Judge Kevin D. Harrell
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- At Least 7 Days Before Pre Trial Conference
Petition
Court-wide- 1 copy • Upon Filing
Communication
Phone
Chambers
Phone
Court-widePhone
Court-widePhone
Court-wideDocument Format Requirements4 rules
Exhibits must be consecutively numbered, and counsel must reserve adequate pre-trial number ranges for their exhibits and possible unanticipated exhibits.
All exhibits are to be consecutively numbered, regardless of which party tenders the exhibit. Prior to trial, counsel shall reserve adequate numbers to accommodate their exhibits, allowing for unanticipated exhibits. (i.e., Petitioner reserves Nos. 1 through 50; Respondent reserves Nos. 51 through 100, Guardian ad Litem reserves Nos. 101 through 150, etc.)
All answers in the pre-trial statement must be typed.
All answers must be typed.
All answers in the statement must be typed.
All answers must be typed.
Attorneys should pre-mark all exhibits to the extent possible.
To the extent possible, all exhibits shall be pre-marked by the attorneys.
Document Filing Requirements9 rules
All parties must provide the court reporter and court with a website-formatted witness and exhibit list on the day of trial.
All parties shall provide the Court Reporter and the Court with a witness and exhibit list in the format provided on this website on the day of trial.
Document Type
Witness And Exhibit List
Each attorney of record must complete the pre-trial statement.
This pre-trial statement must be completed by each attorney of record.
Document Type
Pretrial Statement
Counsel must complete every applicable section of the pre-trial statement.
Counsel shall complete all portions which apply.
Document Type
Pretrial Statement
A Form 14 child-support calculation and a parenting plan must be submitted if they differ from the versions submitted at the case-management conference.
Please submit a Form 14 child support calculation and a parenting plan, if different from those submitted at the case management conference
Document Type
Form 14 And Parenting Plan
Proposed jury instructions must include MAI citations and be emailed to the Division Law Clerk at least one day before the pretrial conference.
All proposed jury instructions (with MAI citations) must be emailed to the Division Law Clerk at least one (1) day prior to the pre-trial conference.
Document Type
Proposed Jury Instructions
Counsel must complete every applicable portion of the statement.
Counsel shall complete all portions which apply.
Document Type
Case Review Permanency Hearing Statement
Each attorney of record must complete the Case Review or Permanency Hearing Statement.
This statement must be completed by each attorney of record.
Document Type
Case Review Permanency Hearing Statement
By executing the statement, counsel certifies that a good-faith effort was made to discuss and resolve all potential disagreements concerning the recommendations presented to the court.
By execution of this Statement, counsel is certifying to the Court that a good faith effort has been made to discuss and resolve all potential disagreements regarding the recommendations to be presented to the Court.
Document Type
Case Review Permanency Hearing Statement
The statement requires a certificate of service confirming electronic service on counsel of record.
I hereby certify that a true copy of the above and foregoing Statement was served upon counsel of record via the e-filing system on this ________ day of _________, 202___.
Document Type
Case Review Permanency Hearing Statement
Filing & Service rules
Electronic Filing Rules
Proposed judgments and orders must be emailed to the division law clerk after trial and within ten days of the trial date unless the court orders otherwise.
Proposed judgments and/or orders shall be e-mailed to the division law clerk after trial, but no later than ten (10) days from the trial date, unless otherwise ordered by the Court.
Page 1 | TRIAL
Filing Timing and Cure Windows
Case management statements must be filed seven days before the case management date.
Case management statements shall be filed seven (7) days prior to the case management date.
Page 1 | CASE MANAGEMENT
Unless the court orders otherwise, proposed judgments and orders must be submitted within ten days after trial.
Proposed judgments and/or orders shall be e-mailed to the division law clerk after trial, but no later than ten (10) days from the trial date, unless otherwise ordered by the Court.
Page 1 | TRIAL
Dispositive motions filed fewer than 90 days before trial will be taken with the case unless the Court rules otherwise.
Any dispositive motions filed less than ninety (90) days prior to the trial date will be taken with the case, unless the Court rules otherwise.
Page 2 | SCHEDULING ORDER
Summary judgment motions must be filed at least 90 days before the trial date.
Summary judgment motions must be filed no less than ninety (90) days prior to the trial date.
Page 2 | SCHEDULING ORDER
Deposition portions designated for presentation to the jury must be filed 30 days before the pretrial conference.
Parties shall file any designated portion of depositions to be read, shown or played to the jury by videotape thirty (30) days before the pre-trial conference.
Page 2 | SCHEDULING ORDER
Counter-designations are due 10 days before the pretrial conference.
Counter-designations are due ten (10) days before the pre-trial conference
Page 2 | SCHEDULING ORDER
Objections to counter-designations are due 7 days before the pretrial conference.
objections to counter-designations are due seven (7) days before the pre-trial conference.
Page 2 | SCHEDULING ORDER
Opposition briefs to motions in limine must be filed no later than 3 days before the pretrial conference.
Briefs in opposition to Motions in Limine must be filed not later than three (3) days before the pre-trial conference.
Page 2 | SCHEDULING ORDER
Objections to proposed deposition designations must be filed 20 days before the pretrial conference.
Objections to proposed deposition designations shall be filed twenty (20) days before the pre-trial conference.
Page 2 | SCHEDULING ORDER
Motion in limine and other pretrial motions must be filed no later than 10 days before the pretrial conference.
All Motions in Limine or other pretrial motions must be filed not later than ten (10) days before the pre-trial conference.
Page 2 | SCHEDULING ORDER
The Attorney for Juvenile Office, Children’s Division attorney, and Guardian Ad Litem must file the statement at least three days before each Case Review or Permanency Hearing or Review.
The Attorney for Juvenile Office and/or Children’s Division attorney and Guardian Ad Litem shall file this Statement with the Court at least three (3) days prior to each Case Review or Permanency Hearing/Review (i.e. the Monday prior).
Page 1 | Instructions
All other counsel must file the statement at least two days before each Case Review or Permanency Hearing or Review.
All other counsel shall file this Statement at least two (2) day prior to each Case Review or Permanency Hearing/Review (i.e. the Tuesday prior).
Page 1 | Instructions
Service and Proof of Service Rules
Copies of the foregoing document were served through the e-filing system.
It is hereby certified that copies of the foregoing were sent through the e-filing system on _________________________.
Page 3 | CERTIFICATE OF MAILING
The statement includes certification that a true copy was served on counsel of record through the electronic filing system.
I hereby certify that a true copy of the above and foregoing Statement was served upon counsel of record via the e-filing system on this ________ day of _________, 202___.
Page 1 | Case Review / Permanency Hearing Statement
Courtesy Copy Requirements
The original pre-trial statement must be filed with the court, and copies must be sent to the judge and all other counsel at least seven days before the pre-trial conference.
The original is to be filed with the Court, and copies sent to the Judge and all other counsel at least seven (7) days prior to the pre-trial conference.
Page 1 | PRE-TRIAL STATEMENT — Instructions
Adjournment & Extension Requirements
The scheduled trial date is final and may be continued only for good cause with leave of the Court.
This trial date is considered final and will not be continued without good cause and leave of the Court.
Page 1 | SCHEDULING ORDER
Failure to follow the Scheduling Order deadlines without prompt notice to the Court cannot support a continuance.
The failure of the parties to follow the dates set forth in the Order without prompt notice to the Court shall not serve as a basis for a continuance
Page 2 | SCHEDULING ORDER
The motions in limine deadlines may not be changed without Court approval.
These deadlines for Motions in Limine may not be changed without approval of the Court.
Page 2 | SCHEDULING ORDER
An unripe summary judgment motion cannot support a request for continuance.
Motions for summary judgment that are not ripe before the trial date shall not serve as a basis for continuance.
Page 2 | SCHEDULING ORDER
Trial dates are special settings, and continuance requests will not be granted as a matter of course.
All trial dates are special settings and therefore continuances will not be freely granted.
Page 1 | CASE MANAGEMENT
The parties may change the listed deadlines by agreement without court notice if the changes do not affect the pretrial conference or trial dates.
Any of the above time deadlines may be changed by agreement of the parties without notice to the Court, as long as such changes do not affect the pre-trial conference and/or trial dates.
Page 2 | SCHEDULING ORDER
Undocumented disputes about changed deadlines will result in strict enforcement of the Scheduling Order.
Disputes over agreements to change deadlines not documented will result in the strict enforcement of the contents of this Scheduling Order.
Page 2 | SCHEDULING ORDER
Any agreement to deviate from the Scheduling Order should be documented by the parties.
In the event that the parties choose to deviate from the Scheduling Order, such agreement should be documented by the parties.
Page 2 | SCHEDULING ORDER
A party seeking to change a deadline without the other party's agreement must obtain leave of the Court.
Any desire to make changes without agreement of the parties will require leave of Court.
Page 2 | SCHEDULING ORDER
Chambers Communication Rules
Proposed jury instructions must be sent by email to the Division Law Clerk at least one day before the pretrial conference.
All proposed jury instructions (with MAI citations) must be emailed to the Division Law Clerk at least one (1) day prior to the pre-trial conference.
Page 2 | SCHEDULING ORDER
The Court should not be notified of a discovery dispute until the parties have attempted to resolve it by phone, video conference, or in-person discussion.
the Court should not be notified of a discovery dispute unless and until the parties have attempted to resolve the issue via phone call, video conference, or in-person discussion.
Page 2 | SCHEDULING ORDER
When contacting the Court about a discovery dispute, each party must briefly describe the dispute by email to the Division Law Clerk.
In contacting the Court, the parties shall each briefly describe the discovery dispute via an e-mail to the Division Law Clerk.
Page 2 | SCHEDULING ORDER
The parties should contact the Court before filing written pleadings concerning discovery disputes.
The parties should contact the Court prior to filing any written pleadings regarding discovery disputes.
Page 2 | SCHEDULING ORDER