Circuit Court of Cook County Document Filing Requirements

CRITICALCivil cases

Applies to

Motion to deviate from hearing format

Requests to deviate from the designated hearing format must be made by written motion stating a valid basis.

Any request to deviate from this format must be requested via written motion with a valid basis required.

CRITICALCivil cases

Applies to

Order setting or continuing hearing

Every order that sets or continues a hearing must specify how the hearing will be held.

All orders setting or continuing a hearing MUST contain language indicating how the hearing will be held. The hearing will be conducted as designated above unless an order is entered to the contrary.

CRITICAL

Applies to

Default judgment motion

A motion for default judgment must be accompanied by the notice, summons showing service, the motion, a draft judgment order, the operative complaint, and materials supporting the prima facie case.

With the motion for default judgment, the movant must provide: The notice, summons showing service, and motion for default judgment; A draft judgment order specifying the precise relief sought; A copy of the operative complaint; and Any other materials supporting the movant's burden of showing a prima facie case for the relief sought.

CRITICAL

Applies to

Agreed order

Must include

proposed order

Following any appearance, parties must send an agreed proposed order to the Court.

Following any appearance in front of this Court, Parties must send an agreed proposed order to ccc.chancerycalendar4@cookcountyil.gov by noon the day of presentment.

CRITICAL

Applies to

Joint motion for class settlement approval

Joint motions to approve proposed class settlements must include a completed Preliminary Approval Chart and parties must be prepared to answer the court's listed questions about the settlement.

When parties submit joint motions to approve proposed class settlements, they must complete and include the below chart with their submission. Parties should also be prepared to answer questions about the proposed settlement, including those stated below the chart.

CRITICAL

Applies to

Brief

When an oversized brief is permitted by a prior court order, that order must be included with the briefs at submission.

If leave to file an oversized brief has been previously granted, include the order with the briefs when submitted.

CRITICAL

Applies to

Brief

Briefs that do not comply with the format and page requirements will be stricken.

Failure to comply with these requirements will result in the noncompliant brief being stricken.

CRITICAL

Applies to

Agreed order

Must include

proposed order

After a clerk’s status, the parties must confer and send the Court an agreed order setting the hearing date.

The parties shall then confer and send the Court an agreed proposed order setting the hearing date.

CRITICAL

Applies to

Default motion

An attorney’s signed and certified statement that the Clerk’s electronic docket indicates that the defendant has not filed an appearance or answer;

An attorney’s signed and certified statement that the Clerk’s electronic docket indicates that the defendant has not filed an appearance or answer;

CRITICAL

Applies to

Proposed order

A proposed order dismissing the entire case must state that all future dates are stricken.

The Proposed Order must also state that all future dates regarding the matter are stricken, if the order dismisses the case in its entirety.

CRITICAL

Applies to

Motion

A motion for a protective order must state the privacy interest and why protection is necessary, supported by affidavit.

The motion(s) must recite the privacy interest involved, and why a protective order is necessary. This should be supported by affidavit.

CRITICAL

Applies to

Case management conference

Counsel authorized to commit to scheduling orders must appear at the case management conference prepared to address the listed subjects.

Counsel with authority to commit to all scheduling orders must appear at the Case Management Conference and be prepared to inform the Court regarding the following (but not limited to): • Service of process upon each defendant, • Nature of the litigation, • Status of the pleadings • Any pending or contemplated motions, and • All contemplated or completed discovery.

CRITICAL

Applies to

Motion for alias summons

Must include

proposed order

An alias-summons movant must email chambers the clerk-file-stamped copy and a proposed order.

For a Motion for Alias Summons, the person making the motion, or “Movant,” shall send the file stamped copy from the Clerk of the Circuit Court’s office, along with a proposed order via email to the chambers email of ccc.chancerycalendar3@cookcountyil.gov.

CRITICAL

Applies to

Motion

A request to appear remotely must be made orally in court or by written motion at least two days before the next court date, with proper notice to opposing parties.

Requests to appear remotely shall be made either orally while appearing for court or by filing a written motion in at least two (2) days in advance of the next court date with proper notice of motion sent to the opposing parties.

CRITICAL

Applies to

Dispositive motion

A dispositive motion with more than three exhibits must include a hyperlink to each exhibit.

Dispositive motions that include more than three (3) exhibits must contain hyperlinks directing to each individual exhibit.

CRITICAL

Applies to

Settlement conference

Clients must attend settlement conferences unless excused, and counsel is expected to have settlement authority and to attempt resolution beforehand; failure to appear or participate in good faith may result in sanctions or other consequences.

d. Counsel is expected to have authority to settle the case. Client(s) must be present for the settlement conference unless excused by the Court. Counsel is expected to have attempted to reach a settlement or agreement on outstanding issues prior to the conference with the Court. Failure to appear at a settlement conference may result in a dismissal for want of prosecution, default, or the entry of any other appropriate sanction. Failure to participate in good faith at the settlement conference may result in an award of sanctions against the offending party and/or counsel.

CRITICAL

Applies to

Settlement conference memorandum

Each party must submit a settlement conference memorandum via email to chambers at least 14 days before the conference, including nature of claims/defenses and settlement demand/offer.

At least fourteen (14) days prior to the settlement conference, each party MUST submit to the Court via email to the chambers email of ccc.chancerycalendar3@cookcountyil.gov and exchange with opposing counsel(s) a brief memorandum advising the Court of the nature of the claims and defenses, as well as the most recent settlement demand and offer. Failure to submit the memorandum in advance of the settlement conference may result in the striking of the settlement conference date.

CRITICAL

Applies to

Proposed order

The proposed order must clarify that it does not itself authorize sealed filing and that parties submitting designated confidential material must follow the court’s sealing rules.

The motion(s) must state in the text of the order that the order does not, by itself, authorize the filing of any document under seal, and that any party wishing to file a document designated as ‘Confidential,’ or ‘Attorney’s Eyes Only Information’ in connection to a motion, brief, or other submission to the Court must comply with court rules pertaining to filings under seal.

CRITICAL

Applies to

Emergency motion

An emergency motion, including a TRO motion, must have a separate first-page paragraph describing the emergency.

Emergency motions, including emergency motions for TRO, MUST contain a separate paragraph on the first page of the motion detailing the emergency nature of the motion.

CRITICAL

Applies to

Order for voluntary dismissal

An order for voluntary dismissal must bear the signatures of all parties and/or their counsel.

Orders for Voluntary Dismissal MUST contain the signature of all parties and/or their counsel.

CRITICAL

Applies to

Default judgment

Must include

certificate of service

A motion for default must include the listed file-stamped documents, summons materials, service certification or affidavit, docket-check certificate, and—when the defaulting party is an individual—a military affidavit.

A Motion for Default MUST contain the following: • File-Stamped Copy of the Notice and Motion from the Clerk of the Circuit Court’s Office, • Face of the Summons, • Copy of the Return of Summons, • The Certificate of the Officer or Affidavit of the Person who served the Summons, • Attorney or Pro Se litigant certificate, certifying that both the court file and docket have been checked for any appearance or answer filed by the defendant, AND • A military affidavit if defaulting and individual.

CRITICAL

Applies to

Settlement conference memorandum

Each party must email and exchange a brief settlement memorandum at least 14 days before the conference, covering the claims, defenses, and most recent settlement demand and offer; noncompliance may result in the conference date being stricken.

c. At least fourteen (14) days prior to the settlement conference, each party MUST submit to the Court via email to the chambers email of ccc.chancerycalendar3@cookcountyil.gov and exchange with opposing counsel(s) a brief memorandum advising the Court of the nature of the claims and defenses, as well as the most recent settlement demand and offer. Failure to submit the memorandum in advance of the settlement conference may result in the striking of the settlement conference date.

CRITICAL

Applies to

Trial materials

Separate trial materials must include a statement detailing the parties’ good-faith efforts to agree on a joint submission.

To the extent separate trial materials are submitted, they must be accompanied by a statement detailing the good faith efforts of the parties to agree on a joint submission.

CRITICAL

Applies to

Brief

A party seeking to file a brief over the page limit must obtain leave of Court before submitting it.

All parties seeking to file a brief exceeding the page limit must first obtain leave of the Court, prior to submitting said brief.

CRITICAL

Applies to

Complaint

Each complaint count must independently state specific factual allegations relevant to the elements of that claim; blanket incorporation is insufficient.

Each count in the complaint must be supported by specific factual allegations that are directly relevant to the elements of that particular claim. General references to earlier paragraphs or the blanket incorporation of "all preceding paragraphs" do not satisfy this requirement. The use of boilerplate incorporation language—such as “Plaintiff incorporates all prior allegations as if fully set forth herein”—without identifying the specific factual allegations that support each count is insufficient. Each count must stand on its own and clearly articulate the factual basis for the legal claim asserted.

CRITICAL

Applies to

Proposed order

The proposed protective order must state that it does not apply to court orders.

The motion(s) must state in the text of the order that the protective order will not apply to Court orders.

CRITICALCivil cases

Applies to

Witness list and exhibits

Witness lists and exhibits must be tendered to all parties, the GAL, and the Court 1 week before trial, or the witnesses and exhibits will be excluded.

For all matters set for trial or hearing on the 2:00 p.m. call, a witness list and exhibits must be tendered to all parties, the GAL and the Court 1 week prior to the commencement of the trial or those witnesses and exhibits will be excluded from trial.

CRITICALCivil cases

Applies to

Discovery motion

Must include

certificate of conference

Discovery motions must include proof of compliance with Illinois Supreme Court Rule 201(k).

Discovery motions must include proof of compliance with Illinois Supreme Court Rule 201(k).

CRITICAL

Applies to

Motion

Must include

proposed order

file stamped copies with a proposed order sent to the Court’s email

file stamped copies with a proposed order sent to the Court’s email

CRITICAL

Applies to

Motion

Must include

caption, case number

Notices of motion, motions, and orders must include a full caption with all party names, case number, and calendar number.

All notices of motion, motions, and orders submitted for the Court’s review must include a full caption containing the names of all parties, the case number, and the calendar number.

CRITICAL

Applies to

Status report

Status reports must include general case status, discovery status and completion estimate, pending motions, and proposed future status dates.

The report should include any pertinent information about the case, such as a general status of the case, the status of discovery, an estimate of when that discovery will be completed, and any motions that are pending before the Court. The report shall also include proposed dates for further status.

CRITICAL

Applies to

Motion to withdraw

Must include

proposed order, certificate of service

with a proposed order and all applicable proof of service and confirmation of service

with a proposed order and all applicable proof of service and confirmation of service

CRITICAL

Applies to

Default motion

Must include

certificate of service

Default motions must include an e-filed Affidavit of Service and prove-up documents.

Motions for Default must be accompanied by an e-filed Affidavit of Service. Prove-up documents of damages must be provided to the Court for a default to be entered.

CRITICAL

Applies to

Motion for order approving sale

Motions for order approving sale seeking a personal deficiency where the defendant has not filed an appearance must include proof of service on the defendant, a copy of the Complaint, a copy of the Judgment of Foreclosure Order, and a BPO/recent appraisal.

ADDITIONAL REQUIREMENTS FOR MOTIONS FOR ORDER APPROVING SALE WHERE PLAINTIFF IS SEEKING A PERSONAL DEFICIENCY AND THE DEFENDANT HAS NOT FILED AN APPEARANCE: • Proof of service on the defendant of whom the deficiency is being sought; • Copy of the Complaint; • Copy of the Judgment of Foreclosure Order; • BPO / Recent Appraisal.

CRITICAL

Applies to

Status report

Must include

caption, case number

For initial case management, parties must file and submit a status report (joint or individual) via the Calendar 52 email no later than 7 days before the court date, with the caption and case number in the subject line.

If your case has been set for an initial case management conference, your case will not be heard on that date either remotely or in person. Instead, parties are required to file and submit either: (a) a joint written status report agreed upon by all of the parties, or (b) each party may submit its own status report. The status reports shall be sent to the Calendar 52 email address, ccc.mfmlcalendar52@cookcountyil.gov, no later than seven (7) days prior to the court date with the case caption and case number in the email’s subject line.

CRITICALCivil cases

Applies to

Discovery motion

Must include

certificate of conference

Discovery motions must include proof of compliance with Illinois Supreme Court Rule 201(k).

Discovery motions must include proof of compliance with Illinois Supreme Court Rule 201(k).

CRITICAL

Applies to

Case management order

Parties must bring copies of all CMC orders to every CMC court date.

*** COPIES OF ALL CMC ORDERS ARE REQUIRED ON ALL CMC COURT DATES ***

CRITICAL

Applies to

Certificate

Attorneys must certify completion of discovery, depositions, and that no dispositive motions are pending before trial.

Attorneys certify the following: 1) All fact, medical and opinion discovery is complete; 2) All depositions of Rule 213(f)(1),(2) and (3)witnesses have been taken or waived in writing or in a court order; 3) All necessary evidence depositions shall be completed no later than 14 days prior to the assigned trial date; 4) No dispositive motions are pending and none will be filed by any party prior to trial

CRITICALCivil cases

Applies to

Motion

Emergency motions must be marked 'EMERGENCY MOTION' and include a factual basis stating the nature of the emergency.

the motion is properly marked as an "EMERGENCY MOTION" and includes a sufficient factual basis clearly stating the nature of the emergency

CRITICALCivil cases

Applies to

Prove up affidavit

Affidavits must explain how damages, including interest and late charges, were calculated and cite contract provisions regarding interest, late fees, and attorney fees.

3. Calculation. An affidavit shall explain how the damages, including interest and late charges, were calculated. It shall cite pertinent provisions of the contract regarding interest, late fees, attorney fees, etc.

CRITICALCivil cases

Applies to

Prove up affidavit

Affidavits must disclose whether they are based on personal knowledge, attached documents, or both, and explain how the affiant knows the facts.

1. Basis. An affidavit shall state whether it is grounded upon personal knowledge, attached documents, or both. The affidavit shall explain how the affiant knows the facts.

CRITICAL

Applies to

Routine motion

Must include

proposed order

All routine motions must include a proposed order.

All routine motions must include a proposed order.

CRITICALCivil cases

Applies to

Attorney fee affidavit

Attorney fee affidavits must attach contemporaneous billing records with detailed entries specifying services, provider, time, and hourly rate.

Contemporaneous billing records shall be attached. Accordingly, the records must provide detailed billing entry descriptions specifying the services performed, who did it, how long it took, and the hourly fee charged based on contemporaneous time records.

CRITICAL

Applies to

Courtesy copy

Must include

certificate of service

All courtesy copies must include a notice of motion and certificate of service.

You must include a notice of motion and certificate of service in all courtesy copies.

CRITICALCivil cases

Applies to

Prove up affidavit

Affidavits must establish the foundation for attached documents and, if they are offered for their truth, must establish they are business records.

2. Foundation. An affidavit shall set forth the foundation for any document attached. If the affiant offers a document for its truth, the affiant shall establish it is a business record.