Judge Stanley J. Wallach
Individual Rules, Standing Orders & Policies
Limits & Logistics
Courtesy Copies
Courtesy copies
- At Least One Week Before Hearing
Document Format Requirements1 rule
The courtesy copies shall be in a binder or otherwise securely bound, shall separately tab each document, and shall contain an index identifying what document is contained under each tab.
- Binding
- Securely bound
- Courtesy copy
Formatting
- •Separately tab each document
Document Filing Requirements2 rules
Counsel must file a joint memorandum in the attached form, stating the meeting date and format, attending attorneys with bar numbers, meeting length, unresolved disputes with discovery requests/objections attached, and a certification that clients were informed.
Court's wording
file their joint Memorandum with the Court, substantially in the form attached hereto, setting forth: 1. The date of the meeting, and whether the meeting was in person or by video conference; 2. The names and bar numbers of the attorneys attending the meeting; 3. The length of the meeting; 4. A brief description of the discovery disputes not resolved at the meeting, with a copy of the discovery request(s) and the objection(s) thereto attached; and 5. A certification by counsel that their respective clients have been informed of the meeting and the inability of counsel to resolve their discovery disputes without a court appearance.
In the event of such refusal, the moving party shall advise the Court in its motion as to what sanctions it seeks against the non-complying party.
Filing & Service rules
Filing Timing and Cure Windows
Oral argument may be requested in writing within ten days of filing a motion, or set by the Court.
For all motions filed in this Division, oral argument may be allowed at the discretion of the Court if requested in writing by either party within ten days of the filing of the motion, or if set for oral argument by the Court.
Page 1 | Standing Order on Oral Arguments
If oral argument is not requested or is denied, the motion may be ruled on the written record without prior notice.
If no party requests oral argument, or if the Court denies a request for oral argument, any motion may be ruled on by the Court on the written record without prior notice to any attorney or party.
Page 1 | Standing Order on Oral Arguments
Courtesy Copy Requirements
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.
In addition to the requirements of the Missouri Rules of Civil Procedure and the requirements of the Local Rules of the 21st Judicial Circuit, counsel for any party setting for hearing a motion for summary judgment shall, at least one week prior to the hearing date, deliver courtesy copies of the following to the Division 12 chambers: 1. The operative pleadings (motion, statement of uncontroverted material facts, memorandum in support, response, memorandum in opposition, response to statement of facts, statement of additional facts, if any, reply, response to additional facts, if any, movant’s statement of additional facts, if any, and sur- reply, if any); 2. Exhibits critical to the argument; 3. Copies of the primary authorities relied on by the parties (no more than 3 cases per party); and 4. The movant’s proposed judgment required by Local Rule 33.6.
Civil cases
Page 1 | SUMMARY JUDGMENT COURTESY COPIES
Filing Bundling Requirements
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.
In cases involving cross-motions for summary judgment, it shall be the responsibility of counsel for the party first filing a motion for summary judgment to prepare and deliver the binder.
Civil cases
Page 1 | SUMMARY JUDGMENT COURTESY COPIES
Pre-Motion Conference Requirements
No discovery dispute will be heard unless counsel meet at least once in person or by video conference in good faith and file a joint memorandum before obtaining a hearing date.
no discovery disputes, including motions to compel discovery responses or motions for sanctions, will be heard in Division 12 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
Civil cases
Page 1 | DISCOVERY DISPUTES IN ALL CIVIL CASES