St. Louis County Circuit Court Filing Rules

In Chapter 211 cases where the Court orders drug and alcohol testing of any party, all testing must include Fentanyl, Xylazine and ETG in addition to the standard drug screens.

The summary judgment package must contain the motion, statement of uncontroverted facts, supporting memorandum, opposition response with statement of uncontroverted facts, reply, and any permitted sur-replies.

The party filing a motion must file a notice of hearing for an agreed-upon date stating whether the motion will be heard in person or by WebEx.

In Chapter 211 cases where the court orders drug and alcohol testing of any party, all testing must include Fentanyl, Xylazine, and Ethyl glucuronide (ETG) in addition to standard screens, and all testing reports must include the results for these substances.

The joint memorandum must set forth the meeting date and format, attending attorneys' names and bar numbers, meeting length, a description of unresolved disputes with the discovery requests and objections attached, and a certification that clients were informed of the meeting and the inability to resolve the disputes without a court appearance.

Defendant's jury instructions must be filed no later than 5 days before the pre-trial conference.

Discovery must be served no later than 30 days before the discovery deadline.

All outstanding motions, motions in limine, and deposition objections will be argued at the pre-trial conference.

Before any discovery dispute (including motions to compel or for sanctions) will be heard in Division 13, counsel must meet at least once in person or by video conference in a good faith effort to resolve the dispute and file the joint Memorandum before obtaining a hearing date from the Division Clerk.

Discovery disputes (including motions to compel or for sanctions) will not be heard unless counsel first meet at least once in person or by video conference and file a joint memorandum before obtaining a hearing date from the division clerk.

Motions must be e-mailed to Heather.Cunningham@courts.mo.gov at least 10 days prior to pre-trial (sentence begins on prior page; beginning of sentence missing from this text).

All outstanding motions, pre-trial motions, motions in limine, and proposed jury instructions must be e-mailed to chambers at Bruce.Hilton@courts.mo.gov at least one week before trial.

Counsel setting a motion for summary judgment for hearing must deliver courtesy copies of the operative pleadings, critical exhibits, up to 3 primary cases per party, and the movant's proposed judgment to Division 12 chambers at least one week before the hearing.

The e-mailed copy of the summary judgment package must be in Word format.

Proposed jury instructions should be submitted in Word format.

Summary judgment courtesy copies must be securely bound in a binder, with each document separately tabbed and an index identifying the document under each tab.

All summary judgment filings under 74.04 RSMo must be filed together in a single package.

Summary judgment motions under Rule 74.04 RSMo must be filed as a single package containing the motion, statement of uncontroverted facts, supporting memorandum, response in opposition with statement of uncontroverted facts, reply, and any permitted sur-replies, by the court-set deadline.

In cross-motion summary judgment cases, counsel for the party who first filed a motion for summary judgment must prepare and deliver the courtesy copy binder.

The Children's Division Case Manager or supervisor and/or the Deputy Juvenile Officer or supervisor must deliver a copy of the standing order with any drug screen court order to the drug testing facility.

Discovery must be served no later than 30 days before the discovery deadline.