Judge Edmond E. Chang
Individual Rules, Standing Orders & Policies
- Rules last changed:
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Page & Word Limits2 rules
The neutral description cannot be more than 200 characters (hopefully, you’ll never come close to that limit).
Each side is limited to 15 proposed disputed questions, unless a motion is filed before the pretrial conference that explains good cause for proposing more than the limit.
Document Format Requirements9 rules
if an instruction is disputed, the objecting party must concisely state—on the page immediately following the instruction—the grounds for the objection, as well as any proposed modification or alternative.
Parties must submit a USB/DVD/CD with all proposed exhibits and 2 sets of exhibit binders with objected-to exhibits only.
Court's wording
the parties must submit to chambers a USB storage device, DVD, or CD with all of the proposed exhibits. In addition to the disc, the parties also must supply 2 sets of exhibit binders containing copies of objected-to exhibits only.
five business days before trial, each party shall supply (a) the exhibits in digital format on a USB drive, DVD, or CD; and (b) the exhibits in paper copy (just 1 set), double-sided in three-ring binders.
- Binding
- Three-ring binder
- Exhibits
JERS accepts these common file types: Documents and Photographs: .pdf, .jpg. Video and Audio Recordings: .avi, .wmv, .mpg, .mp3, .wma, .wav
Formatting
- •Documents and photos must be .pdf or .jpg
- •Video must be .avi, .wmv, .mpg
- •Audio must be .mp3, .wma, .wav
Exhibits must be named with number_underscore_neutral description format.
Formatting
- •Consecutive numbers only, no letters or parts (like 1A, 2A)
Court's wording
To use JERS, both sides must use the following exhibit-naming convention, which also will serve as the file name for the digital file: the exhibit number, followed by an underscore, followed by a neutral description of the exhibit. The convention is thus: Examples: 1_Financial Statement 2009 Annual.pdf 2_Contract 2010 Renewal.pdf 3_Photo Front Door.jpg 4_Audio Dec 11 2013 Phone Call.mp3 5_Video Traffic Stop.wmv
Proposed pretrial orders must be filed electronically using CM/ECF (no need for courtesy copies). To file it, select the appropriate CM/ECF event, “Other Filings” and then “Other Documents,” and choose the Proposed Pretrial Order event. Also email it to Proposed_Order_Chang@ilnd.uscourts.gov in Microsoft Word format.
- File type
- Word
- Pretrial order
Formatting
- •Email to judge
Each party must supply exhibits digitally on a USB drive, DVD, or CD and provide one double-sided paper set in three-ring binders with exhibit-number tabs.
- Binding
- Three-ring binder
- Exhibits
Formatting
- •Separate exhibits in binders with tabs corresponding to exhibit numbers
Court's wording
In sum, each party shall supply (a) the exhibits in digital format on a USB drive, DVD, or CD; and (b) the exhibits in paper copy (just 1 set), double-sided in three-ring binders. The exhibit binders should separate the exhibits with tabs that correspond to the exhibit number.
The exhibit binders should separate the exhibits with tabs that correspond to the exhibit number.
- Exhibits
Formatting
- •Separate exhibits with tabs corresponding to exhibit numbers
JERS allows jury to review digital exhibits on monitors instead of paper copies.
Formatting
- •Exhibits must be submitted in digital format for JERS system
Court's wording
JERS is a computer system that the jury will use to review exhibits on a wide-screen video monitor, rather than reviewing paper copies. The jury room has the JERS computer, a touch-screen monitor for the jury to pick an exhibit to display, and the wide-screen monitor. JERS can display what otherwise would have been on paper (including photos), and JERS also can play audio and video files.
Document Filing Requirements22 rules
The parties shall file on the docket a Joint Pretrial Statement with the following items, and also email the complete Statement to Judge Chang’s Proposed Order email account in MS Word format:
Witness list must be filed on the same date as the Joint Pretrial Statement and emailed to chambers in MS Word format.
Court's wording
On the same date as the Joint Pretrial Statement, each party shall file a list of witnesses (and email an MS Word version to Judge Chang's Proposed Order email account), including expert witnesses, divided into (a) witnesses who will be called; and (b) witnesses who might be called.
Each party must file an exhibit chart (and email an MS Word version to Judge Chang's Proposed Order email account) on the same date as the Joint Pretrial Statement.
Proposed jury instructions must include proponent, legal authority, and objection status for each instruction.
Court's wording
The proposed jury instructions must state, on an instruction-by-instruction basis, the following information: the proponent of the instruction, the legal authority for the instruction, and whether there is an objection to the instruction.
One last thing: a physical object of course will not be imported into JERS, but you should still assign a consecutively numbered exhibit designation to it, along with a neutral description. Then create a one-page .pdf with the exhibit number and neutral description on it, and submit those exhibits as part of the JERS disc.
- Document
- Physical exhibit placeholder
Should include
- •Exhibit number
- •Neutral description
Five business days before the pretrial conference, supply the exhibits to the Court (and to the other side) on a USB drive, DVD, or CD. Consistent with the Standing Order, you’ll also be supplying to chambers three paper copies of only the objected-to exhibits, double-sided in three-ring binders.
Counsel for the offering party must supply the exhibit in digital format as soon as possible (a thumb drive comes in handy for this), and the courtroom deputy will import it into JERS.
Five business days before the trial, supply the trial exhibits to the courtroom deputy and to the other side, again on a USB drive, CVD, or CD.
No later than 10 business days before the Proposed Pretrial Order’s due date, the parties must serve on each other proposed stipulations and uncontested facts. No later than 5 business days before the due date, the parties must confer in good faith to arrive at as many stipulations and uncontested facts as possible.
- Document
- Pretrial order
Must include
- •Stipulations and uncontested facts
Unobjected exhibits deemed admissible by pretrial order.
Court's wording
Any substantive exhibit not objected-to shall be deemed admissible into evidence by this Order (note: for the exhibit to be actually entered into the record for the jury’s consideration, the exhibit still must be referred-to during trial testimony or otherwise published to the jury).
Witnesses who are not on the lists are barred from testifying unless the proponent shows good cause for the failure to disclose the witness.
The parties shall stipulate to the authenticity of exhibits whenever possible.
Proponent of a disputed instruction should concisely explain its basis if needed beyond legal authority.
Court's wording
If an instruction is disputed, the proponent of the instruction should concisely explain the basis for the instruction, if more explanation is required beyond the identified legal authority (often citing to the Pattern or to a case will be explanation enough).
Unless the parties agree otherwise, the party that is objecting to an exhibit is responsible for providing the copy of the objected-to exhibit.
Santiago motions must be specific in identifying the offered statements, so that the parties may brief, and the Court may analyze, the propriety of each statement.
The same principles apply to proposed verdict forms.
If there are multiple parties on a particular side, then you must coordinate with your co-plaintiff’s or co-defendant’s attorney to generate a consecutively numbered set of exhibits.
For now, also supply one copy of the exhibits in paper form (hopefully soon we’ll be able to dispense with this requirement, when we have increased confidence in JERS). This paper set will serve as the backup to JERS, in the event that JERS suffers a technical failure during deliberations.
If JERS fails during deliberations, jury requests help in writing; systems staff requires court permission and jury must be escorted out; paper backup provided if not quickly fixable.
Court's wording
If JERS fails during deliberations, the jury will ask for help in writing. The systems staff will not be permitted in the jury room without the Court’s express permission, and only after the jury has been escorted out of the jury room. If the problem is not fixable in a short time, the Court will provide the jury with the paper-copy backup of the allowed exhibits.
Court prefers Seventh Circuit Pattern Instructions but parties may propose modifications or additional instructions.
Court's wording
Where applicable, the Court generally prefers the Seventh Circuit's Pattern Instructions, but of course the parties may propose modifications to the Pattern and may propose additional, non-Pattern Instructions.
Physical-object exhibits that the Court allows the jury to examine during deliberations will be provided to the jury as usual, via the court security officer.
The jury will not be supplied with paper copies, unless there is good cause for a particular exhibit (or if JERS breaks down).
Filing & Service rules
Filing Timing and Cure Windows
The deadline for motions in limine also covers Santiago motions unless set separately.
Unless set separately, the deadline on motions in limine includes Santiago motions by the government to allow co-conspirator statements.
Criminal cases
Page 3 | Motions in Limine
Proposed stipulations must be served 5 business days before the pretrial conference.
No later than 5 business days before the pretrial conference, the parties must serve on each other proposed stipulations.
Criminal cases
Page 1 | 1. Joint Pretrial Statement
Proposed voir dire questions must be exchanged 5 business days before the Joint Pretrial Statement due date, and parties must confer 2 business days before.
Each side shall provide the other with proposed voir dire questions 5 business days before the due date of the Joint Pretrial Statement, and confer by 2 business days before the due date in order to generate this section of the Statement.
Criminal cases
Page 1 | 1. Joint Pretrial Statement
Proposed exhibit charts must be exchanged 10 business days before the filing deadline; objections must be returned 5 business days before the deadline.
The parties must exchange their respective proposed exhibit charts 10 business days before the deadline for filing the charts, and the objecting side must return the chart with the objection column filled in 5 business days before the deadline.
Criminal cases
Page 2 | 3. Exhibit Lists and Proposed Exhibits at Pretrial Stage
Pre-Motion Conference Requirements
Motions in limine must be thoroughly briefed; the Court will set a briefing schedule.
The motions in limine must be briefed as thoroughly as possible (the Court will set a briefing schedule in each case).
Criminal cases
Page 3 | Motions in Limine
Parties must confer to try to agree on jury instructions and the verdict form.
The parties must confer in order to attempt to agree on as many jury instructions as possible, as well as the verdict form.
Criminal cases
Page 3 | Jury Instructions / Verdict Forms
Parties should raise exhibit objections at the pretrial conference to resolve them before trial.
During the pretrial conference, the parties should raise any objections to exhibits that can be resolved before trial, in order to promote an expeditious trial and to avoid sidebars.
Criminal cases
Page 3 | Exhibit Lists and Proposed Exhibits at Pretrial Stage
Chambers Communication Rules
Jury instructions must be emailed to Judge Chang's Proposed Order email account in MS Word format.
The jury-instructions filing also must be emailed to Judge Chang's Proposed Order email account in MS Word format (a deadline will be set in each case).
Criminal cases
Page 3 | Jury Instructions / Verdict Forms
For courtroom display technology instruction, call the Systems Department at 312.435.6045.
If you need instruction on the courtroom display technology equipment, please call the Systems Department (312.435.6045) within the Clerk's Office.
Criminal cases
Page 4 | Displaying Exhibits on the Video Monitors
For instruction on courtroom display technology, call the Systems Department within the Clerk’s Office at 312.435.6045.
If you need instruction on the courtroom display technology equipment, please call the Systems Department (312.435.6045) within the Clerk’s Office.
Civil cases
Page 1 | Exhibit-Naming Convention & Exhibit Copies