Limits & Logistics
Document Limits
Courtesy Copies
Motion to Continue
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
"Substantive motions in limine" and responses to substantive motions in limine shall be in writing and shall cite any relevant case law or statutory authority supporting the movant's position.
Formatting
- •Must be in writing
Counsel shall have all of their exhibits marked prior to trial with small exhibit stickers that include the case name, case number, and exhibit number.
If trial technology will be used, the parties should test the exhibit with that technology before trial begins.
Court's wording
If any technology including but not limited to laptops, thumb drives, compact disk videos need to be utilized, the parties should test the exhibit with said technology prior to the commencement of the trial.
If technology-dependent evidence will be sent to the jury, the parties should secure a clean machine containing only what is needed to display the admitted evidence.
Court's wording
In addition, should any video, photographic or any other evidence requiring the use of technology need to be sent to the jury, the parties should secure a "clean" machine for the submission of said evidence to the jury. A "clean" machine is one that does not have any other apps, programs, documents or other items continued thereon other than that needed for the display of the admitted evidence.
Document Filing Requirements4 rules
b. All motions to continue shall be in writing and supported by affidavit pursuant to 725 ILCS 5/114-4.
The parties must present jury-instruction sets, a witness list, and an exhibit list with marked exhibits; the state must submit verdict forms.
Court's wording
Parties shall present to the Court the following items: - a. Sets of jury instructions (marked and unmarked) tailored to the anticipated facts of the case being tried. The state shall submit verdict forms. NOTE: It is strongly encouraged that the parties submit these on the Friday prior to the Tuesday trial date. - b. A witness list - c. An exhibit list and marked exhibits
It is strongly recommended that if counsel wishes to address a case specific fact or area of law in voir dire that they first submit those questions in writing as a motion in limine to the Court for approval.
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
Motions in limine must be filed by the Court's specified date, or by the final pretrial conference if no date is specified; noncompliance may result in a continuance.
All motions in limine shall be filed by the date given by the Court. Noncompliance with this may result in a continuance. If the Court does not provide a specified date, the motions shall be filed no later than the final pretrial conference.
Criminal cases
Page 3 | E. Motions in limine in Courtroom 315
The parties are strongly encouraged to submit the jury materials on the Friday before a Tuesday trial.
NOTE: It is strongly encouraged that the parties submit these on the Friday prior to the Tuesday trial date.
Criminal cases
Page 4 | F. Initial Commencement of Trial
Service and Proof of Service Rules
The moving party must contemporaneously provide the motion to continue to opposing counsel and a courtesy copy to the Court.
The moving party shall contemporaneously provide a copy of the motion to continue to opposing counsel and a courtesy copy to the Court.
Criminal cases
Page 2 | D. Jury Status, 4. Motions to Continue Trial
Courtesy Copy Requirements
A courtesy copy of the motion to continue must be provided to the Court contemporaneously.
The moving party shall contemporaneously provide a copy of the motion to continue to opposing counsel and a courtesy copy to the Court.
Criminal cases
Page 2 | D. Jury Status, 4. Motions to Continue Trial
Pre-Motion Conference Requirements
Responses to motions in limine are due within 14 days of filing unless the Court sets a different schedule.
Responses to any motions in limine are due within 14 days of the movant's filing unless scheduled otherwise by the Court.
Criminal cases
Page 3 | E. Motions in limine in Courtroom 315
Motions in limine requiring a hearing are expected to be heard before the jury status date.
Motions in limine requiring a hearing are expected to be heard in advance of the jury status date.
Criminal cases
Page 3 | E. Motions in limine in Courtroom 315
Adjournment & Extension Requirements
A party seeking a continuance based on an unavailable witness should expect the Court to inquire about diligence, including efforts to contact the witness.
d. 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 by trial counsel and office staff to contact a witness.
Criminal cases
Page 2 | D. Jury Status, 4. Motions to Continue Trial
A party should file a motion to continue a jury trial without delay after learning of circumstances affecting readiness for trial.
a. 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.
Criminal cases
Page 2 | D. Jury Status, 4. Motions to Continue Trial
The trial court has discretion over continuance motions and considers the movant’s diligence.
c. 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.
Criminal cases
Page 2 | D. Jury Status, 4. Motions to Continue Trial
Chambers Communication Rules
d. 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 to the Court and opposing counsels' attention immediately.
d. 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 to the Court and opposing counsels' attention immediately.
Criminal cases
Page 2 | D. Jury Status, 3. Jury Status: Other considerations