City of St. Louis Circuit Court Document Filing Requirements

CRITICALCriminal cases

Applies to

Expert disclosure

The parties must disclose in writing and file with the Court the names and addresses of experts they intend to produce at a pretrial hearing or trial, by the date specified in the order.

No later than ________________, the parties will provide and disclose to opposing counsel the names and addresses of any and all experts which the parties intend to produce at a pretrial hearing or trial. Disclosure shall be made in writing and filed with the Court.

CRITICALCriminal cases

Applies to

Jury instructions

The parties must provide the Court with proposed jury instructions by the date specified in the order.

Parties shall provide the Court with proposed jury instructions on or before ________________.

CRITICALCriminal cases

Applies to

Jury instructions

The parties must have draft copies of their proposed jury instructions at the pretrial conference.

The parties are ordered to have draft copies of their proposed jury instructions at the pretrial conference pursuant to the City of St. Louis Local Court Rule 53.1.

CRITICAL

Applies to

Exhibit list

An exhibit list must be provided to the Court, court reporter, and opposing party before trial.

An exhibit list shall be provided to the Court, court reporter, and opposing party prior to trial.

CRITICAL

Applies to

Witness list

Counsel must provide the witness list to the Court, court reporter, and opposing party before trial.

Counsel shall provide a witness list to the Court, court reporter, and opposing party prior to trial.

CRITICAL

Applies to

Witness identity and order disclosure

Counsel must disclose the identity and order of that day’s witnesses to the Court by the beginning of each trial day.

Counsel shall disclose to the Court the identity and order of witnesses not later than the beginning of each day of trial.

CRITICAL

Applies to

Jury instructions

Each proffered instruction must be submitted in clean and dirty copies; the dirty copy must include citations of authority and identify the party that tendered it.

Parties shall submit a “clean” copy and a “dirty” copy of each instruction proffered. The dirty copy shall contain citations of authority and also indicate by which party it was tendered.

CRITICAL

Applies to

Interrogatory and response list

A party offering interrogatories and answers as evidence must first provide the Court and opposing party a written list setting out each interrogatory and its response in full.

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.

CRITICAL

Applies to

Jury instructions

Proposed converse or responsive jury instructions must be provided to the Court by the morning after receiving the other party’s proposed 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.

CRITICAL

Applies to

Jury instructions

In addition to providing hard copies, the parties are expected to be able to make changes while in chambers; therefore, counsel shall bring their instructions on a flash drive, or email them to the Court.

In addition to providing hard copies, the parties are expected to be able to make changes while in chambers; therefore, counsel shall bring their instructions on a flash drive, or email them to the Court.

CRITICAL

Applies to

Jury instructions

A party bearing the burden of proof on a claim or defense must provide proposed jury instructions to the Court and the other parties by the conclusion of plaintiff’s evidence, unless the Court directs otherwise.

Each party who has the burden of proof on a claim or defense shall provide proposed jury instructions to the Court and to the other parties not later than the conclusion of plaintiff’s evidence, unless otherwise directed by the Court.

CRITICAL

Applies to

Proposed jury instructions

In addition to hard copies, the parties must provide proposed instructions to the Court 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 Christopher.McGraugh@courts.mo.gov.

CRITICAL

Applies to

Proposed converse or responsive 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.

CRITICAL

Applies to

Interrogatory evidence list

A party offering interrogatories and answers as evidence must first provide the Court and opposing party a written list setting out each interrogatory and its response in full.

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.

CRITICAL

Applies to

Prospective juror questionnaire and list

Counsel and the parties must return the prospective juror questionnaire and list to the courtroom clerk at the conclusion of voir dire.

Counsel and the parties shall return their prospective juror questionnaire and list to the courtroom clerk at the conclusion of voir dire.

CRITICAL

Applies to

Witness list

Counsel must provide a witness list to the Court, court reporter, and opposing party before trial.

Counsel shall provide a witness list to the Court, court reporter, and opposing party prior to trial.

CRITICAL

Applies to

Proposed jury instructions

Unless the Court directs otherwise, the party with the burden of proof must provide proposed jury instructions 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.

CRITICAL

Applies to

Deposition delineations

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.

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.

CRITICAL

Applies to

Exhibit list

An exhibit list must be provided to the Court, court reporter, and opposing party before trial.

An exhibit list shall be provided to the Court, court reporter, and opposing party prior to trial.

CRITICAL

Applies to

Exhibit

Before an unmarked paper or exhibit is tendered to the Court or a witness, it must be marked for identification and handed to opposing counsel for review.

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.

CRITICAL

Applies to

Proposed jury instructions

The plaintiff must provide a proposed numerical order for numbering and reading the instructions to the jury.

Plaintiff shall also provide a proposed numerical order that the instructions should be numbered and read to the jury.

CRITICAL

Applies to

Proffered jury instruction

Each proffered instruction must be submitted in a hard dirty copy containing citations of authority and identifying the submitting party.

Parties shall submit a hard dirty copy of each instruction proffered. The dirty copy shall contain citations of authority and indicate the submitting party.

CRITICAL

Applies to

Notice of hearing

The attorney signing up a case must submit a Notice of Hearing after scheduling.

After scheduling a case, the attorney signing up the matter MUST electronically file a Notice of Hearing within 24 hours of signing up said cause on this website.

CRITICAL

Applies to

Interrogatory and answer list

A party offering interrogatories and answers as evidence must first provide the Court and opposing party a written list setting out each interrogatory and its response in full.

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.

CRITICAL

Applies to

Proposed jury instruction

Each proffered instruction must have a clean and a dirty copy; the dirty copy must include authority citations and identify whether it was prepared at the Court’s direction or which party tendered it.

Parties shall submit a “clean” copy and a “dirty” copy of each instruction proffered. The dirty copy shall contain citations of authority and also indicate whether it was prepared at the Court’s direction or by which party it was tendered.

CRITICAL

Applies to

Proposed jury instruction order

The plaintiff must provide a proposed numerical order for reading the instructions to the jury.

Plaintiff shall also provide a proposal for the numerical order that the instructions should be read to the jury.

CRITICAL

Applies to

Proposed jury instructions

Each party bearing the burden of proof must provide proposed jury instructions to the Court and other parties by the conclusion of voir dire, unless the Court directs otherwise.

Each party who has the burden of proof on a claim or defense shall provide proposed jury instructions to the Court and to the other parties not later than the conclusion of voir dire, unless otherwise directed by the Court.

CRITICAL

Applies to

Proposed converse or responsive jury instructions

Proposed converse or responsive jury instructions must be provided to the Court by the morning after receiving the other party’s proposed 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.

CRITICAL

Applies to

Exhibit list

An exhibit list must be provided to the Court, court reporter, and opposing party before trial.

An exhibit list shall be provided to the Court, court reporter, and opposing party prior to trial.

CRITICAL

Applies to

Jury panel list

Counsel and the parties must return the jury panel list to the courtroom clerk at the conclusion of voir dire.

Counsel and the parties shall return their jury panel list to the courtroom clerk at the conclusion of voir dire.

CRITICAL

Applies to

Witness list

Counsel must provide a witness list to the Court, court reporter, and opposing party before trial.

Counsel shall provide a witness list to the Court, court reporter, and opposing party prior to trial.

CRITICAL

Applies to

Jury instructions

At the final pretrial conference, the parties must submit jury instructions identifying each instruction’s authority and offering party.

During the final pretrial conference, the parties must submit a set of jury instructions, indicating the source of authority for the instruction and the offering party.

CRITICAL

Applies to

Notice of hearing

After scheduling a matter on the website, the attorney who signed it up must electronically file a Notice of Hearing within 24 hours.

After scheduling a case, the attorney signing up the matter MUST electronically file a Notice of Hearing within 24 hours of signing up said cause on this website.

CRITICAL

Applies to

Paper or exhibit

Any paper or exhibit not already marked for identification must be marked and handed to opposing counsel for review before being tendered to the Court or a witness.

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.

CRITICAL

Applies to

Deposition delineation

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.

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.

CRITICAL

Applies to

Jury instructions

Each dirty copy must include citations of authority and identify the submitting party.

The dirty copy shall contain citations of authority and indicate the submitting party.

CRITICAL

Applies to

Prospective juror questionnaire and list

Counsel and the parties must return their prospective juror questionnaire and list to the courtroom clerk at the conclusion of voir dire.

Counsel and the parties shall return their prospective juror questionnaire and list to the courtroom clerk at the conclusion of voir dire.

CRITICAL

Applies to

Witness list

Before trial, counsel must provide a witness list to the Court, the court reporter, and the opposing party.

Counsel shall provide a witness list to the Court, court reporter, and opposing party prior to trial.

CRITICAL

Applies to

Exhibit list

An exhibit list must be provided to the Court, court reporter, and opposing party before trial.

An exhibit list shall be provided to the Court, court reporter, and opposing party prior to trial.

CRITICAL

Applies to

Interrogatories and answers as evidence

A party offering interrogatories and answers as evidence must first provide the Court and opposing party with a written list separately setting out each interrogatory and its response in full.

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.

CRITICAL

Applies to

Jury instructions

Unless the Court directs otherwise, the party bearing the burden of proof must provide proposed jury instructions.

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.

CRITICAL

Applies to

Proposed jury instruction order

The plaintiff must provide a proposed numerical order for numbering and reading the jury instructions.

Plaintiff shall also provide a proposed numerical order that the instructions should be numbered and read to the jury.