Judge Jerri J. Zhang
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Motions In Limine, Deposition Designations, Interrogatory Designations, Opposition, Objections
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
Communication
Phone
Court-widePhone
Court-widePhone
Court-wideDocument Format Requirements4 rules
Checked against the court's document on Oct 1, 2026Mandatory
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.
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.
Checked against the court's document on Oct 1, 2026Important
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.
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.
Checked against the court's document on Oct 1, 2026Note
Parties may offer during trial additional exhibits that were neither previously listed nor pre-marked.
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.
We could not find this wording in the court's document. Open the source before relying on it.Important?
All exhibits identified on the exhibit list shall be pre-marked prior to the commencement of trial.
Machine summary and details
Summary: All exhibits identified on the exhibit list must be pre-marked before trial begins.
Document Filing Requirements4 rules
Checked against the court's document on Oct 1, 2026Mandatory
The parties must prepare and serve the required property ledger using Form 1402J no later than 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.
Document Type
Property Ledger
Checked against the court's document on Oct 1, 2026Important
Each proposed jury instruction must be designated with the label “Instruction No. __.”
All instructions shall be designated as “Instruction No. __.”
Document Type
Jury Instructions
Not confirmed. Read the court's wording below.Mandatory?
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).
Summary: Before trial, each party must prepare and provide a witness list to the Court and court reporter, using the suggested list or a substantially similar form.
Document Type
Witness List
Not confirmed. Read the court's wording below.Important?
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.
Summary: The order includes a certificate of service identifying the recipients and the method or methods of service.
Document Type
Scheduling Order
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.
Not confirmed. Read the court's wording below. · 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.
Checked and corrected to match the court's document on Oct 1, 2026 · 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.
Checked and corrected to match the court's document on Oct 1, 2026 · Civil cases
Page 1 | 5. DISCOVERY CLOSURE DATE
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.
Checked against the court's document on Oct 1, 2026 · 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.
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 1 | JOINTLY SUBMITTED PROPOSED JURY INSTRUCTIONS
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.
Not confirmed. Read the court's wording below. · 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.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | JOINTLY SUBMITTED PROPOSED JURY INSTRUCTIONS
Service and Proof of Service Rules
All counsel receive the scheduling order through electronic notification.
CC: All counsel via e-Notification
Checked against the court's document on Oct 1, 2026
Page 1 | CC
All pro se parties receive the scheduling order by U.S. mail.
All pro se parties via U.S. Mail
Not confirmed. Read the court's wording below.
Page 1 | CC
All counsel are to receive courtesy copies through e-Notification.
CC: All counsel via e-Notification
Not confirmed. Read the court's wording below. · 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
Not confirmed. Read the court's wording below. · 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.
Not confirmed. Read the court's wording below. · 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.
Checked against the court's document on Oct 1, 2026 · Civil cases
Page 1 | 1. TRIAL