Limits & Logistics
Courtesy Copies
Courtesy copies
Court-wide- 1 copy
Communication
Chambers
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
Parties shall submit a hard, dirty copy of each instruction proffered.
Plaintiff should use numbers and defendant should use letters.
Document Filing Requirements10 rules
The dirty copy shall contain citations of authority and indicate the submitting party.
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 bearing the burden of proof must provide proposed jury instructions.
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.
Counsel shall provide a witness list 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.
An exhibit list shall be provided 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.
After the intended deposition portions are identified and objections are ruled on, the offering party must provide the Court and all parties a written delineation identifying the deponent and the page and line numbers of the portions offered.
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 delineation setting forth the name of the deponent along with all page and line numbers of the portions of the deposition being offered into evidence.
Exhibits should be marked for identification prior to trial.
Filing & Service rules
Electronic Filing Rules
In addition to hard copies, parties must provide proposed instructions to the Court before opening statements on a compact disc, flash drive, or by email.
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 Patrick.Richmond@courts.mo.gov.
Page 2 | JURY INSTRUCTIONS
Filing Timing and Cure Windows
Unless the Court directs otherwise, the burden-bearing party must provide proposed jury instructions no later than the conclusion of voir dire.
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 must be provided to the Court by the morning after receiving the other party’s instructions.
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.
Page 2 | JURY INSTRUCTIONS
The electronic or digital-media copy of proposed instructions must be provided to the Court 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 Patrick.Richmond@courts.mo.gov.
Page 2 | JURY INSTRUCTIONS
Service and Proof of Service Rules
Proposed jury instructions must be provided to the Court and all parties.
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
Pre-Motion Conference Requirements
Before presenting any motion, 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.
Page 4 | TRIAL
Dispositive motions must be scheduled and heard at least 60 days before a Division 19 trial setting, or may not be heard absent good cause.
Pursuant to the Revised Docket Procedures of Division 1 and Civil Motion/Equity Divisions 17 and 20, effective January 1, 2026, all dispositive motions shall be scheduled and heard (in the Motion/Equity Divisions) at least 60 days prior to a trial setting in Division 19 or the motion may not be heard unless circumstances establish good cause why that was not possible.
Page 4 | TRIAL
Dispositive motions shall be heard more than 60 days prior to a trial setting.
Dispositive motions shall be heard more than 60 days prior to a trial setting.
Page 4 | TRIAL
These matters should be scheduled no later than the week before trial.
These matters should be scheduled no later than the week before trial.
Page 4 | TRIAL
Subject to Local Rule 33, other motions, including motions in limine, may be scheduled at a Division 19 status conference, which generally occurs 30 days before trial.
Subject to Local Rule 33, all other motions, including motions in limine, may be scheduled at a status conference in Division 19 which will generally occur 30 days prior to the trial setting.
Page 4 | TRIAL
Chambers Communication Rules
Parties may email proposed jury instructions to the Court at Patrick.Richmond@courts.mo.gov as one of the specified submission methods.
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 Patrick.Richmond@courts.mo.gov.
Page 2 | JURY INSTRUCTIONS