Judge Heather K. McShain
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- 2 copies
Exhibit
- 2 copies • Chambers Drop Off • One Week Before Final Pretrial Conference
Joint Status Report
- Chambers Drop Off • At Least Three Business Days Before Status Conference
Settlement Statement
- Email • Upon Filing
Communication
Chambers
Chambers
Page & Word Limits4 rules
Machine summary. Not checked yet.Mandatory?
Absent prior leave of Court, motions in limine (not including exhibits) are limited to a total of 15 pages per party (not per motion), and responses (not including exhibits) are likewise limited to a total of 15 pages per party.
Summary: Motions in limine and responses limited to 15 pages per party total.
Motion In Limine
15 pages
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
Each side is limited to 10 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 limited to 10 disputed voir dire questions unless good cause shown.
Voir Dire Questions
10 pages
Applies to: Attorney
Machine summary. Not checked yet.Mandatory?
Settlement statements should be no more than 10 pages each.
Summary: Settlement statements limited to 10 pages.
Settlement Statement
10 pages
Applies to: Attorney
Machine summary. Not checked yet.Note?
These limitations do not apply to motions challenging the admissibility of Rule 702 expert testimony pursuant to Daubert v. Merrell Dow Pharmaceuticals, Inc.
Summary: Daubert motions exempt from page limits.
Daubert Motion
Document Filing Requirements36 rules
Checked against the court's document on Oct 4, 2026Mandatory
The joint status report must include the information specified in the order.
The joint status report shall contain the following information:
Document Type
Joint Status Report
Checked against the court's document on Oct 4, 2026Mandatory
The joint status report must describe the pleaded claims and defenses, the basis for federal jurisdiction, and the relief sought, including itemized damages.
a. Describe the claims and defenses raised by the pleadings, including the basis for federal jurisdiction. b. State the relief sought, including an itemization of damages.
Document Type
Joint Status Report
Checked against the court's document on Oct 4, 2026Mandatory
The joint status report must state whether a settlement conference would be productive and briefly explain if the parties believe it would not be.
b. State whether the parties believe a settlement conference would be productive at this time, and if not, briefly explain why.
Document Type
Joint Status Report
Checked against the court's document on Oct 4, 2026Mandatory
The report must state whether ESI discovery is anticipated or underway and, if so, identify agreements and areas of disagreement concerning ESI.
State whether the parties anticipate or are engaged in discovery of ESI in this case, and, if so, what agreements have been reached regarding ESI and whether there are any areas of disagreements regarding ESI.
Document Type
Joint Status Report
Checked against the court's document on Oct 4, 2026Mandatory
The joint status report must address the claims and defenses, federal jurisdiction, relief and itemized damages, referred matters, and existing discovery cutoff dates.
The joint status report shall contain the following information: 1. Description of Claims and Relief Sought. a. Describe the claims and defenses raised by the pleadings, including the basis for federal jurisdiction. ===== PAGE 2 ===== b. State the relief sought, including an itemization of damages. 2. Referral Cases. Describe the matter(s) referred to the magistrate judge. 3. Discovery Schedule. Identify any existing discovery cut-off dates.
Document Type
Joint Status Report
Checked against the court's document on Oct 4, 2026Important
In consent cases, state whether a jury trial is requested, the expected trial-readiness date, and the probable trial length.
In consent cases, state whether a jury trial is requested, the date when the parties expect to be ready for trial, and the probable length of trial.
Requirement
Document requirement
Checked against the court's document on Oct 4, 2026Important
Indicate the status of any pending motions.
Requirement
Document requirement
Checked against the court's document on Oct 4, 2026Important
State whether all parties consent to Judge McShain conducting all further proceedings, including trial and entry of final judgment.
State whether all parties will consent to have Judge McShain conduct all further proceedings in this case, including trial and entry of final judgment, in accordance with 28 U.S.C. § 636(c) and Federal Rule of Civil Procedure 73.
Requirement
Document requirement
Checked against the court's document on Oct 4, 2026Important
State any other matters that should be brought to the Court’s attention for scheduling purposes.
State any other matters that should be brought to the Court’s attention for scheduling purposes.
Requirement
Document requirement
Checked against the court's document on Oct 4, 2026Important
The report should state whether the parties believe a settlement conference would be productive and briefly explain if they do not.
b. State whether the parties believe a settlement conference would be productive at this time, and if not, briefly explain why.
Document Type
Initial Status Report
Checked against the court's document on Oct 4, 2026Important
If expert discovery will occur, the report should provide its completion date and the dates for expert and rebuttal reports, if any, or summaries for non-retained expert testimony.
c. If there will be expert discovery, an expert discovery completion date, including dates for the delivery of expert reports and rebuttal reports, if any (or summaries for non-retained expert testimony).
Document Type
Initial Status Report
Checked against the court's document on Oct 4, 2026Important
The report should state whether the parties anticipate or are engaged in ESI discovery and, if so, identify agreements and areas of disagreement.
State whether the parties anticipate or are engaged in discovery of ESI in this case, and, if so, what agreements have been reached regarding ESI and whether there are any areas of disagreements regarding ESI.
Document Type
Initial Status Report
Checked against the court's document on Oct 4, 2026Important
The report should provide a fact-discovery completion date; for claims involving medical conditions, fact discovery ordinarily includes treating physician depositions.
b. A fact discovery completion date. For claims involving medical conditions, fact discovery ordinarily includes treating physician depositions.
Document Type
Initial Status Report
Checked against the court's document on Oct 4, 2026Important
The report should indicate the status of any pending motions.
Indicate the status of any pending motions.
Document Type
Initial Status Report
Checked against the court's document on Oct 4, 2026Important
The report should identify any other matters that should be brought to the Court’s attention for scheduling purposes.
State any other matters that should be brought to the Court’s attention for scheduling purposes.
Document Type
Initial Status Report
Checked against the court's document on Oct 4, 2026Note
The Court has adopted the Seventh Circuit Electronic Discovery Pilot Program Principles, and the parties should be familiar with them.
Please note the Court has adopted the Principles of the Seventh Circuit Electronic Discovery Pilot Program and the parties should be familiar with them.
Requirement
Document requirement
Checked against the court's document on Oct 4, 2026Note
In patent cases, the Court will apply the Local Patent Rules for Electronically Stored Information.
In a patent case, the Court will apply the Local Patent Rules for Electronically Stored Information.
Requirement
Document requirement
Checked against the court's document on Oct 4, 2026Note
In patent cases, the Court will apply the Local Patent Rules for Electronically Stored Information.
In a patent case, the Court will apply the Local Patent Rules for Electronically Stored Information.
Requirement
Document requirement
Checked against the court's document on Oct 4, 2026Note
The parties should be familiar with the Principles of the Seventh Circuit Electronic Discovery Pilot Program, which the Court has adopted.
Please note the Court has adopted the Principles of the Seventh Circuit Electronic Discovery Pilot Program and the parties should be familiar with them.
Requirement
Document requirement
Not confirmed. Read the court's wording below.Mandatory?
Describe the matter(s) referred to the magistrate judge.
Summary: The joint status report must describe the matters referred to the magistrate judge.
Document Type
Joint Status Report
Not confirmed. Read the court's wording below.Mandatory?
a. Describe the status of settlement discussions.
Summary: The joint status report must describe the status of settlement discussions.
Document Type
Joint Status Report
Machine summary. Not checked yet.Mandatory?
The Proposed Pretrial Order must also be filed on the docket by selecting “Other Filings” and then “Other Documents,” and choosing the Proposed Pretrial Order event in CM/ECF.
Summary: Proposed Pretrial Order must be filed on ECF docket.
Document Type
Pretrial Order
Machine summary. Not checked yet.Mandatory?
Exhibits, if any, to settlement statements should be attached to the email sent to the Court, or counsel should utilize an electronic file sharing service and the Court will download the exhibits.
Summary: Exhibits to settlement statements must be attached to email or shared via file sharing service.
Document Type
Settlement Statement
Machine summary. Not checked yet.Mandatory?
The parties’ settlement statements are not to be filed on ECF, will not be made part of the Court’s record, and will not be admissible as evidence.
Summary: Settlement statements are not filed on ECF and are not part of court record or admissible as evidence.
Document Type
Settlement Statement
Machine summary. Not checked yet.Mandatory?
Counsel and parties are cautioned that failure to attend a scheduled settlement conference without advance notice to the Court may result in the imposition of monetary sanctions against them.
Summary: Failure to attend settlement conference without notice may result in monetary sanctions.
Document Type
Settlement Conference
Not confirmed. Read the court's wording below.Mandatory?
For those cases that are subject to the Mandatory Initial Discovery Pilot Project, the parties must also discuss and follow the requirements of the Standing Order Regarding Mandatory Initial Discovery Pilot Project (available on Judge McShain’s web page).
Summary: In cases subject to the Mandatory Initial Discovery Pilot Project, the parties must discuss and follow that project’s standing-order requirements.
Document Type
Joint Status Report
Not confirmed. Read the court's wording below.Important?
Identify any existing discovery cut-off dates. If no discovery schedule has yet been set and in referral cases, the case has been ===== PAGE 2 ===== referred for discovery supervision, the parties should confer and submit the following information:
Summary: The report must identify existing discovery cutoff dates; if no schedule is set in a qualifying referral case, the parties should confer and submit the listed proposed discovery dates.
Document Type
Joint Status Report
Not confirmed. Read the court's wording below.Important?
b. A date to issue written discovery requests.
Summary: In the specified circumstances, the parties should submit a date to issue written discovery requests.
Document Type
Joint Status Report
Not confirmed. Read the court's wording below.Important?
c. A fact discovery completion date. For claims involving medical conditions, fact discovery ordinarily includes treating physician depositions.
Summary: In the specified circumstances, the parties should submit a fact-discovery completion date; for medical-condition claims, fact discovery ordinarily includes treating-physician depositions.
Document Type
Joint Status Report
Not confirmed. Read the court's wording below.Important?
d. If there will be expert discovery, an expert discovery completion date, including dates for the delivery of expert reports and rebuttal reports, if any (or summaries for non-retained expert testimony).
Summary: If expert discovery will occur, the parties should submit its completion date and dates for expert and rebuttal reports, if any, or summaries for non-retained expert testimony.
Document Type
Joint Status Report
Not confirmed. Read the court's wording below.Important?
a. The due date for Fed. R. Civ. P. 26(a)(1) disclosures.
Summary: In the specified circumstances, the parties should submit the due date for Rule 26(a)(1) disclosures.
Document Type
Joint Status Report
Not confirmed. Read the court's wording below.Important?
If no discovery schedule has yet been set and in referral cases, the case has been referred for discovery supervision, the parties should confer and submit the following information:
Summary: If no discovery schedule has been set and a referral case is referred for discovery supervision, the parties should confer and submit the specified discovery schedule information.
Document Type
Joint Status Report
Not confirmed. Read the court's wording below.Important?
a. Describe the status of settlement discussions.
Summary: The report should describe the status of settlement discussions.
Document Type
Initial Status Report
Not confirmed. Read the court's wording below.Important?
State whether all parties will consent to have Judge McShain conduct all further proceedings in this case, including trial and entry of final judgment, in accordance with 28 U.S.C. § 636(c) and Federal Rule of Civil Procedure 73.
Summary: The report should state whether all parties will consent to Judge McShain conducting all further proceedings, including trial and entry of final judgment.
Document Type
Initial Status Report
Not confirmed. Read the court's wording below.Important?
In consent cases, state whether a jury trial is requested, the date when the parties expect to be ready for trial, and the probable length of trial.
Summary: In consent cases, the report should state whether a jury trial is requested, the expected trial-readiness date, and the probable trial length.
Document Type
Initial Status Report
Machine summary. Not checked yet.Note?
Judge McShain does not require trial briefs in jury trials. Parties who wish to file a trial brief must seek leave of Court to do so.
Summary: Trial briefs not required; leave of court needed to file.
Document Type
Trial Brief
Filing & Service rules
Electronic Filing Rules
The parties must electronically file a joint status report and deliver a courtesy copy to chambers at least three business days before the status conference.
the parties are required to electronically file a joint status report and deliver a courtesy copy to Judge McShain’s chambers at least three business days before the status conference.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 1 | Standing Order for Initial Status Report
Courtesy Copy Requirements
The parties must deliver one courtesy copy of the joint status report to chambers at least three business days before the status conference.
the parties are required to electronically file a joint status report and deliver a courtesy copy to Judge McShain’s chambers at least three business days before the status conference.
Checked against the court's document on Oct 4, 2026 · Civil cases
Page 1 | Standing Order for Initial Status Report
Proposed Pretrial Order must be emailed and two courtesy copies delivered to chambers.
The Proposed Pretrial Order must be e-mailed to Proposed_Order_McShain@ilnd.uscourts.gov in Word or WordPerfect format, with two courtesy copies delivered to chambers.
Machine summary. Not checked yet. · Civil cases
Page 1 | Pretrial Procedures and Preparation of Final Pretrial Orders for Civil Cases Before Judge McShain
Parties must submit 2 sets of exhibit binders to chambers one week before final pretrial conference.
No later than one week prior to the final pretrial conference, the parties must submit to chambers 2 sets of exhibit binders containing copies of all objected-to substantive exhibits. Exhibits that will be used for impeachment purposes only need not be included in the binders.
Machine summary. Not checked yet. · Civil cases
Settlement statements must be emailed to court, no courtesy copies accepted.
The Court does not accept courtesy copies. On the same day the parties provide their settlement statements to opposing counsel, the parties are required to submit their statements to the Court by e-mail.
Machine summary. Not checked yet. · Civil cases
Page 2 | A. Before the Settlement Conference—Telephonic Status Hearing and Exchange of Settlement Statements
Pre-Motion Conference Requirements
Daubert motions should be filed early, separately from other motions.
Such Daubert motions should be filed separately and as soon as reasonably possible, preferably well in advance of the final pretrial conference and the deadline for motions in limine.
Machine summary. Not checked yet. · Civil cases
Page 2 | Motions in Limine and Daubert Proceedings
Chambers Communication Rules
Settlement statements must be emailed to specific court address.
All settlement statements should be sent to the Court via the following email address: Settlement_Correspondence_McShain@ilnd.uscourts.gov
Machine summary. Not checked yet. · Civil cases
Page 2 | A. Before the Settlement Conference—Telephonic Status Hearing and Exchange of Settlement Statements
Parties must email chambers to reschedule or cancel settlement conference.
If the parties must reschedule, or if they conclude that a settlement conference is not necessary at this time, they should inform chambers (via email to Chambers_McShain@ilnd.uscourts.gov) as soon as possible.
Machine summary. Not checked yet. · Civil cases
Page 5 | Settlement Conference Rescheduling