | EXPERT WITNESSES
A party seeking oral argument on a motion must contact the Division 3 Administrative Assistant to schedule the hearing.
Any party who desires a hearing for oral argument on any motion filed is responsible for contacting the Administrative Assistant for Division 3 to schedule such hearing.
Civil cases
Page 5 | MOTIONS
If the parties cannot agree on an expert deposition date within 30 days after service of the designation, counsel must contact the Court for a conference call to set the date.
If for some reason, the parties cannot agree upon a date for the deposition of an expert witness within 30 days of the service of the expert designation, counsel must contact the Court for a conference call to set a deposition date for the expert witness.
Civil cases
Page 2 | EXPERT WITNESSES