Court Rules

St. Louis County Circuit Court Pre-Motion Conference Requirements

7 rules from official source documents

Pre-motion conference and letter requirements before filing motions, including sequential steps. This page is scoped to St. Louis County Circuit Court; use the court rules overview to switch categories without leaving this court.

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.

no discovery disputes, including motions to compel discovery responses or motions for sanctions, will be heard in Division 13 unless, prior to obtaining a hearing date from the Division Clerk, counsel for the parties meet at least once in person or by video conference in a good faith effort to resolve their discovery disputes and file their joint Memorandum with the Court, substantially in the form attached hereto

Chief Judge Bruce F. HiltonCRITICAL

Counsel must set a pre-trial conference to hear their motions no later than 10 days (including weekends) before trial, and any motions not heard by then are deemed abandoned.

Counsel are responsible for setting a pre-trial conference where said motion(s) will be heard no later than 10 days (including Saturday and Sunday) before the trial date. All motions not heard at that time are deemed abandoned.

Judge Heather R. CunninghamCRITICAL

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.

no discovery disputes (including motions to compel discovery responses or motions for sanctions) will be heard in Division 16 unless, prior to obtaining a hearing date from the division clerk, counsel for the parties meet at least once in person or by video conference in a good faith effort to resolve their discovery disputes and file a joint memorandum with the Court, substantially in the form attached hereto

Judge Jeffery T. McPhersonCRITICAL

A party may be excused from the in-person meet-and-confer requirement for good cause shown, such as opposing counsel's refusal to respond to requests to meet and confer.

A party may request excusal from the in-person meeting requirement of this Order for good cause shown, such as opposing counsel's refusal to respond to requests to meet and confer.

Chief Judge Bruce F. HiltonWARNING

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

All outstanding Motions, Motions and Limine and objections in depositions will be argued at the pre-trial conference.

Judge Heather R. CunninghamWARNING

Objections to designated deposition testimony intended for the record must be presented to the court for a ruling at the pre-trial conference.

The parties shall present any objections to the designated deposition testimony that they intend to enter into the record to the court for a ruling at the time of the pre-trial conference.

Judge Heather R. CunninghamWARNING

A party may be excused from the meet-and-confer requirement for good cause shown, such as opposing counsel's refusal to respond to requests to meet and confer.

A party may request excusal from the in-person meeting requirement of this order for good cause shown, such as opposing counsel's refusal to respond to requests to meet and confer.

Judge Jeffery T. McPhersonINFO
Common questions about St. Louis County Circuit Court pre-motion conference requirements

Does St. Louis County Circuit Court require a pre-motion conference or letter before filing a motion?

St. Louis County Circuit Court rules set a pre-motion procedure for motions. Counsel must set a pre-trial conference to hear their motions no later than 10 days (including weekends) before trial, and any motions not heard by then are deemed abandoned.

View ruleSource: page 2, section 13. Setting Pre-Trial Conference Hearings

Does St. Louis County Circuit Court require a pre-motion conference or letter before filing a motion?

Yes. A pre-motion letter is required for discovery and sanctions. 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.

View ruleSource: page 1, section Discovery Disputes in All Civil Cases