Limits & Logistics
Courtesy Copies
Courtesy copies
Court-wide- 1 copy
Document Format Requirements3 rules
All instructions shall be submitted in 14-point font, Times New Roman on Microsoft Word.
- Font
- Times New Roman
- Font size
- 14 points
- Jury instructions
Formatting
- •Submit on Microsoft Word
Exhibits should be marked for identification prior to trial.
Plaintiff should use numbers and defendant should use letters.
Document Filing Requirements11 rules
In addition to hard copies, the parties must provide proposed instructions to the Court on a compact disc, flash drive, or by email.
Court's wording
In addition to providing hard copies, the parties shall provide to the Court, prior to opening statements, their proposed instructions on a compact disc, flash drive, or by email to the Court at Christopher.McGraugh@courts.mo.gov.
Proposed converse or responsive jury instructions shall be provided to the Court not later than the morning after receiving the other party’s proposed jury instructions.
Counsel and the parties shall return their prospective juror questionnaire and list to the courtroom clerk at the conclusion of voir dire.
Unless the Court directs otherwise, the party with the burden of proof must provide proposed jury instructions to the Court and all parties.
Court's wording
As required by Local Rule 53, and unless otherwise directed by the Court, the party with the burden of proof on a claim or defense shall provide their proposed jury instructions to the Court, and to all parties, not later than the conclusion of voir dire.
Plaintiff shall also provide a proposed numerical order that the instructions should be numbered and read to the jury.
Parties shall submit a hard dirty copy of each instruction proffered. The dirty copy shall contain citations of authority and indicate the submitting party.
Counsel shall provide a witness list to the Court, court reporter, and opposing party prior to trial.
Any party offering interrogatories and answers as evidence shall first provide to the Court and the opposing party a written list which separately sets out in full each interrogatory together with response thereto.
An exhibit list shall be provided to the Court, court reporter, and opposing party prior to trial.
Any paper or exhibit not previously marked for identification shall be marked and handed to opposing counsel for review, before it is tendered to the Court or a witness for examination.
After the Court rules on objections, the offering party must provide the Court and all parties written deposition delineations identifying the deponent and the page and line numbers offered into evidence.
Court's wording
Once the deposition portions that a party intends on using as evidence at trial has been identified, after objections have been presented and ruled on by the Court, the party offering the deposition portion into evidence shall present the Court and all parties, a written deposition delineations setting forth the name of the deponent along with all page and line numbers of the portions of the deposition being offered into evidence.
Filing & Service rules
Filing Timing and Cure Windows
The parties must provide the Court with proposed jury instructions in an electronic medium before opening statements.
In addition to providing hard copies, the parties shall provide to the Court, prior to opening statements, their proposed instructions on a compact disc, flash drive, or by email to the Court at Christopher.McGraugh@courts.mo.gov.
Page 2 | JURY INSTRUCTIONS
Proposed jury instructions from the party with the burden of proof are due no later than the conclusion of voir dire, unless the Court directs otherwise.
As required by Local Rule 53, and unless otherwise directed by the Court, the party with the burden of proof on a claim or defense shall provide their proposed jury instructions to the Court, and to all parties, not later than the conclusion of voir dire.
Page 2 | JURY INSTRUCTIONS
Proposed converse or responsive jury instructions are due to the Court by the morning after the other party’s proposed instructions are received.
Proposed converse or responsive jury instructions shall be provided to the Court not later than the morning after receiving the other party’s proposed jury instructions.
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Pre-Motion Conference Requirements
Before presenting any motion to the Court, counsel must make a good-faith effort to resolve disputed issues with opposing counsel.
Prior to presenting any motion to the court, counsel shall make a good faith effort to resolve disputed issues with opposing counsel.
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Motions should be scheduled as soon as possible, preferably by the week before trial; unless otherwise scheduled, the clerk sets them for 1:30 p.m. on the Thursday before trial.
Subject to Local Rule 33, all motions, including motions in limine, may be scheduled by contacting the courtroom clerk. These matters should be scheduled as soon as possible and preferably no later than the week before trial. Unless otherwise specifically scheduled, such motions shall be scheduled by the courtroom clerk for 1:30 pm on the Thursday preceding the day the trial is scheduled.
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Chambers Communication Rules
Remaining deposition objections must be presented to the Court well in advance of the proposed use so the Court can rule and counsel can make necessary edits.
Any remaining objections must be presented to the Court for a ruling well in advance of the proposed use of the deposition, so that the Court can rule on any objections in time for counsel to make the necessary edits without wasting jury time.
Page 5 | EVIDENCE/EXHIBITS
Exhibits may be used during opening statements only with opposing counsel’s consent and advance notice to the Court.
Use of exhibits during opening statements is permitted as long as there is consent from opposing counsel and notice to the Court in advance.
Page 5 | EVIDENCE/EXHIBITS
Motions, including motions in limine, may be scheduled by contacting the courtroom clerk, subject to Local Rule 33.
Subject to Local Rule 33, all motions, including motions in limine, may be scheduled by contacting the courtroom clerk.
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