Chief United States District Judge
Stephen R. Clark
Chambers 14N
Judge’s Requirements (Revised September 3, 2025)
Address
111 S. 10th Street Local and federal rules
Suite 14.148
St. Louis, MO 63102 You may find many answers to frequently asked questions in the Local
Phone
Rules of the Eastern District of Missouri, the Federal Rules of Civil
(314) 244-7540 Procedure, the Federal Rules of Criminal Procedure, and the Federal
Rules of Evidence. I expect counsel to know these rules and to follow
Paralegal them.
Chelsea Langeneckert
Case Management Team
Entry of appearance
John Bernsen
(314) 244-7941 Unless otherwise permitted by the Local Rules, to represent any party
in any case, you must be admitted to practice before this Court, and you
Lauren Jones must file an entry of appearance. If you fail to comply with the Local
(314) 244-7937
Rules or this Requirement, I will not allow you to appear on the
Tiffany Roskowski pleadings, participate in the case, or otherwise represent a party.
(314) 244-7451
Emergency matters
Cassie Thoele
(314) 244-7542
If you have an emergency motion that you believe requires a formal
Law Clerks hearing on the record, you should call my chambers to bring the motion
Ram Desabhotla to my attention and to request a hearing. Counsel also must follow up
Olivia Guidry with an email to my paralegal, Chelsea Langeneckert, at
Nathaniel Shulman
[email protected].
Court Reporter
Reagan Fiorino
(314) 244-7989
Proposed orders
Any proposed order or proposed judgment must be filed electronically as a pdf attachment to the
motion or memorandum to which it pertains. Additionally, the proposed order or judgment must
be emailed to my paralegal, Chelsea Langeneckert, at
[email protected],
in a word processing format.
Criminal case scheduling
Counsel can request a change-of-plea hearing by emailing my paralegal, Chelsea Langeneckert, at
[email protected]. The email should include a copy of the agreed-upon
plea agreement as an attachment. I do not conduct consolidated plea-and-sentencing hearings.
I will hold a status conference approximately three weeks before the scheduled trial date, and
earlier if necessary. If at that time, the parties advise that they intend to proceed with trial, I will
determine whether to conduct the Frye hearing then or schedule it for later. I will also set a pretrial
conference.
Any motion to continue a hearing—e.g., a status conference, change-of-plea hearing, Frye hearing,
or pretrial conference—must include the length of the requested continuance or a proposed date
and opposing counsel’s position on both the motion itself and the length of the continuance or the
proposed date.
The trial date is firm, and the Court will not continue trial without a showing of truly exceptional
reasons. If a party a has true showing of exceptional reasons for continuing a trial date, that party
can file a motion to continue. That motion to continue must include the length of the requested
continuance or a proposed date, and opposing counsel’s position on both the motion itself and the
length of the continuance or the proposed date.
If a criminal defendant requests the continuance of the trial or change-of-plea hearing, the
defendant must also file a waiver of speedy trial, and both the defendant and counsel must
physically sign it.
In cases with multiple defendants, I generally will not consider granting a motion to continue
unless all defendants agree to the continuance of the trial date and file waivers of speedy trial.
If a party must seek a continuance of the sentencing hearing, that party must file a motion as far in
advance of sentencing as possible but no later than 10 days before the hearing, unless the grounds
for the continuance could not have been known at that time. Belated requests for continuances
inconvenience numerous people, including witnesses, victims, court personnel, attorneys, and
others, and hinder the Court’s scheduling of other matters.
Complaints, counterclaims, crossclaims, and responsive pleadings
After filing a complaint, counterclaim, or crossclaim, the party must provide a copy of the filed
pleading to opposing counsel in .doc or .docx format.
When preparing an answer to a complaint, counterclaim, or crossclaim, I strongly encourage the
responding party to: (1) work directly from the .doc or .docx version of the pleading it is
responding to, and (2) include in its answer three things for each allegation it responds to: (a) the
paragraph number of the allegation, (b) the exact text of the allegation, and (c) the answering
party’s response to that allegation. For example, if Plaintiff’s complaint alleges in paragraph two
that Defendant John Doe is a citizen of Missouri, Defendant John Doe’s answer would respond to
that allegation like this:
2. Defendant John Doe is a citizen of Missouri.
Defendant admits this allegation.
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Of course, responding parties must comply with the requirements that relate to partial denials as
set out in Federal Rule of Civil Procedure 8(b)(4).
The provisions of this section do not apply to pro se parties or appeals (e.g., Social Security,
Bankruptcy, and the like).
Motions and memoranda
In both civil and criminal cases, the parties must comply with the response and reply deadlines set
forth in Local Rule 4.01, unless otherwise provided in these Requirements (e.g., discovery-related
motions). As I explain at the Rule 16 conference, absent truly exceptional circumstances, I do not
grant motions for extension of these deadlines. While I understand your multiple competing
priorities, I do this so I can achieve my goal of issuing dispositive-motion rulings 35 days before
trial.
All motions must indicate whether each party consents or objects to the moving party’s request.
In any motion for extension of any deadline, or for leave to vary from the applicable rules or
procedures (including these Requirements), the moving party must specify whether counsel for
each other party consents to the extension. Failing to do so will delay a ruling on the motion and
may result in summary denial. Motions should be filed by consent wherever possible. File the
motion as soon as possible, and before the deadline. Absent a showing of exceptional
circumstances, I do not extend the deadlines for dispositive-motion briefing, as doing so would cut
short the Court’s time to rule on the motion.
If I grant leave and allow a party to file a brief that exceeds the page limitation set forth in Local
Rule 4.01, the brief must have a table of contents and table of authorities.
The following filings must contain precise citations to the record: (1) memoranda in support of
motions for summary judgment, (2) memoranda in opposition to motions for summary judgment,
(3) reply memoranda in support of motions for summary judgment, (4) statements of
uncontroverted material facts, (5) responses to statements of uncontroverted material facts, and (6)
replies to statements of uncontroverted material facts. Citations must include an exhibit number,
page number, and if citing to a transcript, a line number. I will not search the record to find the
evidence on which the parties rely.
I strongly encourage parties to highlight relevant portions of exhibits.
In cases with multiple plaintiffs or multiple defendants, the parties must avoid duplicative filings
of dispositive motions, including statements of undisputed facts. For example, when multiple
movants raise the same or similar issues, they must file a joint motion, with one memorandum in
support. In turn, the respondents must file one joint memorandum in opposition, and the movants
must file one joint reply memorandum. I will not accept separate motions raising the same or
similar issues.
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Parties must avoid multiple filings of summary-judgment motions and motions under Federal Rule
of Evidence 702 or 703 (colloquially referred to as Daubert motions). For summary judgment,
the movant may file only one motion, which incorporates all claims and defenses on which
summary judgment is sought. Likewise, the movant may file only one 702 or 703 motion, which
incorporates all challenged experts.
On summary-judgment motions, multiple movants must file one consolidated statement of
material facts. If necessary, the movants may include sections demarcating facts asserted only by
certain movants. Likewise, multiple respondents must file one consolidated response to the
statement of material facts, also including sections demarcating responses asserted only by one
movant. The same applies to replies to responses to statements of facts. The goal here is to
minimize the number of separate documents that the parties and the Court need to refer to for the
facts.
When moving for leave to amend a pleading, you must include, as exhibits: (1) the amended
pleading with all changes tracked for comparison with the original pleading, and (2) a clean copy
of the amended pleading. When amending a pleading as a matter of right, you must include, as an
exhibit to the amended pleading, the amended pleading with all changes tracked for comparison
with the original pleading.
I strongly encourage parties to highlight relevant portions of exhibits on both the electronically
filed copies and the paper courtesy copies. If a party highlights portions of exhibits, the party must
identically highlight the copies it serves on the opposing parties.
Courtesy copies
I reserve the right to require parties to provide to chambers courtesy copies of filings
Rule 16 conferences
I usually set civil cases for Rule 16 conferences after all defendants have filed a responsive
pleading. If a party believes we need to have a conference sooner, that party should contact my
paralegal, Chelsea Langeneckert, to request an expedited conference. You must notify opposing
counsel before seeking an expedited conference.
Before the conference, I will issue an order setting a Rule 16 conference that requires the parties
to meet and to prepare a proposed Joint Scheduling Plan (JSP). Unless I order otherwise, counsel
for plaintiff is responsible for initiating the meeting and filing the JSP. I encourage the parties to
speak with each other when preparing the JSP, and if counsel have any disagreements, they must
speak with each other to attempt to resolve.
If the parties are unable to resolve disagreements about issues in the JSP after meaningfully
speaking in person or by telephone, they must set forth in the JSP: (1) their respective positions
on the issue and (2) the means they used when trying to resolve the disagreement (whether they
spoke in person or by telephone). I will not accept separate JSPs, even if the parties disagree on
issues.
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Lead trial counsel are required to attend the Rule 16 conference. The attendance of lead counsel
advances the purposes of Rule 16, and (1) it is my first opportunity to manage the case and meet
counsel, (2) it is counsels’ first opportunity to help me manage the case by advising of any
particular issues requiring my attention or guidance, and (3) it allows counsel for both sides to
meet and to further discuss the case with each other. Absent truly exceptional circumstances, I
will not waive the requirement that lead trial counsel appear.
I typically conduct Rule 16 conferences in person in the courtroom. Generally, these proceedings
will be off the record.
When a party appears pro se, I will hold the Rule 16 conference in the courtroom, on the record.
At the Rule 16 conference, you should be prepared to discuss the facts of your case and all other
matters set out in Federal Rules of Civil Procedure 16 and 26(f) and the Rule 16 order itself,
including settlement. I expect all attending counsel to know the case and to be prepared to discuss
all issues, including changes to the proposed schedule and trial setting.
Case-management orders
I manage my docket proactively so that parties can expect to go to trial during the three-week trial
docket set in the Case Management Order. I strictly enforce the deadlines set forth in the CMO.
As I explain at Rule 16 conferences, the following do not constitute exceptional circumstances:
generic “press of other business,” discovery taking longer than expected, or parties’ delay in
initiating or pursuing discovery.
Counsel should read the CMO carefully and refer to it throughout the case. If a party needs to
amend any part of the CMO that is not covered by Federal Rule of Civil Procedure 29, that party
must file a motion to amend before any of the deadlines that party seeks to move pass. The motion
must also specify whether counsel for each other party consents to the amendment. I will grant
the motion only if the movant shows that exceptional circumstances justify the amendment.
Protective orders and sealed documents
Local Rule 13.05 governs filing of sealed documents in both civil and criminal cases. Review that
rule in detail before filing a motion for leave to file under seal. I will deny (generally without
prejudice) motions that fail to comply with that rule or these Requirements.
In civil cases, if you file a proposed protective order that contemplates filing materials under seal,
the proposed order must:
(1) comply with Local Rule 13.05,
(2) require any party seeking to file a document under seal to first file a motion for
leave to file under seal in compliance with Local Rule 13.05 (i.e., you must not
include any provision that allows for automatic filing under seal), and
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(3) include a date certain on which the seal lifts or the documents are removed from
the court file.
I will deny (generally without prejudice) any proposed protective order that fails to comply with
these Requirements or provides for the Court to retain continuing jurisdiction after the case is
resolved.
Discovery disputes
I strongly encourage parties to work out all discovery disputes among themselves. If they are
unable to, Local Rule 3.04 sets out requirements that parties must follow before filing any motion
raising a discovery issue (including motions to compel, motions to quash, and motions for
discovery sanctions). I will not entertain any motion raising a discovery issue unless the parties
have fully complied with Local Rule 3.04 and these Requirements.
Before filing any discovery-related motion, you must meet and confer with opposing counsel and
attempt to resolve the dispute, and you must certify in your motion that you have done so. And
any time I say, “meet and confer,” I mean you must actually speak with one another. Sending
letters, emails, or text messages to one another does not fulfill the meet-and-confer requirement,
and I do not want to see them attached to motions. If opposing counsel does not return your calls
within a reasonable time, you must put the specific dates, times, and methods of contact in your
certification with the motion.
In addition, if any party has a dispute with a nonparty (e.g., regarding a subpoena), the same
procedure applies, and the party must promptly inform the nonparty of my discovery-dispute
requirements. If the nonparty needs me to resolve the dispute, it should follow the procedure
explained above.
In cases involving incarcerated pro se litigants, the Court expects the parties to confer only in
writing before filing a discovery motion.
If the parties cannot settle the dispute themselves, and if they have satisfied Local Rule 3.04 and
these Requirements, they should file an appropriate motion. To make disposition of discovery
disputes efficient, I dispense with the traditional motion-and-memorandum-in-support and instead
use this procedure:
1. The party seeking the Court’s ruling on a discovery issue must only file a one- to
two-page single-spaced motion describing (a) the dispute, (b) how the parties tried
to resolve the dispute, and (c) the party’s legal position.
2. Opposing counsel must then file only a one- to two-page single-spaced response
agreeing with, clarifying, or disputing the assertions in the motion. Counsel should
file the response as soon as possible, but no later than three business days after the
motion was filed. The opposing party must not raise additional discovery issues in
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its response. Instead, if the opposing party wants to have me decide other discovery
disputes, it must comply with Local Rule 3.04 and these Requirements.
3. If the dispute concerns an objection to a specific discovery request, the parties must
submit the specific request and objection simultaneously with the motion or
response.
If I determine that the motion warrants a hearing or additional briefing, I will schedule a video- or
telephone-conference hearing or order briefing as appropriate. Otherwise, I will rule on the motion
in a written order.
Disputes during depositions
If a bona fide dispute arises during a deposition, and the parties are unable to resolve it after
speaking with each other in a good-faith effort, counsel should not hesitate to call my chambers
(314-244-7540). I am usually available by telephone to resolve objections and disputes that arise
during depositions. I will typically do so on the record, so make sure the court reporter for the
deposition is available to transcribe the call.
Discovery objections
Federal Rules of Civil Procedure 33(b)(4), 34(b)(2)(B)–(C), and 36(a)(5) prohibit boilerplate and
general objections in response to discovery requests. Parties should not carelessly raise “standard”
objections such as attorney-client privilege, work-product doctrine, overly broad/unduly
burdensome, irrelevant, and not reasonably calculated to lead to the discovery of admissible
evidence. I will disregard or strike standard, non-specific objections.
Similarly, parties must not include in a response to a discovery request a “Preamble” or a “General
Objections” section stating that the party objects to the discovery request “to the extent that” it
violates some rule pertaining to discovery. Instead, the party must raise a specific objection (or
objections) to each discovery request. This way, the opposing party and I will know exactly what
objection applies to each request.
Discovery stipulations
I encourage parties to stipulate about discovery procedures as set forth in Federal Rule of Civil
Procedure 29. The parties should not file motions on matters covered by Rule 29.
Alternative dispute resolution
I refer civil cases (except habeas corpus and Social Security and bankruptcy appeals) to Alternative
Dispute Resolution, and I encourage parties to view ADR as a process, not an event. For example,
you may schedule multiple mediation sessions over multiple days or weeks if necessary to give
parties time to investigate and absorb information learned in mediation. With virtual mediation,
mediators often will schedule less-than-full-day mediation sessions.
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Unless the parties agree otherwise, counsel for plaintiff will be designated lead counsel for
purposes of coordinating ADR. If the parties agree that someone other than counsel for plaintiff
will serve as lead counsel, they must notify me, in writing, of the agreed-on lead counsel.
Lead counsel must work with opposing counsel to select a neutral. Counsel can get a list of
certified neutrals from the Clerk’s website (http://www.moed.uscourts.gov/neutrals/). The parties
must file a motion seeking permission to appoint a neutral who is not on the list of certified
neutrals. The non-certified neutral must have special subject-matter expertise germane to the case.
All ADR deadlines are binding and may be extended by my order only. If a deadline cannot be
met, the designated lead counsel must file a motion requesting an extension of the deadline before
the expiration of that deadline.
If the parties reach a settlement, they must notify me immediately. I then will enter an order
vacating all pending deadlines and requiring you to file a stipulation for dismissal, a motion for
leave to voluntarily dismiss, or a proposed consent judgment within 30 days.
Pretrial conferences
Counsel should be prepared at the final pretrial conference to argue any motions in limine (and
other preliminary matters), so that I can attempt to rule on them before the trial date. We will put
any necessary argument and all rulings on the record at the end of the pretrial conference or before
the trial starts.
Available courtroom technologies
For all proceedings in open court, I prefer that counsel use the Court’s equipment.
The Court has evidence presentation equipment available, including an evidence camera (e.g.,
ELMO), monitors, and hook ups for computer-stored evidence or computer presentation. You will
find instructions for how to use this equipment on the Court’s website at
http://www.moed.uscourts.gov under Courtroom Technology.
I strongly encourage counsel to use the evidence camera or ELMO for all trials. Please call my
Case Management Team in the Clerk’s Office to schedule training before trial. Training usually
takes no more than 30 minutes and gives you the opportunity to get comfortable with the equipment
before trial. We do not conduct training on the day of trial.
If you intend to use your computer with the Court’s evidence presentation system, you must confer
with the Clerk’s Office before trial to be sure your settings and connections are appropriate for
our system. The Court does not provide equipment to play audio tapes; you will need to bring
your own device.
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Real-time court reporting
My court reporter, Reagan Fiorino, uses real-time court reporting. Reagan’s phone number is 314-
244-7989; her email address is
[email protected]. If you wish to order a daily
copy of the trial transcript, please contact her at least two weeks before trial so she can make
appropriate arrangements.
Decorum and general courtroom rules
I expect counsel to be thoroughly prepared for trial and all hearings.
1. When you arrive, notify the Courtroom Deputy and introduce additional counsel,
support staff, and parties.
2. Counsel must treat each other, all Court personnel, and all witnesses, including
adverse witnesses, professionally and courteously.
3. I do not allow photographs, audio or video recording, or broadcasting in the
courtroom. I do allow laptops and tablets at counsel tables. But if counsel want
someone in the audience to use laptops or tablets, counsel must get advance
approval from me. Please make sure that your clients and witnesses observe these
rules.
4. Stand at all times when speaking.
5. Stand when the jury enters the courtroom.
6. I expect counsel to wear business-professional clothing to all hearings and
conferences.
7. I do not allow eating, drinking (other than water), chewing gum, or carrying audible
beepers or watches.
8. You must turn off your cell phones and other electronic devices, and you may not
use them during court proceedings unless I specifically authorize you to do so.
9. Children are not allowed as spectators unless an adult sits with them in the
spectators’ area. A party to the suit (defendant, attorney, case agent, etc.) cannot
qualify as the attending adult.
Videoconference protocol
To facilitate the flow of the conference and aid in the accuracy of the transcript, I expect parties to
observe the following protocol when participating in videoconferences:
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1. Participate from a quiet place and be aware of your surroundings. Other hearing
participants will have a clear view of the contents of your video frame, including
items around or behind you.
2. Ensure proper lighting.
3. Dress as if you are making a physical appearance in court (see point number 6,
above).
4. Mute yourself when you are not speaking.
5. Avoid talking over others. Wait until the current speaker finishes talking before
you begin to speak.
Additional sources of information that may help answer your questions include:
• The Court’s Local Rules,
• The Federal Judiciary Homepage,
• The Federal Judicial Center, and
• The United States Sentencing Commission.
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