Judge Joel P. Fahnestock
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
Motion, Proposed Order
Proposed Order
Petition
Court-wide- 1 copy • Upon Filing
Adjournments
Court-wideRequest must include
Communication
Clerk, Chambers
Phone
Document Format Requirements13 rules
Letter designations for exhibits are reserved for the Court.
Only the Court uses letters for exhibits.
Before trial or a hearing, each party must mark its exhibits with a sticker identifying the offering party and exhibit number.
Each party shall mark exhibits prior to trial or hearing with an exhibit sticker indicating whether the exhibit is being offered by plaintiff or defendant, along with the exhibit number.
Party exhibits must be numbered rather than lettered, and the parties must not use the same exhibit numbers.
Exhibits shall be numbered, not lettered, and the parties shall not use the same numbers.
The motion for leave to file amended information or information in lieu of indictment, proposed order, and amended information must be provided as PDFs.
Provide any motion for leave to file amended information or information in lieu of indictment, proposed order and amended information as PDFs with this Plea form.
The Division 9 plea form must be submitted as a Word document and must not be scanned or converted to PDF.
DO NOT SCAN OR CONVERT TO PDF. Send as a Word document only.
DOCX
Counsel with civil or domestic cases pending in Division 9 must email PDF copies of all motions.
counsel with civil or domestic cases pending in Division 9 shall email PDF copies of all motions
Proposed orders must be emailed to Division 9 in Word format.
shall email proposed orders in Word format to the Division via div9.cir16@courts.mo.gov
DOCX
The Division 9 plea agreement form must be submitted only as a Word document and may not be scanned or converted to PDF.
DO NOT SCAN OR CONVERT TO PDF. Send as a Word document only.
DOCX
When applicable, the motion for leave, proposed order, and amended information must be provided as PDFs with the plea agreement form.
Provide any motion for leave to file amended information or information in lieu of indictment, proposed order and amended information as PDFs with this Plea form.
The form must remain a Word document and must not be scanned or converted to PDF.
DO NOT SCAN OR CONVERT TO PDF. Send as a Word document only.
DOCX
Proposed orders should be emailed to Division 9 in Word format.
These orders should be sent in Word format via e-mail to Division 9 at Div9.cir16@courts.mo.gov.
Civil and domestic proposed scheduling orders should be submitted to the law clerk in Word format.
Proposed scheduling orders should be submitted in Word format to the law clerk.
Proposed orders should be emailed in Microsoft Word format.
Proposed orders should be sent in Microsoft Word format via e-mail.
DOCX
Document Filing Requirements15 rules
A proposed order should accompany every motion.
Pursuant to Local Rule 33.5.6, proposed orders should accompany all motions.
Document Type
Motion
An attorney appearing for a client must file an entry of appearance or an entry of limited appearance.
If you appear in court on behalf of a client, you must filed an entry of appearance or an entry of limited appearance pursuant to Local Rule 21.2.
Document Type
Entry Of Appearance
At least 24 hours before a hearing, Division 9 must receive an exhibit list, digital exhibit copies, a witness list, and a proposed order or judgment.
At least 24 hours prior to the hearing, please provide Division 9 with an exhibit list, digital copies of all exhibits, a witness list, and a proposed Order or Judgment if
Document Type
Hearing Submission
Each party must provide an exhibit list before trial or a hearing begins.
Each party shall provide an exhibit list prior to the start of trial or a hearing.
Document Type
Exhibit List
For amended counts, the plea form must include the amended charge code and description, any motion for leave to file amended information or information in lieu of indictment, a proposed order, and the amended information.
If any of the counts below are marked as amended, please list the amended charge code and description. Provide any motion for leave to file amended information or information in lieu of indictment, proposed order and amended information as PDFs with this Plea form.
Document Type
Amended Information Package
Attorneys and self-represented parties must provide the court with a street address, telephone number, and e-mail address if they have one, and should make every effort to obtain an email address.
Make sure attorneys and self-represented parties have provided the court with their contact information, including a street address, telephone number, and e-mail address. While court rules only require the providing of an e-mail address if an attorney or party has one, everyone participating in the court process should make every effort to obtain ===== PAGE 2 ===== one.
Document Type
Contact Information
Participants must provide the appropriate clerk with any exhibits they want the court to consider before a telephone or video hearing.
Before telephone and video hearings, provide any exhibits you wish the Court to consider to the appropriate clerk.
Document Type
Hearing Exhibits
Electronically provided pleadings must be attached to an email whose subject line contains the case number.
Pleadings provided electronically shall be attached to an email with the case number in the Subject line of the email.
Document Type
Electronic Pleading
For disputed jury instructions, the parties must submit separate proposed instructions and supporting legal briefing.
If there are some instructions to which the parties cannot agree, the parties shall provide their proposed instructions, separately from the agreed-upon instructions, along with legal briefing in support of their positions.
Document Type
Disputed Jury Instructions
The parties must exchange lists of witnesses and exhibits ten days before the pretrial conference.
The parties shall exchange a list of witnesses and exhibits ten days prior to the pretrial conference.
Document Type
Witness And Exhibit List
Five days before the pretrial conference, the parties must email and file specified trial materials, including witness and exhibit lists, jury instructions, trial briefs, and motions in limine.
A list of witnesses and exhibits; One complete set of jury instructions with supporting citations and including the facts and instruction language supported by your evidence; Non-agreed-upon jury instructions with legal support; An electronic chambers copy of all jury instructions in Microsoft Word; Any trial briefs; and Any motions in limine.
Document Type
Pretrial Submission
An asserting party must identify trial depositions to the defending party ten days before the pretrial conference.
Any depositions used at trial by an asserting party shall be identified to a defending party ten days prior to the pretrial conference.
Document Type
Deposition Designations
Counter deposition designations and objections must be returned five days before the pretrial conference.
Counter designations and objections shall be returned to the asserting party five days prior to the pretrial conference.
Document Type
Counter Deposition Designations
The parties must submit an agreed-upon packet of jury instructions to the Court.
The parties shall submit to the Court a packet of instructions agreed-upon by the parties.
Document Type
Jury Instructions
The form asks the user to enter the case number(s).
STATE OF MISSOURI, CASE NO: Type or Paste Case Number(s)
Document Type
Revocation Agreement
Filing & Service rules
Electronic Filing Rules
Continuance motions must be filed electronically with a courtesy copy emailed to Division 9.
All motions for a continuance must be filed electronically with a courtesy copy e-mailed to the Division 9 e-mail at Div9.cir16@courts.mo.gov.
Page 1 | FILINGS
Filings may be submitted through the e-Filing system or to the Civil Records Department.
All filings must be made either through the e-Filing system or with the Civil Records Department.
Page 1 | FILINGS
Counsel must email PDF copies of all motions and Word-format proposed orders to Division 9, unless the copies are otherwise delivered to the Division.
counsel with civil or domestic cases pending in Division 9 shall email PDF copies of all motions and shall email proposed orders in Word format to the Division via div9.cir16@courts.mo.gov or shall otherwise deliver such copies to the Division.
Page 1 | Administrative Order
The Division 9 plea form is not filed in the case file.
This form is for Division 9 information only and will not be filed in the case file.
Page 1 | Division 09 Plea Agreement
Filing Timing and Cure Windows
Proposed scheduling orders are due to the law clerk by noon on the Thursday before the scheduled case management conference.
Proposed scheduling orders must be submitted to the law clerk no later than by Noon on the Thursday preceding the scheduled case management conference.
Page 2 | CASE MANAGEMENT CONFERENCES (“CMC”) – CIVIL / DOMESTIC
The hearing submission is due at least 24 hours before the hearing.
At least 24 hours prior to the hearing, please provide Division 9 with an exhibit list, digital copies of all exhibits, a witness list, and a proposed Order or Judgment if
Page 2 | HEARINGS AND APPEARANCES
The completed Division 9 plea form must be returned at least 24 hours before the scheduled plea hearing.
Please complete the form below and return it to Division 9 at least 24 hours prior to the scheduled plea hearing.
Page 1 | Division 09 Plea Agreement
The completed plea agreement form must be returned to Division 9 at least 24 hours before the scheduled plea hearing.
Please complete the form below and return it to Division 9 at least 24 hours prior to the scheduled plea hearing.
Page 1 | Division 09 Plea Agreement
The completed revocation agreement must be returned to Division 9 at least 24 hours before the scheduled plea hearing.
Please complete the form below and return it to Division 9 at least 24 hours prior to the scheduled plea hearing.
Page 1 | Division 09 Revocation Agreement
Service and Proof of Service Rules
The scheduling and pretrial order includes a certificate of service sent through the Court’s e-filing system to all attorneys of record.
CERTIFICATE OF SERVICE I hereby certify that notice of the above and foregoing was sent through the Court’s e-filing system to all attorneys of record on: 30-Jan-2025
Page 1 | CERTIFICATE OF SERVICE
Courtesy Copy Requirements
A courtesy copy of each continuance motion must be emailed to the Division 9 email address.
All motions for a continuance must be filed electronically with a courtesy copy e-mailed to the Division 9 e-mail at Div9.cir16@courts.mo.gov.
Page 1 | FILINGS
Copies otherwise delivered to Division 9 must be clearly marked “Courtesy Copy” under Local Rule 33.5.7.
Any copy otherwise delivered to the Division shall be clearly marked as a “Courtesy Copy” pursuant to Local Rule 33.5.7.
Page 1 | Administrative Order
A courtesy copy of the proposed judgment in Word format must be provided to the law clerk when submitting a domestic case by affidavit.
When submitting a domestic case by affidavit, please provide the law clerk a courtesy copy of the proposed Judgment in Word format.
Page 1 | FILINGS
Chamber copies of pleadings and other filings should not be sent except for time-sensitive matters or when specifically directed by the Court.
Do not send chamber copies of pleadings or other filings unless related to time-sensitive matters or as specifically directed by the Court.
Page 1 | CIVIL SCHEDULING ORDER AND PRETRIAL ORDER
Chambers Communication Rules
The specified pretrial materials must be emailed to the identified chambers address and filed five days before the pretrial conference.
Five days before the pretrial conference, the parties will email to chambers at Div9.cir16@courts.mo.gov and file in the casefile:
Page 1 | CIVIL SCHEDULING ORDER AND PRETRIAL ORDER
Emailing the judge directly is prohibited.
Do not e-mail the Judge directly.
Page 1 | GENERAL INFORMATION
Email communications must include all parties, may not be ex parte, and may not copy the Court on ongoing disputes.
Make sure you include all parties on any e-mail. The Court will not accept ex parte communication. Do not copy the Court on ongoing disputes amongst the parties. The Judge will not read these e-mails.
Page 1 | GENERAL INFORMATION
Parties may not seek procedural advice from the Court or Division staff and must file a motion for relief beyond scheduling.
Do not ask the Court or Division staff for advice on how to do something. If you need something beyond scheduling, file a motion seeking relief.
Page 1 | GENERAL INFORMATION
Division 9 permits email contact for scheduling matters.
Division 9 often uses e-mail for scheduling matters.
Page 1 | GENERAL INFORMATION
Email may be used to contact the law clerk or judicial administrative assistant for scheduling matters.
You are welcome to use e-mail to contact either the law clerk or the judicial administrative assistant (JAA) for scheduling. The law clerk handles civil and domestic matters while the JAA handles criminal matters.
Page 1 | GENERAL INFORMATION
Email to the Division 9 forwarding address is automatically sent to both the law clerk and JAA, so separate copies are unnecessary.
Please note the Div9.cir16@courts.mo.gov is automatically forwarded to both the sitting law clerk and the JAA. If you e-mail this address, you do not need to also copy the individual law clerk or JAA.
Page 1 | GENERAL INFORMATION
Participants may contact the court with questions or concerns.
Contact the court with any questions or concerns.
Page 1 | Introduction
Participants may contact the court’s staff through the information on the court website for questions about a division’s policies and procedures.
Contact the court’s staff with any questions regarding any particular Division’s policies and procedures. Their contact information is on the court’s webpage.
Page 2 | General
Participants may call the Division at 816-881-3609 with issues or questions about providing hearing exhibits by email.
Contact the Division at 816-881-3609 if you have any issues or questions.
Page 2 | General
The preferred method of providing hearing exhibits is to email scanned copies to the civil or criminal clerk.
The best way to do this is to provide scanned copies via e-mail to the civil or criminal clerk.
Page 2 | General