Circuit Court of Cook County Pre-Motion Conference Requirements

A motion to exceed brief page limits must be filed before the brief's filing deadline.

Motions to file a brief in excess of these limitations must be filed in advance of the filing deadline.

Parties must confer meaningfully under Supreme Court Rule 201(k) before bringing any discovery dispute to court.

Before bringing any discovery dispute to the Court, the parties must confer meaningfully under Supreme Court Rule 201(k).

Motions to consolidate must be presented on the Presiding Judge of the Chancery Division’s calendar.

Motions to consolidate such motions are heard only by the Presiding Judge of the Chancery Division and must be presented on the Presiding Judge’s calendar.

Reply briefs for 2-615, 2-619, 2-622, and discovery motions require specific leave of court.

If briefing is necessary on such motions, the court will not entertain reply briefs without specific leave of court.

Reply briefs for §2-615, §2-619, §2-622, and motions to compel require specific leave of court.

Briefing on §2-615, §2-619, and §2-622 Motions, and Motions to Compel. If the Court determines that briefing is necessary, it will not entertain reply briefs without specific leave of court.

Emergency motions require presenting a copy to court staff for approval before scheduling, and must comply with local Rule 2.2.

Notice of emergency motions must comply, with local Rule 2.2 and a copy of the motion must first be presented to Court’s staff for approval before being scheduled for hearing.

Sur-replies are only permitted with court approval via a written motion.

A sur-response or sur-reply will be allowed only if the Court deems it necessary, and a party makes such a request by written motion.

Only the listed motion types are considered routine and eligible for email submission without a court appearance.

The Court will only consider the following motions as 'routine': i. Motions for leave to file an appearance, answer, or a motion; ii. Motions to appoint special process server (notice not required); iii. Agreed orders to extend time to file pleadings or briefs, continue of a court date, or amend a briefing schedule; iv. Agreed dismissal orders; and v. Motions for voluntary dismissal of a citation or proceeding.

Emergency motions must meet two criteria, be scheduled with the coordinator, and include specified documents submitted to the law clerk via email.

Emergency Motions must be scheduled with the Court Coordinator Johan Townsend at Johan.Townsend@cookcountyil.gov. The movant shall present the motion, relevant pleadings, attachments, affidavit(s) and complaint stating the basis for the emergency to the law clerk via email. If the matter is a true emergency, an immediate hearing date will be set and movant shall provide notice to the opposing parties or their counsel. 1) there was no opportunity to notice a motion for the regular motion call; and, 2) without immediate court action, there will be irreparable damage to a party. Matters that have become urgent by reason of a party's failure to seek timely relief are not emergencies and will not be scheduled as an emergency.

All motions are presented only on CMC dates; if no CMC date is set, they are heard on the Regular Motion Call.

All motions, including motions to compel discovery, are to be presented ONLY on case management conference (CMC) dates. If a CMC date has not been set, motions can be heard on the Regular Motion Call.

Motions to modify, vacate, alter, or extend CMC orders are only heard on CMC dates, not Regular or Emergency Motion Calls.

All motions to modify, vacate, alter, or extend CMC orders must be brought ONLY on CMC dates, not on the Regular or Emergency Motion Calls.

No briefing schedules for specified motions; continue to a day when the judge is present.

There are NO briefing schedules on: a) motions to dismiss under 2-615; b) motions to dismiss under 2-622; c) motions to compel discovery; d) motions for rulings on objections to discovery; and e) motions for rulings on certified deposition questions. Please continue these motions to a day when the judge is present.

Court screens for 191 discovery in summary judgment and 2-619 motions; if needed, case is continued to status date with order stating specific discovery.

On summary judgment motions and 2-619 motions, the court will screen for 191 discovery, If such discovery is necessary, the case will be continued to a future status date to allow for the completion of that discovery and the order will state what specific discovery is needed.

Emergency motions are signed up at 8:45 AM, heard at 9:00 AM; must be true emergencies, else heard on Regular Motion Call.

Emergency motions are to be signed up at 8:45 AM by the responsible attorney. They are heard at 9:00 AM. All responsible attorneys are to be present at that time. The motion must be a true emergency or it will not be heard; non-emergency motions will have to be spindled on the Regular Motion Call. As a general rule, an emergency is some circumstance which could lead to irreparable damage to a party if relief is not obtained prior to the time a party can be heard on the court’s Regular Motion Call. Motions to extend or compel discovery are not ordinarily emergencies.

Routine motions are held in the courtroom unless noted otherwise on the courtroom door.

Routine motions are ALWAYS done in the courtroom unless otherwise noted on the courtroom door.

Focus case management conferences are held on Wednesdays at 11:00 AM.

Focus case management conferences will be heard on Wednesdays at 11:00 AM.

Regular motions must be spindled for the 9:30 a.m. call or piggybacked on a pre-scheduled date; piggybacking requires filing and courtesy copies two full court dates before presentment.

Regular motions must be spindled and set for presentment on Judge Reilly’s 9:30 a.m. call through the Clerk’s Office. Alternatively, motions may be “piggybacked” onto a pre-scheduled date set by court order or onto a properly spindled motion presentment date. In order to piggyback any motion, the movant must file and provide courtesy copies to the Court at least two (2) full court dates before the presentment date. Failure to properly spindle or piggyback a motion, may result in the Court striking the motion or refusing to hear the motion and requiring the movant to spindle the motion onto the Court’s regular motion call.

Emergency motions must be labeled “Emergency”, include a specific showing of emergency, and have file-stamped copies submitted by 3:00 p.m. the day before presentment.

Procedure: A party must submit a file-stamped copy of the emergency motion, any exhibits, and the complaint setting forth the underlying cause of action to the Court and request a hearing no later than 3:00 p.m. on the day preceding presentment. The motion must be labeled “Emergency” and contain a specific showing of why the motion is an emergency.

Settlement conferences require a party with settlement authority to be present.

The Court will not conduct a conference unless someone who has authority to settle the case is present.

Routine motions do not require a court appearance; motions and draft orders must be emailed to the Court Coordinator at least two court days before entry.

Routine motions will be accepted and do not require a court appearance. Motions should be emailed to Melissa.robbins@cookcountyil.gov and the draft order should be emailed to Melissa.robbins@cookcountyil.gov at least two court days before the order will be entered by this Court.

Only the listed motion types are considered routine motions exempt from appearance requirements.

The Court will only consider the following motions as “routine”: 1. Motions for leave to file an appearance, answer, or a motion; 2. Motions to appoint special process server (notice not required); 3. Agreed orders to extend time to file pleadings or briefs, continue of a court date, or amend a briefing schedule; 4. Agreed dismissal orders; and 5. Motions for voluntary dismissal.

Emergency motions must be scheduled with the Court Coordinator; movant must submit all supporting documents to the law clerk via email.

Emergency Motions must be scheduled with the Court Coordinator at Melissa.robbins@cookcountyil.gov. The movant shall present the motion, relevant pleadings, attachments, affidavit(s) and complaint stating the basis for the emergency to the law clerk via email.

Sur-replies are only permitted with court approval via written motion.

A sur-response or sur-reply will be allowed only if the Court deems it necessary, and a party makes such a request by written motion.

Non-routine motions must be scheduled with the Court Coordinator or via e-filing.

All other motions must be scheduled either with the Court Coordinator or through E-Filing.

Parties must exchange good faith written offers and demands before a settlement conference is scheduled.

Before a Settlement Conference will be scheduled, the parties are required to exchange good faith offers and demands in writing.

Contested motion hearings require in-person appearance in Courtroom 2004.

Contested Motion Hearings: Parties must appear in person in Courtroom 2004.

Parties must inquire with the court prior to filing a summary judgment motion.

Parties, however, should always inquire with the Court prior to filing a summary judgment motion.

Prior leave of court is required before filing a motion to dismiss under 735 ILCS 5/2-619.1; leave may be requested orally.

The Court will not hear motions to dismiss under 735 ILCS 5/2-619.1, without prior leave of court. Such motions for leave to file can be made orally. Failure to seek leave to file may lead to the motion being struck from the call, and the Movant will need to re-spindle the motion to be presented on another day, or other sanction.

Parties must confer meaningfully under Supreme Court Rule 201(k) before bringing any discovery dispute to the Court.

Before bringing any discovery dispute to the Court, the parties must confer meaningfully under Supreme Court Rule 201(k).

Emergency motions must be presented to Court's staff for approval before being scheduled for hearing.

Notice of emergency motions must comply, with local Rule 2.2 and a copy of the motion must first be presented to Court’s staff for approval before being scheduled for hearing.

Piggy-backing a motion onto an existing hearing requires prior leave of the law clerk, courtesy copies, and proper notice of the motion to all parties.

A party may present a motion on a date and at a time previously scheduled for the presentment of another motion or at a hearing (previously scheduled) ('piggy-backing') only after obtaining leave from the law clerk, providing courtesy copies, and giving proper notice of the motion to all parties entitled to notice.

Dispositive motions must be presented no later than 90 days before trial unless otherwise ordered.

Unless otherwise specified by order, dispositive motions shall be presented no later than 90 days before the trial date.

Default judgment may not be entered before case management is stricken, and motions for default judgment may not be noticed before continued case management.

No Default Judgments may be entered prior to case management being stricken by the court. This shall apply to residential and commercial properties. Noticing up motions for judgment prior to continued case management is strictly prohibited.

Sur-replies are not permitted.

No surreplies will be permitted.

Dispositive motions must be presented at least 90 days before trial unless otherwise ordered.

Unless otherwise specified by order, dispositive motions shall be presented no later than 90 days before the trial date.

Parties must always inquire with the Court before filing a summary judgment motion.

Parties, however, should always inquire with the Court prior to filing a summary judgment motion.

Opposing party must serve a written response to a motion in limine within 10 days.

If any motion in limine is served, the opposing party must serve a written response within ten (10) days. Any such response shall become a part of the trial material.

Emergency motions must include a proposed Order, state grounds, provide at least 24 hours notice to other parties, and be presented at 9:30 am.

Emergency Motions, with a proposed Order, must be submitted to law.calHcc@cookcountyil.gov or dropped off in 2209 and include the grounds for the emergency. Emergency motions must provide at least 24 hours to other parties who have appeared, absent an exigent circumstance where such Notice cannot be provided. Emergency Motions will be noticed and presented at 9:30 am.

Emergency motions must be filed and scheduled with the Court Coordinator for Calendar 14N.

Must be filed and scheduled with the Court Coordinator for Cal. 14N

Contested motions require a briefing schedule including a Clerk's Status date; Clerk's Status is held via Zoom on Wednesdays at 9:00 AM; hearing date set at Clerk's Status; motion stricken if movant fails to appear.

Parties may provide the briefing schedule in their proposed orders. The Court’s form order may also be used for a briefing schedule on a contested motion. The briefing schedule shall include a date for Clerk’s Status. At the Clerk’s Status, held at 9:00 a.m. on Wednesdays via Zoom, a hearing date on the motion will be set. It is imperative that the parties appearing at the Clerk’s Status have the responsible counsel’s availability for the hearing date. Prior to the Clerk’s Status, the movant shall provide the Court with electronic and physical courtesy copies of all relevant pleadings, papers, and substantive case law. This includes a copy of the operative complaint or petition, with exhibits. The motion will be stricken if the movant fails to appear for the Clerk’s Status.

Piggy-backing requires leave from a law clerk and proper notice; dispositive motions cannot be piggy-backed if the hearing is less than 14 days away.

A party may present a motion on a date and at a time previously scheduled for the presentment of another motion or at a hearing ('piggy-backing') only after obtaining leave from one of the Court's law clerks, providing courtesy copies, and giving proper notice of the motion to all parties entitled to notice. In the interest of fairness, piggy-backing of dispositive motions to existing hearing dates will generally not be permitted if the scheduled hearing date is less than 14 days from the date one of the Court's law clerks is contacted.

Cases set for trial or three years old or older are ineligible for routine motion procedure.

Cases set for trial and cases three years old or older are not eligible for routine motions.

Motions in limine must be discussed between counsel in advance of the pre-trial conference.

Motions in limine must be discussed between and among counsel in advance of the pre-trial conference to ensure that the motions remaining are those that the parties in good faith cannot resolve before trial.

Required

Always

Parties must confer before every virtual status hearing and motion presentment.

The Court will assume parties have conferred before every virtual status hearing and motion presentment.

Required

Always

Parties must confer with each other before every virtual status hearing and motion presentment; the Court assumes they have done so.

The Court will assume parties have conferred before every virtual status hearing and motion presentment.

To schedule a settlement conference, confer with opposing counsel, email 2-3 suggested dates to the court email, include case name and number, and copy all counsel.

To schedule a settlement conference, confer with opposing counsel and then email the Court at ccc.lawcr2303@cookcountyil.gov with 2 or 3 suggested dates. The case must be pending in the Law Division. Please include the case name and number. Copy all counsel of record. The judge will select the first available date.

Piggy-back a case of dispositive motions onto an existing hearing generally not allowed if the scheduled hearing is less than 14 days from contacting the law clerk.

In the interest of fairness, piggy-backing of dispositive motions to existing hearing dates will generally not be permitted if the scheduled hearing date is less than 14 days from the date the law clerk is contacted.

Transfer requests must be presented on call and will not be approved off call.

Transfer requests will not be approved or entered off call.

The briefing order sets deadlines for the response and the reply in contested motion briefing.

1. The Response of_________________ is due _______________; 2. The Reply of ___________________ is due ________________;

Briefing schedules are unlikely for non-dispositive motions; parties should expect to argue and receive a ruling on the presentment date.

Briefing schedules on any motions that are not potentially dispositive are unlikely to be granted, and the parties should expect to argue such a motion on the date of presentment and receive a ruling that day.

No briefing for §2-615 and §2-622 motions; movant must describe deficiencies and provide pleadings; respondent may submit a response at Court's discretion.

There will generally be no briefing allowed for §2-615 and §2-622 motions. The movant shall succinctly describe alleged deficiencies in the complaint, or the §2-622 Affidavit/report, and shall provide a copy of the pleadings for the court's review. The respondent may be allowed to submit a written response, but only at the Court's discretion.

For contested motions, the court sets a briefing schedule; oral argument is only set upon request and court agreement.

The court will set a briefing schedule on presented contested motions. Oral argument will not be set unless requested by a party and agreed to by the court.

Briefing schedules are not provided for all motions.

Briefing schedules will not be given in all motions.

Initial CMCs are held Wednesdays at 9:30am; FCMCs are held Wednesdays at 10:00am, 10:30am, and 11:00am.

Initial Case Management Conferences [CMC’s] are set for Wednesdays at 9:30 am. Focused Case Management Conferences [FCMC’s] are set for 10:00 am, 10:30 am and 11:00 am.

Oral argument is available upon request, held at 11:30 AM, 1:30 PM, 2:00 PM, or 2:30 PM.

Oral argument is available if requested. Oral arguments are heard at 11:30 AM, 1:30 PM, 2:00 PM, and 2:30 PM.

Pre-trial conferences available 12 PM–3 PM daily, held only if offer made and parties with authority are available; pre-trial memorandums are optional.

The judge is available for pre-trial conferences every afternoon at 12:00 PM — 3:00 PM depending on the court’s scheduled hearings. The clerk will know what times are available. A pre-trial conference will only be held if: 1) an offer has been made; and 2) parties with authority must be available in person or by phone. Pre-trial memorandums are optional.

The Court will generally schedule oral argument for any briefed motion.

For any briefed motion, the Court will generally set the matter for oral argument.

The Court will set a hearing or ruling date after it receives the courtesy copies.

5. Upon receipt of courtesy copies, the Court will enter a date for hearing or ruling.

Routine motions may be submitted with a proposed order for entry off call.

Routine motions may be submitted for entry outside the Court’s regular calls. The following motions are considered routine and may be submitted with a proposed order for entry off call: