Northern District of Illinois Document Filing Requirements

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

Civil cases

Applies to

Exhibit list

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.

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

Civil cases

Applies to

Pretrial statement

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.

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

Civil cases

Applies to

Exhibit chart

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.

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

Civil cases

Applies to

Exhibit chart

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.

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

Civil cases

Applies to

Exhibit chart objections

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.

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

Civil cases

Applies to

Deposition designation chart objections

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

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

Civil cases

Applies to

Pre trial memorandum

The Pre-Trial Memorandum must contain the information specified in the listed sections.

The Pre-Trial Memorandum shall contain the following information:

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

Civil cases

Applies to

Pre trial memorandum

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.

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

Civil cases

Applies to

Pretrial memorandum

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.

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

Civil cases

Applies to

Pretrial memorandum

The pre-trial memorandum must set out stipulations and uncontested facts in numbered paragraphs.

In numbered paragraphs, set forth any stipulations and uncontested facts.

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

Civil cases

Applies to

Pretrial memorandum

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.

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

Civil cases

Applies to

Voir dire questions

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.

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

Civil cases

Applies to

Jury instructions

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.

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

Civil cases

Applies to

Jury instructions

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.

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

Civil cases

Applies to

Jury instructions

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.

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

Civil cases

Applies to

Verdict form

The stated instruction-submission principles also apply to proposed verdict forms.

The same principles apply to proposed verdict forms.

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

Civil cases

Applies to

Pretrial conference

Lead trial counsel for each party must attend the Pre-Trial Conference.

Lead trial counsel for each party must attend the Pre-Trial Conference.

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

Civil cases

Applies to

Impeachment and refreshing recollection exhibits

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.

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

Civil cases

Applies to

Exhibit list

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.

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

Civil cases

Applies to

Exhibits

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.

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

Civil cases

Applies to

Exhibits

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.

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

Civil cases

Applies to

Exhibits

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.

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

Civil cases

Applies to

Proposed exhibits

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).

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

Civil cases

Applies to

Exhibits

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.

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

Civil cases

Applies to

Exhibit list

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.

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

Civil cases

Applies to

Witness list

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.

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

Civil cases

Applies to

Pretrial statement

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.

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

Civil cases

Applies to

Exhibit chart

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.

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

Civil cases

Applies to

Objections to exhibit chart

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.

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

Civil cases

Applies to

Exhibit

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.

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

Civil cases

Applies to

Exhibit chart objections

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.

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

Civil cases

Applies to

Objections to deposition designation chart

Defendant must provide specific objections to Plaintiff’s Deposition Designation Chart even when objecting to deposition testimony.

Even if Defendant objects, Defendant must still provide specific Objections to Plaintiff’s Deposition Designation Chart.

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

Civil cases

Applies to

Objections to deposition designation chart

Defendant must use Plaintiff’s Word deposition designation chart and add a column stating each objection and its concise basis.

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.

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

Civil cases

Applies to

Pretrial memorandum

The parties must confer in good faith about stipulations and uncontested facts at least 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.

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

Civil cases

Applies to

Pretrial memorandum

Counsel for each party must electronically sign the Pre-Trial Memorandum.

The Pre-Trial Memorandum shall be electronically signed by counsel for each party.

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

Civil cases

Applies to

Pretrial conference

Lead trial counsel for each party must attend the Pre-Trial Conference.

Lead trial counsel for each party must attend the Pre-Trial Conference.

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

Civil cases

Applies to

Final deposition transcript

Real-time objections in designated deposition excerpts that were not included with pre-trial objections must be removed or redacted from the transcripts.

Real-time objections within designated excerpts of deposition transcripts, which the parties did not include as part of their objections included with their pre-trial submissions, must also be removed/redacted from the transcripts.

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

Civil cases

Applies to

Impeachment and refreshing recollection exhibits

Planned impeachment and refreshing-recollection exhibits must be included on the USB drive in a separately titled folder.

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.”

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

Civil cases

Applies to

Trial exhibits

Exhibits must be marked before trial; court time may not be used for marking them.

Court time may not be used for marking exhibits. This must be done in advance of trial.

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

Civil cases

Applies to

Plaintiff initial settlement position letter

The plaintiff’s initial settlement letter must address liability, the basis for damages or other relief, itemized damages and supporting evidence and law, and a settlement demand.

The plaintiff’s counsel’s initial letter must set forth at least the following information: (a) a brief summary of the evidence and legal principles that plaintiff asserts will allow it to establish liability; (b) a brief explanation of why damages or other relief would appropriately be granted at trial; (c) an itemization of the damages plaintiff believes can be proven at trial, and a brief summary of the evidence and legal principles supporting those damages; and (d) a settlement demand.

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

Civil cases

Applies to

Defendant initial settlement position letter

The defendant’s response letter must identify points of agreement and disagreement with the plaintiff’s letter and state a settlement offer.

The defendant’s counsel’s letter in response to the plaintiff’s initial letter must set forth at least the following information: (a) any points in plaintiff’s letter with which the defendant agrees; (b) any points in plaintiff’s letter with which defendant disagrees; and (c) a settlement offer.

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

Civil cases

Applies to

Confidential settlement letter

Each confidential letter to chambers must state only the party’s specific settlement figure or, where appropriate, specific settlement proposal, and must not include other information or argument.

The second set of letters shall include only the following information: a specific dollar figure (or, in the appropriate case, other specific settlement proposal) at which the party is willing to settle. The parties shall not include additional information or argument in their confidential letters.

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

Civil cases

Applies to

Pretrial order

Must include

exhibit list

An exhibit not listed in the Pretrial Order will be excluded unless good cause is shown.

Any exhibit not listed in the Pretrial Order will be excluded from evidence absent a showing of good cause.

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

Civil cases

Applies to

Pretrial order

The Pretrial Order’s joint-exhibit list must include each exhibit’s JX number, document date, and brief description.

A list of any joint exhibits, which states: (a) the exhibit number for the document (preceded by “JX”); (b) the date of the document; and (c) a brief description of the document.

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

Civil cases

Applies to

Pretrial order

The parties must jointly prepare a proposed Pretrial Order before trial.

In advance of trial, the Court will require the parties to jointly prepare a proposed Pretrial Order.

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

Civil cases

Applies to

Pretrial order

The proposed final Pretrial Order must include the jurisdiction statement, trial-attorney contact list, and concise joint case statement with the specified information.

1. Jurisdiction - A statement of the basis alleged for the Court’s jurisdiction and, if jurisdiction is disputed, the nature and basis of the dispute. 2. Trial Attorneys – A list of the attorneys trying the case that includes their business and cell phone numbers and email addresses. 3. Case Statement - 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; and the claims, counterclaims and cross-claims asserted by the parties.

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

Civil cases

Applies to

Pretrial order

The proposed Pretrial Order must include a concise numbered list of contested factual or legal issues and a statement of any party stipulations.

4. Contested Issues – A concise, numbered list of contested issues of fact and/or law. 5. Stipulations - A statement of any stipulations reached by the parties.

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

Civil cases

Applies to

Pretrial order

An unlisted witness may not testify absent good cause, except that a party may call necessary rebuttal witnesses who are not presently identifiable as such.

Any witness not listed in the Pretrial Order will be precluded from testifying absent a showing a 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.

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

Civil cases

Applies to

Pretrial order

The Pretrial Order must state all objections to calling witnesses and their reasons; omitted objections are waived absent good cause.

All objections to the calling of any witnesses, and the reasons for the objections, must be stated in the Pretrial Order. Objections not made in the Pretrial Order will be deemed waived absent a showing of good cause.

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

Civil cases

Applies to

Pretrial order

For each witness whose testimony will be presented by deposition or other prior testimony, the Pretrial Order must include a chart identifying the proposed testimony by page and line, objections and supporting citations, and the asserted basis for admissibility with citations.

For witnesses who will be presented by deposition or other prior testimony, the Pretrial Order must include for each such witness a chart containing the following information: (a) the testimony that each side seeks to present, by page and line; (b) a concise statement of objections to any testimony and the basis for the objection with appropriate citations to evidentiary rules or case law; and (c) a concise statement of the asserted basis of admissibility with appropriate citations to evidentiary rules or case law.

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

Civil cases

Applies to

Pretrial order

Must include

proposed order

Parties must submit highlighted deposition transcripts with the Pretrial Order for every witness presented by deposition.

parties must also submit with the Pretrial Order highlighted deposition transcripts for each witness who will be presented by deposition.

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

Civil cases

Applies to

Pretrial order

An objection omitted from the Pretrial Order is waived unless good cause is shown.

Objections not made in the Pretrial Order will be deemed waived absent a showing of good cause.

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

Civil cases

Applies to

Exhibit

A party displaying an exhibit to the jury must provide enough copies for all jurors or use an enlargement or projection.

If an exhibit is to be displayed to the jury, the party intending to display the exhibit must make sufficient copies for all jurors or must use an enlargement or projection of the exhibit.

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

Civil cases

Applies to

Motion in limine

Must include

certificate of conference

Each motion in limine must include a statement confirming conferral and that the opposing party intends to offer the evidence the movant seeks to exclude.

Accordingly, any motion in limine must be accompanied 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, the opposing party actually intends to offer evidence that the movant seeks to exclude.

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

Civil cases

Applies to

Proposed voir dire

Under the Court’s pretrial schedule, the parties must jointly file a document containing each party’s additional proposed voir dire questions and any objections to other parties’ proposed questions.

Pursuant to the pretrial schedule set by the Court, the parties must file a joint document that includes: (a) each party’s proposed additional voir dire questions, and (b) each party’s objections, if any, to the voir dire questions proposed by other parties.

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

Civil cases

Applies to

Jury instructions

The parties must jointly file all agreed and proposed jury instructions no later than 7 calendar days before trial.

By no later than seven (7) calendar days before trial, the parties must file a joint document setting forth all agreed and proposed jury instructions as follows:

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

Civil cases

Applies to

Jury instructions

The joint jury-instruction document must include objections or requests concerning standard preliminary instructions and all proposed preliminary instructions.

The parties’ joint document shall set forth any objections to the standard instructions, or any requests for different or additional preliminary instructions. The joint document must set forth all proposed preliminary instructions.

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

Civil cases

Applies to

Jury instructions

The joint document must include proposed closing instructions in the parties’ proposed order and state any objections or requests to vary standard final instructions.

The joint document must set forth all instructions that the parties propose to be given at the close of trial, arranged in the order that the parties propose they be given. The Court uses certain standard final instructions, which are available on the Court’s website. Any objections to those standard instructions and any requests for variation to those instructions should be set forth in this portion of the submission.

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

Civil cases

Applies to

Jury instructions

Each proposed instruction must show its number, proponent, and agreed-or-disputed status at the top, and supporting legal authority at the bottom.

Each proposed instruction must be identified at the top of the page by number, and must indicate the proponent of the instruction and whether the instruction is agreed or disputed (e.g., “Agreed Plaintiff’s Proposed Preliminary Instruction No. __”; “Defendant’s Disputed Proposed Final Instruction No. __”). The bottom of each instruction must identify the legal authority supporting that instruction.

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

Civil cases

Applies to

Jury instructions

For a disputed instruction, concise objection grounds and any proposed alternative must appear on the immediately following page; the proponent may state supporting reasons on the next page.

If an instruction is disputed, the grounds for the objection (and any proposed modification or alternate instruction) must be concisely stated on the page immediately following the disputed instruction; on the next immediate page, the party proposing the instruction may state concisely the reasons supporting the instruction as proposed.

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

Civil cases

Applies to

Pretrial order

The proposed pretrial order must include a list of all trial exhibits, with each document’s exhibit number, date, brief description, and any admission objections.

5. Exhibit Lists: A list of all trial exhibits (including demonstratives, summaries or other specially prepared exhibits), which includes the following: (a) the exhibit number for each document; (b) the date of the document; (c) a brief description of the document; and (d) any objections to the admission of such document.

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

Civil cases

Applies to

Pretrial order

All motions in limine must be filed with the pretrial order.

7. Motions In Limine: All motions in limine must be filed with the pretrial order.

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

Civil cases

Applies to

Pretrial order

For civil bench trials before Judge Tharp, the parties must jointly prepare and docket a proposed pretrial order by the date set by the Court in advance of trial.

In all civil bench trials scheduled before Judge Tharp, the Court will set the date in advance of trial by which the parties shall jointly prepare and file, on the docket, a proposed pretrial order.

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

Civil cases

Applies to

Pretrial order

The Proposed Pretrial Order must state the jurisdictional basis for each claim.

State the jurisdictional basis for each claim.

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

Civil cases

Applies to

Pretrial order

The Proposed Pretrial Order must state the estimated trial length, including specified trial activities, and the recommended number of jurors, subject to Rule 48(a).

State the estimated number of trial days, including jury selection, opening statements, and closing arguments, as well as the number of jurors the parties recommend be selected (subject to Rule 48(a)).

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

Civil cases

Applies to

Pretrial order

The parties must submit to chambers, with the Proposed Pretrial Order, a binder containing all agreed exhibits, pre-marked.

Along with the Proposed Pretrial Order, the parties shall submit to chambers a binder including all of the agreed exhibits pre-marked.

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

Civil cases

Applies to

Agreed exhibits

If the Court accepts exhibits as agreed at the pretrial conference, later objections to their admission at trial will be rejected as untimely.

If such exhibits are deemed “agreed” at the pretrial conference and accepted by the Court, then any later objections to the admission of these exhibits into evidence at trial shall be rejected as untimely.

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

Civil cases

Applies to

Witness list

An unlisted witness may not testify unless the proponent shows good cause for the failure to disclose the witness.

Witnesses who are not listed are barred from testifying unless the proponent shows good cause for the failure to disclose the witness.

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

Civil cases

Applies to

Exhibit list

The exhibit list must include summary and demonstrative exhibits and identify each exhibit, its relevance, and any objection with the objection’s basis and the proponent’s admissibility theory.

The parties must submit an exhibit list that includes summary exhibits and demonstrative exhibits. The list must state the following: (a) the exhibit number; (b) a concise description of the exhibit (with any pertinent dates of documents); (c) a concise statement of the exhibit’s relevance; and (d) whether there is an objection to the exhibit’s admission, and if so, a concise explanation of the objection and the proponent’s theory of admissibility.

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

Civil cases

Applies to

Requested relief

Plaintiffs and any applicable counterclaimants or cross-claimants must itemize the damages and other relief sought.

Plaintiff(s) (and counter/cross-claimants, if applicable) shall itemize damages and other relief sought.

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

Civil cases

Applies to

Proposed pretrial order

Each party must include a list summarizing its motions in limine in the Proposed Pretrial Order.

In the Proposed Pretrial Order, each party must provide a list summarizing its motions in limine.

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

Civil cases

Applies to

Motion in limine

Motions in limine must be filed separately from the Proposed Pretrial Order by the Court-set due date.

Motions in limine must be filed separately from the Proposed Pretrial Order by the due date set by the Court.

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

Civil cases

Applies to

Motion in limine

Challenges to expert testimony or evidence must be raised in the motions in limine.

Any challenges to expert testimony or evidence must be made within the motions in limine.

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

Civil cases

Applies to

Motion in limine

Each motion in limine must include a statement confirming consultation and that the opposing party actually intends to offer, or actually opposes admission of, the evidence at issue.

Every motion in limine filed by a party must be accompanied by a statement that the party has conferred with the opposing party and the opposing party actually intends to offer the evidence that the movant seeks to exclude, or actually opposes admission of the evidence that the movant seeks to include.

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

Civil cases

Applies to

Proposed pretrial order

Additional voir dire questions must be listed in the Proposed Pretrial Order as agreed or objected-to questions, with a short basis for each objection.

Any additional questions sought by the parties must be listed in the Proposed Pretrial Order, divided into: (a) agreed-upon questions; and (b) proposed questions to which one party objects. A short basis for any objection should accompany the list.

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

Civil cases

Applies to

Jury instructions

The parties must meet and confer to try to agree on jury instructions and verdict forms.

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

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

Civil cases

Applies to

Legal brief

Legal briefs and memoranda of law, including those supporting or opposing judgment-as-a-matter-of-law motions, are not permitted during trial without prior leave of Court.

No legal briefs or memorandums of law will be permitted during trial (including briefs or memoranda supporting or opposing motions for judgment as a matter of law) absent prior leave of Court.

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

Civil cases

Applies to

Pretrial order

In every civil trial before Judge Hunt, the parties must jointly prepare and file a final pretrial order.

In all civil trials before Judge Hunt, the parties shall jointly prepare and file a final pretrial order.

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

Civil cases

Applies to

Pretrial order

Plaintiff’s counsel must prepare the initial final pretrial order draft and provide it to defendant’s counsel at least 21 days before the order is due.

Plaintiff’s counsel has the responsibility to prepare the initial draft of the final pretrial order and must provide a draft to defendant’s counsel no later than twenty-one days before the date the final pretrial order is due.

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

Civil cases

Applies to

Pretrial order

Defendant’s counsel must provide a written response at least 14 days before the final pretrial order is due, including objections, revisions, additions, and defendant’s portions of the draft.

Defendant’s counsel must respond in writing to plaintiff’s draft by no later than fourteen days before the final pretrial order is due, including any objections, changes, and additions to plaintiff’s draft, as well as defendant’s portions of the draft pretrial order (e.g., defendant’s witness list, exhibit list, and objections to exhibits and deposition testimony listed by plaintiff).

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

Civil cases

Applies to

Pretrial order

The parties must meet and confer at least seven days before the final pretrial order is due to discuss their drafts and seek agreement where possible.

The parties must meet and confer by no later than seven days before the final pretrial order is due to discuss their respective drafts and to reach agreement to the extent possible.

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

Civil cases

Applies to

Pretrial order

The final pretrial order must include jurisdictional information, trial attorney and counsel-table participant information, and a concise, agreed, neutral case statement describing the case, claims, and defenses.

The final pretrial order must include the following information: 1. Jurisdiction. State the jurisdictional basis for each claim. If the parties rely on either diversity jurisdiction or another jurisdictional basis that requires a threshold amount, then state whether the parties agree that the amount in controversy exceeds the amount and include a concise explanation of how the evidence supports that statement. 2. Trial Attorneys. List all attorneys trying the case, as well as contact information (business address, telephone number, and e-mail address). 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. 3. Case Statement. Provide a concise agreed statement of the case (no more than one or two short paragraphs) to be read by the Court to the jury pool during jury selection. The statement must describe the nature of the case, claims (plus counterclaims and crossclaims, if any) and defenses. This is a neutral description of the case, with just enough information to introduce

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

Civil cases

Applies to

Pretrial order

Each party must provide a categorized witness list, specified testimony-method information for prior testimony, a two- or three-sentence description of each witness, and an estimate of each witness’s total examination time.

Each party shall provide a list of witnesses, including expert witnesses, divided into (a) witnesses who will be called at trial; (b) witnesses who may be called to testify at trial; and (c) witnesses whose testimony will be presented by deposition or other prior testimony (indicating whether the presentation will be by reading a transcript or playing a video and including a brief summary of the legal and/or factual basis for presenting the testimony in that manner, as opposed to in-person). For each witness, provide a concise (2 or 3 sentences) description of the witness and the witness’ role in the case and estimate the amount of total time (including direct, cross, and redirect) required for each witness.

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

Civil cases

Applies to

Trial exhibits

The parties must upload electronic copies of all anticipated trial exhibits through the link provided by chambers.

In addition, the parties must upload electronic copies of all exhibits anticipated to be used at trial through a link that will be provided by chambers.

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

Civil cases

Applies to

Admitted trial exhibits

After the close of evidence, the parties must be prepared to meet and confer and provide the Court with Plaintiff’s and Defendant’s exhibit binders and a USB containing all admitted exhibits.

After the close of evidence, the parties must be prepared to meet and confer and each provide the Court with exhibit binders for Plaintiff and Defendant and a USB storage device containing all admitted exhibits.

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

Civil cases

Applies to

Trial exhibit certification

The parties must certify on the record that they reviewed and agree the binders and USB contain the admitted exhibits.

The parties will be required to certify on the record that they have reviewed and agree that the binders and USB storage device contain the admitted exhibits.

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

Civil cases

Applies to

Damages itemization

Plaintiff and any counter- or cross-claimants must itemize requested damages and other relief and briefly explain the evidentiary basis for each item.

Plaintiff (and counter/cross-claimants, if any) shall itemize damages and other relief sought and provide a concise explanation of the evidentiary basis for each itemization.

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

Civil cases

Applies to

Motions in limine list

Each party must provide a list briefly summarizing its motions in limine and stating whether each is opposed.

Each party must provide a list that very briefly summarizes its motions in limine and indicates whether they are opposed.

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

Civil cases

Applies to

Proposed pretrial order

Additional party voir dire questions must be listed in the Proposed Pretrial Order, separated into agreed questions and objected-to proposed questions.

Any additional questions sought by the parties must be listed in the Proposed Pretrial Order, divided into (a) agreed-upon questions and (b) proposed questions to which one party objects.

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

Civil cases

Applies to

Jury instruction comparison

A party proposing a modification to an applicable Seventh Circuit Pattern Instruction must submit a comparison document showing the modification.

If the parties wish to modify an applicable Seventh Circuit Pattern Instruction, the party proposing the modification must submit a comparison document to the Court showing the modification to the pattern instruction.

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

Civil cases

Applies to

Proposed jury instructions

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: (1) the proponent of the instruction, (2) the legal authority for the instruction, and (3) whether there is an objection to the instruction.

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

Civil cases

Applies to

Proposed jury instructions

For a disputed instruction, the objector must state the objection grounds and any proposed alternative or modification on the immediately following page.

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.

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

Civil cases

Applies to

Pretrial order

Counsel for each party must electronically sign the Pretrial Order.

The Pretrial Order must be signed (electronically) by counsel for each party.

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

Civil cases

Applies to

Settlement letter

Before the settlement conference, plaintiff’s counsel must send a settlement proposal with an itemized demand and explanation, and defendant’s counsel must respond with a written offer and explanation in time for a response.

Before the settlement conference and with enough time for a response, plaintiff’s counsel shall submit a letter to defendant’s counsel that proposes a settlement and itemizes damages and any other relief sought. The letter must provide a brief explanation of why such a settlement is appropriate. Defendant’s counsel shall submit a written offer to plaintiff’s counsel with a brief explanation of defendant’s response to plaintiff’s demand and an offer from defendant.

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

Civil cases

Applies to

Settlement conference attendance

Parties with ultimate settlement authority must attend in person, subject to specified insurer and corporate representative requirements; telephone availability is not an alternative unless the Court approves extenuating circumstances in advance.

Parties with ultimate settlement authority must be physically present at the conference. An insured party shall appear by a representative of the insurer who is authorized to negotiate, and who has authority to settle the matter up to the limits of the opposing party’s existing settlement demand or offer. An uninsured corporate party shall appear by a representative authorized to negotiate, and who has authority to settle the matter up the amount of the opposing party’s existing settlement demand or offer. The availability of a client by telephone is not an ===== PAGE 2 ===== acceptable alternative except in extenuating circumstances that must be approved by the Court in advance.

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

Civil cases

Applies to

Proposed scheduling order

A completed proposed scheduling order must be presented within seven days after the Rule 26(f) conference, unless the Court directs another time.

A completed proposed version of the scheduling order is to be presented to the Court within seven (7) days after the Rule 26(f) conference or at such other time as the Court directs.

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

Civil cases

Applies to

Claim construction brief

A party relying on witness testimony must include the witness’s sworn declaration with its brief and promptly make the witness available for deposition.

If a party offers the testimony of a witness to support its claim construction, it must include with its brief a sworn declaration by the witness setting forth the substance of the witness' proposed testimony, and promptly make the witness available for deposition concerning the proposed testimony.

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

Civil cases

Applies to

Initial infringement contentions

Initial Infringement Contentions must include the specified claim, accused-instrumentality, claim-element chart, and infringement-theory information.

A party claiming patent infringement must serve on all parties “Initial Infringement Contentions” containing the following information within fourteen (14) days after the Initial Disclosure under LPR 2.1: (a) identification each claim of each patent in suit that is allegedly infringed by the opposing party, including for each claim the applicable statutory subsection of 35 U.S.C. § 271; (b) separately for each asserted claim, identification of each accused apparatus, product, device, process, method, act, or other instrumentality (“Accused Instrumentality”) of the opposing party of which the party claiming infringement is aware. Each Accused Instrumentality must be identified by name, if known, or by any product, device, or apparatus which, when used, allegedly results in the practice of the claimed method or process; (c) a chart identifying specifically where each element of each asserted claim is found within each Accused Instrumentality, including for each element that such party contends is governed by 35 U.S.C. § 112(6), a description of the claimed function of that element and the identity of the structure(s), act(s), or material(s) in the Accused Instrumentality that performs the claimed function; (d) identification of whether each element of each asserted claim is claimed to be present in the Accused Instrumentality literally or under the doctrine of equivalents. For any claim under the doctrine of equivalents, the Initial Infringement Contentions must include an explanation of each function, way, and result that is equivalent and why any differences are not substantial;

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

Civil cases

Applies to

Initial infringement contentions

Initial Infringement Contentions must include the specified information about indirect infringement, priority, willfulness, and qualifying party or licensee products.

(e) for each claim that is alleged to have been indirectly infringed, an identification of any direct infringement and a description of the acts of the alleged indirect infringer that contribute to or are inducing that direct infringement. If alleged direct infringement is based on joint acts of multiple parties, the role of each such party in the direct infringement must be described; (f) for any patent that claims priority to an earlier application, the priority date to which each asserted claim allegedly is entitled; (g) identification of the basis for any allegation of willful infringement; and (h) if a party claiming patent infringement wishes to preserve the right to rely, for any purpose, on the assertion that its own or its licensee's apparatus, product, device, process, method, act, or other instrumentality practices the claimed invention, the party must identify, separately for each asserted patent, each such apparatus, product, device, process, method, act, or other instrumentality that incorporates or reflects that particular claim, including whether it is marked with the patent number.

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

Civil cases

Applies to

Initial non infringement unenforceability and invalidity contentions

Initial Non-Infringement Contentions require a responsive claim-element chart, and Initial Invalidity Contentions require detailed prior-art identification, invalidity positions, combinations and reasons, and a claim-element chart.

(a) Non-Infringement Contentions shall contain a chart, responsive to the chart required by LPR 2.2(c), that identifies as to each identified element in each asserted claim, to the extent then known by the party opposing infringement, whether such element is present literally or under the doctrine of equivalents in each Accused Instrumentality and, if not, the reason for such denial and the relevant distinctions. (b) Invalidity Contentions must contain the following information to the extent then known to the party asserting invalidity: (1) identification, with particularity, of each item of prior art that allegedly anticipates each asserted claim or renders it obvious. Each prior art patent shall be identified by its number, country of origin, and date of issue. Each prior art publication must be identified by its title, date of publication, and where feasible, author and publisher. Prior art under 35 U.S.C. § 102(b) shall be identified by specifying the item offered for sale or publicly used or known, the date the offer or use took place or the information became known, and the identity of the person or entity which made the use or which made and received the offer, or the person or entity which made the information known or to whom it was made known. Prior art under 35 U.S.C. § 102(f) shall be identified by providing the name of the person(s) from whom and the circumstances under which the invention or any part of it was derived. Prior art under 35 U.S.C. § 102(g) shall be identified by providing the identities of the person(s) or entities involved in and the circumstances surrounding the making of the invention before the patent applicant(s); (2) a statement of whether each item of prior art allegedly anticipates each asserted claim or renders it obvious. If a combination of items of prior art allegedly makes a claim obvious, each such combination, and the reasons to combine such items must be identified; (3) a chart identifying where specifically in each alleged item of prior art each element of each asserted claim is found, including for each element that such party contends is governed by 35 U.S.C. § 112(6), a description of the claimed function of that element and

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

Civil cases

Applies to

Joint appendix

The parties must file a Joint Appendix with the opening brief, include the disputed patents and each patent’s prosecution history, paginate the prosecution history, and cite the appendix when referencing its materials.

On the date for filing the Opening Claim Construction Brief, the parties shall file a Joint Appendix containing the patent(s) in dispute and the prosecution history for each patent. The prosecution history must be paginated, and all parties must cite to the Joint Appendix when referencing the materials it contains.

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

Civil cases

Applies to

Responsive claim construction brief

A party relying on witness testimony must include the witness’s sworn declaration with its brief and promptly make the witness available for deposition; doing so extends the reply-brief filing date by seven calendar days.

If a party offers the testimony of a witness to support its claim construction, it must include with its brief a sworn declaration by the witness setting forth the substance of the witness's proposed testimony and promptly make the witness available for deposition concerning the proposed testimony, in which case the date for the filing of a Reply Claim Construction brief shall be extended by seven (7) calendar days.

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

Civil cases

Applies to

Joint claim construction chart and status report

Within seven days after the reply brief, the parties must file a joint chart of addressed terms and proposed constructions and a joint status report proposing the hearing’s nature and form.

With seven (7) days after filing of the Reply Claim Construction Brief, the parties shall file (1) a joint claim construction chart that sets forth each claim term and phrase addressed in the claim construction briefs; each party's proposed construction, and (2) a joint status report containing the parties' proposals for the nature and form of the claim construction hearing pursuant to LPR 4.3.

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

Civil cases

Applies to

Pretrial order

The parties must jointly prepare and submit a final pretrial order containing the specified materials.

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

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

Civil cases

Applies to

Pretrial order

The pretrial order must state the alleged basis for jurisdiction and, if disputed, the nature and basis of the dispute.

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

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

Civil cases

Applies to

Pretrial order

The pretrial order must state whether trial is to the bench or a jury and provide a realistic trial-length estimate.

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

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

Civil cases

Applies to

Pretrial order

The pretrial order must state all objections to calling witnesses and the reasons for each objection.

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

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

Civil cases

Applies to

Pretrial order

For each witness presented by deposition or other prior testimony, the pretrial order must identify proposed testimony by page and line, objections and their basis, and the asserted basis for admissibility.

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.

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

Civil cases

Applies to

Pretrial order

An unlisted witness is precluded absent good cause, except that a party may call necessary rebuttal witnesses not presently identifiable as such.

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.

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

Civil cases

Applies to

Exhibit binder

The parties must submit an exhibit binder with copies of objected-to exhibits at least one week before the pretrial conference.

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

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

Civil cases

Applies to

Final exhibits

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

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.

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

Civil cases

Applies to

Proposed findings conclusions

In a bench trial, the parties must confer about and submit any agreed proposed findings and conclusions, and each party must also submit its own separate proposed findings and conclusions.

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.

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

Civil cases

Applies to

Pretrial order

Plaintiff’s counsel must provide the initial pretrial-order draft to defendant’s counsel at least 21 calendar days before the filing due date.

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.

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

Civil cases

Applies to

Pretrial order

Defendant’s counsel must respond in writing to the draft at least 14 calendar days before the pretrial order is due.

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

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

Civil cases

Applies to

Proposed pretrial order

Must include

caption

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

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."

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

Civil cases

Applies to

Motion in limine

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

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

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

Civil cases

Applies to

Motion in limine

Every motion in limine must include a statement confirming consultation with the opposing party and that the disputed evidence is actually intended to be offered.

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.

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

Civil cases

Applies to

Proposed pretrial order

In jury trials, proposed voir dire questions and jury instructions must be filed separately and not included in the Proposed Pretrial Order.

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.

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

Civil cases

Applies to

Proposed voir dire

The proposed voir dire and jury instructions must follow the stated schedule, which may be changed only by court order.

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:

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

Civil cases

Applies to

Proposed voir dire

The parties must exchange proposed variations or additions to the standard voir dire questions and meet and confer to try to resolve disagreements.

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.

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

Civil cases

Applies to

Proposed voir dire

The parties must file one joint document containing each party’s proposed voir dire questions and any objections to other parties’ proposed questions.

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.

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

Civil cases

Applies to

Jury instructions

The parties must meet and confer to try to agree on jury instructions and verdict forms.

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

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

Civil cases

Applies to

Jury instructions

For a disputed instruction, the objecting party must concisely state the objection grounds and any proposed modification or alternative.

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.

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

Civil cases

Applies to

Joint trial documents

Joint voir dire, jury-instruction, and verdict-form documents must be filed on the docket and emailed in Word format to Judge Rowland’s proposed-order mailbox.

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).

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

Civil cases

Applies to

Pretrial order

Footnotes 1, 2, 4–10, 13, and 14 of Form LR16.1.1 apply when preparing the Western Division FPTO.

Footnotes 1, 2, 4, 5, 6, 7, 8, 9, 10, 13, and 14 of Form LR16.1.1 shall apply to the preparation of the Western Division FPTO.

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

Civil cases

Applies to

Motion

A motion for summary judgment must be accompanied by a Local Rule 56.1 statement of material facts.

and, in the case of a motion for summary judgment, with a Local Rule 56.1 stat ement of mat erial facts.

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

Civil cases

Applies to

Final pretrial order

Parties in civil actions scheduled for trial must jointly prepare and submit a Final Pretrial Order unless the Court modifies the requirement.

Absent prior modification by the Court, the parties in every civil action that is scheduled to proceed to trial shall jointly prepare and submit a Final Pretrial Order.

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

Civil cases

Applies to

Final pretrial order

Plaintiff’s counsel must provide the initial draft to defendant’s counsel at least 21 days before the Final Pretrial Order is due.

Plaintiff’s counsel is responsible for preparing the initial draft of the Final Pretrial Order and must provide a draft to defendant’s counsel no later than twenty-one days before the date on which the Final Pretrial Order is due.

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

Civil cases

Applies to

Final pretrial order

Defendant’s counsel must provide a written response, including specified edits and defendant’s portions of the order, at least 14 days before the order is due.

Defendant’s counsel must respond in writing to plaintiff’s draft no later than fourteen days before the Final Pretrial Order is due, including any objections, changes, and additions to plaintiff’s draft, as well as defendant’s portions of the draft Final Pretrial Order (e.g., defendant’s witness list, exhibit list, and objections to exhibits and deposition testimony listed by plaintiff).

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

Civil cases

Applies to

Final pretrial order

The parties must meet and confer about their drafts no later than 7 days before the Final Pretrial Order is due.

The parties must meet and confer by no later than seven days before the Final Pretrial Order is due to discuss their respective drafts and to reach agreement to the extent possible.

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

Civil cases

Applies to

Final pretrial order

After the meet-and-confer, plaintiff’s counsel must assemble the Final Pretrial Order for filing with full cooperation from defendant’s counsel.

Following the meet-and-confer process, it is the responsibility of plaintiff’s counsel, with full cooperation from defendant’s counsel, to assemble the Final Pretrial Order for filing.

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

Civil cases

Applies to

Final pretrial order

The cover document must include the stated language concerning the order’s control of trial and amendment.

The cover document must state that “This Order will control the course of the trial and may not be amended except by consent of the parties, or by order of the Court to prevent manifest injustice.”

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

Civil cases

Applies to

Final pretrial order

The Final Pretrial Order document must be signed by counsel for each party and include a space for the judge’s signature.

The document also must be signed by counsel for each party and must contain a space for the judge’s signature.

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

Civil cases

Applies to

Final pretrial order

In cases requiring an amount in controversy, the order must include either a stipulation to the jurisdictional amount or a brief evidence-supported statement that the amount reasonably could be awarded.

In diversity cases or other cases requiring a jurisdictional amount in controversy, the Order shall contain either a stipulation that the required jurisdictional amount is involved or a brief written statement citing evidence supporting the claim that such a sum reasonably could be awarded.

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

Civil cases

Applies to

Final pretrial order

The order must concisely state the plaintiffs’ claims, defendants’ defenses, and all counterclaims or cross-claims in one or two paragraphs.

A concise statement (one or two paragraphs) of the claim(s) of the plaintiff(s), defense(s) of the defendant(s), and all counterclaims or cross-claims.

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

Civil cases

Applies to

Final pretrial order

The order must list the names and addresses of all witnesses who will or may be called and those whose depositions will be used at trial.

A list of names and addresses of all witnesses: (a) who will be called; (b) who may be called; and (c) whose deposition will be used at trial.

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

Civil cases

Applies to

Final pretrial order

Unlisted witnesses may not testify absent good cause, except that a party may call necessary rebuttal witnesses who are not presently identifiable.

Any witness not listed in the Final 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 may be necessary.

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

Civil cases

Applies to

Final pretrial order

Witness objections omitted from the Final Pretrial Order are waived absent good cause.

Objections not made in the Final Pretrial Order will be deemed waived absent a showing of good cause.

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

Civil cases

Applies to

Final pretrial order

For each deposition witness, the order must include a chart identifying each side’s proposed testimony by page and line, objections and their bases, and the asserted basis of admissibility.

For each witness whose deposition will be used at trial, a chart containing the following information: (a) a listing, by page and line, of the testimony that each side seeks to present; (b) a concise statement of objections to any testimony and the basis for the objection; and (c) a concise statement of the asserted basis of admissibility.

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

Civil cases

Applies to

Final pretrial order

If deposition objections exist, a copy of the deposition must accompany the Final Pretrial Order; small-type format is preferred.

If there are objections, a copy of the deposition (preferably in small-type format) must be provided with the Final Pretrial Order.

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

Civil cases

Applies to

Final pretrial order

The order must include stipulations or statements of each expert’s qualifications in a form that can be read to the jury when the expert testifies.

Stipulations or statements setting forth the qualifications of each expert witness in such form that the statement can be read to the jury at the time the expert witness takes the stand.

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

Civil cases

Applies to

Final pretrial order

Exhibits not listed in the Final Pretrial Order are excluded absent good cause.

Any exhibit not listed in the Final Pretrial Order will be excluded from evidence absent a showing of good cause.

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

Civil cases

Applies to

Final pretrial order

If an exhibit is objected to, a copy of the proposed exhibit must accompany the Final Pretrial Order.

If there are objections, a copy of the proposed exhibit must be provided with the Final Pretrial Order.

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

Civil cases

Applies to

Exhibit bench book

The joint and separate exhibit bench books must be delivered to the Court and made available to counsel at least two business days before trial.

A bench book of joint exhibits and each party’s separate exhibits is to be delivered to the Court and made available to all counsel no later than two business days before the start of trial.

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

Civil cases

Applies to

Exhibit

A party displaying an exhibit to the jury must provide copies for all jurors or use an enlargement or projection.

If an exhibit is to be displayed to the jury, the party intending to display the exhibit must make sufficient copies for all jurors or must use an enlargement or projection of the exhibit.

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

Civil cases

Applies to

Proposed findings conclusions

For a bench trial, each party must submit proposed findings and conclusions with the Final Pretrial Order in hard copy and on disk in Word or Word Perfect format.

For a bench trial, each party shall submit with the Final Pretrial Order a hard copy and a disk (in Word or Word Perfect) containing its proposed findings of fact and conclusions of law.

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

Civil cases

Applies to

Proposed voir dire questions

For a jury trial, the parties must submit proposed voir dire questions.

For a jury trial, the parties shall submit proposed voir dire questions.

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

Civil cases

Applies to

Final pretrial order

For a jury trial, include proposed instructions, verdict forms, and special interrogatories in the Final Pretrial Order in hard copy and on disk in Word or Word Perfect format.

For a jury trial, proposed jury instructions, verdict forms, and any special interrogatories are to be included in the Final Pretrial Order, both in hard copy and on a disk (in Word or Word Perfect).

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

Civil cases

Applies to

Proposed jury instructions

Before submitting the Final Pretrial Order, the parties must confer and agree on instructions, verdict forms, and special interrogatories to the extent possible.

The parties are directed to confer and agree upon jury instructions, verdict forms, and any special interrogatories to the extent possible, prior to the submission of the Final Pretrial Order.

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

Civil cases

Applies to

Disputed proposed jury instructions

Each disputed proposed instruction must be numbered, identify its proponent, and include supporting authority.

Proposed instructions as to which there is no agreement shall be numbered, shall identify the proponent of the instruction, and shall include supporting authority.

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

Civil cases

Applies to

Jury instructions

When Illinois law supplies the rule of decision, Illinois Pattern Instructions must be used for all substantive-law issues.

In diversity and other cases in which Illinois law provides the rule of decision, use of Illinois Pattern Instructions as to all issues of substantive law is required.

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

Civil cases

Applies to

Final jury instructions

At trial, submit an unmarked original set of instructions, verdict forms, and special interrogatories to the Court on 8½-by-11-inch sheets for the jury room.

At the time of trial, an unmarked original set of instructions, verdict forms, and any special interrogatories shall be submitted to the Court on 8½” x 11” sheets to be sent to the jury room after being read to the jury.

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

Civil cases

No further discovery is permitted absent good cause.

Absent good cause, no further discovery shall be permitted.

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

Civil cases

Applies to

Motion in limine

Each motion in limine must include a statement confirming a conference with the opposing party and that the evidentiary issue is genuinely disputed.

Any motion in limine filed by a party must be accompanied 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 intends to offer the evidence that the movant seeks to exclude, or actually opposes admission of the evidence that the movant seeks to include.

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

Civil cases

Applies to

Joint pre hearing statement

The parties must file a joint pre-hearing statement two weeks before the hearing that states the anticipated hearing length, intended witnesses, and a brief summary and anticipated length of each witness’s testimony.

Two weeks before the claim construction hearing, the parties must file a Joint Pre- hearing Statement with the following information: A. The anticipated length of time anticipated for a claim construction hearing; B. The identity of any witnesses each party intends to call at such a hearing; and C. A brief summary of the nature of each witness’s testimony and the anticipated length of such testimony.

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

Civil cases

Applies to

Memorandum

A party intending to call an expert witness or submit expert affidavits must attach a statement of the expert’s qualifications to any memorandum submitted.

If a party intends to call as a witness and/or submit affidavits of experts, a statement of the expert’s qualifications shall be submitted as an additional attachment to any memorandum submitted.

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

Civil cases

Applies to

Joint status report

The joint status report must address the listed counsel, jurisdiction, claims, service, legal and factual issues, jury demand, and discovery information.

1. In the joint status report, please provide the following information: A. The attorneys of record for each party, including the attorney(s) expected to try the case. B. The basis for federal jurisdiction. C. The nature of the claims asserted in the complaint and any counterclaim. D. The name of any party who or which has not been served, and any fact or circumstance related to non-service of process on such party. E. The principal legal issues. F. The principal factual issues. G. Whether a jury trial has been demanded by any party. H. A brief description of any discovery that has been taken and of the discovery anticipated to be required, and suggested dates for discovery deadlines and cutoff. Parties are reminded of their discovery obligations under Fed. R. Civ. P. 26 and Local Rule 26.1.

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

Civil cases

Applies to

Joint status report

The joint status report must include, if reasonably ascertainable, the parties’ earliest trial-ready date and estimated trial length, as well as the listed consent, settlement, and conference information.

I. If reasonably ascertainable at this early stage of the case, the earliest date the parties would be ready for trial and the estimated length of trial. J. Whether the parties consent unanimously to proceed before a Magistrate Judge. K. The status of any settlement discussions. L. Whether the parties request a settlement conference.

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

Civil cases

Applies to

Voir dire materials

The voir dire materials must include a short case description, expected-witness list, and names of people who may be mentioned at trial.

a. A short description of the case to be read to the venire panel, along with a list of the witnesses expected to testify and the names of people who may be mentioned at the trial;

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

Civil cases

Applies to

Motion in limine

Submit motions in limine under separate cover when filing the pretrial order; they generally will be decided by the final pretrial conference.

7. Motions in limine shall be submitted under separate cover at the time the pretrial order is filed, and will generally be decided at or before the final pretrial conference.

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

Civil cases

Applies to

Jury instructions

In jury trials, follow the cited jury-instruction requirements: present agreed instructions whenever possible, identify each instruction’s proponent and authority, number instructions, and make written objections with supporting citations; failure to object may waive an objection.

For jury trials, the court will insist on strict compliance with footnote 10 of paragraph 2(I) of the final pretrial order Form 16.1.1. This provision reads as follows: "Agreed instructions shall be presented by the parties whenever possible. Whether agreed or unagreed, each marked copy of an instruction shall indicate the proponent and supporting authority and shall be numbered. All objections to tendered instructions shall be in writing and include citations of authorities. Failure to object may constitute a waiver of any objection." (Emphasis in original.)

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

Civil cases

Applies to

Jury instructions

The plaintiff’s attorney must prepare the first draft of jury instructions, and the parties are expected to agree on instructions except those involving a genuine, material dispute.

It is the duty of the plaintiff's attorney to prepare the first draft of jury instructions, keeping in mind that the parties are expected to agree on all instructions other than those about which there is a genuine, material dispute.

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

Civil cases

Applies to

Proposed jury instructions

Unless otherwise ordered, use Seventh Circuit Jury Instructions and, when Illinois law applies, Illinois Pattern Instructions.

a. Unless otherwise ordered, use the Seventh Circuit Jury Instructions and, where Illinois law applies, use the Illinois Pattern Instructions.

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

Civil cases

Applies to

Proposed jury instructions

Proposed jury instructions must be arranged in the order they will be given.

b. Arrange in the order to be given.

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

Civil cases

Applies to

Proposed jury instructions

Place contested instructions in their proposed order and require the opposing party to state objection grounds and, when appropriate, tender an alternative; supporting materials may be included as described and must be included in the proposed-instructions binder.

d. Place contested instructions in the order they would be given if accepted, and for each such instruction the party opposing it must succinctly state the grounds for objection and, if appropriate, tender an alternate instruction. The parties may be able to accomplish this by highlighting, bracketing or redlining the challenged portion of an instruction and indicating alternate language within the body of the instruction. The proposing party may also submit the reasons supporting the instruction as tendered. These objections and supporting materials shall be included in the binder of proposed

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

Civil cases

Applies to

Pretrial order

Parties in civil bench trials before Judge Ellis must jointly prepare and submit a final pretrial order.

In all civil bench trials scheduled before Judge Ellis, the parties shall jointly prepare and submit a final pretrial order.

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

Civil cases

Applies to

Pretrial order

The final pretrial order must state the basis for the Court’s jurisdiction.

The final pretrial order (including the Court’s two courtesy copies) must include the following items: 1. Jurisdiction: A statement of the basis for the Court’s jurisdiction.

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

Civil cases

Applies to

Trial brief

A party wishing to file a trial brief must first obtain leave of the Court.

Parties who wish to file a trial brief must seek leave of the Court to do so.

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

Civil cases

Applies to

Final pretrial order

In civil jury trials before Judge Coleman, the parties must jointly prepare and submit a Final Pretrial Order by the court-set date, at least two weeks before trial.

In all civil jury trials scheduled before Judge Coleman, the parties must jointly prepare and submit a Final Pretrial Order. In each case, the Court will set the date in advance of the trial (a minimum of two weeks before trial) on which the parties must file the Final Pretrial Order.

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

Civil cases

Applies to

Final pretrial order

The Final Pretrial Order, including its courtesy copy, must include the specified jurisdiction statement, attorney list, agreed case statement, categorized witness lists, detailed exhibit lists, and itemization of damages and other relief.

The Final Pretrial Order (including the Court’s courtesy copy) must include the following items: 1. Jurisdiction A statement of the basis for the Court’s jurisdiction. 2. Trial Attorneys A list of the attorneys trying the case, including business addresses and telephone numbers. 3. Case Statement A concise agreed statement of the case, including: the nature of the case; the claims, counterclaims and cross-claims; and the defenses raised to those claims. The Court will read this statement to the jury during voir dire. 4. Witness Lists Separate lists for plaintiff and defendant providing the names of witnesses, including expert witnesses, 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 a party will present by deposition or other prior testimony, indicating whether the presentation will be by transcript or video. The Court will read these lists to the jury during voir dire. 5. Exhibit Lists A list by each side of all trial exhibits (including demonstratives, summaries or other specially prepared exhibits), which includes the following: (a) the exhibit number for each document; (b) the date of the document; (c) a brief description of the document; (d) whether there is an objection to admission of the document and, if so, a concise statement of the basis for the objections (e.g., Rule 402-relevance; Rule 403-undue prejudice or confusion); and (e) a concise statement of the asserted basis of admissibility. 6. Itemization of Damages An itemization of damages and other relief sought.

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

Civil cases

Applies to

Proposed voir dire

The parties must file a joint document containing each party’s proposed voir dire questions and any objections to other parties’ proposed questions.

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

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

Civil cases

Applies to

Jury instructions

The parties must attempt to agree on jury instructions and submit agreed and proposed instructions with the Final Pretrial Order, identifying each instruction’s proponent, status, supporting authority, and, for disputed instructions, the required objection and response pages.

The parties are instructed to meet and attempt to agree on jury instructions. The parties must submit all agreed and proposed 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 that instruction. If an instruction is disputed, the grounds for the objection and any proposed modification or alternate instruction must be concisely stated on the page immediately following the disputed instruction; on the next immediate page, the party proposing the instruction may state concisely the reasons supporting the instruction as proposed.

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

Civil cases

Applies to

Joint status report

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.

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

Civil cases

Applies to

Joint status report

The report must state whether a settlement conference would be productive and briefly explain if the parties believe it would not.

State whether the parties believe a settlement conference would be productive at this time, and if not, briefly explain why.

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

Civil cases

Applies to

Mediation statement

When settlement is likely to depend in whole or in part on financial matters, mediation statements must include a concrete monetary proposal.

The parties' mediation statements must contain a concrete monetary proposal, where settlement is likely to turn in whole or in part on financial matters, as most settlements do.

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

Civil cases

Applies to

Settlement conference

In applicable matters, if the client has received or will receive Medicare conditional payments for treatment related to the case, counsel must bring a Medicare conditional pay letter to the settlement conference.

In applicable matters, 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.

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

Civil cases

Applies to

Discovery motion

Must include

certificate of conference

For discovery disputes, bare emails do not suffice; the required certification must detail the in-person or remote conference or explain why it could not occur through no fault of the movant.

Bare emails to resolve discovery disputes are not enough, and the required certification must state the details of the in-person or remote conference that was had, or state why through no fault of the movant, the conference could not be had.

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

Civil cases

Applies to

Hearing transcript

Same-day hearings must be transcribed by the retained private court reporter, and the transcript must be prepared and filed on an expedited basis.

All same-day hearings shall be conducted on the record as transcribed by the retained private court reporter, with the hearing transcript prepared and filed on an expedited basis to ensure public access.

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

Civil cases

Applies to

Discovery motion

A discovery motion must identify the time, manner, and participants in the Local Rule 37.2 conference.

Nor does a motion comply with the rule if it does not identify the time, manner and persons who participated in the Local Rule 37.2 conference.

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

Civil cases

Applies to

Joint status report

The joint status report must include the information specified in the order.

The joint status report shall contain the following information:

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

Civil cases

Applies to

Joint status report

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.

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

Civil cases

Applies to

Joint status report

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.

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

Civil cases

Applies to

Joint status report

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.

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

Civil cases

Applies to

Joint status report

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.

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

Civil cases

Applies to

Joint status report

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

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.

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

Civil cases

Applies to

Joint status report

The report must describe the status of settlement discussions and state whether the parties believe a settlement conference would be productive, briefly explaining why not if applicable.

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.

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

Civil cases

Applies to

Joint status report

The parties must submit a joint status report before the initial status hearing addressing the listed settlement-readiness and participant topics.

Prior to the initial status hearing, the Court will direct the parties to submit a joint status report addressing the following issues: (1) whether the parties have the necessary information to conduct meaningful settlement discussions; (2) the earliest anticipated date when all parties will be ready to participate in a productive settlement conference; (3) whether the parties have engaged in previous settlement discussions and the current status of those discussions; (4) the individuals who will be present at the settlement conference on behalf of their respective parties, consistent with the requirements of this order; and (5) whether there are outstanding lien holders or third parties who must provide information or should participate in the settlement conference.

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

Civil cases

Applies to

Settlement letter

The parties must exchange settlement letters before the settlement conference.

The parties are required to exchange settlement letters before the conference.

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

Civil cases

Applies to

Plaintiff settlement letter

A plaintiff’s settlement letter must include the case nature, supporting evidence and legal principles, itemized damages, a settlement demand, and any other information the plaintiff believes would assist the Court.

Plaintiff’s settlement letter must set forth the following information: (a) the nature of the case; (b) a brief summary of the evidence and legal principles that support plaintiff’s theory of liability, damages, and any other relief; (c) an itemization of damages; (d) a settlement demand; and (e) any additional information plaintiff believes would be helpful to the Court in assisting the parties to resolve the dispute.

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

Civil cases

Applies to

Plaintiff settlement demand

A plaintiff’s settlement demand must be all-inclusive and specify every monetary and non-monetary element of relief sought.

Plaintiff’s settlement demand must be all inclusive and specify each element of monetary and non-monetary relief that plaintiff seeks to settle the case.

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

Civil cases

Applies to

Defendant settlement letter

A defendant’s settlement letter must state its defense theory and address the specified points, responsive offer, and helpful additional information.

Defendant’s settlement letter must set forth the theory of defense and shall include the following information: (a) any point(s) in plaintiff’s letter with which the defendant agrees; (b) any point(s) in plaintiff’s letter with which defendant disagrees; (c) a settlement offer that is responsive to the monetary and non-monetary elements of relief that plaintiff seeks in its settlement demand; and (d) any additional information defendant believes would be helpful to the Court in assisting the parties to resolve the dispute.

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

Civil cases

Applies to

Settlement letter

Each party’s settlement letter must identify by name and title the individuals expected to attend the settlement conference.

All parties shall include within their letters the names and titles of the individuals they anticipate will be attending the settlement conference.

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

Civil cases

Applies to

Settlement letters

Counsel must provide their clients the complete set of settlement letters to read before the conference.

Counsel are required to provide the full set of settlement letters to their clients to read prior to the conference.

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

Civil cases

Applies to

Verification of inability to pay

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.

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

Civil cases

Applies to

Plaintiff settlement letter

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.

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

Civil cases

Applies to

Defendant settlement letter

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.

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

Civil cases

Applies to

Settlement letter

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.

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

Civil cases

Applies to

Defendant settlement letter

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.

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

Civil cases

Applies to

Settlement letters

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.

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

Civil cases

Applies to

Joint status report

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.

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

Civil cases

Applies to

Joint status report

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.).

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

Civil cases

Applies to

Plaintiff settlement statement

Plaintiff’s counsel must submit a settlement statement describing the action, liability theory, itemized damages, and demand.

Consistent with the schedule that is set, plaintiff’s counsel must submit a settlement statement to defendant’s counsel, describing the nature of the action, the theory of liability, itemization of damages, and plaintiff’s demand.

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

Civil cases

Applies to

Defendant settlement statement

Defendant’s counsel must submit a settlement statement describing the defense theory and defendant’s offer.

Defendant’s counsel must thereafter submit a settlement statement to plaintiff’s counsel, describing the theory of defense and defendant’s offer.

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

Civil cases

Applies to

Settlement statement

Settlement statements must identify all settlement-conference attendees and state each person’s role.

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

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

Civil cases

Applies to

Settlement statement

Counsel must provide their clients the complete set of settlement statements to read before the conference.

All counsel are required to provide the full set of the settlement statements to their clients to read prior to the conference.

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

Civil cases

Statements made during the settlement conference are confidential, may not be used in discovery, and are inadmissible at trial.

Statements made by any party during the settlement conference are confidential, are not to be used in discovery, and will not be admissible at trial.

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

Civil cases

Applies to

Settlement agreement

If the parties reach an agreement, they must detail its material terms at the conclusion of the conference.

If the parties are successful in reaching an agreement, they will be required to detail the material terms of the settlement at the conclusion of the conference.

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

Civil cases

Applies to

Joint initial status report

The joint initial status report must address pending or anticipated motions, confidentiality, a detailed discovery plan, and any other topic the parties wish to raise.

The joint initial status report shall contain: 1) The nature and timing of any pending or anticipated motions 2) Proposal for addressing confidentiality concerns, if applicable 3) Proposed discovery plan, including: a) Any existing discovery cut-off dates b) The type/extent of discovery needed to engage in meaningful settlement negotiations, either now or at a later point c) Deadline for service of Rule 26(a)(1) disclosures d) Deadline for issuance of initial written discovery requests e) Deadline for completion of fact discovery (including treating physician discovery, if applicable) f) Party agreements, if any, regarding the scope of discovery, such as date restrictions or obligations relating to privilege logs g) Comprehensive expert discovery schedule, including interim dates for serving expert reports and rebuttal 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 staggered dates. h) Description of the anticipated scope of discovery involving electronically stored information (ESI) and the potential methodologies for identifying ESI for production. i) Please note the Court has adopted the Principles of the Seventh Circuit Electronic Discovery Pilot Program, and the parties should be familiar with them. ii) In patent cases, the court will apply the Local Patent Rules for Electronically Stored Information. iii) To assist counsel in discovery, the Court has prepared a sample ESI order that can govern non-complex ESI discovery. For complex ESI discovery, including discovery that uses technology assisted review ===== PAGE 2 ===== (TAR), the Court will consider entering a more detailed proposed order submitted by the parties, with an accompanying motion. 4) Any other topic the parties wish to bring to the Court’s attention.

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

Applies to

Answers to court interrogatories

Plaintiff must file the interrogatory answers with the Court under the specified title, no earlier than and by 42 days after the order is issued.

By _________________ [42 days from the date this Order is issued], and no earlier, Plaintiff shall answer the Court's Interrogatories (attached to this Order) under oath or penalty of perjury, serve a copy on Defendant, and file the answers with the Court entitled "Notice of Filing Answers to Court's Interrogatories."

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

Civil cases

Applies to

Proposed final pretrial order

For each claim, the proposed order must state the jurisdictional basis and, when a threshold amount is required, address agreement that the amount in controversy exceeds it and explain the supporting evidence.

State the jurisdictional basis for each claim. If the parties rely on either diversity jurisdiction or another jurisdictional basis that requires a threshold amount, then state whether the parties agree that the amount in controversy exceeds the amount and include a concise explanation of how the evidence supports that statement.

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

Civil cases

Applies to

Proposed final pretrial order

The proposed order must list all trial attorneys and each attorney’s business address, telephone number, and email address.

List all of the attorneys trying the case, as well as contact information (business address, telephone number, and email address).

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

Civil cases

Applies to

Proposed final pretrial order

The proposed order must state estimated trial days based on six-hour testimony days, propose time limits for openings, closings, and witness examination, and recommend a jury size.

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). Propose estimated time limits for: ===== PAGE 2 ===== (a) opening statements per side; (b) closing arguments per side (including an initial close and rebuttal for the plaintiff); and (c) the total number of hours of witness examination per side. Also, state the number of jurors that the parties recommend (subject to Federal Rule of Civil Procedure 48(a)).

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

Civil cases

Applies to

Proposed final pretrial order

The proposed order must state any stipulations and uncontested facts in numbered paragraphs.

In numbered paragraphs, state any stipulations and uncontested facts.

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

Civil cases

Applies to

Proposed exhibits

The parties must submit all proposed exhibits to chambers on a USB storage device, DVD, or CD at least 5 business days before the pretrial conference.

At least 5 business days before the pretrial conference, the parties must submit to chambers a USB storage device, DVD, or CD with all of the proposed exhibits.

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

Civil cases

Applies to

Exhibit binders

With the proposed-exhibit disc, the parties must supply two sets of exhibit binders containing only objected-to exhibits.

In addition to the disc, the parties also must supply 2 sets of exhibit binders containing copies of objected-to exhibits only.

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

Civil cases

Applies to

Final trial exhibits

After exhibit rulings, the parties must submit final trial exhibits on a disc or drive and provide one double-sided paper copy in three-ring binders no later than 5 business days before trial.

After the pretrial conference and rulings on exhibits, no later than 5 business days before trial, the parties must submit the final trial exhibits on a disc or drive and provide one paper copy of the exhibits, double-sided in three-ring binders.

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

Civil cases

Applies to

Damages itemization

The plaintiff and any counter- or cross-claimants must itemize damages and other requested relief and briefly explain the evidentiary basis for each item.

Plaintiff (and counter/cross-claimants, if any) shall itemize damages and other relief sought, and provide a concise explanation of the evidentiary basis for each itemization.

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

Civil cases

Applies to

Proposed final pretrial order

Each party must briefly summarize its motions in limine in the Proposed Final Pretrial Order.

In the Proposed Final Pretrial Order, each party must provide a list that very briefly summarizes its motions in limine, e.g., “Motion to bar reference to Witness A’s drug use.”

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

Civil cases

Applies to

Jury instruction

Each instruction must identify its proponent, legal authority, and whether it is objected to.

(a) the proponent of the instruction; (b) the legal authority for the instruction; and (c) whether there is an objection to the instruction.

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

Civil cases

Applies to

Jury instruction

For a disputed instruction, the proponent should briefly explain its basis when the cited authority needs more explanation, and the objecting party must state its grounds and any proposed modification or alternative on the immediately following page.

If an instruction is disputed, the proponent of the instruction should concisely explain the basis for the instruction, if more explanation is required beyond the identified legal authority. 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.

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

Civil cases

Applies to

Proposed final pretrial order

Counsel for each party must electronically sign the Proposed Final Pretrial Order.

The Proposed Final Pretrial Order must be signed (electronically) by counsel for each party.

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

Applies to

Settlement report

After the settlement conference, counsel must jointly file a Report Regarding Settlement by 90 days from the Order, addressing settlement status or proposed further settlement efforts.

By _________________ [90 days from the date this Order is issued], after the settlement conference, counsel shall jointly file a Report Regarding Settlement that notifies the Court whether: (1) the parties have settled the case; (2) the parties have not settled the case but wish to continue settlement discussions for a specific period of time; (3) the parties wish to engage in a formal mediation conference before a specific mediator on or before a specific date;

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

Civil cases

Applies to

Exhibit chart

The exhibit chart should include proposed demonstrative exhibits in addition to substantive and Rule 1006 summary exhibits.

In addition to substantive exhibits and Rule 1006 summary exhibits, the chart should also include proposed demonstrative exhibits.

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

Civil cases

Applies to

Deposition designation chart

Deposition designations should use a chart substantially similar to the example; landscape orientation is encouraged but not required.

These designations should be in a chart format substantially similar to the example below (landscape orientation is encouraged).

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

Civil cases

Applies to

Exhibit chart objections

Foundation objections must reflect case knowledge and likely witness testimony, and may be included in exhibit-chart objections only when no listed witness could establish foundation.

Objections to foundation should be based on the knowledge of the case and likely testimony of the witnesses; a foundation objection should be made in the party’s exhibit chart objections only if the party knows that there is no witness on the witness list who could establish the proper foundation of the exhibits.

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

Civil cases

Applies to

Deposition designation chart objections

If Defendant objects to deposition testimony, Defendant should state the basis and must still provide specific objections to the Deposition Designation Chart.

If Defendant objects to the introduction of witness testimony via deposition, Defendant should provide the basis for the objection. Even if Defendant objects, Defendant must still provide specific Objections to Plaintiff’s Deposition Designation Chart.

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

Civil cases

Applies to

Pretrial memorandum

Parties requesting a different number of jurors should identify the request and explain its reasoning in the pre-trial memorandum.

If the parties request a different number of jurors, they should so state in the Pre-Trial Memorandum, as well as reasoning why more or less jurors is appropriate.

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

Civil cases

Applies to

Jury instructions

For a disputed instruction, the proponent should briefly explain its basis when the cited authority alone does not sufficiently explain it.

If an instruction is disputed, the proponent of the instruction should concisely explain the basis for the instruction, if more explanation is required beyond the identified legal authority (often citing to the Pattern Instruction or to a case will be explanation enough).

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

Civil cases

Applies to

Exhibits

When multiple parties are on one side, co-counsel must coordinate to produce a consecutively numbered exhibit set.

If there are multiple parties on a particular side, then you must coordinate with your co-counsel to generate a consecutively numbered set of exhibits.

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

Civil cases

Applies to

Exhibits

For each physical object, assign a consecutive exhibit number and neutral description, create a one-page PDF identifying them, and include it in the JERS USB submission.

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.

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

Civil cases

Applies to

Exhibits

If meet-and-confer discussions leave disagreements about admitted exhibits or demonstratives for the jury, Plaintiff must identify them in its filing and the parties should be prepared to discuss them with the Court.

To the extent, as a result of the parties’ meet and confer, there are any disagreements about which exhibits were admitted into evidence or demonstratives that should go back with the jury (keeping in mind that the default is that demonstratives will not be used during deliberations), Plaintiff shall identify those exhibits in its filing, and the parties should be prepared to discuss those exhibits before the Court.

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

Civil cases

Applies to

Witness list

The witness list must include a concise description of each witness’s role in the case, limited to two or three sentences.

For each witness, the party must provide a very concise (i.e., no more than two or three sentences) description of the witness’s role in the case.

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

Civil cases

Applies to

Objections to exhibit chart

Defendant must retain every exhibit row in Plaintiff’s chart and may leave the objection column blank when there is no objection.

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.

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

Civil cases

Applies to

Pretrial objections

A party may assert only good-faith objections; frivolous and boilerplate objections are improper.

A party must limit the objections to only good-faith objections. Frivolous and boilerplate objections will waste time, because in preparation for the Pre-Trial ===== PAGE 6 ===== Conference, the Court will review, as much as possible, the exhibits and the objections.

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

Civil cases

Applies to

Exhibit chart objections

Foundation objections must reflect the case and likely witness testimony and may be included in exhibit-chart objections only when no listed witness could establish foundation.

Objections to foundation should be based on the knowledge of the case and likely testimony of the witnesses; a foundation objection should be made in the party’s exhibit chart objections only if the party knows that there is no witness of the witness list who could establish the proper foundation of the exhibits.

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

Civil cases

Applies to

Exhibit

A substantive exhibit without an objection is deemed admissible, but is not thereby admitted into evidence.

Additionally, any substantive exhibit not objected-to shall be deemed admissible, but not admitted, into evidence by this Order.

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

Civil cases

Applies to

Objections to deposition designation chart

Defendant must retain each deposition-designation row in Plaintiff’s chart and may leave the objection column blank when there is no objection.

If Defendant does not have an objection to a specific deposition designation, Defendant shall not remove that row from Plaintiff’s Deposition Designation Chart, but instead can leave the objection column for that deposition designation row blank.

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

Civil cases

Applies to

Objections to defendant exhibit chart

Plaintiff must use Defendant’s Word exhibit chart, add an objections column, and retain rows for exhibits without objections, leaving those objection cells blank.

Plaintiff shall use the Microsoft Word version of Defendant’s Exhibit Chart, and add a column to the chart listing any objections, similar to the example in Section II.d. If Plaintiff does not have an objection to a specific exhibit, Plaintiff shall not remove that row from Defendant’s Exhibit Chart, but instead can leave the objection column for that exhibit row blank.

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

Civil cases

Applies to

Objections to defendant deposition designation chart

Plaintiff must use Defendant’s Word deposition-designation chart, add an objections column, and retain rows for designations without objections, leaving those objection cells blank.

Plaintiff shall use the Microsoft Word version of Defendant’s Deposition Designation Chart, and add a column to the chart listing any objections, similar to the example in Section II.e. If Plaintiff does not have an objection to a specific deposition designation, Plaintiff shall not remove that row from Defendant’s Deposition Designation Chart, but instead can leave the objection column for that deposition designation row blank.

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

Civil cases

Applies to

Pre trial memorandum

The Pre-Trial Memorandum must list trial attorneys’ contact information and everyone who will sit 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.

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

Civil cases

Applies to

Pre trial memorandum

The Pre-Trial Memorandum must estimate trial days based on six-hour testimony days, give each side’s estimated time subtotal, and propose per-side limits for openings and closings.

State the estimated number of trial days, 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.

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

Civil cases

Applies to

Final deposition transcript

If the Court sustains an objection to deposition testimony, the entire objected-to transcript portion should be redacted.

For deposition transcripts, if the Court has sustained an objection, the entire objected-to portion of the transcript should be redacted in its entirety.

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

Civil cases

Applies to

Opening statement

Exhibits may not be shown during opening statements unless both parties agree.

Unless both parties agree, no exhibits will be shown during opening statements.

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

Civil cases

Applies to

Opening statement

Opening statements should not be argumentative.

Opening statement should not be argumentative.

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

Civil cases

Applies to

Admitted trial exhibits

After the Court resolves all admitted-exhibit disputes, the parties should jointly prepare and submit a USB drive and one binder containing all admitted exhibits to the Courtroom Deputy.

Once the Court has resolved any and all disputes about exhibits admitted into evidence, the parties should jointly prepare and submit to the Court’s Courtroom Deputy a USB Key/Thumb Drive and one binder including all admitted exhibits.

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

Civil cases

Applies to

Pretrial order

The Court will set case-specific deadlines for submitting the proposed final Pretrial Order and filing motions in limine, responses, proposed jury instructions, and proposed voir dire questions.

In each particular case, the Court will set the date on which the proposed final Pretrial Order is to be submitted, as well as deadlines for filing motions in limine, responses thereto, proposed jury instructions and proposed voir dire questions.

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

Civil cases

Applies to

Deposition transcript

Deposition transcripts will not be provided to the jury during deliberations.

Deposition transcripts will not be provided to the jury during deliberations.

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

Civil cases

Applies to

Proposed findings conclusions

For a bench trial, proposed findings and conclusions must be filed separately rather than included in the proposed final Pretrial Order, following the Court’s deadlines.

In a bench trial, proposed findings of fact and conclusions of law are not to be included in the proposed final Pretrial Order but are to be separately filed in accordance with the deadlines set by the Court.

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

Civil cases

Applies to

Juror questionnaire objections

Objections or additions to the juror questionnaire must be filed by the Court’s pretrial deadlines.

Any objections or additions to the questionnaire shall be filed in accordance with the pretrial deadlines set by the Court.

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

Civil cases

Applies to

Pretrial order

If the parties selectively waive and preserve objections, they should detail the waived and preserved objections in the exhibit section of the Proposed Pretrial Order.

If the parties elect to proceed in this fashion, they should set forth in detail (in the exhibit section of the Proposed Pretrial Order) the specific objections being waived and preserved.

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

Civil cases

Applies to

Witness list

Each witness listing must include a concise two- or three-sentence description of the witness and the witness’s role in the case.

For each witness, provide a concise (2 or 3 sentences) description of the witness and the witness’s role in the case.

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

Civil cases

Applies to

Exhibit

When unforeseen trial circumstances lead a party to offer an unlisted exhibit, the party should notify the opposing side and the Court as soon as possible so objections can be discussed.

If, due to unforeseen circumstances during trial a party wishes to introduce an exhibit not previously listed, notice should be given as soon as possible to the opposing side and to the Court, so that any objections can be discussed.

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

Civil cases

Applies to

Exhibit

An unlisted exhibit is not inadmissible solely because it was omitted from the original list if the proponent acts in good faith, does not abuse the process, produced it during discovery, and it otherwise complies with the Federal Rules of Evidence and Civil Procedure.

Upon a showing of good-faith and absent an abuse of this process, an exhibit will not be deemed inadmissible simply because it was not included on the original exhibit list, provided the exhibit was earlier produced to the opposing side during discovery (and otherwise complies with the Federal Rules of Evidence and the Federal Rules of Civil Procedure).

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

Civil cases

Applies to

Evidentiary agreement

Agreements on evidentiary issues reached through meet-and-confer should be memorialized under Section 5 and may be finalized at the Final Pretrial Conference subject to Court approval.

If the meet-and-confer process results in agreement over evidentiary issues, that agreement should be memorialized under the procedure noted in Section 5, and subject to approval by the Court, such agreements may be finalized at the Final Pretrial Conference.

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

Civil cases

Applies to

Proposed pretrial order

The Proposed Pretrial Order should include the complete text of each non-Seventh Circuit Pattern instruction, its proponent, legal authority, and objection status.

In the Proposed Pretrial Order, the parties should set forth the complete text of any non-Seventh Circuit Pattern instruction and identify: (a) the proponent of the instruction; (b) the legal authority for the instruction; and (c) whether there is an objection to the instruction.

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

Civil cases

Applies to

Pretrial order

A substantive exhibit without an objection is deemed admissible without foundation testimony unless it is not referred to during trial testimony or otherwise published to the jury.

Any substantive exhibit not objected to shall be deemed admissible into evidence by operation of the Final Pretrial Order without any need for foundation testimony unless the exhibit is not referred to during trial testimony or otherwise published to the jury.

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

Civil cases

Applies to

Trial exhibits

All exhibits should be numbered, using designations such as PX1 or DX1.

All exhibits should be numbered (e.g., PX1, DX1, etc.)

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

Civil cases

Applies to

Proposed jury instructions

For a disputed instruction, the proponent should briefly explain its basis when the cited authority alone is insufficient.

If an instruction is disputed, the proponent of the instruction should concisely explain the basis for the instruction, if more explanation is required beyond the identified legal authority.

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

Civil cases

Applies to

Finalized jury instructions

After the instructions are finalized, one party should prepare a table of contents.

Once the instructions are finalized, one of the parties should prepare a table of contents for the instructions.

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

Civil cases

Applies to

Trial brief

Trial briefs are not required in jury trials, and a party wishing to file one must obtain leave of court.

Judge Hunt does not require trial briefs in jury trials. Parties who wish to file a trial brief must seek leave of court to do so.

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

Civil cases

Applies to

Settlement conference participant agreement

Participants must agree that statements made by any party or attorney at the settlement conference are inadmissible at trial.

The Court will require the participants to agree that any statements made by any party or attorney at the settlement conference are inadmissible at trial.

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

Civil cases

Applies to

Jury instructions

The parties should submit the complete text of proposed instructions and identify the proponent, any applicable Seventh Circuit Pattern Instruction, legal authority, and whether the instruction is objected to.

The parties should compile and set forth the complete text of all proposed instructions and identify: the proponent of the instruction, the Seventh Circuit Pattern Instruction if applicable, the legal authority for the instruction, and whether there is an objection to the instruction.

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

Civil cases

Applies to

Jury instructions

For a disputed instruction, the proponent should concisely explain its basis when the identified legal authority needs further explanation.

If an instruction is disputed, the proponent of the instruction should concisely explain the basis for the instruction, if more explanation is required beyond the identified legal authority.

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

Civil cases

Applies to

Final pretrial order

The Final Pretrial Order should be submitted with a cover document stating the case caption and the title “FINAL PRETRIAL ORDER.”

The Final Pretrial Order should be submitted to the Court with a cover document setting forth the case caption and the title FINAL PRETRIAL ORDER.

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

Civil cases

Applies to

Final pretrial order

Any objection to another party’s proposed voir dire questions should include its basis in the Final Pretrial Order.

If any party objects to voir dire questions proposed by another party, the basis for the objection should be noted in the Final Pretrial Order.

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

Civil cases

Applies to

Proposed jury instructions

Agreed proposed instructions should be identified as agreed and numbered consecutively.

Agreed proposed instructions should be marked as such and numbered consecutively.

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

Civil cases

Applies to

Supplemental jury instructions

Supplemental instruction requests during trial or after the evidence generally will not be granted, except for matters not reasonably foreseeable when the initial instructions are presented.

Supplemental requests for instructions during the course of the trial or at the conclusion of the evidence generally will not be granted except as to those matters that cannot reasonably be anticipated at the time of presentation of the initial set of instructions.

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

Civil cases

Applies to

Deposition excerpts

Submit one copy of intended deposition excerpts under separate cover before trial, on the schedule set by the court at or before the final pretrial conference.

5. One copy of all deposition excerpts that the parties intend to read into the record should be submitted under separate cover prior to trial as set by the court at or before the final pretrial conference.

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

Civil cases

Applies to

Deposition excerpts

Mark deposition transcript portions subject to objection so the court can identify the objection and the offering party’s response.

All objections to portions of deposition transcripts should be identified by marking such portions in a manner that will inform the court as to the nature of the objection and the offering party's response.

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

Civil cases

Applies to

Prefatory jury instructions

The court will use its standard prefatory instructions unless it approves a proposed variation, and encourages including an elements instruction at this stage.

a. This court will use its standard prefatory instructions, unless counsel suggest and the court approves a variation thereof. The court encourages including a version of the “elements” instruction to the jury at this stage.

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

Civil cases

Applies to

Proposed jury instructions

The parties should agree on all proposed instructions except those subject to a genuine, good-faith dispute.

c. Again, all instructions should be agreed except for those about which there is a genuine, good faith dispute.

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

Civil cases

Applies to

Jury instructions

Proposed jury instructions should be tailored to the parties and the factual and legal issues in the case.

Make sure to tailor your proposed instructions to the parties in the case as well as the factual and legal issues to be presented.

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

Civil cases

Applies to

Trial brief

Trial briefs are not required in jury trials, and a party wishing to file one must seek leave of court.

The Court does not require trial briefs in jury trials. Any party who wishes to file a trial brief must seek leave of the Court to do so.

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

Civil cases

Applies to

Joint status report

Under the stated discovery-schedule conditions, the report should provide a fact-discovery completion date; for claims involving medical conditions, fact discovery ordinarily includes treating physician depositions.

A fact discovery completion date. For claims involving medical conditions, fact discovery ordinarily includes treating physician depositions.

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

Civil cases

In patent cases, the Court applies the Local Patent Rules for Electronically Stored Information.

In a patent case, the Court will apply the Local Patent Rules for Electronically Stored Information.

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

Civil cases

Applies to

Motion

For an agreed or unopposed motion, the movant should file it with a title identifying it as agreed or unopposed.

For agreed or unopposed motions, the movant should file the motion and indicate in the title that it is agreed or unopposed.

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

Civil cases

Applies to

Brief

The Court prefers strict compliance with Local Rules 56.1(a) and (b) when briefing summary judgment motions.

In the event a litigant decides that a summary judgment motion is appropriate, the Court prefers strict compliance with Local Rules 56.1(a) and 56.1(b) in the briefing of all summary judgment motions.

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

Civil cases

Applies to

Privilege log

Privilege logs should identify the listed participants, dates, document type and Bates numbers, privilege asserted, and sufficiently detailed subject matter.

Any privilege log should be detailed enough to enable other parties to assess the applicability of the privilege asserted, and should include: (1) the name and capacity of each individual from whom or to whom a document and any attachments were sent (including which persons are lawyers); (2) the date of the document and any attachments; (3) the type of document; (4) the Bates numbers of the documents, (5) the nature of the privilege asserted; and (6) a description of the subject matter in sufficient detail to determine if legal advice was sought or revealed, or if the document constitutes work product.

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

Civil cases

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.

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

Civil cases

Indicate the status of any pending motions.

Indicate the status of any pending motions.

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

Civil cases

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.

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

Civil cases

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.

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

Civil cases

Applies to

Initial status report

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.

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

Civil cases

Applies to

Initial status report

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).

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

Civil cases

Applies to

Initial status report

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.

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

Civil cases

Applies to

Initial status report

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.

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

Civil cases

Applies to

Initial status report

The report should indicate the status of any pending motions.

Indicate the status of any pending motions.

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

Civil cases

Applies to

Initial status report

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.

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

Civil cases

Applies to

Joint status report

The report should provide a fact-discovery completion date; for claims involving medical conditions, the parties must indicate whether it includes treating physician depositions, which ordinarily are part of fact discovery.

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.

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

Civil cases

The parties 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.

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

Civil cases

The pre-conference letters and settlement conference are governed by Local Rule 83.5 on confidentiality of alternative dispute resolution proceedings.

The pre-conference letters and the settlement conference are governed by Local Rule 83.5 relating to Confidentiality of Alternative Dispute Resolution Proceedings.

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

Civil cases

Applies to

Settlement conference

Failure to attend a settlement conference may subject a party to sanctions.

Counsel and the parties are cautioned that failure to attend a settlement conference may subject a party to sanctions.

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

Civil cases

Applies to

Plaintiff settlement letter

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.

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

Civil cases

Applies to

Plaintiff settlement letter

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.

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

Civil cases

Applies to

Verification of inability to pay

Counsel claiming a party cannot pay a judgment or settlement should raise the issue at the video conference and provide verification before the settlement conference.

If a party is claiming an inability to pay a judgment or settlement, counsel should also raise this issue at the video conference and will be expected to provide verification of that fact prior to the settlement conference.

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

Civil cases

Applies to

Settlement statement

Exhibits to settlement statements should be attached to the Court email or shared electronically for the Court to download.

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.

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

Civil cases

Applies to

Proposed exhibits

Proposed exhibits must use the JERS exhibit-naming convention, for which the Court will provide instructions.

The parties must use the exhibit-naming convention for the Jury Evidence Recording System (JERS); the Court will provide the parties with an instruction memorandum on how to use JERS and name exhibits.

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

Civil cases

Applies to

Deposition designation chart

A Deposition Designation Chart is not required for deposition material used to impeach a witness or refresh the witness’s recollection.

A party does not need to create a Deposition Designation Chart for deposition transcripts/excerpts it plans to use to impeach a witness or to refresh a witness’ recollection.

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

Civil cases

Applies to

Jury instructions

Where applicable, the Court generally prefers Seventh Circuit Pattern Instructions, while permitting parties to propose modifications and additional non-Pattern instructions.

Where applicable, the Court generally prefers the Seventh Circuit’s Pattern Instructions, but of course the parties may propose modifications to the Pattern Instructions and may propose additional, non-Pattern Instructions.

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

Civil cases

Applies to

Exhibits

Demonstratives agreed to be used in jury deliberations should be included on the exhibit lists.

To the extent the parties agree that any such demonstratives may be used in jury deliberations, they should be included on the exhibit list(s).

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

Civil cases

Applies to

Deposition designation chart

A party need not create a Deposition Designation Chart for deposition material planned for impeachment or refreshing a witness’s recollection.

2A party does not need to create a Deposition Designation Chart for deposition transcripts/excerpts it plans to use to impeach a witness or to refresh a witness’ recollection.

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

Civil cases

Applies to

Exhibits

The Court encourages parties to stipulate to exhibit authenticity or foundation whenever possible.

The Court encourages the parties to stipulate to the authenticity and/or foundation of exhibits whenever possible.

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

Civil cases

Applies to

Opening statement

Agreed-upon, non-argumentative exhibits may be used in opening statements.

If exhibits are agreed-upon and non-argumentative, they may be used in opening statement.

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

Civil cases

Applies to

Pretrial order

For an objection covered by a motion in limine or Daubert motion, the Pretrial Order may refer to the motion without repeating its grounds.

If the objection is the subject of a motion in limine or Daubert motion, the Pretrial Order may simply refer to the motion and it need not repeat the grounds stated in the motion.

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

Civil cases

Applies to

Stipulation

If conferral produces agreement that matters are inadmissible, the parties should memorialize it in a stipulation for the Court in the Pretrial Order or at the final pretrial conference.

If the meet-and-confer process results in agreement that certain matters are inadmissible, that agreement should be memorialized in a stipulation to be provided to the Court in the Pretrial Order (see paragraph 5 above) or at the final pretrial conference.

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

Civil cases

Applies to

Agreed exhibits

If the Court approves the exhibits after review, the parties may move the agreed-binder exhibits into evidence at the start of trial or another logical point in the order of proof.

If, after its own review, the Court approves the exhibits submitted, the exhibits included in the agreed binder may be moved into evidence by the parties at the beginning of trial or at another logical point in the order of proof.

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

Civil cases

Applies to

Proposed pretrial order

Agreed Seventh Circuit Pattern Instructions may be listed by citation in the Proposed Pretrial Order.

If the parties agree to use any Seventh Circuit Pattern Instructions, those instructions may simply be listed by citation in the Proposed Pretrial Order.

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

Civil cases

Applies to

Trial brief

Trial briefs are not required in jury trials, but parties may seek leave to file one addressing unique legal or factual issues by the motions-in-limine due date.

Judge Blakey does not require trial briefs in jury trials. Parties who wish to file a trial brief to address any unique issues of law or fact may, however, seek leave of Court to do so on or before the due date for filing motions in limine.

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

Civil cases

Applies to

Trial exhibits

Exhibits used only for impeachment or to refresh memories are exempt from the exhibit-upload requirement.

Exhibits that will be used only for impeachment purposes or to refresh memories need not be included.

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

Civil cases

Applies to

Trial brief

For bench trials, the Court may require separate trial briefs on a case-by-case basis.

For bench trials, the Court may require separate trial briefs on a case-by-case basis.

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

Civil cases

Applies to

Stipulation

Agreements reached in meet-and-confer that certain matters are inadmissible should be memorialized in a stipulation for the pretrial order or final pretrial conference.

If the meet-and-confer process results in agreement that certain matters are inadmissible, that agreement should be memorialized in a stipulation to be provided in the pretrial order or at the final pretrial conference.

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

Civil cases

Applies to

Final pretrial order

For an objection covered by a motion in limine, the order may refer to the motion without repeating its grounds.

If the objection is the subject of a motion in limine, the Pretrial Order may simply refer to the motion and need not repeat the grounds stated in the motion.

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

Civil cases

Applies to

Final pretrial order

Parties need not repeat the judge’s general questionnaire questions in the Final Pretrial Order.

The parties should assume that those general questions will be asked and need not duplicate them in the Final Pretrial Order.

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

Civil cases

Applies to

Proposed voir dire questions

The parties are requested to focus proposed voir dire questions on matters specific to their case.

The parties are requested to focus their attention on areas of questioning that are specific to their case.

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

Civil cases

Applies to

Stipulation

Agreements on admissibility reached through conferral may be memorialized in a stipulation provided with the Final Pretrial Order or at the Final Pretrial Conference.

If the meet- and-confer process results in agreement that certain matters are admissible or inadmissible, that agreement may be memorialized in a stipulation to be provided to Judge Dow with the Final Pretrial Order or at the Final Pretrial Conference.

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

Civil cases

Applies to

Pretrial brief

The parties are permitted to submit pretrial briefs in both non-jury and jury trials.

8. The parties may submit pretrial briefs in non-jury as well as jury trials.

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

Civil cases

The parties should be familiar with the Principles of the Seventh Circuit Electronic Discovery Pilot Program adopted by the Court.

Please note the Court has adopted the Principles of the Seventh Circuit Electronic Discovery Pilot Program and the parties should be familiar with them.

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

Civil cases

Applies to

Status report

When a recent status report is already on file, the Court will rely on it and will not require another report.

If a recent status report is on file, the Court will not require an additional report and will rely on the previously filed report.

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

Civil cases

Applies to

Initial status hearing

At the initial hearing, parties should be prepared to discuss phased discovery as a way to assess whether they may wish to pursue an earlier settlement conference.

At the initial hearing, the parties also should be prepared to address whether they have considered, or will consider, phased discovery aimed at determining whether they mutually might wish to engage in a settlement conference sooner rather than later.

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

Civil cases

Applies to

Joint status report

For a joint status report ordered to address identified issues during case management, the parties may limit the report to those issues.

Where the Court orders a joint status report to address identified issues during the Court's ongoing management of a case, the parties may limit their report to those identified issues.

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

Civil cases

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.

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

Civil cases

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.

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

Civil cases

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.

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

Civil cases

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.

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

Civil cases

Applies to

Plaintiff settlement letter

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.

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

Civil cases

Applies to

Defendant settlement letter

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.

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

Civil cases

Applies to

Defendant settlement letter

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.

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

Civil cases

Applies to

Settlement conference preparation

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.

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

Civil cases

Applies to

Settlement letter

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).

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

Civil cases

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.

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

Civil cases

Applies to

Jury instructions

Where applicable, the Court generally prefers the Seventh Circuit’s Pattern Jury Instructions.

Where applicable, the Court generally prefers the Seventh Circuit’s Pattern Jury Instructions.

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Civil cases

Applies to

Declaration

Plaintiff's attorney of record shall file a single signed declaration under penalty of perjury sufficient to satisfy the following conditions:

Summary: Plaintiff's attorney must file a single signed declaration under penalty of perjury to support a TRO.

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Civil cases

Applies to

Declaration

To obtain the extraordinary and drastic remedy of an ex parte temporary restraining order, the declaration must satisfy Federal Rule of Civil Procedure 65(b)(1), including by identifying: (a) each defendants' sale or offer for sale of the allegedly infringing product(s) within the past two months; (b) the ongoing and immediate harm to plaintiff (e.g., recent listings, transactions, or consumer confusion); (c) a factual link between each defendant and the challenged conduct; and (d) facts supporting plaintiff's position that notice would likely result in concealment, transfer, or destruction of evidence or assets.

Summary: Ex parte TRO declaration must satisfy FRCP 65(b)(1) with specific factual showings.

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Civil cases

Applies to

Declaration

To satisfy Federal Rule of Civil Procedure 20 warranting joinder of the Schedule A defendants, the declaration must provide specific, non-conclusory, non-speculative facts showing that plaintiff's claims against each defendant arise from the same transaction or series of transactions and share common questions of law or fact. It must also identify non-conclusory, non-speculative facts linking defendants through a common scheme or interrelated conduct (e.g., shared identifiers, materially identical listings or products, common sources or fulfillment, coordinated platform activity, geographic and logistical overlap, or temporal proximity) sufficient to satisfy Rule 20.

Summary: TRO declaration must provide specific, non-conclusory facts showing Rule 20 joinder is warranted.

The quote is in the court's document. The summary is not checked yet.CRITICAL?

Civil cases

Applies to

Declaration

The declaration must show that this Court has personal jurisdiction over each defendant—screenshots of websites no longer suffice. Failure to comply will result in dismissal.

Summary: TRO declaration must show personal jurisdiction over each defendant; website screenshots are insufficient and noncompliance results in dismissal.

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Civil cases

Applies to

Temporary restraining order ?

Chief Judge Kendall presumptively requires a bond of $10,000 per defendant.

Summary: Chief Judge Kendall presumptively requires a $10,000 bond per defendant.

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Civil cases

Applies to

Temporary restraining order ?

Third parties not named in the complaint (e.g., Amazon, eBay, DHgate) cannot be named as in active concert or participation with the defendants unless their active concert or participation is proven and they receive advance notice and an opportunity to be heard before the Court enters any order against them.

Summary: Third parties not named in the complaint cannot be named as acting in concert with defendants unless proven and given notice and opportunity to be heard.

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Civil cases

Applies to

Motion

Any motion contending that the Hague Convention does not apply must be accompanied by a declaration under penalty of perjury attesting to the specific facts showing how an exception applies. If that motion is based on defendants' unknown addresses, the plaintiff must first undertake diligent efforts to ascertain and verify the defendants' addresses prior to filing its motion.

Summary: Motions contending the Hague Convention does not apply must be accompanied by a declaration under penalty of perjury; if based on unknown addresses, plaintiff must first undertake diligent efforts to ascertain addresses.

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Civil cases

Applies to

Declaration

In addition to satisfying the Federal Rules of Civil Procedure, to warrant entry of default and default judgment, plaintiff's attorney of record shall file a single signed declaration under penalty of perjury certifying that all defendants were: (a) served; (b) provided notice of the motion for entry of default or default judgment through the same channels authorized for service; and (c) given a reasonable opportunity to appear and respond within the time permitted by the Court's order. The declaration shall further indicate whether any defendants subject to the motion have responded.

Summary: To obtain default judgment, plaintiff's attorney must file a single signed declaration under penalty of perjury certifying service, notice, and opportunity to respond, and indicating whether any defendants responded.

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Civil cases

Applies to

Trial brief

Trial briefs are not expected by the court and will not be accepted absent prior leave of court.

Summary: Trial briefs are not expected and will not be accepted absent prior leave of court.

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Civil cases

Applies to

Final pretrial order

The parties shall jointly prepare and submit, on the date set by the court, a Final Pretrial Order containing the following, absent prior modification by the court:

Summary: The parties must jointly prepare and submit a Final Pretrial Order containing the required contents on the date set by the court, absent prior court modification.

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Civil cases

Applies to

Final pretrial order

Any witness not listed in the final 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 may be necessary.

Summary: Witnesses not listed in the final pretrial order are precluded from testifying absent good cause, except rebuttal witnesses not presently identifiable.

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Civil cases

Applies to

Final pretrial order

Objections. A statement of any objections to the calling of any witness. Objections not made in the final pretrial order will be deemed waived absent a showing of good cause.

Summary: Objections to the calling of any witness must be stated in the final pretrial order or they are deemed waived absent good cause.

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Civil cases

Applies to

Final pretrial order

Daubert objections must be noted in the final pretrial order but should be set forth in a separate motion in limine.

Summary: Daubert objections must be noted in the final pretrial order and should also be raised in a separate motion in limine.

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Civil cases

Applies to

Final pretrial order

Depositions. For each witness whose deposition will be used, a chart containing the following information: (a) a listing, by page and line, of the testimony that each side seeks to present; (b) a concise statement of objections to any testimony and the basis for the objection; and (c) a concise statement of the asserted basis of admissibility. Objections not made in the final pretrial order will be deemed waived absent a showing of good cause.

Summary: For each deposition witness, the Final Pretrial Order must include a chart of page/line designations, objections with bases, and asserted bases of admissibility; unmade objections are deemed waived absent good cause.

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Civil cases

Applies to

Final pretrial order

Any exhibit not listed in the final pretrial order will be excluded from evidence absent a showing of good cause.

Summary: Exhibits not listed in the final pretrial order are excluded from evidence absent a showing of good cause.

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Civil cases

Applies to

Final pretrial order

Objections. A statement of any objections to each exhibit. Objections not made in the final pretrial order will be deemed waived absent a showing of good cause.

Summary: Objections to each exhibit must be stated in the final pretrial order or they are deemed waived absent good cause.

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Civil cases

Applies to

Exhibits ?

is to be delivered to the court at the start of trial.

Summary: An item whose context is cut off at the page break (likely exhibits) must be delivered to the court at the start of trial.

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Civil cases

Applies to

Proposed jury instructions ?

In diversity cases where Illinois law provides the rule of decision, the use of IPI instructions as to issues of substantive law is required.

Summary: In diversity cases governed by Illinois law, IPI instructions must be used for issues of substantive law.

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Civil cases

Applies to

Final pretrial order

Must include

caption, signature blocks ?

The final pretrial order should be submitted to the court with a cover document setting forth the case caption and the title FINAL PRETRIAL ORDER. The cover document must (a) recite that each of the foregoing categories of materials is included; (b) must state that "This order will control the course of the trial and may not be amended except by consent of the parties, or by order of the court to prevent manifest injustice"; and (c) must be signed by counsel for each of the parties and contain a space for the court's signature.

Summary: The final pretrial order must include a cover document with the case caption and title FINAL PRETRIAL ORDER that recites all categories of materials are included, contains the required control-of-trial language, and is signed by counsel for each party with a space for the court's signature.

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Civil cases

Applies to

Original document ?

The actual "original," in whatever form the producing party has it, must be made available to any other party within ten days after a written request.

Summary: The producing party must make the actual original document available to any other party within ten days after a written request.

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Civil cases

Applies to

Discovery document ?

A person designates information in a document or thing as Confidential or Highly Confidential by clearly and prominently marking it on its face as "CONFIDENTIAL" or "HIGHLY CONFIDENTIAL."

Summary: Documents or things are designated Confidential or Highly Confidential by clearly and prominently marking them on their face as 'CONFIDENTIAL' or 'HIGHLY CONFIDENTIAL.'

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Civil cases

Applies to

Expert undertaking ?

A party may not disclose Confidential or Highly Confidential information to an expert or consultant pursuant to paragraph 4(b) or 4(d) of this order until after the expert or consultant has signed an undertaking in the form of Appendix 1 to this Order.

Summary: Confidential or Highly Confidential information may not be disclosed to an expert or consultant until the expert or consultant has signed the undertaking in the form of Appendix 1 to the order.

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Civil cases

Applies to

Sealed document ?

Must include

caption, case number ?

Pursuant to Local Rule 5.8, any document filed under seal must be accompanied by a cover sheet disclosing (i) the caption of the case, including the case number; (ii) the title "Restricted Document Pursuant to Local Rule 26.2;" (iii) a statement that the document is filed as restricted in accordance with a court order and the date of the order; and (iv) the signature of the attorney of record filing the document.

Summary: Any document filed under seal must include a cover sheet with the case caption and number, the title 'Restricted Document Pursuant to Local Rule 26.2,' a statement of the restricting court order and its date, and the filing attorney's signature.

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Civil cases

Applies to

Undertaking

UNDERTAKING OF [Insert name] I, [insert person's name], state the following under penalties of perjury as provided by I have been retained by [insert party's name] as an expert or consultant in connection with this case. I will be receiving Confidential [and Highly Confidential] information that is covered by the Court's protective order dated ffi/I in date]. I have read the Court's protective order and understand that the Confidential [and Highly Confidential] information is provided pursuant to the terms and conditions in that order. I agree to be bound by the Court's protective order. I agree to use the Confidential [and Highly Confidential] information solely for purposes of this case. I understand that neither the Confidential [and Highly Confidential] information nor any notes concerning that information may be disclosed to anyone that is not bound by the Court's protective order. I agree to return the Confidential [and Highly Confidential] information and any notes concerning that

Summary: Experts or consultants retained by a party who will receive Confidential or Highly Confidential information must sign an Undertaking under penalties of perjury agreeing to be bound by the protective order, use the information solely for this case, not disclose it or related notes to anyone not bound by the order, and return the information and notes.

The quote is in the court's document. The summary is not checked yet.CRITICAL?

Civil cases

Applies to

Protective order acknowledgment ?

I submit to the jurisdiction of the Court that issued the protective order for purposes of enforcing that order. I give up any objections I might have to that Court's jurisdiction over me or to the propriety of venue in that Court.

Summary: The protective order acknowledgment must contain language submitting to the jurisdiction of the issuing court and waiving objections to that court's jurisdiction and venue.

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Civil cases

Applies to

Protective order acknowledgment ?

(signature) Subscribed and sworn to before me this day of , 20 . Notary Public

Summary: The protective order acknowledgment must be signed and subscribed and sworn (notarized) before a notary public.

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Applies to

Final pretrial order

In order to assist the court in determining whether or not placing a case on the short civil trial calendar might be inappropriate, counsel will include in the final pretrial order form information concerning the anticipated circumstances of the trial that might impact scheduling.

Summary: Counsel must include in the final pretrial order form information concerning the anticipated circumstances of the trial that might impact scheduling.

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Applies to

Motion for relatedness

The motion for relatedness shall include a listing of the dates and times of filing of each of the matters which movant is asking to be found related.

Summary: A motion for relatedness must include a listing of the filing dates and times of each matter the movant asks to be found related.

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Applies to

Designation sheet

The person filing the petition for withdrawal of reference, report and recommendation, appeal, motion for leave to appeal, or application for a writ shall complete the designation sheet required by LR 3.1 and shall include on the sheet a list of any associated bankruptcy cases, adversary proceedings, non-core proceedings, appeals or motions for leave to appeal, or application for a writ from such proceedings previously assigned to one or more district judges.

Summary: A person filing a petition for withdrawal of reference, report and recommendation, appeal, motion for leave to appeal, or writ application must complete the LR 3.1 designation sheet listing all associated matters previously assigned to district judges.

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Applies to

Joint statement of consent

Parties shall consent to proceed before a magistrate judge by filing a joint statement of consent. See LR 73.1(c).

Summary: Consent to proceed before a magistrate judge must be filed as a joint statement of consent.

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Applies to

Memorandum opinion and order

In cases brought for judicial review under the Social Security Act, the Memorandum Opinion and Order shall not identify the non-government party by using his or her full name. The non-government party shall be named and referred to by using his or her full first name and the first initial of the last name. All parties shall follow the requirements of Local Rule 8.1.

Summary: In Social Security Act judicial review cases, memorandum opinions and orders must refer to the non-government party by full first name and last initial rather than the full name, consistent with Local Rule 8.1.

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Civil cases

Applies to

Motion for relief from mediation referral ?

The party seeking relief must demonstrate that mediation would not be likely to deliver benefits to the parties sufficient to justify the resources consumed by its use and/or would impose an undue hardship upon the moving party and/or would unnecessarily increase litigation costs.

Summary: A motion for relief from court-ordered mediation must demonstrate that mediation would not deliver sufficient benefits, would impose an undue hardship, and/or would unnecessarily increase litigation costs.

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Civil cases

Applies to

Adr certification ?

Unless otherwise ordered, and no later than the date specified in the case management order, the parties, through their attorneys, must e-file with the court a certification indicating: (a) each has read the Local Rules and pamphlet governing the court's mediation program; (b) the attorneys have discussed with their respective clients the available dispute resolution options provided by the court and private entities; (c) an estimate of the fees and costs that would be associated with litigation of the matter, through trial, has been given to the client; and (d) When applicable, the mediator has been selected by the parties and the date of mediation or the other method of ADR selected is identified. This certification may be contained in the body of the CMO.

Summary: Unless otherwise ordered, parties must file an ADR certification confirming counsel read the mediation-program materials, discussed ADR options with clients, provided a litigation fee/cost estimate through trial, and (when applicable) identified the selected mediator and mediation date or other ADR method; the certification may be contained in the body of the CMO.

The quote is in the court's document. The summary is not checked yet.CRITICAL?

Civil cases

Applies to

Motion to extend mediation deadline ?

Must include

proposed order

(3) be accompanied by a proposed order, emailed to the proposed order e-mail, setting forth a new deadline by which the mediation must be held.

Summary: A motion to extend the mediation deadline must be accompanied by a proposed order, emailed to the proposed order e-mail, setting a new mediation deadline.

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Civil cases

Applies to

Motion to be excused from mediation ?

Must include

proposed order

The motion shall: (1) set forth all considerations that support the request; (3) indicate whether the other party or parties join in or object to the request, and (4) be accompanied by a proposed order.

Summary: The motion to be excused from mediation attendance must set forth all supporting considerations, indicate whether other parties join in or object, and be accompanied by a proposed order.

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Civil cases

Applies to

Certification of session

Within 14 calendar days of the close of each mediation session and on the form Certification of Session provided by the court, the mediator must email a report to ADR@ilnd.uscourts.gov indicating: the date the session was held, whether the case settled in whole or in part, whether any follow-up is scheduled, any stipulations the parties agree may be disclosed, and any other data necessary for the effective management of the program which would not violate expectations of confidentiality.

Summary: The Certification of Session must be on the court-provided form and must state the session date, whether the case settled in whole or part, any scheduled follow-up, disclosable stipulations, and other non-confidential program management data.

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Civil cases

Applies to

Letter of complaint

A complaint alleging that any person or party, including the mediator, has materially violated any of the ADR Local Rules shall be presented in writing directly to the ADR Magistrate Judge. Such a letter of complaint must be accompanied by a competent declaration.

Summary: A complaint alleging a material violation of the ADR Local Rules must be presented in writing directly to the ADR Magistrate Judge and must be accompanied by a competent declaration.

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Civil cases

Applies to

Mediator report ?

A mediator who perceives a material violation of these ADR Local Rules shall make a written report directly to the ADR Magistrate Judge and contemporaneously provide copies to all counsel and to the Clerk of Court.

Summary: A mediator who perceives a material violation of the ADR Local Rules must make a written report directly to the ADR Magistrate Judge.

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Applies to

Electronically filed document

Each document filed electronically must, if possible, indicate that it has been electronically filed. Electronically filed documents must include a signature block and must set forth the name, address, telephone number and the attorney's bar registration nurnber, if applicable. Lr addition, the name of the E-Filer under whose login and password the document is submitted must be appear.

Summary: Electronically filed documents must indicate that they were electronically filed where possible and must include a signature block setting forth the filer's name, address, telephone number, and bar registration number (if applicable).

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Civil cases

Applies to

Memorandum ?

a. Joinder. Plaintiff must demonstrate that defendants are properly joined under Federal Rule of Civil Procedure 20.

Summary: The memorandum must demonstrate that defendants are properly joined under Federal Rule of Civil Procedure 20.

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Civil cases

Applies to

Memorandum ?

b. Personal Jurisdiction. Plaintiff must demonstrate the basis for this court's exercise of personal jurisdiction over each defendant.

Summary: The memorandum must demonstrate the basis for the court's exercise of personal jurisdiction over each defendant.

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Civil cases

Applies to

Memorandum ?

each defendant, and how that service complies with the Hague Convention on the Service Abroad of Judicial and Extra-Judicial Documents in Civil and Commercial Matter ("Hague Convention") and the Federal Rules of Civil Procedure.

Summary: The memorandum must address service on each defendant and how that service complies with the Hague Convention and the Federal Rules of Civil Procedure.

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Civil cases

Applies to

Memorandum ?

a. whether plaintiff has address information for each defendant, see Santana, 2026 WL 2546903, at *3 (“When plaintiffs…have address information for a defendant, the court will presume that the defendant’s address is known for purposes of the Hague Convention.”);

Summary: The memorandum must address whether plaintiff has address information for each defendant, which the court presumes known for Hague Convention purposes when available.

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Civil cases

Applies to

Memorandum ?

b. if plaintiff asserts that it possesses no address information for a particular defendant, the efforts that plaintiff undertook to learn the defendant’s mailing address, see id. (When “a plaintiff asserts that it possesses no address information for a defendant….the court will not accept [that] assertion until it satisfies itself that plaintiff has made reasonably diligent efforts to learn the defendant’s mailing address.”).

Summary: If plaintiff claims it has no address information for a defendant, the memorandum must describe the diligent efforts undertaken to learn that defendant's mailing address.

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Civil cases

Applies to

Memorandum ?

c. the basis for this court’s exercise of personal jurisdiction over each defendant.

Summary: The memorandum must set out the basis for the court's exercise of personal jurisdiction over each defendant.

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Civil cases

Applies to

Brief ?

If a plaintiff has proposed a bond or security amount, that plaintiff must include in its briefing an explanation as to why the amount is proper based on the costs and damages that may be sustained by any party found to have been wrongfully enjoined or restrained. Fed. R. Civ. P. 62(c).

Summary: Briefing that proposes a bond or security amount must include an explanation of why the amount is proper based on potential costs and damages to any wrongfully enjoined party.

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Civil cases

Applies to

Affidavit or declaration ?

Before or in conjunction with moving for entry of default, a plaintiff in a "Schedule A" case must file an affidavit, declaration, or other document (e.g., spreadsheet, chart) describing with specificity the following for each defendant and each allegedly infringing product:

Summary: Before or when moving for entry of default, a Schedule A plaintiff must file an affidavit, declaration, or similar document detailing with specificity twelve categories of sales and account information for each defendant and each allegedly infringing product.

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Applies to

List of exhibits entered previous day ?

Prior to the start of any trial day, counsel shall provide the courtroom deputy with a list of exhibits entered the previous day.

Summary: Before the start of each trial day, counsel must provide the courtroom deputy with a list of exhibits entered the previous day.

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Applies to

Attorney certification

At the end of the trial and prior to the electronic exhibits being released for the jury through JERS, each attorney must sign an Attorney Certification verifying that the exhibits contained in JERS are exact replicas of what was admitted in evidence.

Summary: Each attorney must sign an Attorney Certification before electronic exhibits are released to the jury through JERS.

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Applies to

List of exhibits released to jury ?

At the conclusion of trial, counsel will provide the courtroom deputy with a list of exhibits to release to the jury through JERS

Summary: At the conclusion of trial, counsel must provide the courtroom deputy with a list of exhibits to release to the jury through JERS.

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Applies to

List of paper and physical exhibits ?

At the conclusion of trial, counsel will provide the courtroom deputy with a list of exhibits to release to the jury through JERS, and with a second list, where appropriate, of any paper and physical exhibits to be made available during deliberations.

Summary: Where appropriate, counsel must also provide a second list of paper and physical exhibits to be made available during deliberations.

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Applies to

Settlement position letter

The Court requires one letter from each party: a settlement position letter addressed to and exchanged with the other party and submitted to the Court.

Summary: Each party must submit one settlement position letter that is exchanged with the opposing party and provided to the Court.

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Civil cases

Applies to

Discovery document ?

A party may designate a document as Confidential Information for protection under this Order by affixing the words "CONFIDENTIAL-SUBJECT TO PROTECTIVE ORDER" on the document and on all copies in a manner that will not interfere with the legibility of the document. As used in this Order, "copies" includes electronic images, duplicates, extracts, summaries or descriptions that include or reflect the Confidential Information.

Summary: To designate a document as Confidential Information, a party must affix the marking "CONFIDENTIAL-SUBJECT TO PROTECTIVE ORDER" on the document and on all copies (including electronic images, duplicates, extracts, summaries, or descriptions) in a manner that does not interfere with legibility.

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Civil cases

Applies to

Copies of confidential documents ?

Any copies that are made of any documents marked “CONFIDENTIAL-SUBJECT TO PROTECTIVE ORDER” must also be so marked, except that indices, electronic databases or lists of documents that do not show substantial portions or images of the text of marked documents and do not otherwise disclose the substance of the Confidential Information are not required to be marked.

Summary: Copies of documents marked “CONFIDENTIAL-SUBJECT TO PROTECTIVE ORDER” must bear the same marking, except indices, electronic databases, or lists that do not reproduce substantial portions or disclose the substance of the Confidential Information.

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Civil cases

Applies to

Confidentiality designation ?

The designation of a document as Confidential Information is a certification by an attorney or a party appearing pro se that the document includes Confidential Information as defined in this order.

Summary: Designating a document as Confidential Information operates as a certification by the designating attorney or pro se party that the document contains Confidential Information as defined in the Order.