Circuit Court of Cook County Document Filing Requirements

INFOCivil cases

Applies to

Disclosure

Product identification and exposure witness disclosures must be consistent with Rule 213(f)(1) and this Order.

Product identification and exposure witness disclosures shall be consistent with the requirements of Supreme Court Rule 213 (f)(1) and as specified by this Order.

INFOCivil cases

Applies to

Interrogatory answers

Answers to interrogatories and disclosures must specify detailed witness information regarding exposure testimony.

With respect to witnesses expected to testify on issues of product exposure or premises exposure or product identification, answers to interrogatories and disclosures shall specify the defendant(s) against which the witness' testimony will be offered; the product(s) about which the witness will testify; the job site(s) about which the witness will testify; the time frame(s) about which the witness will testify; whether the witness is represented by counsel; and if so, the identity of counsel; and if not represented by counsel, a current and accurate address for the witness.

INFO

Applies to

Case management order

The Court will enter a Case Management Order on the earliest practical date.

The Court will enter a Case Management Order on the earliest practical date

INFOCivil cases

Applies to

Motion

Must include

proposed order

A proposed order should be submitted with routine motions.

For routine motions, please submit a proposed order.

INFOCivil cases

Applies to

Motion to reconsider

No oral argument on motions to reconsider unless requested by the Court.

No oral argument will be heard unless requested by the Court.

INFO

Applies to

Default judgment

The court awards costs without stating a dollar amount, using language such as 'plus costs,' because more costs may accrue post-judgment.

The court shall award "costs" without a stating a dollar amount because more costs may accrue post judgment; e.g., "The court enters a default judgement in favor of Acme, Inc., and against Jones, Inc., in the amount of $222,222.00 plus costs."

CRITICAL

A TRO motion must be accompanied by a verified complaint or an affidavit compliant with the cited statute.

Motions for TRO MUST be accompanied by a verified complaint or affidavit in compliance with Section 11-101 of the Illinois Code of Civil Procedure.

CRITICALCivil cases

Attorney fee affidavits must establish reasonableness of the amount sought and include the specific reasonableness factors listed.

4. Attorney's Fees. 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 and a reasonable connection between the fees and the amount involved in the litigation.

CRITICALCivil cases

Applies to

Prove up documents

Default judgment packages must include, in addition to the Uniform Standing Order requirements, an affidavit of proof of service on defendants, an affidavit of damages with business ledger, and an affidavit of attorney's fees of preparation with actual costs.

In addition to the requirements for the Continuing Compliance with the Uniform Uniform Standing Order for All Commercial Calendars you must tender the prove-up documents: (a) declaration with a certificate of service showing service and compliance of the defendant(s); (b) declaration of damages which includes a business ledger establishing the amount due; and (c) declaration of attorney’s fees with contemporaneous billing records showing data and charges. Failure to provide the court with a complete set of courtesy copies may result in the motion being stricken.

CRITICALCivil cases

Applies to

Proposed order

For the Claims Call (remote), any required proposed order must be emailed to the Clerk within one hour after the appearance.

Within one hour after rough appearance, any required proposed order shall be emailed to the Clerk of probated. Unrequired orders shall be emailed within one hour after the Claim Call appearance.

CRITICALCivil cases

Applies to

Proposed order

For a court appearance, any required proposed order must be emailed to the Clerk by the morning after the hearing.

By the morning after the hearing, any required proposed order shall be emailed* to the Clerk's at the email below.

CRITICALCivil cases

Default-motion email must include the notice, summons, motion, an attorney certification of no appearance/answer, and a military affidavit if against a person.

The Court requires an email to with the following two documents: (i) The notice, summons showing service, and motion; (ii) An attorney’s signed and certified statement that the Clerk’s electronic docket indicates that the defendant has not filed an appearance or answer; and (iii) A military affidavit, if the default is against a person.

CRITICALCivil cases

Applies to

Discovery motion

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

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

CRITICALCivil cases

Applies to

Petition to approve settlement

Petitions to Approve Settlement must follow Local Rule 12.15 and include the prior approval order, an attorney report, accident reports, medical records, a treating physician letter, and certain insurance documents when applicable.

2. Petition to Approve Settlement: a. Please see Local Rule 12.15; b. If the settlement has been approved by another court, include a copy of the order approving settlement; c. If the proposed settlement has not been approved by another court, include a report by counsel, accident reports, medical records, a treating physician’s report of the minor’s treatment and prognosis, and, when the settlement is based on insurance policy limits or uninsured motorist coverage, a copy of the insurance declarations page.

CRITICAL

Settled cases involving minors, disabled persons, and survival/wrongful death claims must use the appropriate form order dismissing the case for Court approval, set as a date certain, to avoid losing jurisdiction after 30 days.

Once settled, cases involving minors, disabled persons, and survival and wrongful death claims should be denied and re-ordered appropriately under the Court to retain jurisdiction for approval and set for a definite date to avoid the Court losing jurisdiction after 30 days.

CRITICALCivil cases

Applies to

Motion

Motions under §2-615 and §2-622 require attached pleadings and typically do not receive briefing schedules.

Typically, briefing schedules will not be entered for motions brought pursuant to §2-615 and §2-622. A copy of the pleadings must be attached to the motion.

CRITICALCivil cases

Discovery motions must include a statement certifying personal consultation and reasonable attempts to resolve disputes, per Illinois Supreme Court Rule 201(k).

Prior to bringing a motion related to discovery, the parties shall strictly adhere to Illinois Supreme Court Rule 201(k), which provides: The parties shall facilitate discovery under these rules and shall make reasonable attempts to resolve differences over discovery. Every motion with respect to discovery shall incorporate a statement that counsel responsible for trial of the case after personal consultation and reasonable attempts to resolve differences have been unable to reach an accord or that opposing counsel made himself or herself unavailable for personal consultation or was unreasonable in attempts to resolve differences.

CRITICAL

TRO motions must be accompanied by a verified complaint or affidavit.

Motions for TRO MUST be accompanied by a verified complaint or affidavit in compliance with Section 11-101 of the Illinois Code of Civil Procedure.

CRITICALCivil cases

Applies to

Proposed agreed order

Proposed agreed orders must be emailed in Word format to chambers with case info in subject line, copying all parties, and followed by a phone call to the case coordinator.

Proposed agreed orders may be submitted electronically. Proposed agreed orders are not to be filed. Rather, they are to be submitted to the judge to consider, to modify, if appropriate, and to enter. For example, proposed agreed orders such as stipulated protective orders require court approval before actually being given full effect. Proposed agreed orders must be attached to an e-mail sent to following e-mail address: law.calscc@cookcountyil.gov. The subject line of the e-mail must include the case number and name, and the title of the order that is proposed. All such documents must be submitted in Microsoft Word format (.docx or .doc). All other parties to the case must be copied on the email. Please advise the court's case coordinator by phone (312-603-5923) after submitting a proposed agreed order.

CRITICALCivil cases

Applies to

Dismissal order

Agreed orders that resolve an entire case must include language striking future court deadlines and identify the specific future dates.

If your agreed order resolves the entire case, the dismissal order must contain language allowing the striking of future dates, specifying which specific future dates are to be stricken.

CRITICALCivil cases

In non-eviction cases, after the initial appearance, parties must transmit Intake and SCR 2188 Case Management Order (CCM 0703) reflecting their agreement on all specified items.

For cases other than eviction, after the initial appearance, the parties must submit an Intake and SCR 97 Case Management Order (CCM 0703) containing their agreement on all specified items, as applicable.

CRITICAL

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.

CRITICALCivil cases

Applies to

Order

No Supreme Court Rule 304(a) appealability language may appear in any order without the judge's advance express approval.

No ISCR 304(a) language may be included in any order without prior express judicial authorization.

CRITICALCivil cases

Must include

proposed order

Every motion must include a proposed mandatory order; otherwise it will not be ruled on.

Movant must include a proposed order as a court order, absence of such an order. The document will not be ruled on.

CRITICALCivil cases

When a case is assigned for trial, attorneys must provide the court in hard copy the complaint, counter-claims and answers, an agreed statement of the case, witness list, exhibit lists, motions in limine, SCR 213 discovery materials, evidence deposition transcripts, stipulations, jury instructions, and trial attorney business cards.

When a case is assigned to Judge Cushing for trial, attorneys shall provide the court the following in hard copy: 1) The current complaint, counter-claims and answers; 2) An agreed statement of the case: a non-argumentative, general statement of the plaintiff's theory of recovery and defendant's denials and counterclaims; 3) An inclusive list of witnesses and names of all trial attorneys; 4) Exhibit lists; 5) Motions in limine; 6) All answers to SCR 213 interrogatories and discovery deposition transcripts of all 213(f)(2) and (3) witnesses; 7) All evidence deposition transcripts with objections requiring the court's rulings highlighted, along with a list of pages where those objections can be found; 8) Any stipulations reached by the parties, and notice of any special accommodations required by a party, witness or counsel; 9) Jury instructions, marked and clean; 10) Business cards or letter head containing the names, addresses and phone numbers for each trial attorney.

WARNINGCivil cases

A trial continuance motion based on an unavailable material witness must include a copy of the served subpoena.

If the party is unavailable, a copy of the executed subpoena must be included.

WARNING

Name-change petitions must be signed and certified.

The petition must be signed and certified for a non-prosecutor.

WARNINGCivil cases

Sur-reply and sur-response briefs require leave of Court based on a written motion showing good cause; agreed orders permitting them are not accepted.

Sur-reply and sur-response briefs are discouraged and will not be accepted without leave of Court upon written motion containing good cause. Agreed orders allowing for the filing of sur-replies will not be accepted.

WARNINGCivil cases

Proposed orders must identify which parties appeared, state the appearance date, and, for remote appearances, include Zoom information unless otherwise ordered.

The Court requests that the parties include the following information for remote appearances: Identify the parties who appeared and did not appear. State the date of the appearance.

WARNING

For jury trials, parties must prepare a complete package including the jury voir dire statement, trial time estimate, witness list, unanimity stipulation statement, motions in limine, trial briefs, I.P.I.-numbered jury instructions, exhibit objections, Rule 237 requests, excerpts of evidence, Rule 213(f)(1-3) disclosures, and final pleadings.

Jury Trials. 1. Concise statement of the case to be read to the jury in voir dire; 2. Estimate of the number of trial days; 3. Witness list to be read to the jury in voir dire; 4. Statement that the party will/will not stipulate to a unanimous verdict of 10 or more jurors; 5. Motions in limine; 6. Trial briefs; 7. Jury instructions with I.P.I. numbers (each instruction marked 'Agreed' or 'Objected To') and compliance with Supreme Court Rule 239(c); to exhibits. Failure to submit and note objections may cause the objections to be waived; 9. Requests to Produce at Trial (Supreme Court Rule 237) must be prepared and delivered to the Court seven days before the final authority; 10. Evidence depositions, 11. Rule 213(f)(1-3) disclosures, and 12. Final pleadings, including: the complaint, answer, counterclaims, affirmative defenses, answers to requests to admit and other relevant pleadings.

WARNING

If the mortgagor is deceased, the plaintiff must obtain appointment of a special representative under the cited authorities.

(c) If the mortgagor(s) is/are deceased, then the plaintiff must have a special representative appointed in accordance with 735 ILCS 15/15-1501, Illinois Supreme Court Rule 113(i), and General Administrative Order No. 2015-02.

WARNINGCivil cases

Pre-trial materials must include a statement of the case, witness/party/attorney lists, exhibit list, motions in limine, proposed jury instructions, and any relevant documentary evidence.

Pre-trial materials include the following: i. Agreed statement of the case or each party's proposed statement, if not agreed; ii. List of all potential witnesses, parties, and attorneys; iii. Exhibit list; iv. Motions in limine; v. Proposed jury instructions: one marked set (identifying the party offering each instruction and the appropriate IPI citation), and one unmarked or "clean" set; vi. Evidence deposition transcripts, if applicable, with marking and submissions/instructions to the Court's resolution.

WARNINGCivil cases

Applies to

Discovery motion

Discovery motions must state the attorney's actual efforts at consultation and attempts to resolve discovery disputes under Rule 201(k), or the motion may be hounded.

All discovery motions must explain the attorney’s actual efforts at personal consultation and reasonable attempts to resolve differences with opposing counsel, in accordance with the Federal Rules (k, 1. F), (Rule 201(k)). Failure to comply with Rule 201(k) will result in the motion being stricken.

WARNINGCivil cases

Case law should not be provided with the courtesy copy unless it is unavailable through any format of LEXIS.

Case law should be made unless it is not available through a public available or inapplicable format.

WARNINGCivil cases

The movant filing an emergency motion must have an appearance of record on file.

The emergency reason must have an appearance on file.

INFOCivil cases

Applies to

Motion to strike

Motions to strike briefs, or portions of briefs, are decided together with the underlying motion.

Motions to Strike in, or portions thereof, the briefs will be taken way with the Court with the motion.