3rd Judicial Circuit Court, Madison County, Illinois Filing Timing and Cure Windows

WARNINGCivil cases

A party may supplement its exhibit list fewer than 14 days before trial if the document was recently obtained, produced in discovery by the opposing party, or improperly withheld in discovery.

Additionally, a party may supplement its exhibit list less than fourteen (14) days before trial under the following circumstances: - (a) Where the document was obtained from another fewer than fourteen (14) days before trial; - (b) Where the document was produced in discovery to the party offering it by the party against which it is offered; - (c) Where the document was improperly withheld in discovery by the party against which it is offered.

WARNINGCivil cases

A party may supplement its exhibit list less than 14 days before trial only if the document was recently obtained, produced in discovery by the opposing party, or improperly withheld in discovery by that party.

Additionally, a party may supplement its exhibit list less than fourteen (14) days before trial under the following circumstances: (a) Where the document was obtained from another fewer than fourteen (14) days before trial; (b) Where the document was produced in discovery to the party offering it by the party against which it is offered; (c) Where the document was improperly withheld in discovery by the party against which it is offered.

WARNINGCivil cases

Parties should attempt to assert challenges to the Standing Order well in advance of trial.

Parties should attempt to assert any challenges they might have to this Standing Order well in advance of trial.

WARNINGCivil cases

In a mesothelioma case, upon any defendant’s request, depositions of known co-workers must be completed 90 days before trial, while the plaintiff may discover and tender co-workers until 60 days before trial.

In cases alleging mesothelioma, upon request by any defendant, one or more of the following adjustments to the above schedule shall be made: (c) that depositions of known co-workers be completed 90 days prior to trial (but plaintiff will have until 60 days before trial to discover and tender co-workers);

WARNINGCivil cases

Forum non conveniens motions should be timed to allow discovery; their timing is presumptively reasonable when first noticed for hearing at least 60 days before trial and presumptively unreasonable when first noticed less than 60 days before trial.

reasonable time prior to the date set for trial and so as to allow sufficient time to conduct discovery on forum issues, as required by Rule 187(b). The timing of the motion for forum non conveniens shall be presumptively reasonable where it is first noticed for hearing to be held 60 days or more before trial. The timing of the motion for forum non conveniens shall be presumptively unreasonable where any forum non conveniens motion is first noticed for hearing to be held less than 60 days before trial.

WARNINGCivil cases

A party intending to use prior deposition testimony as substantive trial evidence must provide opposing counsel a list of the depositions it intends to use, unless the stated master-designation exception applies, by 60 days before trial.

(ii) Any party seeking to use any portion of a prior deposition as substantive evidence at trial shall provide opposing counsel with a listing of the depositions it intends to use unless a master deposition designation was filed as provided in Section II.A.1(b)ii above;

WARNINGCivil cases

In a mesothelioma case, upon any defendant’s request, defendants must provide expert reports by 75 days before trial and tender expert witnesses for deposition by 60 days before trial; both deadlines extend by the same period if the plaintiff tenders co-workers later than 90 days before trial.

In cases alleging mesothelioma, upon request by any defendant, one or more of the following adjustments to the above schedule shall be made: (d) defendants shall provide expert reports no later than 75 days prior to trial and tender their expert witnesses for deposition no later than 60 days prior to trial. In the event the plaintiff tenders coworkers later than 90 days prior to trial under the provision in paragraph (c) above, the deadlines contained in this paragraph shall be extended the same period of time.

WARNINGCivil cases

In cases alleging mesothelioma, upon request by any defendant, one or more of the following adjustments to the above schedule shall be made: (a) that x-rays, tissue blocks, slides and other pathology in plaintiffs' possession which Plaintiffs intend to use at trial be provided 150 days prior to trial;

In cases alleging mesothelioma, upon request by any defendant, one or more of the following adjustments to the above schedule shall be made: (a) that x-rays, tissue blocks, slides and other pathology in plaintiffs' possession which Plaintiffs intend to use at trial be provided 150 days prior to trial;

WARNINGCivil cases

For cases set for trial on the Master Trial Calendar, plaintiffs must answer defendants’ standard written discovery and provide authorizations to the depository 240 days before trial.

## (a) 240 Days Before Trial: (i) plaintiff shall answer defendants' standard written discovery; (ii) plaintiff shall provide authorizations to the depository.

WARNINGCivil cases

A forum non conveniens motion must initially be noticed for hearing a reasonable time before trial to allow sufficient time for discovery on forum issues.

Said motion shall be initially noticed for hearing within a reasonable time prior to the date set for trial and so as to allow sufficient time to conduct discovery on forum issues, as required by Rule 187(b).

WARNINGCivil cases

Defendants shall have thirty (30) days from receiving notice of the

Defendants shall have thirty (30) days from receiving notice of the

WARNINGCivil cases

Plaintiffs must place specified reports in the depository 150 days before trial.

## (b) 150 Days Before Trial: Plaintiffs shall place in the depository all B-read reports, pulmonary function test reports and testifying experts' reports in their possession which Plaintiffs intend to use at trial.

WARNINGCivil cases

The timing of a forum non conveniens motion is presumptively unreasonable when any such motion is first set for hearing less than 60 days before trial.

The timing of the motion for forum non conveniens shall be presumptively unreasonable where any forum non conveniens motion is first noticed for hearing to be held less than 60 days before trial.

WARNINGCivil cases

In cases alleging mesothelioma, upon request by any defendant, one or more of the following adjustments to the above schedule shall be made: (b) that plaintiff's deposition be completed 120 days prior to trial;

In cases alleging mesothelioma, upon request by any defendant, one or more of the following adjustments to the above schedule shall be made: (b) that plaintiff's deposition be completed 120 days prior to trial;

WARNINGCivil cases

Unless the stated master-list exception applies, all parties must file and serve fact-witness lists 120 days before trial; plaintiffs must also place intended trial pathology materials in the depository by then.

## (c) 120 Days Before Trial: (i) all parties shall file and serve lists of fact witnesses unless a master fact witness list was filed as provided in Section II.A.1(b)ii above; (ii) plaintiffs shall place in the depository all x-rays, tissue blocks, slides and other pathology in their possession which plaintiffs intend to use at trial.

WARNINGCivil cases

Plaintiffs’ independent medical examinations must be completed 90 days before trial.

## (d) 90 Days Before Trial: (ii) independent medical examinations of plaintiffs shall be completed.

WARNINGCivil cases

Unless the stated master-list exception applies, all parties must file and serve expert-witness lists and any required disclosures 90 days before trial.

## (d) 90 Days Before Trial: (i) all parties shall file and serve lists of expert witnesses (and disclosures if called for herein) unless a master expert witness list was filed as provided in Section II.A.1(b)ii above;

WARNINGCivil cases

A plaintiff's firm may submit revised Master discovery for future use within 60 days of the Order's date.

Within 60 days of the date of this Order a Plaintiff's firm may submit revised Master discovery to be appended to this Order for future use.

INFOCivil cases

A plaintiff may submit a trial request 30 days after all named parties have been served.

Upon filing of a new case, 30 days after all parties named therein have been served, Plaintiff may submit a request for trial

INFOCivil cases

The timing of a forum non conveniens motion is presumptively reasonable when its first hearing is set 60 or more days before trial.

The timing of the motion for forum non conveniens shall be presumptively reasonable where it is first noticed for hearing to be held 60 days or more before trial.