Court Rules
Judge

Judge D. Renee Jackson

Individual Rules, Standing Orders & Policies

Rules last changed:
Circuit Court of Cook County

Limits & Logistics

Document Limits

Brief
15 pgs
Courtesy CopyCourt-wide
20 pgs

Courtesy Copies

Courtesy copies

  • 1 copy • Email
  • Email
  • Hand Delivery

Emergency Motions

  • Email • When Scheduling

File Under Seal Motions

  • Upon Filing

Filings < 25 pages

  • 1 copy • Email • Upon Filing

Adjournments

  • Requests to continue trial dates must be made in writing before the pre-trial conference, showing good cause with a detailed affidavit.

Request must include

Reason For Request

Communication

Clerk31 contacts

  • tlhudson@cookcountycourt.com
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  • probatecrt1814aorders@cookcountycourt.com
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  • probatecrt1811orders@cookcountycourt.com
  • probatecrt1801orders@cookcountycourt.com
  • joseph.fleming@cookcountyil.gov
  • beanaele@cookcountycourt.com
  • snadams@cookcountycourt.com
  • dwhensel@cookcountycourt.com
  • probatedivservices@cookcountycourt.com
  • efilehelp@cookcountycourt.com
  • jlmckay@cookcountycourt.com
  • probate.divatty@cookcountyil.gov
  • (312) 603-5694
  • (312) 603-2486
  • (312) 603-5025
  • (312) 603-6878
  • (312) 603-2591
  • (312) 603-7229
  • (312) 603-3784, (312) 603-5647
  • (312) 603-6558
  • (312) 603-5157
  • (312) 603-5647

Chambers3 contacts

  • (312) 603-5943
  • (312) 603-7546
  • (312) 603-7545

Other Contacts1 contacts

  • efiling.support@tylertech.com
Filters:AllMandatoryImportantFormattingMemorandaExhibitsEvidence/WitnessesTRO/InjunctionBinders/TabsConferencesCertificates

Page & Word Limits1 rule

Page LimitsCivil cases

Machine summary. Not checked yet.Mandatory?

Briefs and memorandums are limited to fifteen (15) double-spaced pages. Except reply briefs are limited to seven (7) double-spaced pages.

Summary: Briefs/memorandums limited to 15 double-spaced pages; reply briefs limited to 7 double-spaced pages.

Brief

15 pages

Applies to: Attorney

Reply Brief

7 pages

Applies to: Attorney

Document Format Requirements1 rule

FormattingCivil cases

Machine summary. Not checked yet.Important?

Citations to authority must comply with Illinois Supreme Court Rule 6 and the Bluebook, using official reporters. Parallel citations are unnecessary. Parties must include pin cites when applicable. As court personnel only have access to LEXIS, parties should provide copies of any cases cited in their memoranda that are not available from the official reporters or LEXIS.

Summary: Citations must follow Illinois Supreme Court Rule 6 and Bluebook, include pin cites, and provide copies of cases not available on LEXIS.

Document Filing Requirements14 rules

Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

A motion for default must include the following documents: • A copy of the notice and motion • The face of the summons • A copy of the return of summons • A certificate of the officer or an affidavit of the person who served the summons • A certificate from the attorney or pro se litigant, confirming that the court file and docket have been checked for any appearance or answer filed by the defendant • A military affidavit if defaulting an individual

Summary: Motions for default must include specific documents: notice and motion, summons face and return, certificate of service, certificate of no appearance/answer, and military affidavit if applicable.

Document Type

Motion For Default

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

All proposed protective orders must include the following language: “The parties must seek leave of court to file documents or other materials containing Confidential Information under seal. To the extent possible, the parties shall redact Confidential Information from documents or other materials filed with the court so as to minimize requests to file under seal. If leave is allowed to file documents or other materials under seal, such documents or other materials shall be submitted in an envelope or other container labeled “CONTAINS CONFIDENTIAL INFORMATION – SEALED PURSUANT TO COURT ORDER” and including the caption of this action and a description of the nature but not the substance of the contents.”

Summary: Proposed protective orders must include specified language about seeking leave to seal, redacting confidential information, and labeling sealed submissions.

Document Type

Proposed Protective Order

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

TRO motions must be accompanied by a verified complaint or an affidavit that complies with § 5/11-101.

Summary: TRO motions must include a verified complaint or affidavit complying with § 5/11-101.

Document Type

TRO Motion

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

Parties must provide the court with: • A copy of the file-stamped motion. • A notice of motion clearly designating it as routine. • A copy of the proposed order.

Summary: Routine motions must include a file-stamped motion, a notice of motion designating it as routine, and a proposed order.

Document Type

Motion

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Important?

If an insurance contract is at issue, the movant (or the insurance company on cross-motions) must provide Bates-stamped copies of the contract, including the application and any relevant certificates. All motions should reference these Bates-stamped copies and need not include the policy as an exhibit.

Summary: When insurance contract is at issue, movant must provide Bates-stamped copies of the contract, application, and certificates; motions should reference these copies.

Document Type

Motion

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Important?

These copies may be submitted via email unless otherwise instructed and should include: • Motion, supporting brief, response brief, reply brief, and all exhibits (tabbed for physical copies and clearly marked for electronic versions). • Sur-response and sur-reply, and if applicable, along with all exhibits. • Most recent complaint. • All relevant pleadings. • The administrative record for administrative review cases.

Summary: Courtesy copy set for contested motions must include motion, briefs, exhibits, complaint, pleadings, and administrative record if applicable.

Document Type

Courtesy Copy

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Important?

Required trial materials include: • A joint short statement outlining the nature of the case. • A list of all potential witnesses, indicating those who will and may testify for each party. • A comprehensive table of contents listing all exhibits each party intends to use at trial. • Exhibits should be page-numbered, tabbed, and presented in binders. • All exhibits shall be listed by the number that the party offering it intends to use at trial, and any stipulations or agreements as to foundations or admissibility.

Summary: Trial materials must include joint statement, witness list, exhibit table of contents, and exhibits in binders with page numbers and tabs.

Document Type

Trial Materials

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Note?

An affidavit of compliance with all Supreme Court Rule 237 notices and a statement of all outstanding disputes regarding such notices.

Summary: Parties must provide an affidavit of compliance with Rule 237 notices and statement of disputes.

Document Type

Affidavit Of Compliance

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Note?

Parties must execute a settlement conference stipulation and consent, available on the court’s website.

Summary: Parties must execute a settlement conference stipulation and consent form.

Document Type

Settlement Conference Stipulation And Consent

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Note?

Copies of all motions in limine and supporting and opposing memoranda. Motions in limine must be discussed between and among counsel in advance of the pre-trial conference to ensure that the motions remaining are those that the parties in good faith cannot resolve before trial.

Summary: Parties must bring copies of motions in limine and memoranda, and discuss them before pre-trial conference.

Document Type

Motion In Limine

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Note?

Copies of any Supreme Court Rule 216 requests to admit and responses thereto which any party anticipates using at trial.

Summary: Parties must bring copies of Rule 216 requests to admit and responses anticipated for trial.

Document Type

Pre Trial Materials

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Note?

Copies of the most recent pleadings (i.e., complaint, answer, counterclaim, third-party complaint with all exhibits attached, and so forth).

Summary: Parties must bring copies of the most recent pleadings with exhibits.

Document Type

Pleadings

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Note?

Parties expecting to offer opinion testimony shall tender responses to Supreme Court Rule 213 interrogatories (with any supplements) and/or deposition testimony that will support the opinion testimony to be offered at trial. If testimony is challenged at trial as not in compliance with Rule 213, the proponent will be expected to promptly locate the previous disclosure demonstrating compliance with the Rule’s requirements.

Summary: Parties offering opinion testimony must tender Rule 213 responses and deposition testimony supporting the opinion.

Document Type

Opinion Testimony Disclosure

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Note?

Evidence depositions, if there are objections requiring rulings.

Summary: Parties must bring evidence depositions if there are objections.

Document Type

Evidence Deposition

Specific requirements detailed in rule text.

Filing & Service rules

Electronic Filing Rules

Motions for alternative service or publication must be spindled on the docket through Odyssey or piggy-backed.

Any motion for alternative service or motion for publication are not considered routine motions and must be spindled on the Court’s docket through Odyssey or “piggy-backed.”

Machine summary. Not checked yet. · Civil cases

Page 3 | f

Special Process Server motions and motions with notice may be filed as routine motions without spindling.

The following motions may be filed as routine motions and do not require spindling with the Clerk’s office: • Special Process Server • See 735 ILCS 5/2-202. • Motions with notice:

Machine summary. Not checked yet. · Civil cases

Page 4 | h

Settlement conference worksheets must not be filed with the clerk; they must be delivered to the court.

The worksheets shall not be filed with the clerk, but delivered to the court no later than fourteen (14) days before the status date set for the conference.

Machine summary. Not checked yet. · Civil cases

Page 7 | VIII. SETTLEMENT CONFERENCES

Filing Timing and Cure Windows

Settlement conference worksheets must be delivered to the court at least 14 days before the status date.

The worksheets shall not be filed with the clerk, but delivered to the court no later than fourteen (14) days before the status date set for the conference.

Machine summary. Not checked yet. · Civil cases

Page 7 | VIII. SETTLEMENT CONFERENCES

Routine motions are accepted Monday through Friday from 9:00 a.m. to 4:00 p.m.

Routine motions and orders will be accepted off-call Monday through Friday from 9:00 a.m. to 4:00 p.m.

Machine summary. Not checked yet. · Civil cases

Page 5 | III. i. Submission Guidelines

Service and Proof of Service Rules

Emergency motions require at least 24 hours notice to opposing party before scheduling.

Except in extraordinary circumstances, the court will not schedule an emergency motion with less than 24 hours notice.

Machine summary. Not checked yet. · Civil cases

Page 4 | g

Courtesy Copy Requirements

Motions under 25 pages require file-stamped courtesy copies emailed to the court.

File-stamped courtesy copies of all motions under twenty-five (25) pages must be emailed to the court.

Machine summary. Not checked yet. · Civil cases

Page 2 | III. MOTIONS

Motions over 25 pages require email and hard copies (tabbed and bound) delivered to Courtroom 2305 at least 7 business days before presentment.

For courtesy copies over twenty-five (25) pages, please email AND deliver hard copies tabbed and bound to Courtroom 2305 at least seven (7) business days before the presentment date.

Machine summary. Not checked yet. · Civil cases

Page 2 | III. MOTIONS

Courtesy copies of motions to file under seal must include both redacted and unredacted versions with proposed redactions highlighted.

Courtesy copies of a motion to file under seal should include both redacted and unredacted versions, with the proposed redactions clearly highlighted, as indicated here.

Machine summary. Not checked yet. · Civil cases

Page 3 | d

Motions to reconsider require courtesy copies of previous briefs.

For any motion requiring the court to rule on prior briefings, such as a motion to reconsider, the movant must also provide courtesy copies of the previous briefs.

Machine summary. Not checked yet. · Civil cases

Page 3 | e

Courtesy copies of prove-up affidavits and draft judgment order must be submitted at least 5 days before prove-up hearing.

Courtesy copies of any prove-up affidavits and a draft judgment order must be submitted to the court at least five (5) days before the prove-up hearing.

Machine summary. Not checked yet. · Civil cases

Page 3 | c

Emergency motions require a courtesy copy of the file-stamped motion marked 'EMERGENCY MOTION' with all supporting documents when scheduling.

The party seeking to obtain a hearing on an emergency motion must contact Calendar 11 chambers after filing the same with the Clerk of the Circuit Court of Cook County by sending an email with a courtesy copy of the file-stamped motion, clearly marked “EMERGENCY MOTION,” along with all supporting documents, must be provided to the law clerk when scheduling the motion.

Machine summary. Not checked yet. · Civil cases

Page 4 | g

Motions over 25 pages require emailed courtesy copies and hard copies tabbed and bound delivered to Courtroom 2305.

For courtesy copies over twenty-five (25) pages, please email AND deliver hard copies tabbed and bound to Courtroom 2305.

Machine summary. Not checked yet. · Civil cases

Page 5 | III. i. Submission Guidelines

Motions under 25 pages require courtesy copies emailed to the court.

Courtesy copies of all motions under twenty-five (25) pages must be emailed to the court.

Machine summary. Not checked yet. · Civil cases

Page 5 | III. i. Submission Guidelines

For contested motions, movant must submit courtesy copies via email upon completion of briefing, including specified documents.

When setting a briefing schedule, the court typically requests that the movant submit a full set of courtesy copies upon completion of briefing. These copies may be submitted via email unless otherwise instructed and should include: • Motion, supporting brief, response brief, reply brief, and all exhibits (tabbed for physical copies and clearly marked for electronic versions). • Sur-response and sur-reply, and if applicable, along with all exhibits. • Most recent complaint. • All relevant pleadings. • The administrative record for administrative review cases.

Machine summary. Not checked yet. · Civil cases

Page 6 | VI. a. Hearings on Contested Motions

Courtesy copies of pleadings must be emailed at least one week before the initial case management conference.

Parties should prepare and submit courtesy copies of their pleadings (e.g., complaint, answer, affirmative defenses, counterclaims, and cross-claims) via email at least one week before the conference. Failure to submit courtesy copies via email may result in a delay of the conference.

Machine summary. Not checked yet. · Civil cases

Page 2 | II. CASE MANAGEMENT CONFERENCES

Sealing & Redaction Procedures

Motions to file under seal must detail privacy interests, be supported by affidavit, include redacted version as exhibit, and cannot apply to all documents; protective orders must state they do not apply to court orders.

Motions to File Under Seal & Protective Orders • Cannot be applied to all documents and/or pleadings. • Must explicitly state that the protective order will not apply to court orders. • The request must detail the privacy interests involved and justify the necessity of the protective order, supported by an affidavit. • Motions to file under seal should include the redacted version as an exhibit. • Courtesy copies of a motion to file under seal should include both redacted and unredacted versions, with the proposed redactions clearly highlighted, as indicated here.

Machine summary. Not checked yet. · Civil cases

Page 3 | d

Adjournment & Extension Requirements

Requests to continue trial dates must be made in writing before the pre-trial conference, showing good cause with a detailed affidavit.

Trial dates are firm. Requests to continue a trial date must be made in writing before the pre-trial conference, demonstrating good cause and supported by a detailed affidavit.

Machine summary. Not checked yet. · Civil cases

Page 7 | Motions to Continue Trial Dates

Chambers Communication Rules

Emergency motions must be scheduled via email to Calendar 11 law clerks; phone calls not required; do not send notice to opposing parties until court confirms scheduling.

All emergency motions must be scheduled via email by one of the Calendar 11 law clerks. The party seeking to obtain a hearing on an emergency motion must contact Calendar 11 chambers after filing the same with the Clerk of the Circuit Court of Cook County by sending an email with a courtesy copy of the file-stamped motion, clearly marked “EMERGENCY MOTION,” along with all supporting documents, must be provided to the law clerk when scheduling the motion. Phone calls to the Calendar 11 law clerks is NOT required. Notice of the motion should not be sent to opposing parties until the court has confirmed scheduling.

Machine summary. Not checked yet. · Civil cases

Page 4 | g

All communications with the court must be made through filed documents, not direct contact.

All communications with the court must be made through the filing of pleadings, motions, applications, petitions, briefs, legal memoranda, etc.

Machine summary. Not checked yet. · Civil cases

Page 1 | General

Direct communications with law clerks are allowed only for administrative and scheduling matters, not substantive legal issues.

Direct communications with law clerks are permitted only for administrative and scheduling matters and not on substantive legal issues or legal advice.

Machine summary. Not checked yet. · Civil cases

Page 1 | General

Court-wide rules

Applies court-wide

These 118 rules apply across Circuit Court of Cook County. Where this judge's own standing orders above address the same topic, the judge's requirement controls.

Communication

All 59
  • Contact
    Email

    Questions, comments, or concerns about the eFileIL e-filing system should be directed to Tyler Technologies at efiling.support@tylertech.com.

  • Contact
    Email to chambers

    Courtesy copies for Judge Daniel R. Degnan must be submitted via email to daniel.degnan@cookcountyil.gov.

  • Contact
    Phone to chambers
    Phone
    (312) 603-5943

    Judge Daniel R. Degnan's chambers phone number is (312) 603-5943.

Filing Timing

All 12
  • Deadline
    60 calendar days

    Attorney fee petitions for court-appointed attorneys must be filed within 60 days after final order or 6 months after service/cost, whichever is earlier.

  • Deadline
    2 business days

    Guardianship agreed order requests must be filed and submitted 2-5 business days prior to the scheduled court date.

  • Deadline
    2 business days

    Guardians must email annual reports and guardian training certificates in PDF format, one email per case, 2-5 business days prior to assigned court date.

Filing Requirements

All 11
  • Applies to
    Complaint
    Must include
    caption

    Chancery Division complaints must include specific caption designations based on the relief sought.

  • Applies to
    Motion
    Must include
    caption

    Motions to correct errors in criminal cases must be in writing, accompanied by affidavit, and notice must be served on the prosecution.

  • Applies to
    Complaint
    Must include
    caption

    All initiating papers must include the court name and department/division/district in the caption; small claims complaints must be endorsed 'Small Claims'.

E-Filing

All 9
  • Applies to
    Civil case filing

    E-filing is mandatory for all Cook County civil cases through the eFileIL system as of July 1, 2018, except Quasi-Criminal, Housing, and Wills cases.

  • Applies to
    Verified status report

    Attorneys must e-file a verified status report via Odyssey system before submitting decedent's estate agreed order requests.

  • Attorneys must maintain accurate email address in Odyssey e-filing system and be filed as attorney of record to receive entered orders via email.

About Judge D. Renee Jackson

D. Renee Jackson is a judge on the Circuit Court of Cook County, the Illinois trial court serving Chicago and suburban Cook County. The court handles general trial matters, including civil, criminal, and family cases.

This judge's published procedures include a settlement conference worksheet and a standing order for Chancery Calendar 11.

Common questions about Judge D. Renee Jackson's rules

Are courtesy copies required for Judge D. Renee Jackson?

Courtesy-copy rule applies when a filing is < 25 pages. Details: 1 copy, delivery upon filing, by email. Motions under 25 pages require file-stamped courtesy copies emailed to the court.

View ruleSource: page 2, section III. MOTIONS

What page or word limits apply to brief before Judge D. Renee Jackson?

Judge D. Renee Jackson's rule states these limits: attorney: 15 pages; attorney: 7 pages. Briefs/memorandums limited to 15 double-spaced pages; reply briefs limited to 7 double-spaced pages.

View ruleSource: page 5, section V. a. Length and Format

What must be included with motion for default filings before Judge D. Renee Jackson?

The rule identifies required filing content or certificates. Motions for default must include specific documents: notice and motion, summons face and return, certificate of service, certificate of no appearance/answer, and military affidavit if applicable.

View ruleSource: page 3, section c

What must be included with proposed protective order filings before Judge D. Renee Jackson?

The rule identifies required filing content or certificates. Proposed protective orders must include specified language about seeking leave to seal, redacting confidential information, and labeling sealed submissions.

View ruleSource: page 3, section d

How may parties contact Judge D. Renee Jackson's chambers?

The rule addresses email communications with Judge D. Renee Jackson's chambers. Emergency motions must be scheduled via email to Calendar 11 law clerks; phone calls not required; do not send notice to opposing parties until court confirms scheduling.

View ruleSource: page 4, section g

How does Judge D. Renee Jackson handle sealed or redacted filings?

A motion to seal is required for covered sealed filings before Judge D. Renee Jackson. Process: file redacted on ecf. Motions to file under seal must detail privacy interests, be supported by affidavit, include redacted version as exhibit, and cannot apply to all documents; protective orders must state they do not apply to court orders.

View ruleSource: page 3, section d

How do I request an adjournment or extension before Judge D. Renee Jackson?

Advance notice is not fully stated in the structured details. The request must include reason for request. Requests to continue trial dates must be made in writing before the pre-trial conference, showing good cause with a detailed affidavit.

View ruleSource: page 7, section Motions to Continue Trial Dates

Is electronic filing required before Judge D. Renee Jackson?

Yes. Electronic filing is required for the covered filings. Motions for alternative service or publication must be spindled on the docket through Odyssey or piggy-backed.

View ruleSource: page 3, section f

What filing deadlines does Judge D. Renee Jackson set?

Settlement conference worksheets must be delivered to the court at least 14 days before the status date.

View ruleSource: page 7, section VIII. SETTLEMENT CONFERENCES

What service or proof of service rules apply before Judge D. Renee Jackson?

The rule addresses service method, recipient, or timing requirements. Details: timing: 24 hours before hearing. Emergency motions require at least 24 hours notice to opposing party before scheduling.

View ruleSource: page 4, section g
Complete rules summary for Judge D. Renee Jackson

All communications with the court must be made through filed documents, not direct contact.

Direct communications with law clerks are allowed only for administrative and scheduling matters, not substantive legal issues.

Motions under 25 pages require file-stamped courtesy copies emailed to the court.

Motions for default must include specific documents: notice and motion, summons face and return, certificate of service, certificate of no appearance/answer, and military affidavit if applicable.

Courtesy copies of prove-up affidavits and draft judgment order must be submitted at least 5 days before prove-up hearing.

Motions over 25 pages require email and hard copies (tabbed and bound) delivered to Courtroom 2305 at least 7 business days before presentment.

Motions to file under seal must detail privacy interests, be supported by affidavit, include redacted version as exhibit, and cannot apply to all documents; protective orders must state they do not apply to court orders.

Proposed protective orders must include specified language about seeking leave to seal, redacting confidential information, and labeling sealed submissions.

Motions to reconsider require courtesy copies of previous briefs.

Motions for alternative service or publication must be spindled on the docket through Odyssey or piggy-backed.

Emergency motions must be scheduled via email to Calendar 11 law clerks; phone calls not required; do not send notice to opposing parties until court confirms scheduling.

Emergency motions require a courtesy copy of the file-stamped motion marked 'EMERGENCY MOTION' with all supporting documents when scheduling.

Emergency motions require at least 24 hours notice to opposing party before scheduling.

TRO motions must include a verified complaint or affidavit complying with § 5/11-101.

Special Process Server motions and motions with notice may be filed as routine motions without spindling.

Courtesy copies of motions to file under seal must include both redacted and unredacted versions with proposed redactions highlighted.

Routine motions must include a file-stamped motion, a notice of motion designating it as routine, and a proposed order.

Routine motions are accepted Monday through Friday from 9:00 a.m. to 4:00 p.m.

Briefs/memorandums limited to 15 double-spaced pages; reply briefs limited to 7 double-spaced pages.

Citations must follow Illinois Supreme Court Rule 6 and Bluebook, include pin cites, and provide copies of cases not available on LEXIS.

When insurance contract is at issue, movant must provide Bates-stamped copies of the contract, application, and certificates; motions should reference these copies.

For contested motions, movant must submit courtesy copies via email upon completion of briefing, including specified documents.

Parties must bring copies of Rule 216 requests to admit and responses anticipated for trial.

Courtesy copy set for contested motions must include motion, briefs, exhibits, complaint, pleadings, and administrative record if applicable.

Trial materials must include joint statement, witness list, exhibit table of contents, and exhibits in binders with page numbers and tabs.

Requests to continue trial dates must be made in writing before the pre-trial conference, showing good cause with a detailed affidavit.

Settlement conference worksheets must be delivered to the court at least 14 days before the status date.

Settlement conference worksheets must not be filed with the clerk; they must be delivered to the court.

Parties must execute a settlement conference stipulation and consent form.

Parties must bring copies of motions in limine and memoranda, and discuss them before pre-trial conference.

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