Court Rules
Magistrate Judge

Judge Karyn L. Bass Ehler

Individual Rules, Standing Orders & Policies

Rules last changed:
Northern District of Illinois

Limits & Logistics

Document Limits

Settlement Letter
7 pgs
Joint Status Report
5 pgs

Courtesy Copies

Deposition Transcript

  • 2 copies

Exhibits

  • 2 copies

Pretrial Order

  • 2 copies

Communication

Email

Chambers

settlement_correspondence_bassehler@ilnd.uscourts.gov
Email

Chambers

chambers_bassehler@ilnd.uscourts.gov
Phone

Chambers

Scheduling
Filters:AllMandatoryImportantFormattingSettlementJuryLettersConferencesDiscoveryMemorandaTRO/Injunction

Page & Word Limits4 rules

Page LimitsCivil cases

Checked against the court's document on Oct 4, 2026Mandatory

Settlement letters are limited to seven pages unless a party specifically requests additional pages.

Settlement letters shall be no more than seven pages, unless a party specifically has requested additional pages.

Settlement Letter

7 pages

Standing Order Settlement Conferences · Jun 2026 · p. 2
|SecA. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters
Page LimitsCivil cases

Checked against the court's document on Oct 4, 2026Mandatory

The joint status report must include the information specified in the order and may not exceed five pages.

The joint status report shall contain the following information and be no more than five pages:

Joint Status Report

5 pages

Standing Order - Initial Joint Status Report 5 5 26 · May 2026 · p. 1
|SecSTANDING ORDER FOR INITIAL JOINT STATUS REPORTS
Page LimitsCivil cases

Machine summary. Not checked yet.Mandatory?

Settlement letters should be no more than 7 pages each.

Summary: Settlement letters are limited to a maximum of 7 pages.

Settlement Letter

7 pages

Applies to: Attorney

Standing Order Settlement Conferences 5 18 26 Final · May 2026 · p. 2
|SecA. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters
Page LimitsCivil cases

Machine summary. Not checked yet.Mandatory?

The joint status report shall contain the following information and be no more than five pages:

Summary: When the Court requires an initial joint status report, the report must not exceed five pages.

Joint Status Report

5 pages

Applies to: Attorney

Standing Order Initial Joint Status Reports · Jun 2026 · p. 1
|SecSTANDING ORDER FOR INITIAL JOINT STATUS REPORTS

Document Format Requirements2 rules

FormattingCivil cases

Machine summary. Not checked yet.Mandatory?

In preparation for the final pretrial conference, the parties shall jointly prepare and submit a Proposed Final Pretrial Order containing the below listed items by email to Chambers_BassEhler@ilnd.uscourts.gov in Word format with all counsel included as cc: recipients.

Summary: Proposed Final Pretrial Order must be in Word format.

Required Format

DOCX

Webpage Pretrial Order · May 2026 · p. 1
|SecSTANDING ORDER FOR PREPARATION OF PROPOSED FINAL PRETRIAL ORDER
FormattingCivil cases

Machine summary. Not checked yet.Note?

Judge Bass Ehler refers to the Seventh Circuit Pattern Jury Instructions, and where applicable those instructions should be used absent a good reason for not doing so.

Summary: Parties should use Seventh Circuit Pattern Jury Instructions for jury trials where applicable, unless there is a good reason to not use them.

Webpage Pretrial Order · May 2026 · p. 3
|SecProposed jury instructions / verdict forms

Document Filing Requirements33 rules

Filing RequirementsCivil cases

Checked against the court's document on Oct 4, 2026Mandatory

Counsel must raise any claimed inability or hindrance to pay at the initial hearing and provide verification before the settlement conference.

If a party is claiming an inability or hindrance to pay a judgment, counsel must raise it at this initial hearing and provide verification of that assertion prior to any settlement conference.

Document Type

Verification Of Inability To Pay

Specific requirements detailed in rule text.
Standing Order Settlement Conferences · Jun 2026 · p. 1
|SecA. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters
Filing RequirementsCivil cases

Checked and corrected to match the court's document on Oct 4, 2026Mandatory

Plaintiff’s counsel must submit a settlement letter on the Court’s schedule to defendant’s counsel and the Court, containing the specified case, liability, demand, damages, and legal-authority information.

Consistent with the schedule that is set by the Court, Plaintiff’s counsel must submit a settlement letter to Defendant’s counsel and the Court, describing the nature of the action, the theory of liability, Plaintiff’s demand and its reasoned basis, an itemization of damages, and ===== PAGE 2 ===== citation to legal authority supporting the claimed damages.

Document Type

Plaintiff Settlement Letter

Specific requirements detailed in rule text.
Standing Order Settlement Conferences · Jun 2026 · p. 1
|SecA. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters
Filing RequirementsCivil cases

Checked against the court's document on Oct 4, 2026Mandatory

Counsel must provide clients with the complete set of settlement letters, and clients must read them before the conference.

All counsel are required to provide the full set of the settlement letters to their clients, who must read them prior to the conference.

Document Type

Settlement Letters

Specific requirements detailed in rule text.
Standing Order Settlement Conferences · Jun 2026 · p. 2
|SecA. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters
Filing RequirementsCivil cases

Checked against the court's document on Oct 4, 2026Mandatory

Each settlement letter must identify all settlement-conference attendees and each person’s role.

The parties must include in their settlement letters the names of all individuals who will be attending the settlement conference, along with their role.

Document Type

Settlement Letter

Specific requirements detailed in rule text.
Standing Order Settlement Conferences · Jun 2026 · p. 2
|SecA. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters
Filing RequirementsCivil cases

Checked against the court's document on Oct 4, 2026Mandatory

Defendant’s counsel must submit a response settlement letter to plaintiff’s counsel and the Court describing the defense theory and explaining the offer.

Defendant’s counsel must submit a settlement letter to Plaintiff’s counsel and the Court in response to Plaintiff’s demand, describing the theory of defense and Defendant’s offer, including an explanation for it.

Document Type

Defendant Settlement Letter

Specific requirements detailed in rule text.
Standing Order Settlement Conferences · Jun 2026 · p. 2
|SecA. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters
Filing RequirementsCivil cases

Checked against the court's document on Oct 4, 2026Mandatory

Defendant’s settlement letter must state whether insurance representatives will be involved and confirm their attendance if they will be involved.

Defendant also must include whether any insurance representative(s) will be involved, and if so, confirm their attendance.

Document Type

Defendant Settlement Letter

Specific requirements detailed in rule text.
Standing Order Settlement Conferences · Jun 2026 · p. 2
|SecA. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters
Filing RequirementsCivil cases

Checked against the court's document on Oct 4, 2026Mandatory

The joint status report must describe the pleaded claims and defenses, state the basis for federal jurisdiction, and identify the relief sought, including an itemization of damages.

1. Description of Claims and Relief Sought. a. Describe the claims and defenses raised by the pleadings. Make sure to include the basis for federal jurisdiction. b. State the relief sought, including an itemization of damages.

Document Type

Joint Status Report

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Checked against the court's document on Oct 4, 2026Mandatory

The joint status report must describe settlement discussions, address whether a settlement conference would be productive and why if not, and explain why discussions have not occurred and what must happen before they would be appropriate and potentially fruitful.

a. Describe the status of any settlement discussions. b. State whether the parties believe a settlement conference would be productive at this time, and if not, briefly explain why. c. If no settlement discussions have taken place, state why that is so, and what needs to occur before settlement discussions would be appropriate and potentially fruitful (i.e., ruling(s) on pending motion(s), completion of particular discovery, focused damages discovery or analysis, etc.).

Document Type

Joint Status Report

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Checked against the court's document on Oct 4, 2026Important

Plaintiff’s settlement demand should exclude any punitive-damages demand or itemization.

Accordingly, for the purpose of settlement, any demand and/or itemization for punitive damages should not be included in Plaintiff’s demand.

Document Type

Plaintiff Settlement Letter

Specific requirements detailed in rule text.
Standing Order Settlement Conferences · Jun 2026 · p. 2
|SecA. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters
Filing RequirementsCivil cases

Checked against the court's document on Oct 4, 2026Important

For cases involving personal, physical, emotional-distress, or similar injuries, Plaintiff should include comparable jury verdicts or settlements supporting the demand.

For cases involving personal, physical, emotional distress, or similar injuries, Plaintiff should include a list of comparable jury verdicts and/or settlements to support their demand amount.

Document Type

Plaintiff Settlement Letter

Specific requirements detailed in rule text.
Standing Order Settlement Conferences · Jun 2026 · p. 2
|SecA. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters
Filing RequirementsCivil cases

Checked against the court's document on Oct 4, 2026Note

Defendant’s offer is expected to account for the possibility of liability.

Defendant is expected to offer a number that does not assume that there will be no liability.

Document Type

Defendant Settlement Letter

Specific requirements detailed in rule text.
Standing Order Settlement Conferences · Jun 2026 · p. 2
|SecA. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters
Filing RequirementsCivil cases

Checked against the court's document on Oct 4, 2026Note

Defendant should update the offer rather than simply rest on a prior negotiating position.

As with Plaintiff, Defendant should provide an offer that is updated from any prior negotiations, i.e., not just stand on a prior position.

Document Type

Defendant Settlement Letter

Specific requirements detailed in rule text.
Standing Order Settlement Conferences · Jun 2026 · p. 2
|SecA. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters
Filing RequirementsCivil cases

Checked against the court's document on Oct 4, 2026Note

The parties should ensure that each party has the information and documents needed for meaningful settlement discussions.

The parties should further establish that each party has the necessary information and documents to engage in meaningful settlement discussions during the conference.

Document Type

Settlement Conference Preparation

Specific requirements detailed in rule text.
Standing Order Settlement Conferences · Jun 2026 · p. 2
|SecA. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters
Filing RequirementsCivil cases

Checked against the court's document on Oct 4, 2026Note

Plaintiff should update the settlement demand rather than simply rest on a prior negotiating position.

Additionally, Plaintiff should provide a demand that is updated from any prior negotiations, i.e., not just stand on a prior position.

Document Type

Plaintiff Settlement Letter

Specific requirements detailed in rule text.
Standing Order Settlement Conferences · Jun 2026 · p. 2
|SecA. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters
Filing RequirementsCivil cases

Checked against the court's document on Oct 4, 2026Note

When preparing settlement letters, parties are encouraged to consider areas of agreement, creative solutions, and outstanding lienholders and lien amounts.

In preparing their settlement letters, the parties are encouraged to consider whether there are any areas of agreement; whether there are any creative solutions (e.g., licensing agreement, allowing the use of a trademark, re-employment, trainings, payment plan, etc.); and whether there are any outstanding lien holders, particularly Worker’s Compensation, Medicare, or other medical liens (and in what amount).

Document Type

Settlement Letter

Specific requirements detailed in rule text.
Standing Order Settlement Conferences · Jun 2026 · p. 2
|SecA. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters
Filing RequirementsCivil cases

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; in patent cases, the Court will apply the Local Patent Rules for ESI.

Please note the Court has adopted the Principles of the Seventh Circuit Electronic Discovery Pilot Program and the parties should be familiar with them. In a patent case, the Court will apply the Local Patent Rules for Electronically Stored Information.

Requirement

Document requirement

Specific requirements detailed in rule text.
Standing Order - Initial Joint Status Report 5 5 26 · May 2026 · p. 2
|SecConsideration of Issues Concerning Electronically Stored Information (“ESI”)
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

Consistent with the schedule that is set by the Court, Plaintiff’s counsel must submit a settlement letter to Defendant’s counsel and the Court, describing the nature of the action, the theory of liability, Plaintiff’s demand and its reasoned basis, an itemization of damages, and demand that is not what Plaintiff expects to win at trial, but rather a number that takes into account the risk of loss, cost, and time savings from settling before trial. Accordingly, for the purpose of settlement, any demand and/or itemization for punitive damages should not be included in Plaintiff’s demand. For cases involving personal, physical, emotional distress, or similar injuries, Plaintiff should include a list of comparable jury verdicts and/or settlements to support their demand amount. Additionally, Plaintiff should provide a demand that is updated from any prior negotiations, i.e., not just stand on a prior position. Defendant’s counsel must submit a settlement letter to Plaintiff’s counsel and the Court in response to Plaintiff’s demand, describing the theory of defense and Defendant’s offer, including an explanation for it. Defendant is expected to offer a number that does not assume that there will be no liability. As with Plaintiff, Defendant should provide an offer that is updated from any prior negotiations, i.e., not just stand on a prior position. The parties must include in their settlement letters the names of all individuals who will be attending the settlement conference, along with their role. Defendant also must include whether any insurance representative(s) will be involved, and if so, confirm their attendance.

Summary: Settlement letters must include specified content related to the case, demands/offers, attendees, and insurance representatives.

Document Type

Settlement Letter

Specific requirements detailed in rule text.
Standing Order Settlement Conferences 5 18 26 Final · May 2026 · p. 1
|SecA. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

The subject line of the email should include the case number, case name, and title of the submission.

Summary: Email subject line must include case number, case name, and title of submission.

Document Type

Pretrial Order

Specific requirements detailed in rule text.
Webpage Pretrial Order · May 2026 · p. 1
|SecSTANDING ORDER FOR PREPARATION OF PROPOSED FINAL PRETRIAL ORDER
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

Each side is limited to 10 proposed disputed questions.

Summary: Each side is limited to 10 proposed disputed voir dire questions.

Document Type

Pretrial Order

Specific requirements detailed in rule text.
Webpage Pretrial Order · May 2026 · p. 2
|SecContents of the Proposed Final Pretrial Order - 8. Proposed voir dire questions
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

In addition to those questions, any proposed voir dire special to the case as well as any objection to that question should be included in the Proposed Final Pretrial Order.

Summary: Proposed voir dire questions and objections should be included in Proposed Final Pretrial Order.

Document Type

Pretrial Order

Specific requirements detailed in rule text.
Webpage Pretrial Order · May 2026 · p. 2
|SecContents of the Proposed Final Pretrial Order - 8. Proposed voir dire questions
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

For a jury trial, the parties are directed to meet and agree on proposed jury instructions and verdict forms to the maximum extent possible and to file the jury instructions and verdict forms with the Proposed Final Pretrial Order, noting any objections as needed.

Summary: For jury trials, parties must meet and agree on proposed jury instructions and verdict forms to the maximum extent possible, and file them with the Proposed Final Pretrial Order noting any objections.

Document Type

Proposed Final Pretrial Order

Specific requirements detailed in rule text.
Webpage Pretrial Order · May 2026 · p. 3
|SecProposed jury instructions / verdict forms
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

The proposed jury instructions must state, on an instruction-by-instruction basis, the proponent of the instruction, the legal authority for the instruction, any objection to the instruction, the basis for the objection, and any proposed modification or alternative instruction. The same principles apply to proposed verdict forms.

Summary: Proposed jury instructions and verdict forms must include per-instruction proponent, legal authority, objections, objection basis, and proposed modifications/alternatives.

Document Type

Jury Instructions And Verdict Forms

Specific requirements detailed in rule text.
Webpage Pretrial Order · May 2026 · p. 3
|SecProposed jury instructions / verdict forms
Filing RequirementsCivil cases

Not confirmed. Read the court's wording below.Mandatory?

Identify any existing discovery deadlines. If no discovery schedule exists and the case is referred for discovery supervision, the parties should confer and submit the following information:

Summary: The joint status report must identify existing discovery deadlines; if no schedule exists and the case is referred for discovery supervision, the parties should confer and submit the specified discovery schedule information.

Document Type

Joint Status Report

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Not confirmed. Read the court's wording below.Mandatory?

2. Referral Cases. 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

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Not confirmed. Read the court's wording below.Mandatory?

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 joint status report must state whether a jury trial is requested, the expected trial-readiness date, and the probable trial length.

Document Type

Joint Status Report

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Not confirmed. Read the court's wording below.Mandatory?

State whether the parties anticipate or are engaged in ESI discovery, and, if so, what agreements have been reached regarding ESI and whether there are any areas of disagreement.

Summary: The joint status report must state whether the parties anticipate or are engaged in ESI discovery and, if so, identify their agreements and any areas of disagreement.

Document Type

Joint Status Report

Specific requirements detailed in rule text.
Standing Order - Initial Joint Status Report 5 5 26 · May 2026 · p. 2
|SecConsideration of Issues Concerning Electronically Stored Information (“ESI”)
Filing RequirementsCivil cases

Not confirmed. Read the court's wording below.Mandatory?

Indicate the status of any pending motions.

Summary: The joint status report must indicate the status of any pending motions.

Document Type

Joint Status Report

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Not confirmed. Read the court's wording below.Mandatory?

State whether all parties will consent to have Judge Bass Ehler 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. Note: if all parties do not consent, then please state simply that not all parties consent pursuant to 28 U.S.C. § 636(c); do not identify any particular party by name, whether that party consents or not, in a mixed-consent situation. See Federal Rule of Civil Procedure 73(b)(1).

Summary: The joint status report must state whether all parties consent to the magistrate judge conducting all further proceedings; if they do not all consent, report only that not all parties consent and do not identify any party in a mixed-consent situation.

Document Type

Joint Status Report

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Not confirmed. Read the court's wording below.Mandatory?

State any other matters that should be brought to the Court’s attention for scheduling purposes.

Summary: The joint status report must identify any other matters that should be brought to the Court’s attention for scheduling purposes.

Document Type

Joint Status Report

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Machine summary. Not checked yet.Mandatory?

The joint status report shall contain the following information and be no more than five pages: 1. Description of Claims and Relief Sought. a. Describe the claims and defenses raised by the pleadings. Make sure to include the basis for federal jurisdiction. 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 deadlines. If no discovery schedule exists and the case is referred for discovery supervision, the parties should confer and submit the following information: a. A date to exchange Federal Rule of Civil Procedure 26(a)(1) disclosures or confirmation that the information already has been exchanged. b. A date to issue written discovery requests or confirmation that the parties already have exchanged written discovery. c. A date for the completion of all fact discovery, which ordinarily includes treating physician depositions. The parties shall indicate whether the proposed date includes treating physician depositions. d. If the parties anticipate expert discovery, a proposed schedule for Federal Rule of Civil Procedure 26(a)(2) expert disclosures, rebuttal expert reports, and a final date for completion of all expert discovery. If the parties agree on staggered expert discovery, the proposed schedule should set out those dates. e. Any existing pretrial or trial dates set by the assigned district judge. 4. Consideration of Issues Concerning Electronically Stored Information (“ESI”). State whether the parties anticipate or are engaged in ESI discovery, and, if so, what agreements have been reached regarding ESI and whether there are any areas of disagreement. In a patent case, the Court will apply the Local Patent Rules for Electronically Stored Information. 5. Settlement. a. Describe the status of any settlement discussions. b. State whether the parties believe a settlement conference would be productive at this time, and if not, briefly explain why. c. If settlement discussions have not taken place, state why that is so, and what needs to occur before settlement discussions would be appropriate and potentially fruitful (i.e., ruling on any pending motions, completion of particular discovery, focused damages discovery or analyses etc.). 6. Consent to the Magistrate Judge. State whether all parties will consent to have Judge Bass Ehler 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. If all parties do not consent, then simply state that not all parties consent pursuant to 28 U.S.C. § 636(c); do not identify any particular party by name, or whether that party consents or not, in a mixed-consent situation. See Federal Rule of Civil Procedure 73(b)(1). 7. Pending Motions. Indicate the status of any pending motions. 8. Trial. 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: When the Court requires an initial joint status report, the report must contain specified sections on claims, referrals, discovery, ESI, settlement, magistrate judge consent, pending motions, and trial.

Document Type

Joint Status Report

Specific requirements detailed in rule text.
Standing Order Initial Joint Status Reports · Jun 2026 · p. 1
|SecSTANDING ORDER FOR INITIAL JOINT STATUS REPORTS
Filing RequirementsCivil cases

Not confirmed. Read the court's wording below.Important?

a. The deadline for Fed. R. Civ. P. 26(a)(1) disclosures. b. A date to issue written discovery requests. c. A fact discovery completion date. For claims involving medical conditions, fact discovery ordinarily includes treating physician depositions. The parties shall indicate whether the proposed date includes treating physician depositions. The parties need not include expert discovery dates. The Court will set expert discovery deadlines at the conclusion of fact discovery. d. Any existing pretrial or trial dates.

Summary: When submitting a proposed discovery schedule, the parties should provide the Rule 26(a)(1) disclosure deadline, a date for issuing written discovery, a fact-discovery completion date, and any existing pretrial or trial dates; they must indicate whether the fact-discovery date includes treating-physician depositions, need not include expert-discovery dates, and the Court will set expert deadlines after fact discovery.

Document Type

Joint Status Report

Specific requirements detailed in rule text.
Filing RequirementsCivil cases

Not confirmed. Read the court's wording below.Note?

Indeed, the parties should have multiple discussions about settlement between the date on which the Court sets the settlement conference and the actual date of the conference.

Summary: The parties should have multiple settlement discussions after the conference is scheduled and before it occurs.

Document Type

Settlement Conference Preparation

Specific requirements detailed in rule text.
Standing Order Settlement Conferences · Jun 2026 · p. 2
|SecA. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters
Filing RequirementsCivil cases

Machine summary. Not checked yet.Note?

The parties should also jointly submit proposed jury instructions and verdict forms to Chambers by email with all counsel included as cc: recipients.

Summary: Parties should jointly submit proposed jury instructions and verdict forms to Chambers via email, copying all counsel.

Document Type

Jury Instructions And Verdict Forms

Specific requirements detailed in rule text.
Webpage Pretrial Order · May 2026 · p. 3
|SecProposed jury instructions / verdict forms

Filing & Service rules

Electronic Filing Rules

When submitting settlement letters to the opposing side, parties must also email them to the Court at the specified address.

Upon submission to the other side, the parties also are required to submit their settlement letters to the Court by e-mail to Settlement_Correspondence_BassEhler@ilnd.uscourts.gov.

Checked against the court's document on Oct 4, 2026 · Civil cases

Page 2 | A. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters

Settlement letters are prohibited from being filed with the Clerk’s Office, are not part of the court record, and are not admissible as evidence.

Settlement letters are not to be filed with the Clerk’s Office, will not be made part of the Court’s record, and will not be admissible as evidence.

Machine summary. Not checked yet. · Civil cases

Page 2 | A. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters

Settlement letters must not be filed with the Clerk’s Office or on CM/ECF and are not part of the Court’s record or admissible as evidence.

Settlement letters are not to be filed with the Clerk’s Office or on the CM/ECF system, will not be made part of the Court’s record, and will not be admissible as evidence.

Not confirmed. Read the court's wording below. · Civil cases

Page 2 | A. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters

Proposed Final Pretrial Order must be filed on CM/ECF.

The Proposed Final Pretrial Order (excluding copies of exhibits and deposition transcripts) must also be filed on the docket in CM/ECF.

Machine summary. Not checked yet. · Civil cases

Page 1 | STANDING ORDER FOR PREPARATION OF PROPOSED FINAL PRETRIAL ORDER

Exhibits should not be filed on CM/ECF.

The exhibits should not be filed on CM/ECF with the Proposed Pretrial Order.

Machine summary. Not checked yet. · Civil cases

Page 2 | Contents of the Proposed Final Pretrial Order - 7. Exhibits

Deposition transcripts should not be filed on CM/ECF.

The deposition transcripts should not be filed on CM/ECF with the Proposed Pretrial Order.

Machine summary. Not checked yet. · Civil cases

Page 2 | Contents of the Proposed Final Pretrial Order - 6. Witnesses

Filing Timing and Cure Windows

The parties must file a joint status report at least three business days before the initial status hearing, unless the Court orders otherwise.

the parties are required to file a joint status report at least three business days before the initial status hearing unless otherwise ordered by the Court.

Checked against the court's document on Oct 4, 2026 · Civil cases

Page 1 | STANDING ORDER FOR INITIAL JOINT STATUS REPORTS

Service and Proof of Service Rules

Parties must exchange settlement letters with opposing counsel prior to the settlement conference.

Plaintiff’s counsel must submit a settlement letter to Defendant’s counsel and the Court, describing the nature of the action, the theory of liability, Plaintiff’s demand and its reasoned basis, an itemization of damages, and Defendant’s counsel must submit a settlement letter to Plaintiff’s counsel and the Court in response to Plaintiff’s demand, describing the theory of defense and Defendant’s offer, including an explanation for it.

Machine summary. Not checked yet. · Civil cases

Page 1 | A. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters

Courtesy Copy Requirements

Two courtesy copies of Proposed Final Pretrial Order must be delivered to Chambers.

In addition, two courtesy copies organized in a manner that is conducive to facilitating the Court's review of the materials must be delivered to Chambers.

Machine summary. Not checked yet. · Civil cases

Page 1 | STANDING ORDER FOR PREPARATION OF PROPOSED FINAL PRETRIAL ORDER

Two courtesy copies of exhibits must be submitted to Chambers.

The parties shall also submit two courtesy copies of the exhibits to Chambers.

Machine summary. Not checked yet. · Civil cases

Page 2 | Contents of the Proposed Final Pretrial Order - 7. Exhibits

Two courtesy copies of highlighted deposition transcripts must be delivered to Chambers.

For any witness testimony proposed to be offered by deposition, the parties shall jointly submit to Chambers by email the deposition transcript(s) with the proposed designations from each party highlighted in different colors and shall also deliver two courtesy copies of the highlighted transcript(s) to Chambers.

Machine summary. Not checked yet. · Civil cases

Page 2 | Contents of the Proposed Final Pretrial Order - 6. Witnesses

Pre-Motion Conference Requirements

Counsel primarily responsible for representing each party at the settlement conference must participate in the status hearing or call.

Counsel primarily responsible for representing the parties during the settlement conference must participate in this status hearing or call.

Checked against the court's document on Oct 4, 2026 · Civil cases

Page 1 | A. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters

Counsel who fail to attend a confirmed settlement conference may be sanctioned.

Counsel are cautioned that failure to attend a confirmed settlement conference may result in the imposition of sanctions against them.

Checked against the court's document on Oct 4, 2026 · Civil cases

Page 4 | E. Cancellation or Rescheduling of the Conference

Parties must meet and confer on all motions in limine before filing; absent prior leave, each side is limited to 5 total motions in limine.

The parties must meet and confer on all motions in limine before filing any such motion. Absent prior leave of court, each side is limited to a total of five (5) motions in limine.

Machine summary. Not checked yet. · Civil cases

Page 3 | Motions in limine

Adjournment & Extension Requirements

Parties should notify Judge Bass Ehler’s Courtroom Deputy as soon as possible if they need to reschedule, no longer consider the conference necessary or helpful, or have resolved the case.

If the parties must reschedule, have concluded that a settlement conference is not necessary or helpful at this time, or have otherwise resolved the case, they should inform Judge Bass Ehler’s Courtroom Deputy as soon as possible.

Checked against the court's document on Oct 4, 2026 · Civil cases

Page 4 | E. Cancellation or Rescheduling of the Conference

Parties rescheduling a settlement conference must inform the Courtroom Deputy as soon as possible.

If the parties must reschedule, have concluded that a settlement conference is not necessary or helpful at this time, or have otherwise resolved the case, they should inform Judge Bass Ehler’s Courtroom Deputy as soon as possible.

Machine summary. Not checked yet. · Civil cases

Page 4 | Prepare for Success

Chambers Communication Rules

Counsel responsible for settlement must participate in the initial status hearing, identify attendees with settlement authority, and raise inability to pay at the initial hearing.

The Court generally will hold an initial status hearing or conference call to set dates for the settlement conference and the exchange of settlement letters. Counsel primarily responsible for representing the parties during the settlement conference must participate in this status hearing or call. Counsel will be expected to identify the individuals who will participate (i.e., not just available via phone) in the settlement conference with settlement authority on behalf of their respective clients, including any insurers, consistent with the requirements of this Standing Order. If a party is claiming an inability or hindrance to pay a judgment, counsel must raise it at this initial hearing and provide verification of that assertion prior to any settlement conference.

Machine summary. Not checked yet. · Civil cases

Page 1 | A. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters

Parties must submit settlement letters to the Court via email to the provided chambers address upon sending to opposing counsel.

Upon submission to the other side, the parties also are required to submit their settlement letters to the Court by e-mail to Settlement_Correspondence_BassEhler@ilnd.uscourts.gov

Machine summary. Not checked yet. · Civil cases

Page 2 | A. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters

Proposed Final Pretrial Order must be submitted by email to Chambers_BassEhler@ilnd.uscourts.gov with all counsel cc'd.

In preparation for the final pretrial conference, the parties shall jointly prepare and submit a Proposed Final Pretrial Order containing the below listed items by email to Chambers_BassEhler@ilnd.uscourts.gov in Word format with all counsel included as cc: recipients.

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Page 1 | STANDING ORDER FOR PREPARATION OF PROPOSED FINAL PRETRIAL ORDER

Exhibit chart must be submitted to Chambers by email with all counsel cc'd.

Each party shall submit to Chambers by email with all counsel included as cc: recipients a chart of all exhibits the party may introduce at trial, as well as any demonstrative exhibits

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Page 2 | Contents of the Proposed Final Pretrial Order - 7. Exhibits

Joint chart of objections to designated testimony must be submitted to Chambers by email.

The parties shall also jointly submit to Chambers by email a joint chart containing any objections to designated testimony by page and line number and the basis for the objection, as well as the opposing party's response to such objections.

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Page 2 | Contents of the Proposed Final Pretrial Order - 6. Witnesses

Deposition transcripts with proposed designations highlighted must be submitted to Chambers by email and two courtesy copies delivered to Chambers.

For any witness testimony proposed to be offered by deposition, the parties shall jointly submit to Chambers by email the deposition transcript(s) with the proposed designations from each party highlighted in different colors and shall also deliver two courtesy copies of the highlighted transcript(s) to Chambers.

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Page 2 | Contents of the Proposed Final Pretrial Order - 6. Witnesses

About United States Magistrate Judge Karyn L. Bass Ehler

Important Information **Communication with Chambers:** The Court strongly prefers email communication with Judge Bass Ehler's Courtroom Deputy, Jose Mejia, at [jose\_mejia@ilnd.uscourts.gov](mailto:jose_mejia@ilnd.uscourts.gov). All counsel should be copied on any communication with the Court, and substantive issues must be raised by motion, not email. **Proposed Orders:** All proposed orders should be sent to [Proposed\_Order\_BassEhler@ilnd.uscourts.gov](mailto:Proposed_Order_BassEhler@ilnd.uscourts.gov). **Settlement Correspondence:** All settlement correspondence should be sent to [Settlement\_Correspondence\_BassEhler@ilnd.uscourts.gov](mailto:Settlement_Coresspondence_BassEhler@ilnd.uscourts.gov). **Courtesy Copies:** Courtesy copies are not required at this time. error Status and Motion Hearings Magistrate Judge Bass Ehler will have status and motion hearings on Tuesdays, Wednesdays, and Thursdays at 10:00 a.m. unless otherwise scheduled by the Court. **All court hearings are in person.** In the event counsel is unable to appear in person, counsel MUST request to appear by telephone by emailing the Courtroom Deputy at least 3 days prior to the hearing. Joint, uncontested, and agreed motions must be so identified in the title and body of any motion. **Parties should not file a notice of motion with any submission. Parties also are not allowed to file a brief in response or reply of a discovery motion without leave of Court.** If the Court requests additional briefing, the Court will enter a minute order setting forth a schedule, when appropriate, or otherwise schedule the motion for hearing. - [summarize Case Procedures](https://www.ilnd.uscourts.gov/judge_display.php?LastName=Bass+Ehler#procedures) - [event Calendar Schedule](https://www.ilnd.uscourts.gov/judge_display.php?LastName=Bass+Ehler#calendar) - [date\_range Motion Schedule](https://www.ilnd.uscourts.gov/judge_display.php?LastName=Bass+Ehler#motion) - [groups Chambers Staff](https://www.ilnd.uscourts.gov/judge_display.php?LastName=Bass+Ehler#chambers) Procedures to be followed in cases assigned to Judge Karyn L. Bass Ehler **Initial Status Report** chevron\_right [print](https://www.ilnd.uscourts.gov/PrintContent.aspx?cmpid=1560) Upon assignment of cases by consent or referral to Judge Bass Ehler, the Court will enter a minute order requiring the parties to file a joint status report. See Judge Bass Ehler’s Standing Order for Initial Status Report for the information to be included in the parties' [joint initial status report](https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_judges/Bass-ehler/Standing%20Order%20Initial%20Joint%20Status%20Reports.pdf). Consistent with the scope of the consent or referral and after reviewing the joint initial status report, the Court will either set an initial status hearing or by minute order set discovery schedules, briefing schedules, and other deadlines and timetables. If the Court sets a status hearing, the lead trial counsel for each party, or an attorney with substantial familiarity with and responsibility for the case, shall appear and be prepared to discuss all aspects of the case. A joint status report is not required in cases that are referred solely for a settlement conference, unless otherwise specifically ordered by the Court. **Discovery Motions** chevron\_right [print](https://www.ilnd.uscourts.gov/PrintContent.aspx?cmpid=1561) The Court believes that the parties can and should work out most discovery disputes, and thus discourages the filing of discovery motions. The Court will not hear or consider any discovery motion unless the parties have complied with the meet and confer requirement under Local Rule 37.2. Any discovery motion must state with specificity when and how the movant complied with Local Rule 37.2 by separate certificate filed with the motion and attested to by the attorney. Parties are reminded that compliance with Local Rule 37.2 requires a good faith effort to resolve discovery disputes through communication and negotiation. The Court believes face to face communications regarding discovery disputes are the most effective way to resolve them and **requires counsel for parties to meet in person unless it is impracticable to do so, and, if impracticable, describe why.** Videoconferencing satisfies this requirement. The Rule 37.2 Certificate must state that this requirement has been met or why it cannot be met with particularity. The mere exchange of correspondence (through emails, text messages, instant messaging, etc.) will not be sufficient to comply with Local Rule 37.2. Parties who fail to indicate that they have met in person to attempt to resolve their dispute risk having their motion stricken. Any motions to compel must identify and attach the specific discovery requests at issue, as well as the opposing party’s response (i.e., motions must not simply identify specific “categories” of documents or discovery that the movant seeks). Motions to compel must also include arguments supporting the relevance and proportionality of the requested discovery. Motions to compel may be summarily stricken for a failure to comply with these rules. Moreover, parties must not seek overbroad requests in the hope that the Court will tailor the resolution on its own; each discovery request will be adjudicated based on the totality of the request, so parties should appropriately narrow their requests ahead of time. Failure to do so may result in denial of the motion to compel with prejudice; the Court will not tailor a discovery request for the party when it could have done it on its own. **Parties are not allowed to file a brief in response or reply of a discovery motion without leave of Court. If the Court requests additional briefing, the Court will enter a minute order setting forth a schedule.** **The Court reminds the parties of Federal Rule of Civil Procedure 37(a)(5), which requires the Court to award the winning side fees and costs unless the losing party’s position was substantially justified or awarding fees and costs would be unjust.** With particular respect to electronic discovery disputes, if the parties have reached an impasse regarding the discovery of records from a database, server, computer, service provider or similar electronic storage facility (ESF), before filing a motion to compel, the parties are required to meet and confer with an IT representative for each party in order to determine the most effective and feasible ways to retrieve the requested material, as well as the proper format for the retrieval of the records. This electronic discovery conference must take place in person or by videoconference, and both sides should be prepared to discuss specifically the parameters of both the search(es) and the ESF. **Social Security Cases** chevron\_right [print](https://www.ilnd.uscourts.gov/PrintContent.aspx?cmpid=1562) The Court will generally enter an order setting dates that adhere to the [Federal Rules of Civil Procedure, Supplemental Rules for Social Security Motions Under 42 U.S.C. § 405(g)](https://www.law.cornell.edu/rules/frcp/supplemental-rules-for-social-security-actions-under-42-U.S.C.-405-g), typically providing that: (a) an answer must be filed within 60 days after notice of the actions is given under FRCP 3. Pursuant to Local Rule 8.1(b), the Social Security Administration's filing of the certified administrative record, in and of itself, shall suffice as the agency's answer to the complaint; (b) Plaintiff's brief in support of reversing or remanding the decision subject to review shall be filed within 30 days of the filing of the administrative record (no motion required); (c) The Social Security Administration’s motion to affirm the decision subject to review and its brief in support shall be filed within 30 days after plaintiff’s brief is filed; (d) Plaintiff’s reply brief, if any, shall be filed 14 days after defendant’s brief is filed. Judge Bass Ehler will only grant extensions on the briefing schedule for good cause shown. The page limit on briefs in Social Security Cases is twenty (20) pages. Briefs exceeding twenty (20) pages are discouraged and may be filed only with leave of Court. - Plaintiff's Memorandum The plaintiff shall identify the specific grounds for reversal or remand. Arguing generally that the ALJ’s decision is not supported by substantial evidence is not sufficient. The plaintiff shall include only those facts that relate to the issues presented. It is not necessary to include plaintiff’s entire medical history if it is not relevant to the issues raised. It is also not necessary to devote multiple pages to the well-recognized standards for the five-part test. Please cite a case that you believe accurately states the legal principles you wish the Court to apply and make the Court aware of relevant contrary authority. - The Commissioner’s Memorandum The Commissioner is strongly encouraged (where it makes sense) to respond to the plaintiff’s assertions and arguments raised in plaintiff’s brief in the same order raised by Plaintiff. Arguing generally that the ALJ’s decision is supported by substantial evidence is not sufficient. The Commissioner’s brief may supplement the plaintiff’s facts where needed. Do not feel compelled to repeat facts included in the plaintiff’s brief. Be sure to cite to specific record evidence in support of each argument. **Standing Order for Settlement Conferences** chevron\_right [print](https://www.ilnd.uscourts.gov/PrintContent.aspx?cmpid=1564) The Court has prepared a Standing Order setting forth its settlement conference procedures. That Standing Order may be obtained [here](https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_judges/Bass-ehler/Standing%20Order%20Settlement%20Conferences.pdf). Counsel and their clients must read and follow the procedures in that Standing Order prior to any initial status hearing on settlement and/or any settlement conference with Judge Bass Ehler. **Requirements for Preparation of Final Pretrial Order** chevron\_right [print](https://www.ilnd.uscourts.gov/PrintContent.aspx?cmpid=1566) Magistrate Judge Bass Ehler has prepared a Standing Order setting forth the requirements for the preparation of the proposed final pretrial order. That Standing Order may be obtained [here](https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_judges/Bass-ehler/Webpage%20Pretrial%20Order.pdf). Select a date below to view all schedules. **Tuesday, July 7, 2026** 4 cases expand\_more | Case No. | Name | Time | Type | | --- | --- | --- | --- | | 1:24-cv-11991 | Johnson v. Hoehn | 10:00AM | Status Hearing | | 1:19-cv-00114 | White v. United Airlines, Inc. | 10:15AM | Status Hearing | | 1:22-cv-01820 | Alholm v. Vrdolyak Law Group | 10:30AM | Status Hearing | | 1:24-cv-05850 | White v. Department of Veterans Affair | 10:30AM | Status Hearing | **Wednesday, July 8, 2026** 3 cases expand\_more | Case No. | Name | Time | Type | | --- | --- | --- | --- | | 1:24-cv-09444 | Carmichael v. Hoselton #158 | 10:15AM | Status Hearing | | 1:24-cv-04771 | Cruz v. Klich | 10:30AM | Telephone Conference | | 1:25-cv-09602 | IGG, LLC v. McWright | 11:00AM | Telephone Conference | **Thursday, July 9, 2026** 3 cases expand\_more | Case No. | Name | Time | Type | | --- | --- | --- | --- | | 1:24-cv-13131 | Zhang v. The Individuals, Corporations, Limited Liability C | 10:00AM | Status Hearing | | 1:25-cv-08491 | Kao v. Hengda Kite | 10:15AM | Status Hearing | | 1:25-cv-03498 | Dawson v. National University | 10:30AM | Status Hearing | **Courtroom Deputy** **[Jose Mejia](mailto:Jose_Mejia@ilnd.uscourts.gov)** (312) 818-6538 Room 1362 * * * ![](https://fonts.gstatic.com/s/i/productlogos/translate/v14/24px.svg) Original text Rate this translation Your feedback will be used to help improve Google Translate ![Chat widget](https://files.alive5.com/images/widgets/upload/design1-1712013259702.png) 0

**Courtroom:** 1838 **Chambers:** 1828 **Telephone:** (312) 435-5707 **Fax:** (312) 554-8522

Common questions about Judge Karyn L. Bass Ehler's rules

Are courtesy copies required for Judge Karyn L. Bass Ehler?

Courtesy-copy rule applies for exhibits. Details: 2 copies. Two courtesy copies of exhibits must be submitted to Chambers.

View ruleSource: page 2, section Contents of the Proposed Final Pretrial Order - 7. Exhibits

Does Judge Karyn L. Bass Ehler require a pre-motion conference or letter before filing a motion?

Judge Karyn L. Bass Ehler's rules set a pre-motion procedure for covered motions. Counsel primarily responsible for representing each party at the settlement conference must participate in the status hearing or call.

View ruleSource: page 1, section A. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters

What page or word limits apply to settlement letter before Judge Karyn L. Bass Ehler?

Judge Karyn L. Bass Ehler's rule states these limits: attorney: 7 pages. Settlement letters are limited to a maximum of 7 pages.

View ruleSource: page 2, section A. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters

What page or word limits apply to joint status report before Judge Karyn L. Bass Ehler?

Judge Karyn L. Bass Ehler's rule states these limits: 5 pages. The joint status report must include the information specified in the order and may not exceed five pages.

View ruleSource: page 1, section STANDING ORDER FOR INITIAL JOINT STATUS REPORTS

What formatting rules apply to filings before Judge Karyn L. Bass Ehler?

Judge Karyn L. Bass Ehler's formatting rule includes file format docx. Proposed Final Pretrial Order must be in Word format.

View ruleSource: page 1, section STANDING ORDER FOR PREPARATION OF PROPOSED FINAL PRETRIAL ORDER

What must be included with settlement letter filings before Judge Karyn L. Bass Ehler?

The rule identifies required filing content or certificates. Settlement letters must include specified content related to the case, demands/offers, attendees, and insurance representatives.

View ruleSource: page 1, section A. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters

What must be included with verification of inability to pay filings before Judge Karyn L. Bass Ehler?

The rule identifies required filing content or certificates. Counsel must raise any claimed inability or hindrance to pay at the initial hearing and provide verification before the settlement conference.

View ruleSource: page 1, section A. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters

How may parties contact Judge Karyn L. Bass Ehler's chambers?

The rule addresses email communications with Judge Karyn L. Bass Ehler's chambers. The rule lists email Settlement_Correspondence_BassEhler@ilnd.uscourts.gov. Parties must submit settlement letters to the Court via email to the provided chambers address upon sending to opposing counsel.

View ruleSource: page 2, section A. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters

How do I request an adjournment or extension before Judge Karyn L. Bass Ehler?

Advance notice is not fully stated in the structured details. Parties rescheduling a settlement conference must inform the Courtroom Deputy as soon as possible.

View ruleSource: page 4, section Prepare for Success

Is electronic filing required before Judge Karyn L. Bass Ehler?

No. Electronic filing is prohibited for the covered filings. Settlement letters are prohibited from being filed with the Clerk’s Office, are not part of the court record, and are not admissible as evidence.

View ruleSource: page 2, section A. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters

What filing deadlines does Judge Karyn L. Bass Ehler set?

The parties must file a joint status report at least three business days before the initial status hearing, unless the Court orders otherwise.

View ruleSource: page 1, section STANDING ORDER FOR INITIAL JOINT STATUS REPORTS

What rule applies to service for settlement letter before Judge Karyn L. Bass Ehler?

The rule addresses service method, recipient, or timing requirements. Details: recipient: the opposing party. Parties must exchange settlement letters with opposing counsel prior to the settlement conference.

View ruleSource: page 1, section A. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters
Complete rules summary for Judge Karyn L. Bass Ehler

Settlement letters are limited to a maximum of 7 pages.

Settlement letters must include specified content related to the case, demands/offers, attendees, and insurance representatives.

Parties must exchange settlement letters with opposing counsel prior to the settlement conference.

Parties must submit settlement letters to the Court via email to the provided chambers address upon sending to opposing counsel.

Settlement letters are prohibited from being filed with the Clerk’s Office, are not part of the court record, and are not admissible as evidence.

Counsel responsible for settlement must participate in the initial status hearing, identify attendees with settlement authority, and raise inability to pay at the initial hearing.

Parties rescheduling a settlement conference must inform the Courtroom Deputy as soon as possible.

Counsel primarily responsible for representing each party at the settlement conference must participate in the status hearing or call.

Counsel must raise any claimed inability or hindrance to pay at the initial hearing and provide verification before the settlement conference.

Plaintiff’s counsel must submit a settlement letter on the Court’s schedule to defendant’s counsel and the Court, containing the specified case, liability, demand, damages, and legal-authority information.

Plaintiff’s settlement demand should exclude any punitive-damages demand or itemization.

For cases involving personal, physical, emotional-distress, or similar injuries, Plaintiff should include comparable jury verdicts or settlements supporting the demand.

Plaintiff should update the settlement demand rather than simply rest on a prior negotiating position.

Defendant’s counsel must submit a response settlement letter to plaintiff’s counsel and the Court describing the defense theory and explaining the offer.

Defendant’s offer is expected to account for the possibility of liability.

Defendant should update the offer rather than simply rest on a prior negotiating position.

Each settlement letter must identify all settlement-conference attendees and each person’s role.

Defendant’s settlement letter must state whether insurance representatives will be involved and confirm their attendance if they will be involved.

Settlement letters are limited to seven pages unless a party specifically requests additional pages.

Counsel must provide clients with the complete set of settlement letters, and clients must read them before the conference.

The parties should have multiple settlement discussions after the conference is scheduled and before it occurs.

The parties should ensure that each party has the information and documents needed for meaningful settlement discussions.

When preparing settlement letters, parties are encouraged to consider areas of agreement, creative solutions, and outstanding lienholders and lien amounts.

When submitting settlement letters to the opposing side, parties must also email them to the Court at the specified address.

Settlement letters must not be filed with the Clerk’s Office or on CM/ECF and are not part of the Court’s record or admissible as evidence.

Parties should notify Judge Bass Ehler’s Courtroom Deputy as soon as possible if they need to reschedule, no longer consider the conference necessary or helpful, or have resolved the case.

Counsel who fail to attend a confirmed settlement conference may be sanctioned.

Deposition transcripts should not be filed on CM/ECF.

Exhibit chart must be submitted to Chambers by email with all counsel cc'd.

Two courtesy copies of exhibits must be submitted to Chambers.

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