Limits & Logistics
Document Limits
Courtesy Copies
Motion
- Before Court Arrival
Brief
Court-wideCourt Document, Exhibit
Court-wide- No Later Than 4 30 Pm Three Business Days Before Hearing
Courtesy copies
Court-wide- Hand Delivery
- Upon request
Communication
Phone
Court-wideClerk
Phone
Court-wideClerk
Phone
Court-wideClerk
Document Format Requirements4 rules
All motions to continue shall be in writing and supported by affidavit pursuant to 725 ILCS 5/114-4
“Substantive” motions in limine shall be in writing and shall cite any relevant case law or statutory authority supporting the movant’s position.
Formatting
- •The motion must be in writing
Before trial, counsel must mark each exhibit with a small sticker showing the case name and exhibit number.
Court's wording
Counsel shall have all of their exhibits marked prior to trial with small exhibit stickers that include the case name and exhibit number and will provide an exhibit list to the court prior to opening statements.
It is strongly recommended that if counsel seeks to address a case specific fact or area of law in voir dire, they first submit those questions in writing as a motion in limine to the Court for approval. (See paragraph (E)(2)(b) above).
Document Filing Requirements8 rules
Parties must present marked and unmarked jury instructions and verdict forms tailored to the anticipated facts; earlier submission is encouraged and the Court may order it.
Court's wording
Parties shall present to the court the following items: - a. Sets of jury instructions and verdict forms (marked and unmarked) tailored to the anticipated facts of the case being tried. NOTE: It is encouraged that the parties submit these prior to the trial date and can expect that the court may order the same.
A response to a substantive motion in limine must cite relevant case law or statutory authority supporting the response.
Court's wording
Opposing counsel may file a response to the movant’s “substantive” motion in limine within 14 days of the movant’s filing unless otherwise scheduled by the Court and shall cite any relevant case law or statutory authority supporting their response.
“Substantive” motions in limine shall be in writing and shall cite any relevant case law or statutory authority supporting the movant’s position.
Parties must present a list of qualifying anticipated voir dire questions; earlier submission is encouraged and the Court may order it.
Court's wording
- b. A list of voir dire questions (if any) that the attorney expects to ask prospective jurors which the attorney believes an objection may be lodged, or that may be rejected by the Court. The court will issue a preliminary ruling regarding the question. NOTE: It is encouraged that the parties submit these prior to the trial date and can expect that the court may order the same.
- c. A witness list. NOTE: It is encouraged that the parties submit these prior to the trial date and can expect that the court may order the same.
Counsel must provide the court with an exhibit list before opening statements.
Court's wording
Counsel shall have all of their exhibits marked prior to trial with small exhibit stickers that include the case name and exhibit number and will provide an exhibit list to the court prior to opening statements.
- G. Whenever a motion is submitted, it should incorporate and cite the applicable statute or other authority with which the request for relief is based.
If necessary, the motion in limine may include a proffer of facts, if needed, to provide context for the motion.
Filing & Service rules
Filing Timing and Cure Windows
Responses to substantive motions in limine are due within 14 days after filing unless the Court sets a different schedule.
Responses to any “substantive motion in limine” are due within 14 days of the movant’s filing unless scheduled otherwise by the Court.
Page 5 | D. Motions in Limine in Courtroom A
Opposing counsel may file a response within 14 days unless the Court sets another schedule, and any response must cite relevant supporting case law or statutory authority.
Opposing counsel may file a response to the movant’s “substantive” motion in limine within 14 days of the movant’s filing unless otherwise scheduled by the Court and shall cite any relevant case law or statutory authority supporting their response.
Page 5 | D. Motions in Limine in Courtroom A
Substantive motions in limine must be filed by the stated deadline.
All “substantive” motions in limine are to be filed no later than the deadline given.
Page 5 | D. Motions in Limine in Courtroom A
File pre-trial motions at the earliest available date so they can be set for hearing promptly.
- F. File pre-trial motions at the earliest available date so that they can be promptly set for hearing.
Page 1 | Courtroom Etiquette and Protocol Expectations
If at any time after answering ready for trial but before the jury trial begins a party is no longer “ready for trial” any motions related to the change in readiness should be brought immediately to the attention of the Court and opposing counsel.
If at any time after answering ready for trial but before the jury trial begins a party is no longer “ready for trial” any motions related to the change in readiness should be brought immediately to the attention of the Court and opposing counsel.
Page 4 | C. Jury Status
Courtesy Copy Requirements
Submit courtesy copies together with any authority upon which the motion is based to the Court and private counsel. The courtesy copies should be distributed BEFORE you come to court and NOT after you arrive.
Submit courtesy copies together with any authority upon which the motion is based to the Court and private counsel. The courtesy copies should be distributed BEFORE you come to court and NOT after you arrive.
Page 1 | Courtroom Etiquette and Protocol Expectations
Pre-Motion Conference Requirements
Substantive motions in limine and other substantive motions must be heard before the jury status date.
All “substantive” motions in limine and any other substantive motions are required to be heard in advance of the jury status date.
Page 5 | D. Motions in Limine in Courtroom A
Adjournment & Extension Requirements
If a continuance is granted, make every effort to accomplish its purpose before the next court dates.
- H. If you must request a continuance, make every effort to accomplish the goal for which the continuance was obtained before the next court dates.
Page 1 | Courtroom Etiquette and Protocol Expectations
For a potential motion to continue affecting a previously scheduled matter, notify the court in advance or request an early status to address the scheduling issue.
- D. If you believe that a motion, hearing, or trial previously set will not proceed for some reason, please notify the court in advance for scheduling purposes and/or request to status the matter before the court early to address any scheduling issue or motion to continue. This will assist the court in managing its schedule in a more efficient manner.
Page 1 | Courtroom Etiquette and Protocol Expectations
If a party is seeking to file a motion to continue a jury trial, it should be filed, without delay, upon learning of circumstances effecting the readiness to proceed to trial.
If a party is seeking to file a motion to continue a jury trial, it should be filed, without delay, upon learning of circumstances effecting the readiness to proceed to trial.
Page 4 | 4. Motions to Continue Trial
Motions to continue a jury trial are governed by 725 ILCS 5/114-4.
Any motion to continue a jury trial will be governed by 725 ILCS 5/114-4.
Page 4 | 4. Motions to Continue Trial
For a continuance based on an unavailable witness, the moving party should expect inquiry into diligence, including witness-contact attempts, subpoena service, efforts to secure and prepare the witness, subpoena issuance dates, and whether the defendant will stipulate to the testimony.
The moving party of a motion to continue a jury trial based on the unavailability of a witness should expect the court to inquire as to matters regarding diligence including but not limited to: - i. The number and extent of attempts to contact a witness. - ii. The method, number of attempts, and result of subpoena service. - iii. In person, telephonic, or other electronic live methods of communication to secure the presence and prepare for testimony for a witness. - iv. Issuance date of subpoenas. - v. Whether the defendant will stipulate that the testimony of the witness would be as alleged.
Page 4 | 4. Motions to Continue Trial
The trial court has discretion over motions for continuance and considers the movant's diligence.
All motions for continuance are addressed to the discretion of the trial court and shall be considered in the light of the diligence shown on the part of the movant.
Page 4 | 4. Motions to Continue Trial
Chambers Communication Rules
Copy opposing counsel on scheduling emails and other authorized correspondence between counsel and the court.
- E. Always make sure to carbon copy (cc) opposing counsel in any scheduling emails or any other authorized correspondence between counsel and the court.
Page 1 | Courtroom Etiquette and Protocol Expectations
If a previously scheduled motion, hearing, or trial may not proceed, notify the court in advance or request an early status of the matter to address scheduling or a motion to continue.
- D. If you believe that a motion, hearing, or trial previously set will not proceed for some reason, please notify the court in advance for scheduling purposes and/or request to status the matter before the court early to address any scheduling issue or motion to continue. This will assist the court in managing its schedule in a more efficient manner.
Page 1 | Courtroom Etiquette and Protocol Expectations
If unavoidably detained, notify the Courtroom A Bailiff or Administrative Assistant and provide where you can be reached and when you will be available.
- A. Be on time for court. If you are unavoidably detained, please notify the Courtroom A Bailiff or Administrative Assistant and let them know where you can be reached and when you will be available to handle your case.
Page 1 | Courtroom Etiquette and Protocol Expectations
Do not give directions to the clerk, bailiff, court reporter, or witness; ask the Court or bailiff for needed assistance or accommodations.
- L. Do not give directions to the clerk, bailiff court reporter or witness. If you need assistance simply ask the Court or bailiff for any accommodation needed from any of the court personnel.
Page 2 | Courtroom Etiquette and Protocol Expectations
While court is in session, do not discuss matters with the bailiff or clerk that are not before the court, except to coordinate arrival in another courtroom, check in, or obtain information about your case from the clerk.
- M. Do not engage the bailiff or clerk about matters that are not before the court while court is in session unless you are discussing coordination of arrival time in other courtrooms, checking your case in, or obtaining information about your case from the clerk.
Page 2 | Courtroom Etiquette and Protocol Expectations