Judge Franklin U. Valderrama
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- 1 copy
- Chambers Drop Off • 28 Days Before Pretrial Conference
- Chambers Drop Off • 5 Days After Pretrial Conference
Exhibits, Deposition Transcripts
Communication
Chambers
Clerk
Chambers
Phone
Chambers
Page & Word Limits7 rules
Checked against the court's document on Oct 4, 2026Mandatory
Each side may file a total of 15 pages of motions in limine, excluding exhibits; the limit applies per side, not per motion.
Motions in limine (not including exhibits) are limited to a total of 15 pages per side (not per motion).
Motion In Limine
15 pages
Not confirmed. Read the court's wording below.Mandatory?
Motions in limine (not including exhibits) are limited to a total of 15 pages per side (not per motion).
Summary: Each side’s motions in limine are limited to 15 total pages, excluding exhibits; the limit is per side, not per motion.
Motion In Limine
15 pages
Not confirmed. Read the court's wording below.Mandatory?
Responses (not including exhibits) are limited to a total of 15 pages per side, not per motion.
Summary: Responses to Plaintiff’s motions in limine are limited to 15 pages per side, excluding exhibits, in total across motions.
Response
15 pages
Machine summary. Not checked yet.Mandatory?
Each side is limited to 15 proposed disputed questions, unless a motion is filed before the Pre-Trial Conference that explains good cause for proposing more than the limit.
Summary: Each side limited to 15 disputed voir dire questions unless good cause shown.
Structured details unavailable. See the source text.
Machine summary. Not checked yet.Mandatory?
Unless otherwise ordered, all motions in limine shall be e-filed 35 days (5 weeks) before the Pre-Trial Conference; responses are due and shall be e-filed 21 days (3 weeks) before the Pre-Trial Conference; and replies are due and shall be e-filed 14 days (2 weeks) before the Pre-Trial Conference.
Summary: Motions in limine must be e-filed 35 days before Pre-Trial Conference; responses due 21 days; replies due 14 days.
Motion In Limine
Not confirmed. Read the court's wording below.Mandatory?
Responses (not including exhibits) are limited to a total of 15 pages per side, not per motion.
Summary: Responses to Plaintiff’s motions in limine are limited to 15 pages per side, excluding exhibits, regardless of the number of motions.
Response
15 pages
Not confirmed. Read the court's wording below.Important?
Each side is limited to 15 proposed disputed questions, unless a motion is filed before the Pre-Trial Conference that explains good cause for proposing more than the limit.
Summary: Each side may propose no more than 15 disputed questions unless it files a pre-trial-conference motion explaining good cause for more.
Voir Dire Questions
Document Format Requirements36 rules
Checked against the court's document on Oct 4, 2026Mandatory
The parties must use the JERS exhibit-file format and exhibit-naming convention when creating and naming electronic exhibits.
With regard to creating and naming the electronic versions of the exhibits, the parties must use the exhibit-file format and exhibit-naming convention for the Jury Evidence Recording System (JERS).
Checked against the court's document on Oct 4, 2026Mandatory
The parties must work together to provide the jury with one binder of all admitted exhibits, separated by tabs, for deliberations.
In order to minimize the possibility of disruption due to technical issues, the parties shall work together to provide one binder containing all admitted exhibits, with tabs separating exhibits, to be sent back to the jury for deliberations.
Checked against the court's document on Oct 4, 2026Mandatory
Exhibits supplied to the Court must be in digital format and named using the specified convention.
With JERS, the jury can zoom-in on parts of an exhibit and search for text, and for audio and video, there’s no need for a party to supply the jury with a laptop for deliberations. Thanks in advance for your patience as we continue to adapt JERS. JERS is not directly used to present evidence in court during trial; right now, it’s just used to display exhibits during deliberations. But JERS does indirectly affect your trial preparation because you must supply your exhibits to the Court in digital format, and you must name your exhibits using a specific convention.
Checked against the court's document on Oct 4, 2026Mandatory
Each digital exhibit filename must use a three-digit exhibit number, an underscore, a neutral exhibit description, and the file extension.
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 (3 digits), followed by an underscore, followed by a neutral description of the exhibit. The convention is thus: <exhibit number>_<exhibit description>.<file extension> 5
Checked against the court's document on Oct 4, 2026Mandatory
Hard-copy exhibits and deposition transcripts must be double-sided, placed in a three-ring binder, and separated by tabs.
The exhibits and/or deposition transcripts must be printed double-sided and placed in a three-ring binder with tabs separating each exhibit and/or deposition transcript.
Checked against the court's document on Oct 4, 2026Mandatory
Provide one binder containing each final trial exhibit and qualifying deposition transcript, printed double-sided with tabs separating each item.
One binder containing a copy of each final trial exhibit and final deposition transcript that will be read in place of live testimony. The exhibits and/or final deposition transcripts must be printed double-sided and placed in a three-ring binder with tabs separating each exhibit and/or deposition transcript.
Checked against the court's document on Oct 4, 2026Important
The exhibit chart must be substantially similar in format to the example; landscape orientation is encouraged but not required.
The chart’s format shall be substantially similar to the example below (landscape orientation is encouraged).
Checked against the court's document on Oct 4, 2026Important
Trial exhibits must use the JERS exhibit format and naming convention.
Just as at the pre-trial stage, when preparing exhibits for the trial itself, once again use the JERS exhibit format and naming convention.
Checked against the court's document on Oct 4, 2026Important
Do not renumber exhibits after the Pre-Trial Conference, even if the Court deemed some inadmissible.
After the Pre-Trial Conference, do not renumber the exhibits, even if during the Pre-Trial Conference the Court deemed some of them inadmissible.
Checked against the court's document on Oct 4, 2026Important
Exhibits must use consecutive numbers, not letters or exhibit parts, and their neutral descriptions may not exceed 200 characters.
Use consecutive numbers to designate exhibits; do not use letters to distinguish exhibits. Also, do not use an “exhibit part,” such as 1A or 2A. Just use consecutive numbers (plus the neutral description). The neutral description cannot be more than 200 characters (hopefully, you’ll never come close to that limit).
Checked against the court's document on Oct 4, 2026Important
The exhibit chart must substantially follow the provided example’s format; landscape orientation is encouraged but not required.
The chart’s format shall be substantially similar to the example below (landscape orientation is encouraged).
Checked against the court's document on Oct 4, 2026Important
Final exhibit files must use the specified P- or D-numbered naming format.
The file name of each exhibit shall be P-1 or D-1, P-2 or D-2, etc.
Checked against the court's document on Oct 4, 2026Important
Exhibit files must use the specified P- or D-numbered naming format and have OCR-text recognition.
The file name of each exhibit shall be P-1 or D-1, P-2 or D-2, etc. All exhibits must have OCR-text recognition run on them.
Checked against the court's document on Oct 4, 2026Note
Digital exhibit stickers are permitted, but should show only the party designation and exhibit number.
If you’re using litigation-display software that imprints a “digital” exhibit sticker on documentary exhibits, that’s fine, though you should confine the exhibit sticker to the party designation (e.g., Pla or Gov, and Def) and the exhibit number.
Not confirmed. Read the court's wording below.Mandatory?
One binder containing a copy of each party’s proposed exhibits and deposition transcripts to which the opposing party has raised an objection. The exhibits and/or deposition transcripts must be printed double-sided and placed in a three-ring binder with tabs separating each exhibit and/or deposition transcript. Unless the parties agree otherwise, the party that is offering the exhibit or deposition transcript is responsible for providing the copy of the objected-to exhibit or deposition transcript.
Summary: Each party must provide one tabbed three-ring binder of the specified objected-to materials, printed double-sided, unless the parties agree otherwise; the offering party provides the copy.
Not confirmed. Read the court's wording below.Mandatory?
A USB Key/Thumb Drive with no password protection 3 containing a .pdf of each of each party’s own proposed exhibits and deposition transcripts to which the opposing party has raised an objection. The parties must use the exhibit-file format and exhibit-naming convention for JERS. See Exhibit 3. All exhibits must have OCR- text recognition run on them.
Summary: The pre-conference USB drive must contain PDFs of the specified objected-to materials, follow JERS file and naming conventions, and include exhibits with OCR text recognition.
Not confirmed. Read the court's wording below.Mandatory?
A USB Key/Thumb Drive with no password protection 4 containing a .pdf of each final trial exhibit and final deposition transcript that will be read in place of live testimony. The parties must use the exhibit-file format and exhibit-naming convention for JERS. See Exhibit 3.
Summary: The post-conference USB drive must be unpassworded and contain PDFs of final trial exhibits and deposition transcripts to be read instead of live testimony, following JERS file and naming conventions.
Not confirmed. Read the court's wording below.Mandatory?
One binder containing a copy of each final trial exhibit and final deposition transcript that will be read in place of live testimony. The exhibits and/or deposition transcripts must be printed double-sided and placed in a three-ring binder with tabs separating each exhibit and/or deposition transcript. For deposition transcripts, please see above, see supra Section VII.a.
Summary: Each party must provide one three-ring binder of final trial exhibits and specified deposition transcripts, printed double-sided and tabbed.
Not confirmed. Read the court's wording below.Mandatory?
JERS does not accept .xls files. All spreadsheets need to be submitted as a .pdf file.
Summary: Spreadsheets submitted for JERS must be PDFs because JERS does not accept XLS files.
Not confirmed. Read the court's wording below.Mandatory?
One binder containing one copy of each admitted exhibit. The binder must include the filed exhibits list as the first page, and must include tabs separating exhibits.
Summary: Provide one binder containing one copy of each admitted exhibit, with the filed exhibit list first and tabs separating the exhibits.
Not confirmed. Read the court's wording below.Mandatory?
If Plaintiff puts on a rebuttal case, if new exhibits are admitted, after Plaintiff rests and before closing arguments, after consulting with Defendant, Plaintiff must file an updated exhibit list, including the exhibits admitted during Plaintiff’s case-in- chief and the exhibits admitted during Plaintiff’s rebuttal case, and distinguish which exhibits were admitted during the rebuttal case. Plaintiff must also provide to the Courtroom Deputy a USB Key/Thumb Drive and a binder of hard copies including only the new exhibits admitted during Plaintiff’s rebuttal case.
Summary: If new exhibits are admitted during Plaintiff’s rebuttal case, Plaintiff must provide the Courtroom Deputy a USB drive and a binder containing only those new exhibits.
Machine summary. Not checked yet.Mandatory?
With regard to creating and naming the electronic versions of the exhibits, the parties must use the exhibit-file format and exhibit-naming convention for the Jury Evidence Recording System (JERS).
Summary: Electronic exhibits must use JERS format and naming convention.
Machine summary. Not checked yet.Mandatory?
A USB Key/Thumb Drive with no password protection 1 containing a .pdf of
Summary: USB key/thumb drive must have no password protection.
Machine summary. Not checked yet.Mandatory?
One binder containing a copy of any proposed exhibits to which a party has raised an objection. The exhibits must be printed double-sided and placed in a three-ring binder with tabs separating each exhibit. Unless the parties agree otherwise, the party that is offering an exhibit is responsible for providing the copy of the objected-to exhibit.
Summary: Objected exhibits must be double-sided in tabbed three-ring binder.
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?
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 USB Key/Thumb Drive.
Summary: Physical objects need numbered exhibit designation and one-page PDF stand-in for JERS.
Machine summary. Not checked yet.Mandatory?
One binder containing a copy of each final trial exhibit. The exhibits must be printed double-sided and placed in a three-ring binder with tabs separating each exhibit.
Summary: Final trial exhibits must be double-sided in tabbed three-ring binder.
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 (3 digits), followed by an underscore, followed by a neutral description of the exhibit. The convention is thus: <exhibit number> <exhibit description>.<file extension>
Summary: Exhibits must follow specific naming convention: 3-digit number, underscore, neutral description.
Machine summary. Not checked yet.Mandatory?
For any exhibits that a party plans to use at trial to impeach a witness or to refresh a witness’s recollection, the party must provide the exhibits on the USB Key/Thumb Drive in a separate folder titled “Impeachment and RR Exhibits.” The party must also include in this folder a separate .pdf exhibit chart of these exhibits in a format similar to the primary exhibit chart, with only columns for exhibit number, date, and description. The party should begin numbering these exhibits at least 50 numbers after its last exhibit on its primary exhibit chart. The party need not provide hard copies of these exhibits in advance of trial.
Summary: Impeachment/RR exhibits require separate USB folder with chart, no hard copies.
Machine summary. Not checked yet.Mandatory?
A USB Key/Thumb Drive with no password protection 2 containing a .pdf of each final trial exhibit. The parties must use the exhibit-file format and exhibit-naming convention for JERS. See Exhibit 3. All exhibits must have OCR-text recognition run on them.
Summary: Final trial exhibits must be on password-free USB drive with OCR.
We could not find this wording in the court's document. Open the source before relying on it.Mandatory?
A USB Key/Thumb Drive with no password protection 3 containing a .pdf of each of each party’s own proposed exhibits and deposition transcripts to which the opposing party has raised an objection.
Machine summary and details
Summary: The pre-conference USB drive must be unpassword-protected and contain PDFs of the party’s proposed exhibits and objected-to deposition transcripts.
Document Filing Requirements122 rules
Checked against the court's document on Oct 4, 2026Mandatory
The exhibit chart must cover exhibits the party will definitely use, including demonstratives, summaries, and specially prepared exhibits, and provide each exhibit’s number, applicable date, concise neutral description, and concise statement of relevance.
The party must submit an exhibit chart of the exhibits the party will definitely use at trial (including demonstratives, summaries, or other specially prepared exhibits), which includes the following: (a) the exhibit number; (b) the date of the document or exhibit, if applicable; (c) a concise, neutral description of the exhibit; and (d) a concise statement of the exhibit’s relevance.
Document Type
Exhibit Chart
Checked against the court's document on Oct 4, 2026Mandatory
Absent exceptional circumstances, deposition testimony is not allowed unless the Pre-Trial Statement identifies it and includes a deposition designation chart.
Finally, absent exceptional circumstances, the Court will not allow the introduction of witness testimony via deposition unless the party’s Pre-Trial Statement so indicated and the party provided a deposition designation chart with its Pre-Trial Statement.
Document Type
Pretrial Statement
Checked against the court's document on Oct 4, 2026Mandatory
Defendant must use Plaintiff’s Word exhibit chart, add an objection column with concise explanations when applicable, and retain rows for exhibits without objections.
Defendant shall use the Microsoft Word version of Plaintiff’s Exhibit Chart, and add a column to the chart listing whether there is an objection to the exhibit, and if so, a concise explanation of the objection, similar to the example below. If Defendant does not have an objection to a specific exhibit, Defendant shall not remove that row from Plaintiff’s Exhibit Chart, but instead can leave the objection column for that exhibit row blank.
Document Type
Exhibit Chart
Checked against the court's document on Oct 4, 2026Mandatory
Except for foundation objections, objections omitted from the exhibit charts are waived unless the objecting party shows no prejudice or good cause at trial.
Apart from objections to foundation, all other objections not included on the exhibit charts shall be deemed waived, unless the objecting party shows at trial an absence of prejudice to the opposing party or good cause for the failure to object to the exhibit in the pretrial materials.
Document Type
Exhibit Chart Objections
Checked against the court's document on Oct 4, 2026Mandatory
Defendant must use Plaintiff’s Word deposition chart and add a column listing objections with concise grounds; the text also directs Defendant not to remove designations without objections.
Defendant shall use the Microsoft Word version of Plaintiff’s Deposition Designation Chart, and add a column to the chart listing any objections, including a concise basis for the objection, similar to the Exhibit Chart. If Defendant does not have an objection to a specific deposition designation, Defendant shall not remove
Document Type
Deposition Designation Chart Objections
Checked against the court's document on Oct 4, 2026Mandatory
The Pre-Trial Memorandum must list trial attorneys’ contact information and the names of everyone sitting at counsel table.
A list of the attorneys trying the case, including e-mail addresses, telephone numbers (both office and cell phone numbers), and business addresses. A list of the names of all people who will be sitting at counsel table, including parties, consultants, legal and technical assistants, etc., should also be provided.
Document Type
Pre Trial Memorandum
Checked against the court's document on Oct 4, 2026Mandatory
The Pre-Trial Memorandum must contain the information specified in the listed sections.
The Pre-Trial Memorandum shall contain the following information:
Document Type
Pre Trial Memorandum
Checked against the court's document on Oct 4, 2026Mandatory
The parties must confer in good faith about stipulations and uncontested facts no later than two business days before the joint pre-trial memorandum is due.
No later than 2 business days before the due date of the joint Pre-Trial Memorandum, the parties must confer in good faith to arrive at as many stipulations and uncontested facts as possible.
Document Type
Pretrial Memorandum
Checked against the court's document on Oct 4, 2026Mandatory
The pre-trial memorandum must state estimated trial length, plaintiff and defendant subtotals, and proposed opening and closing argument time limits per side.
State the estimated number of trial days, including jury selection and deliberations, premised on six-hour trial-testimony days (the six hours already accounts for lunch and breaks). Provide estimated sub-totals for Plaintiff’s case and Defendant’s case. Propose time limits for opening statements and closing arguments, per side.
Document Type
Pretrial Memorandum
Checked against the court's document on Oct 4, 2026Mandatory
The pre-trial memorandum must set out stipulations and uncontested facts in numbered paragraphs.
In numbered paragraphs, set forth any stipulations and uncontested facts.
Document Type
Pretrial Memorandum
Checked and corrected to match the court's document on Oct 4, 2026Mandatory
For a disputed instruction, the objecting party must state the objection grounds and any proposed modification or alternative on the immediately following page.
Moreover, 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.
Document Type
Jury Instructions
Checked against the court's document on Oct 4, 2026Mandatory
The stated instruction-submission principles also apply to proposed verdict forms.
The same principles apply to proposed verdict forms.
Document Type
Verdict Form
Checked against the court's document on Oct 4, 2026Mandatory
Each proposed jury instruction must identify its proponent, legal authority, and whether it is objected to.
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.
Document Type
Jury Instructions
Checked against the court's document on Oct 4, 2026Mandatory
Additional juror-questionnaire questions must be filed in separate agreed and objected-to categories, with a short basis for each objection.
For additional questions to be included on the juror questionnaires, the parties must file a list divided into (a) agreed-upon questions and (b) proposed questions to which there is an objection. A short basis for any objection must accompany the list.
Document Type
Voir Dire Questions
Checked against the court's document on Oct 4, 2026Mandatory
The parties must confer to attempt to agree on as many jury instructions as possible and on 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.
Document Type
Jury Instructions
Checked against the court's document on Oct 4, 2026Mandatory
Lead trial counsel for each party must attend the Pre-Trial Conference.
Document Type
Pretrial Conference
Checked against the court's document on Oct 4, 2026Mandatory
Impeachment and refreshing-recollection exhibits must be placed in a separately named USB folder with a PDF chart limited to three specified columns; numbering should start at least 50 numbers after the primary chart’s last exhibit, and advance hard copies are not required.
For any exhibits that a party plans to use at trial to impeach a witness or to refresh a witness’ recollection, the party must include such exhibits on the above USB Key/Thumb Drive in a separate folder titled “Impeachment and RR Exhibits.” The party must also include in this folder a separate .pdf exhibit chart of these exhibits in a format similar to the primary exhibit chart, with only columns for exhibit number, date, and description. The party should begin numbering these exhibits at least 50 numbers after its last exhibit on its primary exhibit chart. The party need not provide hard copies of these exhibits in advance of trial.
Document Type
Impeachment And Refreshing Recollection Exhibits
Checked against the court's document on Oct 4, 2026Mandatory
The filed exhibit list must identify agreed demonstratives for deliberations and any disagreements about admitted exhibits or demonstratives.
The filed list must include any demonstratives the parties agree may be used during deliberations (keeping in mind that the default is that demonstratives will not be used during deliberations), as well as any disagreements about exhibits admitted into evidence or demonstratives to go back with the jury.
Document Type
Exhibit List
Checked against the court's document on Oct 4, 2026Mandatory
Plaintiff must provide the Courtroom Deputy a USB drive and one binder containing only new exhibits admitted during rebuttal.
Plaintiff must also provide to the Courtroom Deputy a USB Key/Thumb Drive and one binder including only the new exhibits admitted during Plaintiff’s rebuttal case.
Document Type
Exhibits
Checked against the court's document on Oct 4, 2026Mandatory
Plaintiff must submit a USB drive and one binder of hard-copy exhibits to the Courtroom Deputy as detailed in Exhibit 3.
Plaintiff must also submit a USB Key/Thumb Drive and one binder containing hard copies of exhibits to the Courtroom Deputy, as detailed in Exhibit 3.
Document Type
Exhibits
Checked against the court's document on Oct 4, 2026Mandatory
Defendant must provide the Courtroom Deputy a USB drive and a binder of hard-copy exhibits as described in Exhibit 3.
Defendant must also provide to the Courtroom Deputy a USB Key/Thumb Drive and a binder containing hard copies, as described in Exhibit 3.
Document Type
Exhibits
Checked against the court's document on Oct 4, 2026Mandatory
The parties must exchange proposed exhibits before the pretrial conference.
This in turn affects your preparation even for the pretrial conference, because Judge Valderrama requires that the parties exchange proposed exhibits before the pretrial conference (more on this below).
Document Type
Proposed Exhibits
Checked against the court's document on Oct 4, 2026Mandatory
No later than one calendar day after Plaintiff’s case-in-chief closes, Plaintiff must submit to the Courtroom Deputy one password-free USB drive containing each admitted exhibit in JERS-required format, with OCR-text recognition applied.
At the same time (no later than one calendar day after the close of Plaintiff’s case-in-chief), Plaintiff must submit the following to the Courtroom Deputy the following: a. USB Key/Thumb Drive One USB Key/Thumb Drive with no password protection containing each admitted exhibit in the format required by JERS. The exhibits must have OCR-text recognition run on them.
Document Type
Exhibits
Checked against the court's document on Oct 4, 2026Mandatory
After the defense rests and before closing arguments, Defendant must consult Plaintiff, file its list of admitted trial exhibits following the referenced instructions, and provide the Courtroom Deputy a USB drive and hard copies.
After Defendant rests and before closing arguments, after consulting with Plaintiff, Defendant must file on the docket its list of Defendant’s exhibits which were admitted into evidence during trial, following the same instructions included above regarding Plaintiff’s list. Defendant must also provide to the Courtroom Deputy a USB Key/Thumb Drive and Hard Copies, as described above.
Document Type
Exhibit List
Checked and corrected to match the court's document on Oct 4, 2026Mandatory
If Plaintiff presents a rebuttal case and new exhibits are admitted, Plaintiff must consult Defendant, file an updated list distinguishing rebuttal exhibits after resting and before closing arguments, and provide the Courtroom Deputy a USB drive and a binder containing only the new rebuttal exhibits.
If Plaintiff puts on a rebuttal case, if new exhibits are admitted, after Plaintiff rests and before closing arguments, after consulting with Defendant, Plaintiff must file an updated exhibit list, including the exhibits admitted during Plaintiff’s case-in- chief and the exhibits admitted during Plaintiff’s rebuttal case, and distinguish which exhibits were admitted during the rebuttal case. Plaintiff must also provide to the Courtroom Deputy a USB Key/Thumb Drive and a binder of hard copies including only the new exhibits admitted during Plaintiff’s rebuttal case.
Document Type
Exhibit List
Checked against the court's document on Oct 4, 2026Mandatory
Absent exceptional circumstances, deposition testimony will not be allowed unless the Pre-Trial Statement identifies it and includes a deposition designation chart.
Finally, absent exceptional circumstances, the Court will not allow the introduction of witness testimony via deposition unless the party’s Pre-Trial Statement so indicated and the party provided a deposition designation chart with its Pre-Trial Statement.
Document Type
Pretrial Statement
Checked against the court's document on Oct 4, 2026Mandatory
The exhibit chart must cover exhibits the party definitely intends to use, including demonstratives, summaries, and specially prepared exhibits, and include the specified identifying, descriptive, and relevance information.
The party must submit an exhibit chart of the exhibits the party will definitely use at trial (including demonstratives, summaries, or other specially prepared exhibits), which includes the following: (a) the exhibit number; (b) the date of the document or exhibit, if applicable; (c) a concise, neutral description of the exhibit; and (d) a concise statement of the exhibit’s relevance.
Document Type
Exhibit Chart
Checked against the court's document on Oct 4, 2026Mandatory
For witnesses whose deposition testimony will be used instead of live testimony, the party must list them and provide the applicable Rule 32 provision and a brief explanation next to each name.
Additionally, pursuant to Federal Rule of Civil Procedure 32, the party must provide a list of witnesses for which it intends to use deposition testimony at trial in lieu of live testimony. Next to the witness’s name, the party shall cite to the applicable provision of Rule 32 allowing for use of the deposition and provide a brief explanation.
Document Type
Witness List
Checked against the court's document on Oct 4, 2026Mandatory
Defendant must use Plaintiff’s Word exhibit chart and add an objection column with a concise explanation for each objection.
Defendant shall use the Microsoft Word version of Plaintiff’s Exhibit Chart, and add a column to the chart listing whether there is an objection to the exhibit, and if so, a concise explanation of the objection, similar to the example below.
Document Type
Objections To Exhibit Chart
Checked against the court's document on Oct 4, 2026Mandatory
Except for foundation objections, an objection omitted from the exhibit charts is waived unless the objecting party shows no prejudice or good cause at trial.
Apart from objections to foundation, all other objections not included on the exhibit charts shall be deemed waived, unless the objecting party shows at trial an absence of prejudice to the opposing party or good cause for the failure to object to the exhibit in the pretrial materials.
Document Type
Exhibit Chart Objections
Checked against the court's document on Oct 4, 2026Mandatory
A party must move an exhibit into evidence before publishing it to the Court during trial.
During the trial, for the clarity of the record, a party must still move the exhibit into evidence before publishing it to the Court.
Document Type
Exhibit
Not confirmed. Read the court's wording below.Mandatory?
The party must provide a list of witnesses, including expert witnesses and rebuttal witnesses, identifying the following: 1. witnesses that the party will call to testify at trial; 2. witnesses that the party may call to testify at trial; and 3. witnesses whose testimony the party plans to present by deposition or other prior testimony, indicating whether the presentation will be by transcript or video.
Summary: The witness list must include expert and rebuttal witnesses and identify witnesses who will testify, may testify, or will be presented through prior testimony, including whether that presentation is by transcript or video.
Document Type
Pretrial Statement
Filing & Service rules
Electronic Filing Rules
The jury-instructions filing must also be emailed to the specified address in Microsoft Word format on the day the pre-trial memorandum is due.
The jury-instructions filing also must be e-mailed to Proposed_Order_Valderrama@ilnd.uscourts.gov in Microsoft Word format the same day the Pre-Trial Memorandum is due.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 10 | h. Jury Instructions / Verdict Forms
Defendant must e-file objections to Plaintiff’s Exhibit Chart as part of its Pre-Trial Statement and Objections.
Defendant shall then e-file Defendant’s Objections to Plaintiff’s Exhibit Chart as part of Defendant’s Pre-Trial Statement and Objections.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 5 | II. Exchange and Filing of Trial Materials – Defendant’s Pre-Trial Statement and Objections
Defendant must e-file objections to Plaintiff’s Deposition Designation Chart as part of its Pre-Trial Statement and Objections.
Defendant shall then e-file Defendant’s Objections to Plaintiff’s Deposition Designation Chart as part of Defendant’s Pre-Trial Statement and Objections.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 6 | II. Exchange and Filing of Trial Materials – Defendant’s Pre-Trial Statement and Objections
To e-file it, select the appropriate CM/ECF event, then choose “Other Filings,” “Other Documents,” and the Supplement event.
To e-file it, select the appropriate CM/ECF event, “Other Filings” and then “Other Documents,” and choose the Supplement event.
Checked and corrected to match the court's document on Oct 4, 2026 · Civil cases
Page 7 | III. Exchange and Filing of Materials – Plaintiff’s Pre-Trial Objections
File the Pre-Trial Statement in CM/ECF using the Supplement event under Other Filings and Other Documents.
To e-file it, select the appropriate CM/ECF event, “Other Filings” and then “Other Documents,” and choose the Supplement event.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | I. Exchange and Filing of Trial Materials – Plaintiff’s Pre-Trial Statement
Defendant must e-file the exhibit-chart objections as part of the Pre-Trial Statement and separately email a Word version to the specified chambers address.
Defendant shall then e-file Defendant’s Objections to Plaintiff’s Exhibit Chart as part of Defendant’s Pre-Trial Statement and Objections. Separately, Defendant shall e-mail a Microsoft Word version of Defendant’s Objections to Plaintiff’s Exhibit Chart to Proposed_Order_Valderrama@ilnd.uscourts.gov.
Not confirmed. Read the court's wording below. · Civil cases
Page 5 | II.d. Objections to Plaintiff’s Exhibit Chart
Defendant must e-file the Pre-Trial Statement and Objections using CM/ECF 42 days before the Pre-Trial Conference.
42 days (6 weeks) before the Pre-Trial Conference, Defendant shall e-file Defendant’s Pre-Trial Statement and Objections, comprised of the below items (listed in Section II.a–g) using CM/ECF.
Not confirmed. Read the court's wording below. · Civil cases
Page 5 | II. Exchange and Filing of Trial Materials – Defendant’s Pre-Trial Statement and Objections
Plaintiff must e-file objections to Defendant’s Exhibit Chart as part of Plaintiff’s Pre-Trial Objections.
Plaintiff shall then e-file Plaintiff’s Objections to Defendant’s Exhibit Chart as part of Plaintiff’s Pre-Trial Objections.
Not confirmed. Read the court's wording below. · Civil cases
Page 7 | III.a. Objections to Defendant’s Exhibit Chart
Defendant must separately email a Microsoft Word version of the objections to the specified address.
Separately, Defendant shall e-mail a Microsoft Word version of Defendant’s Objections to Plaintiff’s Deposition Designation Chart to Proposed_Order_Valderrama@ilnd.uscourts.gov.
Not confirmed. Read the court's wording below. · Civil cases
Page 7 | II. Exchange and Filing of Trial Materials – Defendant’s Pre-Trial Statement and Objections
Plaintiff must e-file the specified Pre-Trial Objections through CM/ECF 35 days before the Pre-Trial Conference.
35 days (5 weeks) before the Pre-Trial Conference, Plaintiff shall e-file Plaintiff’s Pre-Trial Objections, comprised of the below items (listed in Section III.a– d) using CM/ECF.
Not confirmed. Read the court's wording below. · Civil cases
Page 7 | III. Exchange and Filing of Materials – Plaintiff’s Pre-Trial Objections
Defendant must e-file the objections as part of Defendant’s Pre-Trial Statement and Objections.
Defendant shall then e-file Defendant’s Objections to Plaintiff’s Deposition Designation Chart as part of Defendant’s Pre-Trial Statement and Objections.
Not confirmed. Read the court's wording below. · Civil cases
Page 7 | II. Exchange and Filing of Trial Materials – Defendant’s Pre-Trial Statement and Objections
Plaintiff must separately email a Microsoft Word version of the exhibit-chart objections to the specified address.
Separately, Plaintiff shall e-mail a Microsoft Word version of Plaintiff’s Objections to Defendant’s Exhibit Chart to Proposed_Order_Valderrama@ilnd.uscourts.gov.
Not confirmed. Read the court's wording below. · Civil cases
Page 7 | III.a. Objections to Defendant’s Exhibit Chart
Plaintiff must separately email a Microsoft Word version of the deposition-designation objections to the specified address.
Separately, Plaintiff shall e-mail a Microsoft Word version of Plaintiff’s Objections to Defendant’s Deposition Designation Chart to Proposed_Order_Valderrama@ilnd.uscourts.gov.
Not confirmed. Read the court's wording below. · Civil cases
Page 8 | III.b. Objections to Defendant’s Deposition Designation Chart
Plaintiff must e-file objections to Defendant’s Deposition Designation Chart as part of Plaintiff’s Pre-Trial Objections.
Plaintiff shall then e-file Plaintiff’s Objections to Defendant’s Deposition Designation Chart as part of Plaintiff’s Pre-Trial Objections.
Not confirmed. Read the court's wording below. · Civil cases
Page 8 | III.b. Objections to Defendant’s Deposition Designation Chart
Plaintiff must e-file the parties’ jointly prepared Pre-Trial Memorandum 28 days before the Pre-Trial Conference.
28 days (4 weeks) before the Pre-Trial Conference, Plaintiff shall e-file the parties’ jointly prepared Pre-Trial Memorandum.
Not confirmed. Read the court's wording below. · Civil cases
Page 8 | IV. Final Pre-Trial Memorandum
Plaintiff must additionally email a Microsoft Word version of the Pre-Trial Memorandum to the specified address.
Additionally, Plaintiff shall e-mail a Microsoft Word version of the Pre-Trial Memorandum to Proposed_Order_Valderrama@ilnd.uscourts.gov.
We could not find this wording in the court's document. Open the source before relying on it. · Civil cases
Page 8 | IV. Final Pre-Trial Memorandum
Plaintiff must e-file the Pre-Trial Statement and its listed components 49 days before the Pre-Trial Conference, subject to any controlling deadlines in the Court’s minute entry.
49 days (7 weeks) before the Pre-Trial Conference, Plaintiff shall e-file Plaintiff’s Pre-Trial Statement, comprised of the below items (listed in Section I.a–d) using CM/ECF.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | I. Exchange and Filing of Trial Materials – Plaintiff’s Pre-Trial Statement
Defendant must e-file the Pre-Trial Statement and Objections using CM/ECF 42 days before the Pre-Trial Conference.
42 days (6 weeks) before the Pre-Trial Conference, Defendant shall e-file Defendant’s Pre-Trial Statement and Objections, comprised of the below items (listed in Section II.a–g) using CM/ECF.
Not confirmed. Read the court's wording below. · Civil cases
Page 4 | II. Exchange and Filing of Trial Materials – Defendant’s Pre-Trial Statement and Objections
Plaintiff must e-file the deposition-designation objections with the Pre-Trial Objections and separately email a Microsoft Word version to the specified address.
Plaintiff shall then e-file Plaintiff’s Objections to Defendant’s Deposition Designation Chart as part of Plaintiff’s Pre-Trial Objections. Separately, Plaintiff ===== PAGE 8 ===== shall e-mail a Microsoft Word version of Plaintiff’s Objections to Defendant’s Deposition Designation Chart to Proposed_Order_Valderrama@ilnd.uscourts.gov.
Not confirmed. Read the court's wording below. · Civil cases
Page 7 | III.b. Objections to Defendant’s Deposition Designation Chart
Plaintiff must e-file the exhibit-chart objections with the Pre-Trial Objections and separately email a Microsoft Word version to the specified address.
Plaintiff shall then e-file Plaintiff’s Objections to Defendant’s Exhibit Chart as part of Plaintiff’s Pre-Trial Objections. The Court’s statements regarding objections in Section II.d apply here as well. Separately, Plaintiff shall e-mail a Microsoft Word version of Plaintiff’s Objections to Defendant’s Exhibit Chart to Proposed_Order_Valderrama@ilnd.uscourts.gov.
Not confirmed. Read the court's wording below. · Civil cases
Page 7 | III.a. Objections to Defendant’s Exhibit Chart
Plaintiff must e-file the Pre-Trial Objections using CM/ECF 35 days before the Pre-Trial Conference.
35 days (5 weeks) before the Pre-Trial Conference, Plaintiff shall e-file Plaintiff’s Pre-Trial Objections, comprised of the below items (listed in Section III.a– d) using CM/ECF.
Not confirmed. Read the court's wording below. · Civil cases
Page 7 | III. Exchange and Filing of Materials – Plaintiff’s Pre-Trial Objections
Plaintiff must e-file the jointly prepared Pre-Trial Memorandum 28 days before the conference and separately email a Microsoft Word version to the specified address.
28 days (4 weeks) before the Pre-Trial Conference, Plaintiff shall e-file the parties’ jointly prepared Pre-Trial Memorandum. Additionally, Plaintiff shall e- mail a Microsoft Word version of the Pre-Trial Memorandum to Proposed_Order_Valderrama@ilnd.uscourts.gov.
Not confirmed. Read the court's wording below. · Civil cases
Page 8 | IV. Final Pre-Trial Memorandum
When e-filing the Pre-Trial Statement, select the CM/ECF event path “Other Filings,” then “Other Documents,” and choose “Supplement.”
To e-file it, select the appropriate CM/ECF event, “Other Filings” and then “Other Documents,” and choose the Supplement event.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | I. Exchange and Filing of Trial Materials – Plaintiff’s Pre-Trial Statement
Filing Timing and Cure Windows
Plaintiff’s Pre-Trial Objections must be e-filed 35 days before the Pre-Trial Conference.
35 days (5 weeks) before the Pre-Trial Conference, Plaintiff shall e-file Plaintiff’s Pre-Trial Objections, comprised of the below items (listed in Section III.a– d) using CM/ECF.
Checked and corrected to match the court's document on Oct 4, 2026 · Civil cases
Page 7 | III. Exchange and Filing of Materials – Plaintiff’s Pre-Trial Objections
The jointly prepared Pre-Trial Memorandum must be e-filed 28 days before the Pre-Trial Conference.
28 days (4 weeks) before the Pre-Trial Conference, Plaintiff shall e-file the parties’ jointly prepared Pre-Trial Memorandum.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 8 | IV. Final Pre-Trial Memorandum
Each party must deliver the specified materials to chambers 28 days before the Pre-Trial Conference.
28 days (4 weeks) before the Pre-Trial Conference, each party shall have delivered to chambers the following:
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 11 | V. Exhibits and Deposition Designations – Before Pre-Trial Conference
After Defendant rests and before closing arguments, Defendant must consult Plaintiff and file its admitted-exhibit list following the instructions for Plaintiff’s list.
After Defendant rests and before closing arguments, after consulting with Plaintiff, Defendant must file on the docket its list of Defendant’s exhibits which were admitted into evidence during trial, following the same instructions included above regarding Plaintiff’s list.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 14 | d. Exhibits at Trial
Plaintiff must confer with Defendant and file its admitted-exhibit list no later than one calendar day after its case-in-chief closes.
As explained in detail in Exhibit 3, no later than one calendar day after the close of Plaintiff’s case-in-chief, Plaintiff must confer with Defendant about admitted exhibits and file on the docket its list of Plaintiff’s exhibits which were admitted into evidence during trial.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 14 | d. Exhibits at Trial
If new exhibits are admitted during Plaintiff’s rebuttal case, Plaintiff must consult Defendant and file an updated list after resting and before closing arguments, distinguishing rebuttal exhibits.
If Plaintiff puts on a rebuttal case, if new exhibits are admitted, after Plaintiff rests and before closing arguments, after consulting with Defendant, Plaintiff must file an updated exhibit list, including the exhibits admitted during Plaintiff’s case-in- chief and the exhibits admitted during Plaintiff’s rebuttal case, and distinguish which exhibits were admitted during the rebuttal case.
Checked and corrected to match the court's document on Oct 4, 2026 · Civil cases
Page 14 | d. Exhibits at Trial
Within one calendar day after Plaintiff’s case-in-chief closes, Plaintiff must consult Defendant and file a docket list of its trial exhibits admitted into evidence.
No later than one calendar day after the closing of Plaintiff’s case-in-chief, after consulting with Defendant, Plaintiff must file on the docket its list of Plaintiff’s exhibits which were admitted into evidence during trial.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 26 | 6. Close of Plaintiff’s Case-in-Chief and Close of Evidence
If Plaintiff presents a rebuttal case and new exhibits are admitted, Plaintiff must file the updated list after resting and before closing arguments, after consulting Defendant.
If Plaintiff puts on a rebuttal case, if new exhibits are admitted, after Plaintiff rests and before closing arguments, after consulting with Defendant, Plaintiff must file an updated exhibit list, including the exhibits admitted during Plaintiff’s case-in- chief and the exhibits admitted during Plaintiff’s rebuttal case, and distinguish which exhibits were admitted during the rebuttal case. Plaintiff must also provide to the Courtroom Deputy a USB Key/Thumb Drive and a binder of hard copies including only the new exhibits admitted during Plaintiff’s rebuttal case.
Checked and corrected to match the court's document on Oct 4, 2026 · Civil cases
Page 27 | Plaintiff’s Rebuttal Case
Defendant must file its admitted-exhibits list after resting and before closing arguments, following consultation with Plaintiff.
After Defendant rests and before closing arguments, after consulting with Plaintiff, Defendant must file on the docket its list of Defendant’s exhibits which were admitted into evidence during trial, following the same instructions included above regarding Plaintiff’s list. Defendant must also provide to the Courtroom Deputy a USB Key/Thumb Drive and Hard Copies, as described above.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 27 | Close of Defense Case
Defendant’s Pre-Trial Statement and Objections are due 42 days before the Pre-Trial Conference.
42 days (6 weeks) before the Pre-Trial Conference, Defendant shall e-file Defendant’s Pre-Trial Statement and Objections, comprised of the below items (listed in Section II.a–g) using CM/ECF.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 4 | II. Exchange and Filing of Trial Materials – Defendant’s Pre-Trial Statement and Objections
Plaintiff’s Pre-Trial Objections are due 35 days before the Pre-Trial Conference.
35 days (5 weeks) before the Pre-Trial Conference, Plaintiff shall e-file Plaintiff’s Pre-Trial Objections, comprised of the below items (listed in Section III.a– d) using CM/ECF.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 7 | III. Exchange and Filing of Materials – Plaintiff’s Pre-Trial Objections
The jointly prepared Pre-Trial Memorandum is due 28 days before the Pre-Trial Conference.
28 days (4 weeks) before the Pre-Trial Conference, Plaintiff shall e-file the parties’ jointly prepared Pre-Trial Memorandum. Additionally, Plaintiff shall e- mail a Microsoft Word version of the Pre-Trial Memorandum to Proposed_Order_Valderrama@ilnd.uscourts.gov.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 8 | IV. Final Pre-Trial Memorandum
After Defendant rests and before closing arguments, Defendant must consult Plaintiff and docket a list of Defendant’s admitted trial exhibits following the instructions for Plaintiff’s list.
After Defendant rests and before closing arguments, after consulting with Plaintiff, Defendant must file on the docket its list of Defendant’s exhibits which were admitted into evidence during trial, following the same instructions included above regarding Plaintiff’s list.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 12 | VIII. Additional Pre-Trial Information – Exhibits at Trial
Within one calendar day after Plaintiff’s case-in-chief closes, Plaintiff must confer with Defendant about admitted exhibits and docket a list of Plaintiff’s admitted exhibits.
No later than one calendar day after the close of Plaintiff’s case-in-chief, Plaintiff must confer with Defendant about admitted exhibits and file on the docket its list of Plaintiff’s exhibits which were admitted into evidence during trial.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 12 | VIII. Additional Pre-Trial Information – Exhibits at Trial
If new exhibits are admitted during Plaintiff’s rebuttal case, Plaintiff must consult Defendant and file an updated list after resting and before closing arguments, identifying rebuttal exhibits separately.
If Plaintiff puts on a rebuttal case, if new exhibits are admitted, after Plaintiff rests and before closing arguments, after consulting with Defendant, Plaintiff must file an updated exhibit list, including the exhibits admitted during Plaintiff’s case-in- chief and the exhibits admitted during Plaintiff’s rebuttal case, and distinguish which exhibits were admitted during the rebuttal case.
Checked and corrected to match the court's document on Oct 4, 2026 · Civil cases
Page 12 | VIII. Additional Pre-Trial Information – Exhibits at Trial
The Court may change the listed deadlines, and the submission dates in its minute entry before the Pre-Trial Conference control.
The Court may change the below deadlines and will specify exact submission deadlines in a minute entry before the Pre-Trial Conference. The dates in the minute entry shall govern timing of submission of the documents below.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 1
The Court will schedule the Pre-Trial Conference two to three weeks before trial begins.
The Court will schedule the Pre-Trial Conference two to three weeks before the commencement of trial.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 10 | VI. Pre-Trial Conference
Plaintiff must e-file the Pre-Trial Statement and its listed components 49 days before the Pre-Trial Conference, subject to the Court’s later-specified deadlines.
49 days (7 weeks) before the Pre-Trial Conference, Plaintiff shall e-file Plaintiff’s Pre-Trial Statement, comprised of the below items (listed in Section I.a–d) using CM/ECF.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | I. Exchange and Filing of Trial Materials – Plaintiff’s Pre-Trial Statement
Each party must deliver the specified materials to chambers five days after the Pre-Trial Conference.
5 days following the Pre-Trial Conference, each party shall have delivered to chambers the following:
Not confirmed. Read the court's wording below. · Civil cases
Page 11 | VII. Exhibits and Deposition Designations – After Pre-Trial Conference
Plaintiff must submit the Pre-Trial Statement 49 days before the Pre-Trial Conference, unless the Court’s minute entry specifies different controlling deadlines.
49 days (7 weeks) before the Pre-Trial Conference, Plaintiff shall e-file Plaintiff’s Pre-Trial Statement, comprised of the below items (listed in Section I.a–d) using CM/ECF.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | I. Exchange and Filing of Trial Materials – Plaintiff’s Pre-Trial Statement
The Court will schedule the Pre-Trial Conference two to three weeks before trial begins.
The Court will schedule the Pre-Trial Conference two to three weeks before the commencement of trial.
Not confirmed. Read the court's wording below. · Civil cases
Page 11 | VI. Pre-Trial Conference
Service and Proof of Service Rules
Plaintiff must separately email Defendant Microsoft Word versions of the Exhibit Chart and Deposition Designation Chart.
Separately, Plaintiff shall e-mail a Microsoft Word version of Plaintiff’s Exhibit Chart and Plaintiff’s Deposition Designation Chart to Defendant.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 1 | I. Exchange and Filing of Trial Materials – Plaintiff’s Pre-Trial Statement
Defendant must separately email Plaintiff Microsoft Word versions of Defendant’s Exhibit Chart and Deposition Designation Chart.
Separately, Defendant shall e-mail a Microsoft Word version of Defendant’s Exhibit Chart and Defendant’s Deposition Designation Chart to Plaintiff.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 5 | II. Exchange and Filing of Trial Materials – Defendant’s Pre-Trial Statement and Objections
The parties must serve proposed stipulations on each other at least five business days before the joint pre-trial memorandum is due.
No later than 5 business days before the due date of the joint Pre-Trial Memorandum, the parties must serve on each other proposed stipulations.
Checked and corrected to match the court's document on Oct 4, 2026 · Civil cases
Page 9 | e. Stipulations and Uncontested Facts
The parties must serve proposed jury instructions on each other at least five business days before the joint memorandum is due and confer by two business days before the due date.
No later than 5 business days before the due date of the joint Pre-Trial Memorandum, the parties must serve on each other proposed jury instructions, and confer by 2 business days before the due date in order to generate this section of the Pre-Trial Memorandum.
Checked and corrected to match the court's document on Oct 4, 2026 · Civil cases
Page 10 | h. Jury Instructions / Verdict Forms
Each side must provide proposed voir dire questions to the other five business days before the joint memorandum is due and confer by two business days before its due date.
Each side shall provide the other with proposed voir dire questions 5 business days before the due date of the joint Pre-Trial Memorandum, and confer by 2 business days before the due date in order to generate this section of the Pre-Trial Memorandum.
Checked and corrected to match the court's document on Oct 4, 2026 · Civil cases
Page 10 | g. Voir Dire Questions
Plaintiff must separately email Defendant Microsoft Word versions of the Exhibit Chart and Deposition Designation Chart.
Separately, Plaintiff shall e-mail a Microsoft Word version of Plaintiff’s Exhibit Chart and Plaintiff’s Deposition Designation Chart to Defendant.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 1 | I. Exchange and Filing of Trial Materials – Plaintiff’s Pre-Trial Statement
Defendant must email Plaintiff Microsoft Word versions of its Exhibit Chart and Deposition Designation Chart.
Separately, Defendant shall e-mail a Microsoft Word version of Defendant’s Exhibit Chart and Defendant’s Deposition Designation Chart to Plaintiff.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 5 | II. Exchange and Filing of Trial Materials – Defendant’s Pre-Trial Statement and Objections
The parties must serve proposed stipulations on each other at least five business days before the joint Pre-Trial Memorandum is due.
No later than 5 business days before the due date of the joint Pre-Trial Memorandum, the parties must serve on each other proposed stipulations.
Checked and corrected to match the court's document on Oct 4, 2026 · Civil cases
Page 9 | e. Stipulations and Uncontested Facts
A request to use exhibits during opening statements must be made to the opposing party at least two business days before trial begins.
Any request for the use of exhibits during opening statements must be made to the opposing party no later than two business days before the start of trial.
Checked and corrected to match the court's document on Oct 4, 2026 · Civil cases
Page 11 | VIII. Additional Pre-Trial Information – Opening Statement
Courtesy Copy Requirements
Unless the parties agree otherwise, the party offering an objected-to exhibit or deposition transcript must provide its copy.
Unless the parties agree otherwise, the party that is offering the exhibit or deposition transcript is responsible for providing the copy of the objected-to exhibit or deposition transcript.
Checked and corrected to match the court's document on Oct 4, 2026 · Civil cases
Page 10 | V.b. Hard Copies
Microsoft Word version of exhibit chart must be emailed to chambers.
Each party shall also e-mail a Microsoft Word version of the chart to Proposed_Order_Valderrama@ilnd.uscourts.gov.
Machine summary. Not checked yet. · Criminal cases
Page 3 | III. Exhibit Charts
Each party must deliver the specified trial materials to chambers 28 days before the Pre-Trial Conference.
28 days (4 weeks) before the Pre-Trial Conference, each party shall have delivered to chambers the following:
Not confirmed. Read the court's wording below. · Civil cases
Page 9 | V. Exhibits and Deposition Designations – Before Pre-Trial Conference
Each party must deliver the specified final trial materials to chambers five days after the Pre-Trial Conference.
5 days following the Pre-Trial Conference, each party shall have delivered to chambers the following:
Not confirmed. Read the court's wording below. · Civil cases
Page 10 | VII. Exhibits and Deposition Designations – After Pre-Trial Conference
Each party must provide one binder containing its proposed exhibits and objected-to deposition transcripts.
One binder containing a copy of each party’s proposed exhibits and deposition transcripts to which the opposing party has raised an objection.
Not confirmed. Read the court's wording below. · Civil cases
Page 10 | V.b. Hard Copies
Filing Bundling Requirements
Multiple motions in limine should be submitted in one document with exhibits.
Parties filing multiple motions in limine should submit their initial motions and the supporting exhibits in one document for the Court. Responses to motions in limine and replies in support of motions in limine should also be submitted in one document.
Machine summary. Not checked yet. · Criminal cases
Page 6 | IV. Motions in Limine
Pre-Motion Conference Requirements
The parties must confer before filing any motion in limine.
The parties must confer on all motions in limine before filing them.
Not confirmed. Read the court's wording below. · Civil cases
Page 3 | I. Exchange and Filing of Trial Materials – Plaintiff’s Pre-Trial Statement
The parties must confer on every motion in limine before filing it.
The parties must confer on all motions in limine before filing them.
Not confirmed. Read the court's wording below. · Civil cases
Page 3 | I. Exchange and Filing of Trial Materials – Motions in Limine
Chambers Communication Rules
Defendant must email a Microsoft Word version of the exhibit-chart objections to the specified chambers address.
Separately, Defendant shall e-mail a Microsoft Word version of Defendant’s Objections to Plaintiff’s Exhibit Chart to Proposed_Order_Valderrama@ilnd.uscourts.gov.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 5 | II.d. Objections to Plaintiff’s Exhibit Chart
Defendant must email a Microsoft Word version of its exhibit-chart objections to the specified address.
Separately, Defendant shall e-mail a Microsoft Word version of Defendant’s Objections to Plaintiff’s Exhibit Chart to Proposed_Order_Valderrama@ilnd.uscourts.gov.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 5 | II. Exchange and Filing of Trial Materials – Defendant’s Pre-Trial Statement and Objections
Defendant must email a Microsoft Word version of its deposition-designation objections to the specified address.
Separately, Defendant shall e-mail a Microsoft Word version of Defendant’s Objections to Plaintiff’s Deposition Designation Chart to Proposed_Order_Valderrama@ilnd.uscourts.gov.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 6 | II. Exchange and Filing of Trial Materials – Defendant’s Pre-Trial Statement and Objections
Parties needing courtroom display technology instruction may consult the court’s technology webpage or contact the Technology Administrator to schedule WebEx training.
If the parties need instruction on the courtroom display technology equipment, please visit https://www.ilnd.uscourts.gov/Pages.aspx?page=CourtRoomTechnology and/or contact Alexander Zeier, the Courtroom Technology Administrator, to schedule a WebEx training session.
Checked and corrected to match the court's document on Oct 4, 2026 · Civil cases
Page 12 | VIII. Additional Pre-Trial Information – Displaying Exhibits on the Video Monitors
If the parties agree that a password is necessary, they must email it to the courtroom deputy on the day the USB drive is delivered.
If the parties agree a password is necessary, they must send an e-mail to the Court’s courtroom deputy, Jonathan Martinez (Jonathan_Martinez@ilnd.uscourts.gov), with the password on the same day that the USB/Key Drive is delivered.
Not confirmed. Read the court's wording below. · Civil cases
Page 11 | V. Exhibits and Deposition Designations – Before Pre-Trial Conference
When contacting the Technology Administrator, the parties should coordinate a joint visit and copy the Courtroom Deputy so he can assist.
When reaching out to Mr. Zeier, the parties should coordinate with each other to arrange for a time to come at the same time, and should also copy the Court’s Courtroom Deputy, Jonathan Martinez, so he can be present to assist.
Not confirmed. Read the court's wording below. · Civil cases
Page 12 | VIII. Additional Pre-Trial Information – Displaying Exhibits on the Video Monitors
Parties needing courtroom display technology instruction may contact the Courtroom Technology Administrator to schedule WebEx training, coordinating their attendance and copying the Courtroom Deputy.
If the parties need instruction on the courtroom display technology equipment, please visit https://www.ilnd.uscourts.gov/Pages.aspx?page=CourtRoomTechnology and/or contact Alexander Zeier, the Courtroom Technology Administrator, to schedule a WebEx training session. Mr. Zeier can be reached at (312) 435-6045 or alexander_zeier@ilnd.uscourts.gov. When reaching out to Mr. Zeier, the parties should coordinate with each other to arrange for a time to come at the same time, and should also copy the Court’s Courtroom Deputy, Jonathan Martinez, so he can be present to assist.
Not confirmed. Read the court's wording below. · Civil cases
Page 15 | Displaying Exhibits on the Video Monitors
The Courtroom Technology Administrator may be reached by phone or email at the listed contact details.
Mr. Zeier can be reached at (312) 435-6045 or alexander_zeier@ilnd.uscourts.gov.
Not confirmed. Read the court's wording below. · Civil cases
Page 12 | VIII. Additional Pre-Trial Information – Displaying Exhibits on the Video Monitors