Judge Marian E. Perkins
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Citation To Discover Assets
Courtesy copies
- Email • Seven Court Days Before Presentment
Motion To Appoint Receiver
- Seven Court Days Before Hearing
Communication
Chambers7 contacts
- daisy.valladares@cookcountyil.gov
- ccc.mfmlcalendar62@cookcountyil.gov
- (312) 603-3914
- (312) 603-3905
- (312) 603-5943
- (312) 603-7546
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- (312) 603-7545
Other Contacts1 contacts
- efiling.support@tylertech.com
Page & Word Limits2 rules
Motions and briefs are limited to 15 pages, excluding exhibits, unless the Court grants leave.
No motion or brief submitted to the Court shall exceed fifteen (15) pages, excluding exhibits, without prior leave of the Court.
Motion
15 pages
Motions and briefs in support/opposition are limited to 15 pages; reply briefs to 10 pages, excluding attached pleadings and exhibits.
There is a fifteen-page limit on motions and briefs in support of the motions, along with response briefs. Collectively, the motion and brief must fit within the 15-page limit. There is a ten-page limit for Reply Briefs. These page limitations exclude attached pleadings and exhibits.
Motion
15 pages
Support Brief
15 pages
Opposition Brief
15 pages
Reply Brief
10 pages
Document Format Requirements11 rules
All briefs must be double-spaced, 12-point Times New Roman, with 1-inch margins.
All briefs should be double-spaced with twelve-inch point and "Times New Roman" font, with one (1) inch margins.
Proposed orders must not place the judge's name on a stand-alone page.
The proposed order must not place the judge's name on a stand-alone page.
Courtesy copy email subject lines must include only the case number, case name, and court date, with 'off call' used for routine motions.
The subject line of the e-mail must include only the case number, the case name, and the court date (e.g., 23 CH 01234 State Bank v. Canipsy 5/15/2023). For routine motions, please indicate "off call" instead of the court date.
Courtesy copies must not include the law firm's internal file numbers.
Please do not include any "internal" file numbers of the law firm submitting the courtesy copies.
Proposed orders must be attached as a separate, clearly labeled PDF in the same courtesy copy email, with multiple proposed orders in one PDF attachment.
Proposed orders must be attached as a separate PDF attachment in the same courtesy copy e-mail and clearly labeled as mentioned above. Multiple proposed orders should also be submitted together in ONE PDF attachment.
The body of the courtesy copy email should include a brief description of the case to be heard.
The body of the email should include a brief description of the case to be heard.
Courtesy copy file names must be labeled with the last two digits of the year, a space before and after CH, and all five digits of the case number.
A case file name should be labeled as the last two digits of the year, followed by the remaining case number. A space must be included before and after CH. When labeling the documents, be sure to include all five digits.
Attachments to the courtesy copy email must be in PDF form only.
Attachments to the e-mail should be in PDF form only.
All motions must be submitted in one bookmarked/tabbed PDF with clearly titled bookmarks, or include a table of contents with page numbers if not bookmarked.
All motions must be in ONE Bookmarked/tabbed PDF file with all supporting documents. Each motion must be clearly titled and well-organized. Each bookmark/tab must be clearly titled (e.g., Notice of Motion, Complaint, Service Affidavits, Motion for Default, etc.) and neatly organized. PDFs without bookmarks/tabs should include a table of contents providing page numbers for each referenced pleading submitted to the Court.
All such Orders must be submitted in PDF format.
Please submit all such Orders in a PDF format and include a sentence striking any previously set court date, where applicable.
Document Filing Requirements25 rules
Except for Petitions to Intervene, a movant must file an Appearance before presenting any motion, including emergency motions.
Except for a Petition to Intervene, no motions, including Emergency Motions, may be presented unless the movant has filed an Appearance electronically with the Clerk of the Circuit Court or in Room 802 of the Clerk of the Circuit Court of Cook County.
Document Type
Motion
All filed and scheduled motions must bear the Clerk's file stamp.
All motions filed and scheduled must bear the file stamp of the Clerk of the Circuit Court of Cook County.
Document Type
Motion
The caption must include the Plaintiff(s), Defendant(s), Case No., Calendar No., and the judge's name.
The caption must include the Plaintiff(s), Defendant(s), and Case No. and Calendar No. and the judge's name
Document Type
Motion
Motions for service by special order of court must be accompanied by an affidavit detailing the investigation into the defendant's whereabouts and why service is impractical.
All motions for service by special order of court pursuant to 735 ILCS 5/2-203.1 shall be accompanied with an affidavit stating the nature and extent of the investigation made to determine the whereabouts of the defendant and the reasons why service is impractical under items (1) AND (2) of subsection (a) of Section 2-203, including a SPECIFIC statement showing that a diligent inquiry as to the location of the individual defendant was made and reasonable efforts to obtain service of process has been unsuccessful.
Document Type
Motion
For hearing, movants must deliver copies of the listed documents to the court no later than seven court days prior to presentment.
For hearing, movants must deliver to the court copies of the following documents, no later than seven (7) court days prior to presentment: 1. Notice of Motion(s);
Document Type
Motion
An off-call motion for voluntary dismissal must state there are no pending cross claims or counter claims, strike future court dates, and be properly filed with the Clerk.
A motion to voluntarily dismiss that is presented "off" call must set forth the following: (1) make an affirmative ===== PAGE 8 ===== statement that there are no pending cross claims or counter claims; (2) strike any future scheduled court dates; and (3) be properly filed with the Clerk of the
Document Type
Motion
Plaintiff's attorneys must include with foreclosure and sale motions a printout evidencing a bankruptcy inquiry with the Clerk's Office.
Plaintiff's Attorneys are required to include with Motions for Judgment of Foreclosure and Sale and Motions for Entry of Order Approving Sale and for an Order of Possession, a printout that indicates evidence that the plaintiff's attorney has conducted an inquiry with the Clerk's Office to determine whether the mortgagor has filed a petition for bankruptcy in the U.S District Bankruptcy Court of the Northern District of Illinois – Eastern Division.
Document Type
Motion
To schedule a motion for presentment, movants must file specified documents with the Clerk, including notice of motion, complaint, signed motions, military service affidavit, affidavit of proof, and attorney's fees affidavit.
To obtain a date for presentment, movants must file, at the time of scheduling the motion, the following documents with the Clerk of the Circuit Court: 1. Notice of Motion(s); 2. Complaint with Mortgage and Note; 3. All motions noticed for presentment (i.e., Motion for Default, Motion for Judgment of Foreclosure, Motion to Appoint Selling Officer, etc.) must be signed by an attorney as required by Supreme Court Rule 147 (with the name readably printed, typed, or stamped to indent the signature); 4. Affidavit of Military Service, with attached U.S. Department of Defense website printout current within six (6) months; 5. A signed affidavit of proof attached to and incorporated by express reference within the motion for default and/or foreclosure; and 6. Affidavit of attorney's fees and costs (attorney's fees sought, in excess of $2,750.00, must be supported by a time and task affidavit).
Document Type
Motion
Judgment of foreclosure order must include a provision requiring the movant to mail a copy within 7 days to the mortgagor's last known address.
The judgment of foreclosure order must include a provision requiring that the movant mail a copy of the order within seven (7) days to the last known address of the mortgagor.
Document Type
Judgment Of Foreclosure
Motion to confirm judicial sale must include specified documents including notice of motion with certificate of service and proposed order.
Movants must deliver to the court copies of the following documents, no later than seven (7) court days prior to presentment: 1. Notice of Motion with Certificate of Service; 2. Motion for Order to Approve/Confirm Judicial Sale (which must include a description of the property, date of last inspection, and certificate holder's contact information); 3. Motion for Immediate Possession, with vacancy affidavit and photographs that indicate vacancy, if seeking immediate possession; 4. Notice of Sale; ===== PAGE 10 ===== 5. Judicial Selling Officer's Report of Sale and Distribution; 6. Affidavit of Proof of Notice of Sale by Publication, with publications attached; 7. Receipt of Sale; 8. Certificate of Sale; and 9.
Document Type
Motion To Confirm Sale
Affidavit required (Ill. S. Ct. Rule 113/191 and Loss Mitigation Affidavit under Rule 114 if applicable), but not required for consent foreclosure or if defendant has not appeared.
Affidavit, Illinois Supreme Court Rule 113/191 Affidavit; 8. Loss Mitigation Affidavit pursuant to Ill. S. Ct. Rule 114, if applicable. An affidavit will not be required for a consent foreclosure or in a case where the defendant has not filed an appearance with the Clerk of the Circuit
Document Type
Motion
Personal deficiency judgment requires additional documents including complaint, judgment, affidavit of service, BPO/appraisal, and memorandum of judgment.
If the plaintiff is seeking a personal deficiency judgment, the court requires the following additional documents: 1. Mortgage Foreclosure Complaint, with all exhibits; 2. Judgment of Foreclosure; 3. Affidavit of Service of Process on the defendant, who is claimed to be personally liable; 4. Broker's Price Opinion ("BPO") or Appraisal; 5. Memorandum of Judgment (if any); and 6. Copies of all of these documents, including the "BPO," must be filed with the Clerk of the Court and communicated to the parties.
Document Type
Personal Deficiency Judgment
Counsel for movant must include the official court surplus request form with the notification.
Counsel for the movant must include the official court surplus request form with the notification.
Document Type
Letter
Motions for order of possession must include caption, property type, last inspection date, defendant names, and multi-unit possession scope.
All Motions for Order of Possession and proposed orders must include the following: 1. Complete Caption of the case; 2. Identify the type of property involved (i.e., single-family residence, multi-unit, commercial, etc.); 3. State when the property was last inspected by the movant; 4. Identify the names of all parties personally named as defendants in the complaint; and 5. In the case of a multi-unit property where the purchaser is seeking possession of the building, specify that possession extends only to the building and not individual units.
Document Type
Motion For Order Of Possession
Motions to appoint a receiver must include specified exhibits, including the complaint with mortgage and note, the proposed receiver's resume, the authorizing provision reference, proof of service, and a proposed order.
**Motions to Appoint a Receiver must include the following exhibits:** 1. The Complaint, with mortgage and note; 2. Resume of the proposed receiver, including his/her rates of compensation 3. Specific reference to the complaint or to the mortgage provision authorizing appointment of a Receiver; 4. Proof of service of either the complaint or the motion on the defendants in the manner required pursuant to Section 15-1706 (d) of the Illinois Mortgage Foreclosure Act; and 5. Proposed order.
Document Type
Motion To Appoint Receiver
Emergency motions to stay possession must include the foreclosure judgment date, the possession expiration date, and whether the party previously sought a stay.
Emergency Motion to Stay Possession – This emergency motion must include the date of the entry of the judgment of foreclosure, the possession expiration date, and whether the party previously sought a stay.
Document Type
Emergency Motion To Stay Possession
Emergency motions to stay judicial sale must fully inform the court of specified facts and circumstances and attach all relevant documents.
Emergency Motions to Stay Judicial Sale – This emergency motion should fully inform the court of all the relevant facts and circumstances, including the following: (1) the property address; (2) when the case was filed; (3) when the defendants were served; (4) when the foreclosure order was entered; (5) the originally scheduled date of the sale; (6) whether any previous stay orders were entered; and (7) whether the sale will fall outside of the publication date. All documents relevant to the request should be attached to the motion, e.g., short sale contracts, loan modifications.
Document Type
Emergency Motion To Stay Judicial Sale
An emergency petition to intervene will only be heard if the petitioner establishes that he or she is a necessary party as defined in the Illinois Mortgage Foreclosure Act.
Emergency Petition to Intervene – An Emergency Petition to Intervene will only be heard if the petitioner can establish that he/ she is a "necessary" party as defined in the Illinois Mortgage Foreclosure Act.
Document Type
Emergency Petition To Intervene
An emergency motion to appoint a receiver or mortgagee in possession will only be heard when the verified motion contains factual allegations of an immediate health or safety threat.
Emergency Motion to Appoint Receiver/Mortgagee in Possession – This emergency motion will only be heard when the verified motion contains factual allegations indicating an immediate health or safety threat.
Document Type
Emergency Motion To Appoint Receiver
Joint, uncontested, and agreed motions should be identified as such in the title and body of the motion.
Document Type
Motion
Judge Perkins will sign a transfer order upon presentation of the proper motion to transfer matters to the Law Division.
In order to properly transfer matters to the Law Division, Judge Perkins will sign a transfer order upon presentation of the proper motion.
Document Type
Motion
Orders must include a sentence striking any previously set court date, where applicable.
Please submit all such Orders in a PDF format and include a sentence striking any previously set court date, where applicable.
Document Type
Order
Agreed Orders may be presented in court or off call only if accompanied by a stipulation signed by all parties or their attorneys.
Agreed Orders may be presented in court or off call, if accompanied by a stipulation and signed by all the parties or their attorneys.
Document Type
Agreed Order
After scheduling a date with the law clerk, the motion and notice of motion must be filed with the clerk's office.
After obtaining a date from the law clerk, the motion and notice of motion must be filed with the clerk's office.
Document Type
Motion To Appoint Receiver
The movant must have an appearance on file with the Clerk of the Circuit Court before presenting an emergency motion to the judge's law clerk.
Movant must have an Appearance on file with the Clerk of the Circuit Court before presenting the Emergency Motion to the Judge's Law Clerk.
Document Type
Emergency Motion
Filing & Service rules
Electronic Filing Rules
All motions must be filed and scheduled for presentment with the Clerk, either in person in Room 802 or electronically.
All motions must be filed and scheduled for presentment with the Clerk of the Circuit Court in Room 802, or electronically with the Clerk of the Circuit Court.
Page 2 | Filing and Scheduling Motions in Calendar 62
Filing Timing and Cure Windows
Attorneys must provide an Order to the court within 48 hours after an Order has been granted.
Upon the conclusion of a court call, attorneys must provide an Order to the court within 48 hours after an Order has been granted by the court.
Page 3 | III. COURTESY COPIES
Disclosure of expert witnesses must be completed no later than 15 months after entry of Order 4331.
Disclosure of expert witnesses is completed no later than | 15 months
Page 5 | VI. TIME STANDARDS FOR THE DISPOSITION OF MORTGAGE FORECLOSURE CASES IN ILLINOIS
Mortgage foreclosure cases must be disposed of within three years from the date the case is instituted.
The period set forth for mortgage foreclosure cases is three (3) years from the date of institution of the case.
Page 5 | VI. TIME STANDARDS FOR THE DISPOSITION OF MORTGAGE FORECLOSURE CASES IN ILLINOIS
Oral discovery must be completed no later than 14 months after entry of Order 4331.
Oral discovery completed no later than | 14 months
Page 5 | VI. TIME STANDARDS FOR THE DISPOSITION OF MORTGAGE FORECLOSURE CASES IN ILLINOIS
Parties must comply with the discovery, dispositive motion filing, and trial-setting timeline.
The parties shall comply with the above-referenced timeline for discovery, filing of dispositive motions, and setting the case for trial.
Page 5 | I. DISCOVERY
Expert witness discovery must be completed no later than 17 months after entry of Order 4331.
Expert witness discovery completed no later than | 17 months
Page 5 | VI. TIME STANDARDS FOR THE DISPOSITION OF MORTGAGE FORECLOSURE CASES IN ILLINOIS
Written discovery must be completed no later than 8 months after entry of Order 4331.
Written discovery completed no later than | 8 months
Page 5 | VI. TIME STANDARDS FOR THE DISPOSITION OF MORTGAGE FORECLOSURE CASES IN ILLINOIS
All discovery must be completed and all final dispositive motions filed no later than 20 months after entry of Order 4331.
All discovery completed and all final dispositive motions filed no later than | 20 months
Page 5 | VI. TIME STANDARDS FOR THE DISPOSITION OF MORTGAGE FORECLOSURE CASES IN ILLINOIS
The case must be set for trial no later than 24 months after entry of Order 4331.
Set for trial no later than | 24 months
Page 5 | VI. TIME STANDARDS FOR THE DISPOSITION OF MORTGAGE FORECLOSURE CASES IN ILLINOIS
Movants must deliver required documents to the court at least 7 court days before presentment.
Movants must deliver to the court copies of the following documents, no later than seven (7) court days prior to presentment:
Page 9 | V. MOTION FOR ORDER TO CONFIRM A JUDICIAL SALE
Transfer requests will not be entertained or entered off call.
Transfer requests will not be entertained or entered "off call."
Page 6 | Citation to Discover Assets
The Court may modify the discovery timeline for good cause, on its own motion or a party's motion.
The Court retains the authority to modify this order, for "good cause," on its own motion or by a motion of a party, where appropriate.
Page 5 | I. DISCOVERY
The Court may strike a case from the case management call and enter a separate discovery timeline order.
Any matter coming before the Court for a case management conference pursuant to Illinois Supreme Court Rule 218, where the Court is fully advised in the premises, the Court may strike the case from the case management call ("4331") and, by separate order of the Court, enter a timeline for discovery order.
Page 5 | I. DISCOVERY
Service and Proof of Service Rules
Proper notice of the hearing must be sent to all parties of record.
proper notice of the hearing must be sent to all parties of record
Page 6 | Citation to Discover Assets
Proof of service by publication must include a sworn affidavit and comply strictly with Cook County Circuit Rule 7.3.
Proof of service by publication must be accompanied by a sworn affidavit. Service by publication must be in strict compliance with the Cook County Circuit Rule 7.3.
Page 7 | III. NON-CONTESTED MOTIONS - Service by Publication Affidavit
Counsel for movant must notify mortgagor by letter of surplus and procedures to obtain funds.
counsel for the movant shall notify the mortgagor, by letter, of the surplus, specifying that the funds may be obtained by petition and notifying the mortgagor as to the procedures for doing so.
Page 10 | V. MOTION FOR ORDER TO CONFIRM A JUDICIAL SALE
Movant must mail a copy of the order to the mortgagor's last known address within 7 days.
The movant shall mail a copy of the order within seven (7) days to the last known address of the mortgagor.
Page 10 | V. MOTION FOR ORDER TO CONFIRM A JUDICIAL SALE
No notice of motion should be sent to any opposing party until the motion has been cleared for placement on the judge's emergency call.
No Notice of Motion should be sent to any opposing party until the motion has been cleared for placement on the judge's emergency call.
Page 12 | VII. EMERGENCY MOTIONS
Notice must be given in accordance with the Illinois Code of Civil Procedure.
Notice must be given in accordance with the Illinois Code of Civil Procedure.
Page 11 | VI. MOTION TO APPOINT A RECEIVER OR TO PLACE A MORTGAGEE-IN-POSSESSION
Courtesy Copy Requirements
Movants must deliver courtesy copies of all hearing documents to the court by email no later than seven court days before presentment, except for emergency motions.
Movants must supply the court with copies of all documents relevant to the hearing, including pleadings. Except for emergency motions, the documents must be delivered to the court no later than seven (7) court days, prior to the scheduled date of presentment. Courtesy copies are to be delivered electronically via e-mail to ccc.mfmlcalendar62@cookcountyil.gov.
Page 3 | III. COURTESY COPIES
The movant must submit courtesy copies seven court days in advance of the hearing date.
The movant must submit courtesy copies seven (7) court days in advance of the hearing date.
Page 11 | VI. MOTION TO APPOINT A RECEIVER OR TO PLACE A MORTGAGEE-IN-POSSESSION
Courtesy copies should be provided to the court for citations to discover assets.
Courtesy copies should be provided to the court.
Page 6 | Citation to Discover Assets
Pre-Motion Conference Requirements
Piggybacking a motion onto a previously scheduled court date requires prior leave of court, which may be requested in court or by emailing chambers seven days in advance; certain motions may be piggybacked, but not on case management conference calls or Motions to Appoint Receiver.
“Piggybacking” a motion onto a previously scheduled court date in the same case is only allowed with prior leave of court. Parties may request leave to piggyback a motion while in court for a hearing or by emailing the Judge’s chamber staff seven (7) days in advance of the requested date. Generally, Motions to Substitute a Party or Motions to Substitute an Attorney, Motions to Withdraw as Counsel, and Motions for Extension of Time may be piggybacked onto existing motion dates. No piggybacking is permitted on the case management conference call or Motions to Appoint Receiver
Page 8 | III. NON-CONTESTED MOTIONS - Piggy Backing Motions
When no appearance or answer has been filed by a non-movant mortgagor, specified uncontested motions may be scheduled for presentment on the 9:30 a.m. Default Call.
If no court appearance or answer to the complaint has been filed by a non-movant mortgagor, the following motions may be scheduled for presentment on the court's 9:30 a.m. Default Call: - To Amend Complaint; - To strike a case management date; - To Substitute Parties or Attorneys; - To Add or Dismiss a Party; - For entry of an order of default judgment of foreclosure and sale; - To shorten the redemption period, with a sworn affidavit of vacant or abandoned property; - To prove up the lien of a junior lien holder; - To amend the judgment of foreclosure and sale; - To appoint a judicial selling officer; - For an Order Approving Sale and for Order of Possession.
Page 7 | III. NON-CONTESTED MOTIONS - Default Call
When no appearance, answer, or motion has been filed by any mortgagor, specified motions may be delivered to the court off call at any time with proposed orders.
If no court appearance, answer to the complaint, or other motion has been filed by any mortgagor, the following motions may be delivered to the court at any time with proposed orders for entry: - Agreed Continuances; - Motion for Voluntary Dismissal*; - Motion to Substitute Attorney; - Petitions for Special Representative Fees; and - Motions for Substitution of Judge as a Matter-of-Right.
Page 7 | III. NON-CONTESTED MOTIONS - Off-Call Motions
Chambers Communication Rules
A copy of the proposed emergency motion must be emailed to Calendar 62 by 4:00 p.m. the day before the desired presentment date.
A copy of the proposed Emergency Motion must be emailed to Calendar 62 email by 4:00 p.m. the day before the desired date of presentment.
Page 11 | VII. EMERGENCY MOTIONS
Motions to appoint a receiver or mortgagee in possession must be scheduled with the Judicial Law Clerk by phone at (312) 603-3914.
Pursuant to Chancery Division General Administration Order No. 2014-01, Motions to Appoint a Receiver or Mortgagee in Possession must be scheduled with the Judicial Law Clerk via phone at (312) 603-3914.
Page 11 | VI. MOTION TO APPOINT A RECEIVER OR TO PLACE A MORTGAGEE-IN-POSSESSION
Contact the administrative assistant for administrative concerns and order status follow-up.
For administrative concerns and follow-up on the status of entered court orders, please contact Daisy Valladares, the Court's administrative assistant. Daisy Valladares can be reached at daisy.valladares@cookcountyil.gov or via telephone at (312) 603-3914.
Page 2 | II. COURTESY COMMUNICATION TO THE COURT'S JUDICIAL CHAMBER
Notify the judicial law clerk if a fully briefed matter is resolved and will not be heard.
As a courtesy to the Court, please contact Erica Thomas, the Court's judicial law clerk, via email at ccc.mfmlcalendar62@cookcountyil.gov or at (312) 603-3905, if any fully briefed matter has been resolved and will not be heard.
Page 2 | II. COURTESY COMMUNICATION TO THE COURT'S JUDICIAL CHAMBER
Contact the judicial law clerk for legal matters or procedural concerns.
For legal matters or procedural concerns, please contact Erica Thomas, the Court's judicial law clerk. Erica Thomas can be reached at ccc.mfmlcalendar62@cookcountyil.gov or via telephone at (312) 603-3905.
Page 2 | II. COURTESY COMMUNICATION TO THE COURT'S JUDICIAL CHAMBER
A hearing date for citations to discover assets may be obtained from the Clerk's Office in Room #802.
A hearing date may be obtained from the Clerk's Office in Room #802
Page 6 | Citation to Discover Assets