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Court Rules
Judge

Judge Jerri J. Zhang

Individual Rules, Standing Orders & Policies

Jackson County Circuit Court

Limits & Logistics

Document Limits

SuggestionsCourt-wide
5 pgs
Application for ContinuanceCourt-wide
3 pgs
Continuance ApplicationCourt-wide
3 pgs

Courtesy Copies

Motions in Limine, Deposition Designations, Interrogatory Designations, Opposition, Objections

  • Email

Petition

Court-wide
  • 1 copy • Upon Filing

Adjournments

  • A continuance will not be granted unless good cause is shown to the court as soon as possible.

Request must include

Reason for Request

Communication

Phone
Court-wide
(816) 881-3920
Hours: Monday through Friday, 8:30 A.M. to 4:30 P.M.
Phone
Court-wide
Judge: Kansas City (816) 881-3759, Independence (816) 881-1732; Commissioner: Kansas City (816) 881-3761, Independence (816) 881-1732; Deputy Commissioner: Kansas City (816) 881-3753, Independence (816) 881-1732
Phone
Court-wide
SchedulingEmergencies
No status inquiries
Filters:

Document Format Requirements4 rules

FormattingMandatory

Offered exhibits which have not been pre-marked shall be provided to the court reporter to be marked and numbered before they are tendered to the Court or to the witness for examination.

PoliciesProceduresandCourtroomDecorumDiv3 · p. 3|SectionWitnesses, Exhibits and Demonstrative Evidence
FormattingImportant

Each party must number exhibits consecutively, with plaintiff exhibits starting at 1, defendant exhibits starting at 101, and additional parties using corresponding successive number blocks.

Applies to
  • Exhibits

Formatting

  • Exhibits must be numbered consecutively
  • Additional parties must likewise number their exhibits

Court's wording

Exhibits shall be numbered consecutively with each party starting their respective numbering at 1, 101, 201, 301, etc. Plaintiff’s exhibits shall start at 1 and continue through 100 (higher if necessary). Defendant’s exhibits shall start at 101 and continue through 200 (higher if necessary). Any additional parties shall likewise number their exhibits.

PoliciesProceduresandCourtroomDecorumDiv3 · p. 3|SectionWitnesses, Exhibits and Demonstrative Evidence
FormattingImportant

All exhibits identified on the exhibit list shall be pre-marked prior to the commencement of trial.

PoliciesProceduresandCourtroomDecorumDiv3 · p. 3|SectionWitnesses, Exhibits and Demonstrative Evidence
FormattingNote

Parties may offer during trial additional exhibits that were neither previously listed nor pre-marked.

Court's wording

The Court recognizes there may be additional exhibits offered during trial which have not been previously included in the exhibit list and pre-marked. The requirement to pre-mark exhibits does not prevent offering additional exhibits at trial.

PoliciesProceduresandCourtroomDecorumDiv3 · p. 3|SectionWitnesses, Exhibits and Demonstrative Evidence

Document Filing Requirements4 rules

Filing RequirementsMandatoryCivil cases

The property ledger required by Jackson County Circuit Court Local Rule 68.4.2 SHALL BE prepared and served no later than 10 business days before trial – the parties shall use Form 1402J for this purpose.

Document
Property ledger

Must include

  • Form 1402J
div-3---domestic-scheduling-order|Section5. DISCOVERY CLOSURE DATE
Filing RequirementsMandatory

Prior to the commencement of trial, each party shall prepare a witness list and an exhibit list and provide same to the Court and the court reporter (a suggested witness list and exhibit list are posted on Division 3’s website – counsel may use them or substantially similar forms).

PoliciesProceduresandCourtroomDecorumDiv3 · p. 3|SectionWitnesses, Exhibits and Demonstrative Evidence
Filing RequirementsImportantCivil cases

The order includes a certificate of service identifying the recipients and the method or methods of service.

Placement
Certificate section

Include

  • Certificate of service

Court's wording

CERTIFICATE OF SERVICE This is to certify that a copy of the foregoing was hand delivered/faxed/emailed/mailed and/or sent through the eFiling system to the following attorneys of record on . and to anyone appointed as GAL or in any other capacity, and to the parties/attorneys in this case who did not appear in court.

div-3---domestic-scheduling-order|SectionCERTIFICATE OF SERVICE
Filing RequirementsImportantCivil cases

All instructions shall be designated as “Instruction No. __.”

div-3---civil-pre-trial-conference-order|SectionJOINTLY SUBMITTED PROPOSED JURY INSTRUCTIONS

Filing & Service rules

Electronic Filing Rules

The property ledger must be submitted at the start of trial and must not be filed electronically.

Pursuant to Local Rule, the ledger shall be submitted to the Court at the commencement of trial and shall not be electronically filed.

Civil cases

Page 1 | 5. DISCOVERY CLOSURE DATE

Filing Timing and Cure Windows

Discovery must end by the stated closure date unless the parties agree or the court grants a timely extension motion for good cause before that date.

Discovery may not be conducted after the closure date except by agreement of the parties or a prior order of the Court for good cause shown upon the filing of a timely motion to extend discovery filed before the original closure date.

Civil cases

Page 1 | 5. DISCOVERY CLOSURE DATE

The required property ledger must be prepared and served at least 10 business days before trial.

The property ledger required by Jackson County Circuit Court Local Rule 68.4.2 SHALL BE prepared and served no later than 10 business days before trial – the parties shall use Form 1402J for this purpose.

Civil cases

Page 1 | 5. DISCOVERY CLOSURE DATE

Oppositions or objections to motions in limine, deposition designations, or interrogatory designations must be provided to or filed with the court no later than two days before the pre-trial conference.

Any party opposing same shall provide to the Court and/or file with the Court, their opposition/objections thereto, no later than two days before the pre-trial conference.

Civil cases

Page 1 | PRE-TRIAL MOTIONS/DESIGNATIONS

The parties must jointly submit an annotated set of proposed jury instructions one week before the pre-trial conference.

One week prior to the pre-trial conference, the parties shall jointly submit an annotated (with sources) set of proposed jury instructions.

Civil cases

Page 1 | JOINTLY SUBMITTED PROPOSED JURY INSTRUCTIONS

Motions in limine, deposition designations, and interrogatory designations must be provided to or filed with the court no later than three days before the pre-trial conference.

No later than three days before the pre-trial conference, counsel shall provide to the Court and/or file with the Court all motions in limine, deposition designations, and interrogatory designations.

Civil cases

Page 1 | PRE-TRIAL MOTIONS/DESIGNATIONS

Objections and alternative proposed jury instructions must be submitted one week before trial.

The deadline for submitting objections and alternative proposed instructions is one (1) week before the date of trial.

Civil cases

Page 1 | JOINTLY SUBMITTED PROPOSED JURY INSTRUCTIONS

Service and Proof of Service Rules

All pro se parties receive the scheduling order by U.S. mail.

All pro se parties via U.S. Mail

Page 1 | CC

All counsel receive the scheduling order through electronic notification.

CC: All counsel via e-Notification

Page 1 | CC

CC: All counsel via e-Notification

CC: All counsel via e-Notification

Civil cases

Page 1 | PRE-TRIAL CONFERENCE ORDER

All pro se parties receive the order by U.S. mail.

All pro se parties via U.S. Mail

Civil cases

Page 1 | PRE-TRIAL CONFERENCE ORDER

Courtesy Copy Requirements

Courtesy copies of qualifying pleadings filed with the court must be emailed to Division 3, marked as courtesy copies, and reflect the original filing's file-stamp date.

Courtesy copies of any such pleadings filed with the Court shall be provided to Division 3 (such courtesy copies shall be marked as “courtesy copies” and shall reflect the file stamp date of the original). Courtesy copies shall be emailed to Div3.cir16@courts.mo.gov.

Civil cases

Page 1 | PRE-TRIAL MOTIONS/DESIGNATIONS

Adjournment & Extension Requirements

A continuance will not be granted unless good cause is shown to the court as soon as possible.

NO CONTINUANCES WILL BE GRANTED ABSENT A SHOWING OF GOOD CAUSE MADE KNOWN TO THE COURT AS SOON AS POSSIBLE.

Civil cases

Page 1 | 1. TRIAL

Court-wide rules

Applies court-wide

These 824 rules apply across Jackson County Circuit Court. Where this judge's own standing orders above address the same topic, the judge's requirement controls.

Filing Requirements

All 385
  • Applies to
    Reimbursement claim

    A request for reimbursement of advanced funds must be supported by proper vouchers.

  • Applies to
    Request for nfp

    To place an adult protectee's estate on NFP where all assets are restricted or held in trust with a corporate trustee, the conservator must file the eight listed forms, ledger, account verification, trust instrument, and NFP order.

  • Applies to
    Petition and proposed order

    The conservator may annually file a petition and proposed order to pay specified taxes, bond premiums, tax-return-preparer fees, and related attorney fees without changing the estate's non-final account probable classification.

Filing Timing

All 126

  • The Clerk must provide at least 40 days' notice that a settlement is due, but failure to receive notice does not excuse timely filing.

  • A settlement is due on the anniversary date of the issuance of letters.

  • If a settlement is not timely filed, the court will issue a continuance giving two weeks to file before an order for citation may issue.

Service

All 106
  • Applies to
    Notice of hearing

    For the specified VA-benefit estates, a support-and-maintenance order requires notice to the Veterans Administration unless the agency has waived hearing notice.

  • Service
    Publication

    Notice of filing the final settlement must be published and mailed unless waivers have been obtained, and this requirement does not apply to minors' estates.

  • Service
    Publication

    If the property exceeds $15,000 and less than one year has elapsed since the decedent's death, notice to creditors must be published.

Fees

All 89
  • Applies to
    Show cause order

    Payment of the show cause order's costs is required for dismissal after the exception letter is cleared.

  • Applies to
    Show cause order

    The costs of a show cause order may not be paid from estate assets.

  • Applies to
    Order of nfp

    Outstanding court costs and previously allowed fees must be paid before the court enters an order placing an estate on no further process.

More categories

View all Jackson County Circuit Court rules
About Judge Jerri J. Zhang

Circuit judge for Division 3.

Appointed to the bench: 2021

Current assignment: Civil, Criminal, Domestic

Division email: Div3.cir16@courts.mo.gov

Jackson County Courthouse, 415 E 12th Street, Kansas City, MO 64106 Phone: (816) 881-3658

Judicial Administrative Assistant: Jennifer Hart, Jennifer.Hart@courts.mo.gov Law Clerk: William Youngs, William.Youngs@courts.mo.gov Court Reporter: Christina Ragon, Christina.Ragon@courts.mo.gov

Common questions about Judge Jerri J. Zhang's rules

Are courtesy copies required for Judge Jerri J. Zhang?

Courtesy-copy rule applies for motions in limines, deposition designations, interrogatory designations, oppositions, and objections. Details: by email. Courtesy copies of qualifying pleadings filed with the court must be emailed to Division 3, marked as courtesy copies, and reflect the original filing's file-stamp date.

View ruleSource: page 1, section PRE-TRIAL MOTIONS/DESIGNATIONS

What must be included with property ledger filings before Judge Jerri J. Zhang?

The parties must prepare and serve the required property ledger using Form 1402J no later than 10 business days before trial.

View ruleSource: page 1, section 5. DISCOVERY CLOSURE DATE

What must be included with witness list filings before Judge Jerri J. Zhang?

Prior to the commencement of trial, each party shall prepare a witness list and an exhibit list and provide same to the Court and the court reporter (a suggested witness list and exhibit list are posted on Division 3’s website – counsel may use them or substantially similar forms).

View ruleSource: page 3, section Witnesses, Exhibits and Demonstrative Evidence

How do I request an adjournment or extension before Judge Jerri J. Zhang?

The request must include reason for request. A continuance will not be granted unless good cause is shown to the court as soon as possible.

View ruleSource: page 1, section 1. TRIAL

Is electronic filing required before Judge Jerri J. Zhang?

No. Electronic filing is prohibited for the covered filings. The property ledger must be submitted at the start of trial and must not be filed electronically.

View ruleSource: page 1, section 5. DISCOVERY CLOSURE DATE

What filing deadlines does Judge Jerri J. Zhang set?

Discovery must end by the stated closure date unless the parties agree or the court grants a timely extension motion for good cause before that date.

View ruleSource: page 1, section 5. DISCOVERY CLOSURE DATE

What rule applies to e-service before Judge Jerri J. Zhang?

Details: method: e-service. All counsel receive the scheduling order through electronic notification.

View ruleSource: page 1, section CC
Complete rules summary for Judge Jerri J. Zhang

A continuance will not be granted unless good cause is shown to the court as soon as possible.

Discovery must end by the stated closure date unless the parties agree or the court grants a timely extension motion for good cause before that date.

The parties must prepare and serve the required property ledger using Form 1402J no later than 10 business days before trial.

The required property ledger must be prepared and served at least 10 business days before trial.

The property ledger must be submitted at the start of trial and must not be filed electronically.

The order includes a certificate of service identifying the recipients and the method or methods of service.

Parties may offer during trial additional exhibits that were neither previously listed nor pre-marked.

Each party must number exhibits consecutively, with plaintiff exhibits starting at 1, defendant exhibits starting at 101, and additional parties using corresponding successive number blocks.

An exhibit offered without prior pre-marking must be given to the court reporter for marking and numbering before tender to the Court or witness.

Prior to the commencement of trial, each party shall prepare a witness list and an exhibit list and provide same to the Court and the court reporter (a suggested witness list and exhibit list are posted on Division 3’s website – counsel may use them or substantially similar forms).

All exhibits identified on the exhibit list must be pre-marked before trial begins.

All counsel receive the scheduling order through electronic notification.

All pro se parties receive the scheduling order by U.S. mail.

Motions in limine, deposition designations, and interrogatory designations must be provided to or filed with the court no later than three days before the pre-trial conference.

Each proposed jury instruction must be designated with the label “Instruction No. __.”

Objections and alternative proposed jury instructions must be submitted one week before trial.

Oppositions or objections to motions in limine, deposition designations, or interrogatory designations must be provided to or filed with the court no later than two days before the pre-trial conference.

Courtesy copies of qualifying pleadings filed with the court must be emailed to Division 3, marked as courtesy copies, and reflect the original filing's file-stamp date.

The parties must jointly submit an annotated set of proposed jury instructions one week before the pre-trial conference.

CC: All counsel via e-Notification

All pro se parties receive the order by U.S. mail.

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