Judge Edmond E. Chang
Individual Rules, Standing Orders & Policies
- Rules last changed:
Communication
Phone
Clerk
Page & Word Limits2 rules
Machine summary. Not checked yet.Mandatory?
The neutral description cannot be more than 200 characters (hopefully, you’ll never come close to that limit).
Summary: Neutral description in exhibit names limited to 200 characters.
Structured details unavailable. See the source text.
Machine summary. Not checked yet.Important?
Each side is limited to 15 proposed disputed questions, unless a motion is filed before the pretrial conference that explains good cause for proposing more than the limit.
Summary: Each side is limited to 15 proposed disputed voir dire questions unless good cause shown.
Voir Dire Questions
15 pages
Applies to: Attorney
Document Format Requirements9 rules
Checked against the court's document on Oct 4, 2026Mandatory
Each party must supply exhibits digitally on a USB drive, DVD, or CD and provide one double-sided paper set in three-ring binders with exhibit-number tabs.
In sum, each party shall supply (a) the exhibits in digital format on a USB drive, DVD, or CD; and (b) the exhibits in paper copy (just 1 set), double-sided in three-ring binders. The exhibit binders should separate the exhibits with tabs that correspond to the exhibit number.
Machine summary. Not checked yet.Mandatory?
if an instruction is disputed, the objecting party must concisely state—on the page immediately following the instruction—the grounds for the objection, as well as any proposed modification or alternative.
Summary: Objecting party must state grounds for objection and proposed modification on the page immediately following the disputed instruction.
Machine summary. Not checked yet.Mandatory?
the parties must submit to chambers a USB storage device, DVD, or CD with all of the proposed exhibits. In addition to the disc, the parties also must supply 2 sets of exhibit binders containing copies of objected-to exhibits only.
Summary: Parties must submit a USB/DVD/CD with all proposed exhibits and 2 sets of exhibit binders with objected-to exhibits only.
Machine summary. Not checked yet.Mandatory?
five business days before trial, each party shall supply (a) the exhibits in digital format on a USB drive, DVD, or CD; and (b) the exhibits in paper copy (just 1 set), double-sided in three-ring binders.
Summary: Five business days before trial, each party must supply exhibits on USB/DVD/CD and one paper set double-sided in three-ring binders.
Machine summary. Not checked yet.Mandatory?
JERS accepts these common file types: Documents and Photographs: .pdf, .jpg. Video and Audio Recordings: .avi, .wmv, .mpg, .mp3, .wma, .wav
Summary: JERS accepts specific file types for documents, photos, video, and audio.
Machine summary. Not checked yet.Mandatory?
To use JERS, both sides must use the following exhibit-naming convention, which also will serve as the file name for the digital file: the exhibit number, followed by an underscore, followed by a neutral description of the exhibit. The convention is thus: Examples: 1_Financial Statement 2009 Annual.pdf 2_Contract 2010 Renewal.pdf 3_Photo Front Door.jpg 4_Audio Dec 11 2013 Phone Call.mp3 5_Video Traffic Stop.wmv
Summary: Exhibits must be named with number_underscore_neutral description format.
Machine summary. Not checked yet.Mandatory?
Proposed pretrial orders must be filed electronically using CM/ECF (no need for courtesy copies). To file it, select the appropriate CM/ECF event, “Other Filings” and then “Other Documents,” and choose the Proposed Pretrial Order event. Also email it to Proposed_Order_Chang@ilnd.uscourts.gov in Microsoft Word format.
Summary: Proposed pretrial orders filed electronically via CM/ECF; email Word copy to judge.
DOCX
Machine summary. Not checked yet.Important?
The exhibit binders should separate the exhibits with tabs that correspond to the exhibit number.
Summary: Exhibit binders must have tabs corresponding to exhibit numbers.
Machine summary. Not checked yet.Note?
JERS is a computer system that the jury will use to review exhibits on a wide-screen video monitor, rather than reviewing paper copies. The jury room has the JERS computer, a touch-screen monitor for the jury to pick an exhibit to display, and the wide-screen monitor. JERS can display what otherwise would have been on paper (including photos), and JERS also can play audio and video files.
Summary: JERS allows jury to review digital exhibits on monitors instead of paper copies.
Document Filing Requirements22 rules
Machine summary. Not checked yet.Mandatory?
The parties shall file on the docket a Joint Pretrial Statement with the following items, and also email the complete Statement to Judge Chang's Proposed Order email account in MS Word format.
Summary: Joint Pretrial Statement must be filed on the docket and emailed to chambers in MS Word format.
Document Type
Joint Pretrial Statement
Machine summary. Not checked yet.Mandatory?
On the same date as the Joint Pretrial Statement, each party shall file a list of witnesses (and email an MS Word version to Judge Chang's Proposed Order email account), including expert witnesses, divided into (a) witnesses who will be called; and (b) witnesses who might be called.
Summary: Witness list must be filed on the same date as the Joint Pretrial Statement and emailed to chambers in MS Word format.
Document Type
Witness List
Machine summary. Not checked yet.Mandatory?
Each party must file an exhibit chart (and email an MS Word version to Judge Chang's Proposed Order email account) on the same date as the Joint Pretrial Statement.
Summary: Exhibit chart must be filed on the same date as the Joint Pretrial Statement and emailed to chambers in MS Word format.
Document Type
Exhibit Chart
Machine summary. Not checked yet.Mandatory?
The proposed jury instructions must state, on an instruction-by-instruction basis, the following information: the proponent of the instruction, the legal authority for the instruction, and whether there is an objection to the instruction.
Summary: Proposed jury instructions must include proponent, legal authority, and objection status for each instruction.
Document Type
Jury Instructions
Machine summary. Not checked yet.Mandatory?
One last thing: a physical object of course will not be imported into JERS, but you should still assign a consecutively numbered exhibit designation to it, along with a neutral description. Then create a one-page .pdf with the exhibit number and neutral description on it, and submit those exhibits as part of the JERS disc.
Summary: Physical objects need placeholder PDFs for JERS with exhibit number and description.
Document Type
Physical Exhibit Placeholder
Machine summary. Not checked yet.Mandatory?
Five business days before the pretrial conference, supply the exhibits to the Court (and to the other side) on a USB drive, DVD, or CD. Consistent with the Standing Order, you’ll also be supplying to chambers three paper copies of only the objected-to exhibits, double-sided in three-ring binders.
Summary: Supply exhibits on USB/DVD/CD to court and opposing side 5 business days before pretrial conference; provide 3 double-sided paper copies of objected-to exhibits to chambers in three-ring binders.
Document Type
Exhibits
Machine summary. Not checked yet.Mandatory?
Counsel for the offering party must supply the exhibit in digital format as soon as possible (a thumb drive comes in handy for this), and the courtroom deputy will import it into JERS.
Summary: Supply newly admitted exhibits in digital format as soon as possible for JERS import.
Document Type
Exhibits
Machine summary. Not checked yet.Mandatory?
Five business days before the trial, supply the trial exhibits to the courtroom deputy and to the other side, again on a USB drive, CVD, or CD.
Summary: Supply trial exhibits on USB/DVD/CD to courtroom deputy and opposing side 5 business days before trial.
Document Type
Exhibits
Machine summary. Not checked yet.Mandatory?
No later than 10 business days before the Proposed Pretrial Order’s due date, the parties must serve on each other proposed stipulations and uncontested facts. No later than 5 business days before the due date, the parties must confer in good faith to arrive at as many stipulations and uncontested facts as possible.
Summary: Stipulations must be served 10 days before due date; confer 5 days before.
Document Type
Pretrial Order
Machine summary. Not checked yet.Mandatory?
Any substantive exhibit not objected-to shall be deemed admissible into evidence by this Order (note: for the exhibit to be actually entered into the record for the jury’s consideration, the exhibit still must be referred-to during trial testimony or otherwise published to the jury).
Summary: Unobjected exhibits deemed admissible by pretrial order.
Document Type
Pretrial Order
Machine summary. Not checked yet.Mandatory?
Witnesses who are not on the lists are barred from testifying unless the proponent shows good cause for the failure to disclose the witness.
Summary: Witnesses not on disclosure lists barred from testifying without good cause.
Document Type
Pretrial Order
Machine summary. Not checked yet.Mandatory?
The parties shall stipulate to the authenticity of exhibits whenever possible.
Summary: Parties must stipulate to exhibit authenticity whenever possible.
Document Type
Pretrial Order
Machine summary. Not checked yet.Important?
If an instruction is disputed, the proponent of the instruction should concisely explain the basis for the instruction, if more explanation is required beyond the identified legal authority (often citing to the Pattern or to a case will be explanation enough).
Summary: Proponent of a disputed instruction should concisely explain its basis if needed beyond legal authority.
Document Type
Jury Instructions
Machine summary. Not checked yet.Important?
Unless the parties agree otherwise, the party that is objecting to an exhibit is responsible for providing the copy of the objected-to exhibit.
Summary: The objecting party must provide copies of objected-to exhibits unless parties agree otherwise.
Document Type
Exhibits
Machine summary. Not checked yet.Important?
Santiago motions must be specific in identifying the offered statements, so that the parties may brief, and the Court may analyze, the propriety of each statement.
Summary: Santiago motions must specifically identify the offered statements for briefing and analysis.
Document Type
Motion
Machine summary. Not checked yet.Important?
The same principles apply to proposed verdict forms.
Summary: The same requirements for jury instructions apply to proposed verdict forms.
Document Type
Verdict Form
Machine summary. Not checked yet.Important?
If there are multiple parties on a particular side, then you must coordinate with your co-plaintiff’s or co-defendant’s attorney to generate a consecutively numbered set of exhibits.
Summary: Multiple parties on same side must coordinate exhibit numbering.
Document Type
Exhibit
Machine summary. Not checked yet.Important?
For now, also supply one copy of the exhibits in paper form (hopefully soon we’ll be able to dispense with this requirement, when we have increased confidence in JERS). This paper set will serve as the backup to JERS, in the event that JERS suffers a technical failure during deliberations.
Summary: Supply one paper copy of exhibits as backup to JERS in case of technical failure during deliberations.
Document Type
Exhibits
Machine summary. Not checked yet.Important?
If JERS fails during deliberations, the jury will ask for help in writing. The systems staff will not be permitted in the jury room without the Court’s express permission, and only after the jury has been escorted out of the jury room. If the problem is not fixable in a short time, the Court will provide the jury with the paper-copy backup of the allowed exhibits.
Summary: If JERS fails during deliberations, jury requests help in writing; systems staff requires court permission and jury must be escorted out; paper backup provided if not quickly fixable.
Document Type
Exhibits
Machine summary. Not checked yet.Note?
Where applicable, the Court generally prefers the Seventh Circuit's Pattern Instructions, but of course the parties may propose modifications to the Pattern and may propose additional, non-Pattern Instructions.
Summary: Court prefers Seventh Circuit Pattern Instructions but parties may propose modifications or additional instructions.
Document Type
Jury Instructions
Machine summary. Not checked yet.Note?
Physical-object exhibits that the Court allows the jury to examine during deliberations will be provided to the jury as usual, via the court security officer.
Summary: Physical exhibits for jury examination provided via court security officer during deliberations.
Document Type
Exhibits
Machine summary. Not checked yet.Note?
The jury will not be supplied with paper copies, unless there is good cause for a particular exhibit (or if JERS breaks down).
Summary: Jury receives exhibits only via JERS unless good cause exists or JERS fails.
Document Type
Exhibits
Filing & Service rules
Filing Timing and Cure Windows
The deadline for motions in limine also covers Santiago motions unless set separately.
Unless set separately, the deadline on motions in limine includes Santiago motions by the government to allow co-conspirator statements.
Machine summary. Not checked yet. · Criminal cases
Page 3 | Motions in Limine
Proposed stipulations must be served 5 business days before the pretrial conference.
No later than 5 business days before the pretrial conference, the parties must serve on each other proposed stipulations.
Machine summary. Not checked yet. · Criminal cases
Page 1 | 1. Joint Pretrial Statement
Proposed voir dire questions must be exchanged 5 business days before the Joint Pretrial Statement due date, and parties must confer 2 business days before.
Each side shall provide the other with proposed voir dire questions 5 business days before the due date of the Joint Pretrial Statement, and confer by 2 business days before the due date in order to generate this section of the Statement.
Machine summary. Not checked yet. · Criminal cases
Page 1 | 1. Joint Pretrial Statement
Proposed exhibit charts must be exchanged 10 business days before the filing deadline; objections must be returned 5 business days before the deadline.
The parties must exchange their respective proposed exhibit charts 10 business days before the deadline for filing the charts, and the objecting side must return the chart with the objection column filled in 5 business days before the deadline.
Machine summary. Not checked yet. · Criminal cases
Page 2 | 3. Exhibit Lists and Proposed Exhibits at Pretrial Stage
Pre-Motion Conference Requirements
Motions in limine must be thoroughly briefed; the Court will set a briefing schedule.
The motions in limine must be briefed as thoroughly as possible (the Court will set a briefing schedule in each case).
Machine summary. Not checked yet. · Criminal cases
Page 3 | Motions in Limine
Parties must confer to try to agree on jury instructions and the verdict form.
The parties must confer in order to attempt to agree on as many jury instructions as possible, as well as the verdict form.
Machine summary. Not checked yet. · Criminal cases
Page 3 | Jury Instructions / Verdict Forms
Parties should raise exhibit objections at the pretrial conference to resolve them before trial.
During the pretrial conference, the parties should raise any objections to exhibits that can be resolved before trial, in order to promote an expeditious trial and to avoid sidebars.
Machine summary. Not checked yet. · Criminal cases
Page 3 | Exhibit Lists and Proposed Exhibits at Pretrial Stage
Chambers Communication Rules
For instruction on courtroom display technology, call the Systems Department within the Clerk’s Office at 312.435.6045.
If you need instruction on the courtroom display technology equipment, please call the Systems Department (312.435.6045) within the Clerk’s Office.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 1 | Exhibit-Naming Convention & Exhibit Copies
Jury instructions must be emailed to Judge Chang's Proposed Order email account in MS Word format.
The jury-instructions filing also must be emailed to Judge Chang's Proposed Order email account in MS Word format (a deadline will be set in each case).
Machine summary. Not checked yet. · Criminal cases
Page 3 | Jury Instructions / Verdict Forms
For courtroom display technology instruction, call the Systems Department at 312.435.6045.
If you need instruction on the courtroom display technology equipment, please call the Systems Department (312.435.6045) within the Clerk's Office.
Machine summary. Not checked yet. · Criminal cases
Page 4 | Displaying Exhibits on the Video Monitors