Judge Mary M. Rowland

The Proposed Pretrial Order must be e-mailed in Word format to: Proposed_Order_Rowland@ilnd.uscourts.gov.

The parties shall jointly prepare and submit a final pretrial order containing the following:

A statement of the basis alleged for the Court’s jurisdiction and, if jurisdiction is disputed, the nature and basis of the dispute.

A statement of whether the case will be a bench trial or jury trial, and a realistic estimate of the length of the trial.

All objections to the calling of any witnesses, and the reasons for the objections, must be stated in the pretrial order.

Any witness not listed in the pretrial order will be precluded from testifying absent a showing of good cause, except that each party reserves the right to call such rebuttal witnesses (who are not presently identifiable as rebuttal witnesses) as may be necessary.

For wit- nesses who will be presented by deposition or other prior testimony, the pretrial order must include the following information for each such witness: (a) the tes- timony that each side seeks to present, by page and line; (b) a concise statement of objections to any testimony and the basis for the objections; and (c) a concise statement of the asserted basis of admissibility.

Plaintiff’s counsel must prepare the initial draft of the pretrial order and provide a draft to de- fendant’s counsel by no later than twenty-one (21) calendar days before the date the pretrial order is due to be filed.

After the pretrial conference and rulings on exhibits, parties must submit to the Court on two thumb drives the final, pre-marked exhibits along with ex- hibit lists.

10. Proposed Findings and Conclusions. In a bench trial, proposed findings of fact and conclusions of law. The parties shall confer about and submit any agreed proposed findings of fact and conclusions of law. Each party also shall submit its separate proposed findings of fact and conclusions of law.

The Proposed Pretrial Order must also be filed on the docket with a cover page with the case caption and the title "Proposed Pretrial Order."

Defendant’s counsel must respond in writing to the draft by no later than fourteen (14) calendar days before the pretrial order is due.

At least one week before the pretrial conference, the parties must submit an exhibit binder containing copies of the objected-to exhibits.

The parties must file a joint document that includes both (a) each party’s proposed voir dire questions, and (b) each party’s ob- jections, if any, to the voir dire questions proposed by other parties.

The parties must meet and confer in order to attempt to agree on jury instructions and the verdict forms.

The parties must exchange any proposed variations or additions to these general voir dire questions and must meet and confer to attempt to resolve any disagreements about the questions.

Any motion in limine filed by a party must be ac- companied by a statement that the party has conferred with the opposing party and has determined that the matter upon which a ruling is sought is actually in dispute – that is, that the opposing party actually intends to offer the evidence that the movant seeks to exclude.

Joint documents of proposed voir dire, jury instructions and verdict forms must be filed on the docket and also submitted in Word format to Judge Rowland’s proposed or- der mailbox (Proposed_Order_Rowland@ilnd.uscourts.gov).

Moreover, if an instruction is disputed, the objecting party must concisely state the grounds for the objection, as well as any proposed modification or alternative.

The proposed voir dire and jury instructions are to be prepared and submitted according to the following schedule, which may be varied only by Court order:

Motions in limine and supporting memoranda must be filed separately from the pretrial order as separate docket entries.

In a jury trial, proposed voir dire questions and jury instructions are not to be in- cluded in the Proposed Pretrial Order, but are to be separately filed.

The parties must submit all agreed and proposed jury instructions with the final pretrial order. Each proposed instruction must indicate the proponent of the instruction and whether the instruction is agreed or disputed.

The bottom of each instruction must identify the legal authority supporting the instruction.

In addition, parties are advised that at the close of evidence at trial they will be expected to file a final exhibit list on the docket.

If an instruction is disputed, the grounds for the objection (and any proposed modification or alternate instruction) must be concisely stated on the same page immediately following the disputed instruction.

To propose questions to be included in the written questionnaire distributed to the venire, the parties must file a joint proposed voir dire document that includes both: (a) each party’s proposed voir dire questions; and (b) each party’s objections, if any, to the voir dire questions proposed by the other parties.

Please consider whether your client has received or will be receiving conditional payments from Medicare to pay for treatment related to this case. If so, you must bring a conditional pay letter from Medicare to the settlement conference.

Counsel are cautioned that failure to attend a settlement conference without authorization may result in the imposition of monetary sanctions against them.

Separate lists of plaintiff’s and defendant’s exhibits, which each state: (a) the exhibit number of the document (preceded by “PX” for plaintiff’s exhibits and “DX” for defendant’s exhibits); (b) the date of the docu- ment; (c) a brief description of the document; (d) whether there is an objection to

All expert witnesses who will or may be called must be included on the witness list.

Lists of the trial exhibits (including demonstratives, summaries or other specially prepared exhibits), which are to be prepared in the following manner: A list of any joint exhibits, which states: (a) the exhibit number for the document (preceded by “JX”); (b) the date of the document;

Separate lists for plaintiff and defendant providing the names and addresses of witnesses, including experts, divided into the following three categories: (a) witnesses who will be called to testify at trial; (b) witnesses who may be called to testify at trial; and (c) witnesses whose testimony will be pre- sented by deposition or other prior testimony (indicating whether the presenta- tion will be by transcript or video).

In numbered paragraphs, set forth any stipulations and uncontested facts, as well as any stipulations regarding the presentation or admissibility of evidence.

A concise joint statement of the case, which includes the names of the parties and the attorneys who will be representing them at trial; the nature of the case; the claims, counterclaims and cross-claims; and the de- fenses raised to those claims.

An itemization of damages and other relief sought.

A list of the attorneys trying the case, including business addresses and telephone numbers.

9. List of motions in limine: each party must provide a list summarizing its mo- tions in limine.

The parties are required to meet and confer to discuss their respective drafts, and should attempt to reach agreement to the maximum extent possible.

It is then the responsibility of the plaintiff’s counsel – with full cooperation from defendant’s counsel – to assemble the pretrial order and file it.