Union County Circuit Court, Kentucky Pre-Motion Conference Requirements

CRITICAL

A CR 78(2) motion may be routinely granted ten days after filing unless an objection or response is filed.

Motions may be made under CR 78(2) and shall direct the opposing attorney's attention to the fact that under this rule the motion may be granted routinely by the Court ten (10) days after filing unless an objection is received or a response filed.

CRITICAL

Opposing memoranda may be submitted within 30 days, with 15 days allowed for reply; afterward, the motion stands submitted.

Opposing memoranda may be submitted within thirty (30) days with fifteen (15) days allowed for reply, after which the motion will stand submitted.

CRITICAL

A motion to compel discovery compliance must include counsel’s certificate that counsel conferred or corresponded with opposing counsel and could not resolve the dispute without a hearing.

All motions to compel discovery compliance shall contain a certificate by counsel that she or he has conferred or corresponded with opposing counsel and that they are unable to reconcile their differences without a hearing.

CRITICALCivil cases

Before moving to compel discovery, counsel must confer or correspond with opposing counsel and be unable to resolve the dispute without a hearing.

Motions to compel discovery shall contain a certificate, by counsel, that he or she has conferred or corresponded with opposing counsel and that they are unable to reconcile their difference without a hearing.

CRITICALCivil cases

An opposing party who wants an oral hearing must say so and notice the motion for the following motion day.

If a party opposing the motion desires oral hearing, they shall so state, and proceed to notice the motion for the following motion day.

WARNING

In the stated foreclosure and combined default-judgment circumstances, the Court waives the 30-day response requirement for answering defendants when there is no real issue.

EXCEPTION: In cases involving a foreclosure action where there is also a combination motion for Default Judgment against the Debtor, the Court will waive the 30 day response requirement for those who have filed an answer but there is no real issue. For example, Counties and Cities who have been named as Defendants due to outstanding taxes or institutions that have superior liens.

INFO

A party may request oral argument, which the Court will consider, and the Court may request oral argument on its own.

The Court will consider any party's request for oral argument or may request same on its own.