Circuit Court of Cook County Document Filing Requirements

WARNING

Applies to

Opposition

A respondent who fails to file a written response brief waives oral argument and any defense other than a general denial, and the Court will set a ruling date.

If the Respondent fails to file a written brief in response to the Motion, the Respondent will be deemed to have waived oral argument and any defense other than a general denial. Accordingly the Court will set a ruling date on the Motion.

WARNING

Applies to

Settlement memorandum

Each party must submit to the Court and exchange with opposing counsel a brief settlement memorandum at least 14 days before the settlement conference, stating the most recent settlement demand and offer and the general nature of claims and defenses.

At least fourteen (14) days before the settlement conference, unless otherwise ordered by the Court, each party MUST submit to the Court, and exchange with opposing counsel, a brief memorandum advising of the most recent settlement demand and offer as well as the general nature of the claims and defenses. Pre-trial memoranda need not be filed.

WARNINGCivil cases

Applies to

Routine motion

Must include

proposed order, notice of motion

Routine motions must be accompanied by courtesy copies of Notice of Motion, Routine Motion, and Proposed Order.

Prior to the noticed date, the movant must provide the court with electronic courtesy copies of the Notice of Motion, Routine Motion, and a Proposed Order.

WARNINGCivil cases

Applies to

Proposed order

Must include

proposed order

Following a remote proceeding, the parties should promptly submit a proposed order in to ccc.chancerycalendar5@cookcountyil.gov. Orders must be received no later than 3:00 p.m. of the day of the proceeding.

Following a remote proceeding, the parties should promptly submit a proposed order in to ccc.chancerycalendar5@cookcountyil.gov. Orders must be received no later than 3:00 p.m. of the day of the proceeding.

WARNINGCivil cases

Applies to

Pretrial submission

Pre-trial submissions must include a joint statement, stipulations, exhibit binder, witness list, Rule 237 disputes, Rule 213 disclosures, motions in limine, and evidence depositions.

The pre-trial submissions shall consist of the following: 1) A joint short statement of the nature of the case; 2) A joint statement and stipulation to facts, if any; 3) A separate binder from each party with an exhibit list for that party. The exhibits shall be listed by the number that the party offering it intends to use at trial. 4) A list of each party's witnesses; 5) A statement of disputes regarding requests to product individuals or items at trial, per Illinois Supreme Court Rule 237; 6) A copy of all applicable Rule 213 disclosure if opinion witnesses are to be presented; 7) Motions in limine; and 8) Copies of evidence depositions if there are objections requiring rulings.

WARNINGCivil cases

Applies to

Requests for admission

Parties must provide a list of Supreme Court Rule 216 requests for admission and responses.

A list of each party's Supreme Court Rule 216 Request for Admission of Facts and responses thereto, if any;

WARNINGCivil cases

Applies to

Transfer order

Parties must obtain a transfer order from Room 2005 before pretrial settlement conference.

Parties must first obtain an Order from Room 2005 transferring the case to Room 2407 for pre-trial purposes only.

WARNINGCivil cases

Applies to

Pretrial settlement order

After transfer order, parties must present a second order setting the pretrial date to chambers or clerk.

After the transfer order is entered, the parties must present a second order to the courtroom clerk or nichole.patton@cookcountyil.gov setting it for the agreed date and time assigned by the Judge.

WARNINGCivil cases

Applies to

Stipulations

Parties must provide any stipulations between them.

Any stipulations between the parties;

WARNINGCivil cases

Applies to

Evidence deposition transcripts

Parties must meet and confer on objections before submitting evidence deposition transcripts.

If evidence depositions are to be used, the parties must meet and confer with regards to objections before copies of transcripts are submitted to the Court;

WARNINGCivil cases

Applies to

Proposed order

Must include

proposed order

Bar attorneys must prepare all proposed orders (continuance, motion, and fee petition orders) and upload them into Sharepoint.

Bar attorneys are required to prepare all proposed orders, including continuance orders, orders on motions, and fee petition orders and upload them into Sharepoint.

WARNINGCivil cases

Applies to

Motion

Motions must include particularized supporting facts and legal authority, with copies of the cited legal authority attached.

The motion must state, with particularity, the supporting facts and legal authority upon which all arguments are based, with a copy of all such relevant legal authority attached.

WARNINGCivil cases

Applies to

Petition

Where multiple petitions are submitted, each petition may include only expenses attributable to the parties involved in that particular settlement.

In any case where more than one petition is submitted (i.e., where parties settle at different times during the litigation), only those expenses attributable to the parties involved in the particular settlement shall be included in each respective petition.

WARNINGCivil cases

Applies to

Petition and order of distribution

Expenses that are ambiguous as to task, purpose, or time spent are unrecoverable.

Expenses that that are indistinct in terms of the task performed, its purposes, or the time spent on the task are considered "ambiguous" and unrecoverable.

WARNINGCivil cases

Applies to

Voucher

Vouchers must evidence that funds were distributed as ordered and that claimed attorney expenses match costs actually paid.

In all settlements where the distribution of the proceeds is not supervised by the Probate Division, the plaintiff's attorney must, within 60 days of entry, file and submit to the settling judge vouchers evidencing that: 1) the funds have been distributed and received in accordance with the settlement order and 2) the attorney expenses claimed in the settlement order are consistent with costs actually paid.

WARNINGCivil cases

Applies to

Distribution order

The court shall exclude deductions for excessive, redundant, duplicative, or otherwise unnecessary expenses from distribution orders.

The court shall exclude from any distribution order deductions for expenses that are "excessive, redundant, duplicative, or otherwise unnecessary."

WARNINGCivil cases

Applies to

Distribution order

Prospective expenses are not recoverable in the Law Division or 1st Municipal Division, but an attorney may include specified language in the order to preserve recovery from the Probate estate.

Expenses that are prospective, such as expenses to be paid by the attorney subsequent to the entry of the settlement and distribution order, Probate filing fees, bond fees, etc., are not recoverable in the Law Division or the 1st Municipal Division. However, to ensure recovery of said expenses the attorney may include the following language in the order: "The Probate expense(s) claimed herein appear reasonable, however, reimbursement of the same must be obtained from the Probate estate."

WARNINGCivil cases

Applies to

Petition and order of distribution

Attorneys may not separately itemize and charge clients for overhead expenses.

An attorney cannot separately itemize and charge to the client expenses properly designated as overhead.

WARNINGCivil cases

Applies to

Summary judgment motion

Summary judgment motions cannot be filed after a trial date is set without leave of Court.

No motion for summary judgment may be filed once a trial date is set absent leave of Court.

WARNINGCivil cases

Applies to

Notice of motion

Notice of motion must include Courtroom, date, time, Zoom meeting ID, password, and call-in number.

All notices of motions shall provide the Courtroom, date, time, Zoom meeting ID, password and call-in number.

WARNINGCivil cases

Applies to

Scheduling order

Court will enter a Rule 218 Scheduling Order; parties must use the form order; Trial Setting Date will not be moved absent extraordinary circumstances.

The Court will enter a Rule 218 Scheduling Order in all appropriate cases. The Parties must utilize the form order, which can be found on the Court’s website. Note that the Court will enter a Trial Setting Date in most cases. The Trial Setting Date will not be moved absent extraordinary circumstances.

WARNINGCivil cases

Applies to

Discovery motion

Discovery motions must include a statement of efforts under Rule 201(k) and identify specific discovery items.

Discovery motions must contain a specific statement as to the efforts undertaken by the parties under Illinois Supreme Court Rule 201(k) and shall clearly identify the specific discovery items outstanding or sought to be compelled.

WARNINGCivil cases

Applies to

Notice of motion

The notice of motion should be marked "Special Routine" and indicate the time as 8:30 a.m.

The notice of motion should be marked "Special Routine" and indicate the time as 8:30 a.m.

WARNINGCivil cases

Applies to

Brief

Citations must include official Illinois Reporters; citing only the Northeastern Reporter is not acceptable.

Citations shall include citation to Official Illinois Reporters. Reference to the Northeastern Reporter, alone, is not acceptable.

WARNINGCivil cases

Applies to

Motion

An attorney's affidavit for attorneys' fees must state the nature of services, hours spent, hourly rate, year of law school graduation, and a statement that the hours and rate are fair and reasonable.

If attorneys' fees are recoverable, an affidavit from the attorney is necessary to establish the amount. The affidavit shall state: 1. the nature of the services performed; 2. the number of hours spent performing these services; 3. the attorney's hourly rate; 4. the year the attorney graduated from law school; 5. a statement that the number of hours spent and the rate charged per hour is fair and reasonable, and within the normal standards of the community for the type of services performed.

WARNINGCivil cases

Applies to

Pretrial memo

Plaintiff's counsel and all parties with claims must submit an updated pretrial memo covering issues, damages, settlement status, and other helpful information.

Plaintiff's counsel and counsel for all parties with claims shall submit an updated pretrial memo that sets forth the issues, damages, status of settlement negotiations and any additional information that will help the court hold a meaningful pretrial conference.

WARNINGCivil cases

Applies to

Motion

Affidavits in support of the relief sought in special routine default motions must be based on the affiant's personal knowledge.

Affidavits in support of relief sought must be based on personal knowledge of the affiant.

WARNINGCivil cases

Applies to

Trial materials

In bench trials, trial materials must include specified items (1,3,4,5,6,8,9).

In a Bench Trial, submitted materials must include item numbers 1, 3, 4, 5, 6, 8, and 9.

WARNINGCivil cases

Applies to

Motion

Motions affecting discovery must be accompanied by a copy of the last discovery and case management orders.

Any motion which affects discovery must be accompanied by a copy of the last discovery and case management order(s).

WARNINGCivil cases

Applies to

Filing

Must include

ai disclosure

AI use disclosure is not required for pleadings, but the use of AI in any other filing must be disclosed in writing on the submitted document.

Per the Illinois Supreme Court Policy on Artificial Intelligence, this Court does not require a party submitting any pleading to disclose the use of AI in the pleading's creation. However, use of AI in other filings must be disclosed in writing on the submitted document.

WARNINGCivil cases

Applies to

Motion in limine

Parties must provide written Motions in Limine to the Court; they are reciprocal unless specified.

Written Motions in Limine. Parties should provide a copy of these to the Court. Unless specified, all Motions in Limine are reciprocal.

WARNINGCivil cases

Applies to

Motion for substitution

Parties should use the provided standing order form to file with the Clerk.

Parties should use the provided standing order form to file with the Clerk.

WARNINGCivil cases

Parties must verify the existence and accuracy of every cited authority; failure to do so may result in sanctions.

Parties remain fully responsible for verifying the existence and accuracy of any authority cited. Failure to do so may result in sanctions.

WARNING

Applies to

Agreed dismissal order

If the dismissal is pursuant to settlement, please identify in the Order whether minors or Wrongful Death claims are involved.

If the dismissal is pursuant to settlement, please identify in the Order whether minors or Wrongful Death claims are involved.

WARNING

Applies to

Agreed trial certification order

Agreed Trial Certification Orders must use the most recent form, include agreed trial date within 14 days, and strike the actual Trial Cert date.

Please use the most recent form Order on the clerk's website and agree on a date in Room 2005 for trial setting within 14 days. Please also include in your Order the striking of the actual Trial Cert date in Room 2204.

WARNING

Applies to

Order transferring case for pretrial

For non-Calendar Z cases, parties must obtain an order transferring the case to Judge Saltouros for pre-trial.

For a case not on Calendar Z, the parties must obtain from Courtroom 2005 an Order transferring the case to Judge Saltouros for pre-trial only.

WARNINGCivil cases

Applies to

Cover letter

Must include

case number

The courtesy copy submission must include a cover letter with the case name, case number, and date and time of the clerk status.

with an accompanying cover letter containing the case name, the case number and the date and time of the clerk status.

WARNING

Applies to

Motion

Must include

proposed order

These matters may be entered off call. Please provide a proposed order to accompany the filed motion and request for entry via email.

These matters may be entered off call. Please provide a proposed order to accompany the filed motion and request for entry via email.

WARNING

Applies to

Pretrial memorandum

Pre-trial memoranda should include a short statement of the issues, the damages, the status of settlement negotiations, and any additional helpful information.

The memoranda should include a short statement of the issues, the damages, the status of settlement negotiations, and any additional information which will help the court hold a meaningful settlement conference.

WARNING

Applies to

Trial materials

Trial materials must include estimated trial days, statement of the case, witness list, stipulations, motions in limine, and evidence depositions.

The following information and documents shall be delivered: (A) Estimated number of trial days (B) Statement of the case (C) Witness list (D) Stipulations (E) Motions in Limine (F) Evidence depositions

WARNING

Applies to

Affidavit

A prove-up affidavit must set forth the foundation for any attached document and establish the document's admissibility if offered for its truth.

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

WARNING

Applies to

Affidavit

A prove-up affidavit must state whether it is grounded on personal knowledge, attached documents, or both, and explain how the affiant knows the facts.

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.

WARNING

Applies to

Proposed order

Parties must tender a draft order granting permission to bring trial equipment into the building.

Please tender a draft order granting permission to bring equipment into the building for the court's consideration.

WARNING

Applies to

Business record

A business record must be accompanied by a certification that it was made at or near the time of the occurrence by a person with knowledge, kept in the regular course of business, and made regularly.

A record of regularly conducted shall be accompanied by a certification that it (1) was made at or near the time of the occurrence of the matters set forth by a person with knowledge of these matters, (2) the document was kept in the regular course of business, and (3) was made regularly.

WARNING

Applies to

Clerk status packet

Must include

case number

At clerk status, the movant must deliver copies of all briefs, pleadings, relevant documents, and the most recent complaint with a cover letter stating the case name, case number, and date/time of the clerk status.

At the clerk status, the movant is obligated to deliver copies of all the briefs, pleadings, relevant documents and the most recent complaint, with an accompanying cover letter containing the case name, the case number, date and time of the clerk status, and

WARNING

Applies to

Proposed order

Must include

proposed order

Orders tendered via Zoom must be provided in both PDF and Word formats within one hour of the court appearance, or the court may enter its own order.

Orders tendered for the court's consideration shall be tendered in both PDF and Word formats within the hour of court appearance when appearing via Zoom or the court may enter its own.

WARNING

Applies to

Agreed dismissal order

Settled parties should tender an agreed dismissal order to retain jurisdiction to enforce the settlement and strike all upcoming court dates, specifying the dates in the order.

If the parties have settled and agree on the material terms, please tender an agreed dismissal order with the court to retain jurisdiction to enforce the settlement. Please also strike any and all upcoming dates (specify the court date(s) in the order).

WARNING

Applies to

Trial materials

Trial materials must include exhibit lists/exhibits, Ill. S. Ct. R. 213 disclosures, identification of objects and demonstrative evidence, and, when appropriate, a short trial brief.

(G) Exhibit lists and/or Exhibits (H)Ill. S. Ct. R. 213 disclosures (I) Identification of objects and demonstrative evidence to be used at trial (photographs, slides, pictures, videotapes, exhibition of injuries, and courtroom demonstrations) (J) When appropriate, short trial brief with attention to primary contested issues of fact, unusual issues of law and authority;

WARNING

Applies to

Default judgment

In collection cases, the plaintiff must submit a ledger accompanied by an affidavit establishing that it is a business record.

In collection cases, the plaintiff shall submit a ledger accompanied by an affidavit establishing that it is a business record.

WARNING

Applies to

Attorney fees affidavit

An attorney's fee award requires an affidavit establishing reasonableness based on seven listed factors, with contemporaneous billing records attached that provide detailed entry descriptions of services, provider, duration, and hourly rate.

An affidavit shall establish the reasonableness of the amount sought. It must include: (1) the skill and standing of the attorneys, (2) the nature of the case and the novelty and/or difficulty of the issues and work involved, (3) the value and importance of the matter, (4) the degree of responsibility required, (5) the usual and customary charges for comparable services, (6) the benefit to the client, and (7) whether there is a reasonable connection between the fees and the amount involved in the litigation.4 Contemporaneous billing records shall be attached. The records must provide detailed billing entry descriptions specifying the services performed, who performed it, how long it took, and the hourly rate charged using facts based on contemporaneous time records.