Judge John H. Ehrlich
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- Five Business Days Before Presentment
- On Clerk Status Date
Notice Of Motion, Motion
- Five Business Days Before Scheduled Proceeding
Adjournments
- Trials are not rescheduled absent compelling circumstances; a motion to continue trial under Rule 231 must include a detailed affidavit and be filed by written motion at least five business days before trial, unless an emergency exists.
Communication
Clerk31 contacts
- tlhudson@cookcountycourt.com
- probatecrt1807orders@cookcountycourt.com
- probatecrt1803orders@cookcountycourt.com
- probatecrt1802orders@cookcountycourt.com
- probatecrt1806orders@cookcountycourt.com
- probatecrt1810orders@cookcountycourt.com
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- probatecrt1814aorders@cookcountycourt.com
- probatecrt1812orders@cookcountycourt.com
- probatecrt1809orders@cookcountycourt.com
- probatedivorders@cookcountycourt.com
- probatecrt1804orders@cookcountycourt.com
- probatecrt1811orders@cookcountycourt.com
- probatecrt1801orders@cookcountycourt.com
- joseph.fleming@cookcountyil.gov
- beanaele@cookcountycourt.com
- snadams@cookcountycourt.com
- dwhensel@cookcountycourt.com
- probatedivservices@cookcountycourt.com
- efilehelp@cookcountycourt.com
- jlmckay@cookcountycourt.com
- probate.divatty@cookcountyil.gov
- (312) 603-5694
- (312) 603-2486
- (312) 603-5025
- (312) 603-6878
- (312) 603-2591
- (312) 603-7229
- (312) 603-3784, (312) 603-5647
- (312) 603-6558
- (312) 603-5157
- (312) 603-5647
Chambers4 contacts
- john.ehrlich@cookcountyil.gov
- (312) 603-5943
- (312) 603-7546
- (312) 603-7545
Other Contacts1 contacts
- efiling.support@tylertech.com
Page & Word Limits2 rules
Memoranda supporting motions and responses are limited to 15 pages, and reply memoranda are limited to 7 pages.
Memoranda supporting motions and responses are limited to 15 pages with replies limited to seven pages.
Brief
15 pages
Reply Brief
7 pages
Document Format Requirements5 rules
Proposed orders must be in Microsoft Word format and e-mailed to all parties and the court on the day of the hearing; other formats are unacceptable.
The agreed-to draft order in Microsoft Word format must be e-mailed to all parties and the court the day of the hearing. Proposed orders in any other format are unacceptable.
DOCX
All written submissions must be double spaced in 11-point or larger Century Schoolbook font.
All written submissions are to be double spaced in 11-point or larger Century Schoolbook font only.
Text must have one-inch margins and page numbers at the center bottom of every page except the first.
Text is to be surrounded by one-inch margins and numbered at the center bottom of each page save the first.
Exhibits must be tabbed or separated by colored paper bearing an identifier.
Exhibits are to be tabbed or separated by colored paper with an identifier.
All legal citations must comply with the latest Bluebook edition, and citations to unreported decisions (except the Illinois Appellate Court) must use LEXIS system-generated format exclusively.
All legal citations must comply with the latest edition of "The Bluebook." Citations to unreported court decisions, excluding the Illinois Appellate Court, must be to LEXIS system-generated format exclusively.
Document Filing Requirements9 rules
After a case management or status call, parties must confer and agree to a proposed order reflecting the court's ruling.
After a case management or status call, the parties are to confer and agree to a proposed order reflecting this court's ruling.
Document Type
Proposed Order
Parties must present to the trial judge the agreed statement of the case, witness lists, motions in limine, the complaint and depositions with contested designations, and two sets of proposed jury instructions (one with IPI numbering and citations and one without).
Documents to be Presented to the Trial Judge 1. Agreed Statement of the Case 2. Witness lists 3. Motions in limine 4. The complaint, depositions, Rule 213 disclosures, and evidence depositions with contested designations 5. Proposed jury instructions—two sets; one with IPI numbering and citations and one without
Document Type
Trial Submission
At assignment in courtroom 2005, parties must exchange witness lists, motions in limine, proposed jury instructions, and evidence depositions; meet and confer on and categorize in limine motions; and agree to a statement of the case including estimated trial length.
At the Time of Assignment in courtroom 2005, the parties are to: 1. Exchange: (a) witness lists; (b) motions in limine; (c) proposed jury instructions; and (d) evidence depositions; 2. Meet and confer as to motions in limine and categorize those that are agreed and contested; and 3. Agree to a statement of the case to be read to the venire panel that includes an estimated length of the trial.
Document Type
Trial Assignment Exchange
A pre-trial transfer order must be entered in courtroom 2005 after the conference date is confirmed.
After a date is confirmed, a pre-trial transfer order must be entered in courtroom 2005.
Document Type
Pre Trial Transfer Order
Routine and agreed motions must include a proposed court order.
Document Type
Motion
Dismissal orders must unambiguously state the case is disposed of, the order is final, and all future dates are stricken, and any retained jurisdiction must be explained.
Dismissal orders must state unambiguously that the case is disposed of, that the order is a final order, and that all future dates are stricken. If this court is to retain jurisdiction for any reason, that reason must be explained.
Document Type
Dismissal Order
A default motion must include a proposed draft order plus specified attachments, including proof of service, copies of pleadings, a certification of an appearance search within the last five business days, and, for individual defaulting parties, a Service Members Civil Relief Act affidavit.
A default motion must attach must include: - The sheriff's return of service or a process server's affidavit - A copy of the notice of motion, motion, summons, complaint, and exhibits - A certification that within the last five business days an attorney or self-represented litigant searched for appearances in their file and the electronic docket - If the defaulting party is an individual, an affidavit in compliance with the Federal and the Illinois Service Members Civil Relief Act. 50 U.S.C. §§ 3931-3939; 330 ILCS 63/1 et seq. - A proposed draft order
Document Type
Default Motion
Pretrial memorandum must include specified content: trial length estimate, case statement, witness list, stipulated facts, Rule 216 responses, exhibit list, Rule 237 compliance, Rule 213 disclosures, statement of law, and jury demand certifications.
A pretrial memoranda must include the following information: - The parties' estimated length of the trial; - A concise statement of the case, specifying the claims and defenses; - A list of all witnesses, potential witnesses, and the names of persons who will be mentioned through the testimony of others; - A list of all stipulated facts; - All Supreme Court Rule 216 requests to admit and responses; - Each party's exhibit list, explaining any stipulations, agreements, or objections; - Affidavits of compliance with Supreme Court Rule 237 notices and a statement of all outstanding disputes; - All Supreme Court Rule 213(f)(1), (2), and (3) interrogatories and responses as well as deposition testimony supporting opinions to be presented at trial; - A statement of the law governing the issues in the case with pertinent citations; - Certifications from each party that no jury demand has been made or that a written waiver has been executed.
Document Type
Pretrial Memorandum
Pretrial materials for a matter proceeding to trial must include all motions in limine.
If a matter is proceeding to trial, the pretrial materials must also include all motions in limine.
Document Type
Pretrial Materials
Filing & Service rules
Electronic Filing Rules
Motions must be filed and noticed for presentment through the Clerk's office, or in room 802 for parties with an e-filing exemption; emergency ex parte motions are excepted.
All motions, except emergency motions ex parte, must be filed and noticed for presentment through the Cook County Clerk's office or, for parties with an e-filing exemption, in Daley Center room 802.
Page 2 | MOTIONS
Exhibits should be filed as a single entry in the electronic docket.
Exhibits should be filed as a single entry in the electronic docket.
Page 4 | Submissions, Exhibits, Citations, and Artificial Intelligence
Filing Timing and Cure Windows
Motions, except routine and agreed motions, must be presented within 90 days of filing.
All motions, except routine and agreed motions, must be presented within 90 days of filing. Circuit Court Rule 2.3.
Page 2 | MOTIONS
Motions for default must be provided to the court by e-mail and a paper copy at least five business days before presentment.
At least five business days before presentment, motions for default are to be provided to this court by e-mail and by placing a paper copy in the basket outside courtroom 2008.
Page 4 | Motions for Default
Pre-trial submissions must be delivered one week before the pre-trial conference.
Pre-trial submissions are to be delivered one week before the conference.
Page 1 | I. PRE-TRIAL CONFERENCES
Service and Proof of Service Rules
Parties must deliver a joint final pretrial memorandum by email and paper copy at least five business days before the pretrial conference.
At least five business days before a pretrial conference, the parties are to deliver by e-mail and in a paper copy a joint, final pretrial memorandum.
Page 5
Courtesy Copy Requirements
For every motion, courtesy copies must be delivered at least two days before presentment together with an agreed briefing schedule.
Courtesy copies of all motions are to be delivered at least two days before presentment along with an agreed briefing schedule.
Page 1 | III. MOTIONS
On the clerk status date, parties must provide submissions via e-mail and paper copy in the basket, at their own expense, with exceptions for voluminous exhibits.
On the clerk status date, the parties are to provide this court with their respective submissions, at their own expense, both by e-mail and by placing a paper copy of the submissions in the basket outside courtroom 2008. Exceptions may be made for motions that attach voluminous exhibits.
Page 2 | MOTIONS
Motions brought at regularly scheduled court proceedings must have the notice of motion and motion supplied at least five business days before the proceeding.
Motions may also be brought at any regularly scheduled court proceeding. Such motions must be filed and noticed as with any other filing. The notice of motion and the motion must be supplied at least five business days before the scheduled proceeding, as explained above.
Page 2 | MOTIONS
At least five business days before presentment, courtesy copies of the motion, notice, and exhibits must be e-mailed and a paper copy placed in the basket outside courtroom 2008.
At least five business days before presentment, a courtesy copy of the notice of motion, the motion, and any exhibits must be both e-mailed to this court and a paper copy of the submissions placed in the basket outside courtroom 2008.
Page 2 | MOTIONS
Adjournment & Extension Requirements
Trials are not rescheduled absent compelling circumstances; a motion to continue trial under Rule 231 must include a detailed affidavit and be filed by written motion at least five business days before trial, unless an emergency exists.
Trials will not be rescheduled absent compelling circumstances. A motion to continue a trial pursuant to Supreme Court Rule 231 must be supported by a detailed affidavit and presented by written motion no less than five business days before the scheduled trial date save for emergencies.
Page 5
Page extensions and additional pleadings require prior court approval and are granted only for good cause.
Page extensions and additional pleadings must be approved by this court prior to filing and will be granted only for good cause.
Page 4 | Submissions, Exhibits, Citations, and Artificial Intelligence
Chambers Communication Rules
Emergency motions and all exhibits must be e-mailed to the court; a non-file-stamped version is sufficient.
Emergency motions and all exhibits must be e-mailed to the court. A non-file-stamped version is sufficient.
Page 3 | Emergency Motions and Motions for Temporary Restraining Orders
To schedule a pre-trial conference, parties should speak with the judge directly or email chambers.
The court welcomes the opportunity to conduct pre-trials conferences in Law Division cases. To schedule a pre-trial, speak with the judge directly or send an e-mail to the address above.
Page 1 | I. PRE-TRIAL CONFERENCES
Contact the judge or email the court to obtain a motion presentment date and time.
Speak with the judge or e-mail the court for a presentment date and time.
Page 1 | III. MOTIONS
Pretrial conference dates and times should be requested via e-mail.
Dates and times for such conferences should be requested via e-mail.
Page 4 | Pretrials, Trials, and Evidentiary Hearings