Circuit Court of Cook County Filing Bundling Requirements

Exhibits must be provided separately in a single packet with table of contents and tabs.

Exhibits should be provided separately in a single packet with a table of contents and tabs.

Contested motions require a briefing schedule order; materials must be delivered in one package for oral argument. Forum Non Conveniens motions get written decision, no oral argument.

Contested motions require the entry of a briefing schedule order which includes a clerk status date. Upon receipt of complete briefs, pleadings, depositions and exhibits from Movant, in one delivery, a hearing will be set for oral arguments. Exception: Motions to Dismiss based upon Forum Non Conveniens will receive a written decision. No oral argument hearing will be set upon receipt of complete briefs, pleadings and exhibits from Movant. If granted the case will be transferred. If denied, a status date and time will be included in the order.

Briefs for contested motions must not be submitted until all briefing is complete, then one electronic and one physical set of courtesy copies are required.

Parties should not submit copies of any briefs relating to contested motions until all briefing is complete. Courtesy copies should be one complete set sent electronically to the Calendar R email, and one complete set of physical courtesy copies delivered to Room 2208. In the physical copy all exhibits must be tabbed and all materials must be printed double-sided.

Trial materials must be joint submissions; separate allowed only with good faith disagreement.

must be submitted to the Court by joint submissions no less than thirty (30) days before the scheduled pretrial or trial (whichever is sooner). Separate submissions are permitted only if the parties cannot in good faith agree on joint submissions.

Evidentiary hearing materials must be joint submissions; separate allowed only with good faith disagreement.

Separate submissions are permitted only if the parties cannot in good faith agree on joint submissions

Admitted trial exhibits must be jointly filed with courtesy copy to chambers.

The parties shall jointly file a complete set of admitted trial exhibits and supply the Court with a courtesy copy thereof.

On the clerk's status date, the movant must email a bundled submission of file-stamped PDF copies of all briefs, exhibits, and the operative pleading to the Court.

At or shortly before 9:15 a.m. on the clerk’s status date, the movant shall submit to the Court by email, with a copy to all opposing parties, file-stamped PDF copies of all of the briefs and any exhibits, and including a copy of the operative pleading.

A default and a default judgment must be obtained separately and cannot be bundled or decided at the same time.

The Court requires each to be obtained separately and not simultaneously. In other words, a party must first be held in default, then given notice of a separate prove-up date for a default judgment.

The movant must email file-stamped PDF copies of all briefs, exhibits, and the operative pleading together to Calendar 1 before the clerk's status call.

At or shortly before 9:30 a.m. on the clerk’s status date, the Court requires the movant to email Calendar 1 with a copy to all parties of record, file-stamped PDF copies of all of the briefs and any exhibits, including a copy of the operative pleading.

Required

Always

Requests for a sealed-bid auction must be presented by separate motion.

All requests for a sealed-bid auction must be presented by separate motion.

Required

Always

Plaintiff must notice up all judgment motions simultaneously.

Plaintiff shall notice up ALL judgment motions (inter alia, motions to dismiss unknown parties or other defendants, default, summary judgment, judgment of foreclosure, appoint selling officer, reformation of mortgage or deed) simultaneously.

Required

Always

Moving for judgment in a piecemeal fashion against separate litigants is strictly prohibited.

Moving for judgment in a piecemeal fashion against separate litigants is strictly PROHIBITED.

Required

Always

The Court will not enter multiple judgments of foreclosure in one case without prior consent.

The Court will NOT enter multiple judgments of foreclosure in one case without the Court's prior consent to proceed in such a piecemeal fashion.

Required

Always

All damages must be proven up together in one motion, not piecemeal, without the Court's prior consent.

All parties seeking a determination of damages shall prove up all damages sought together in one motion and shall NOT be brought in a piecemeal fashion without the Court's prior consent to deviate from this requirement.

Required

Always

A plaintiff seeking judgment of foreclosure must file a separate motion with all supporting documents and may not integrate it into a summary judgment, default, or other judgment motion.

A plaintiff seeking a judgment of foreclosure pursuant to 735 ILCS 5/15-1506 SHALL file a separate motion for entry of judgment of foreclosure with all supporting documents required by law attached thereto. Movants for entry of judgment of foreclosure may NOT integrate a motion for entry of judgment of foreclosure into a motion for summary judgment, default, or any other judgment motion.

Motions to confirm multiple judicial sales must be brought together (single motion or simultaneous motions); piecemeal filing requires prior court consent.

If multiple properties are sold via judicial sale in a single case and pursuant to an entered judgment of foreclosure permitting the sale of multiple properties, movants seeking to confirm such sales shall bring all motions to confirm the sales of these properties in either a single motion or multiple motions (one per property) simultaneously. If the Court approves the sales, the Court will enter all orders approving sale in one case concurrently. Parties seeking approval of multiple judicial sales shall NOT bring such motions in a piecemeal fashion without the Court's prior consent.

Sur-replies are not permitted.

No sur-replies will be permitted.

Contested motions may not be presented at or piggybacked onto a case-management conference.

Contested motions may not be presented at a case management conference, and no motions may be piggy-backed on to a case management conference.

Motions must be bundled into a single tabbed PDF with all supporting documents.

All motions shall be in ONE tabbed PDF file with all supporting documents. Each tab shall be clearly titled (e.g., Notice of Motion, Complaint, Service Affidavits, Motion for Default, etc.) and neatly and intuitively organized.

If multiple motions are submitted, each motion's folder includes its response and reply, and each folder and contents must be zipped into a .zip file.

If there are multiple motions, they shall be contained within a separate folder for each respective motion along with that motion’s response and reply. Each folder and its contents shall be saved within a .zip file.

Proposed orders must not be attached to or bundled with any other document.

Proposed orders for each motion should be provided to the Court with the courtesy copy submission and should not be attached to any other document.

Motions to strike briefs, affidfields, or portions of either are decided with the underlying motion without a separate response or reply.

Motions to strike briefs, affidavits, or portions of either, will be taken with the motion without response or reply.

Parties must not submit courtesy copies of contested-motion briefs until all briefing is complete.

Other than the copy provided to the court for presentment (see 2(b) above), parties should not submit copies of any briefs relating to contested motions until all briefing is complete.

Required

Always

The Court accepts piggybacked motions for presentment onto pre-set court dates; file and notice them but do not spindle, and Illinois Rules of Civil Procedure still apply.

The Court accepts motions “piggybacked” for presentment onto pre-set court dates. File and notice them, but do not spindle. Note the Illinois Rules of Civil Procedure still apply.

Motions may be piggy-backed on previously set case management dates without formal scheduling.

Motions may also be “piggy-backed” on a previously set case management date without formal scheduling.

Parties may delay submitting courtesy copies of briefings under a briefing schedule until the Clerk’s Status date.

Once parties have entered into a briefing schedule on a motion, parties can wait to submit courtesy copies of the briefings (e.g. the response and reply) until the Clerk’s Status date.

The parties may, by mutual agreement, file a joint pretrial memorandum in lieu of separate filings, or submit agreed memoranda, stipulations, or other pre-trial material.

The parties may, by mutual agreement, submit a joint pretrial memorandum in lieu of separate filings, and may submit agreed memoranda, stipulations and/or other material that may assist in the resolution of factual and/or legal issues prior to trial.