Circuit Court of Cook County Pre-Motion Conference Requirements

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

Source text: 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.

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

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

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

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

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.

Source text: 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.

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.

Source text: 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.

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

Source text: 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.

Source text: 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.

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

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

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

Source text: 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.

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

Source text: 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.

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

Source text: 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.

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

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

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

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

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

Source text: 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.

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.

Source text: 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.

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

Source text: 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.

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

Source text: 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.

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

Source text: 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.

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

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

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

Source text: 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.

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

Source text: 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.

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

Source text: 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.

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.

Source text: 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.

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

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

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

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

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

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

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

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

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

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

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

Source text: 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.

Briefing schedules are not provided for all motions.

Source text: Briefing schedules will not be given in all motions.

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.

Source text: 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.

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

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