Judge John F. Kness
Individual Rules, Standing Orders & Policies
Limits & Logistics
Courtesy Copies
Pretrial Order
- 2 copies
Adjournments
- Expedited transcript requests must be made 7 days before trial.
- Opposing party must serve objections and counter-designations 14 business days before pretrial order due date.
Page & Word Limits1 rule
Each side is limited to 12 proposed disputed questions, unless a motion is filed before the pretrial conference that explains good cause for proposing more than the limit.
Disputed Questions
Document Format Requirements1 rule
Deposition designations must be submitted on USB drives with color-coding.
At least five business days before the pretrial conference, the parties must submit to chambers two USB storage devices with all of the disputed deposition designations. Plaintiff’s designations must be color-coded in blue, and Defendant’s designations must be color-coded in red.
Document Filing Requirements12 rules
Joint chart required for deposition designations with specific content.
The parties shall generate a joint chart, in page order, that sets forth the designation by page and line number, objection, counter-designation if objection overruled, any counter-designations, and any objections to the counter-designations (again with a concise basis for the objection).
DocumentJoint Deposition Designation Chart
Motions in limine must include meet-and-confer statement.
Every motion in limine filed by a party must be accompanied by a statement that the party has conferred with the opposing party and the opposing party actually intends to offer the evidence that the movant seeks to exclude, or actually opposes admission of the evidence that the movant seeks to include.
DocumentMotion In Limine
The parties must meet and confer by no later than seven days before the Proposed Pretrial Order is due to discuss their respective drafts and to reach agreement to the extent possible.
DocumentPretrial Order
Defendant must respond to plaintiff's draft with objections and additions 14 days before due date.
Defendant’s counsel must respond in writing to plaintiff’s draft no later than 14 days before the Proposed Pretrial Order is due, including any objections, changes, and additions to plaintiff’s draft, as well as defendant’s portions of the draft Proposed Pretrial Order (for example, defendant’s witness list, exhibit list, and objections to exhibits and deposition testimony listed by plaintiff).
DocumentPretrial Order
The Proposed Pretrial Order should be submitted to the Court with a cover document setting forth the case caption and the title “PROPOSED PRETRIAL ORDER.”
DocumentPretrial Order
Objections not made in the final pretrial order will be deemed waived absent a showing of good cause.
DocumentPretrial Order
The Proposed Pretrial Order must be signed (electronically) by counsel for each party.
DocumentPretrial Order
Proposed Pretrial Orders must also be filed on the docket by selecting “Other Filings” and then “Other Documents” and choosing the Proposed Pretrial Order event in CM/ECF.
DocumentPretrial Order
Witnesses who are not on the lists are barred from testifying unless the proponent shows good cause for the failure to disclose the witness.
DocumentPretrial Order
The document must be signed by counsel for each party and must contain a space for the judge’s signature.
DocumentPretrial Order
Plaintiff must provide draft Proposed Pretrial Order to defendant 21 days before due date.
Plaintiff’s counsel is responsible for preparing the initial draft of the Proposed Pretrial Order and must provide a draft to defendant’s counsel no later than 21 days before the date on which the Proposed Pretrial Order is due.
DocumentPretrial Order
If there is no objection to a motion, but the movant wishes to file a motion memorializing the non- objection, then the motion must state that there is no objection.
DocumentMotion In Limine
Filing & Service rules
Courtesy Copy Requirements
Proposed Pretrial orders must be e-mailed to Proposed_Order_Kness@ilnd.uscourts.gov in Microsoft Word format, and two courtesy copies (with labeled tabs for each requirement listed below) should be delivered to chambers.
Proposed Pretrial orders must be e-mailed to Proposed_Order_Kness@ilnd.uscourts.gov in Microsoft Word format, and two courtesy copies (with labeled tabs for each requirement listed below) should be delivered to chambers.
Civil cases · Proposed or draft document; may not be in force
Filing Bundling Requirements
Exhibit submission requirements: USB drives and binders for proposed and final exhibits.
At least five business days before the pretrial conference, the parties must submit to chambers two USB storage devices with all of the proposed exhibits. In addition to the storage devices, the parties also must supply two sets of exhibit binders containing copies of objected-to exhibits only. The party that is objecting to an exhibit is responsible for providing the copy of the objected-to exhibit. After the final pretrial conference and rulings on exhibits, no closer than five business days before trial, the parties must submit the final trial exhibits on a USB drive and provide two paper copies of the exhibits, double-sided in three-ring binders.
Civil cases · Proposed or draft document; may not be in force
Page 3 | Exhibits and Exhibit Charts
Encouraged to consolidate multiple motions in limine filings.
To the extent reasonable, file multiple motions in one filing (or a few consolidated filings) to reduce the number of filings.
Civil cases · Proposed or draft document; may not be in force
Page 4 | Motions in Limine
Pre-Motion Conference Requirements
Meet-and-confer required before filing motions in limine.
The parties must confer on all motions in limine before filing them.
Civil cases · Proposed or draft document; may not be in force
Page 4 | Motions in Limine
Adjournment & Extension Requirements
Opposing party must serve objections and counter-designations 14 business days before pretrial order due date.
The opposing party must serve objections to designations (including a concise basis for the objection, like the Exhibit Chart) and also state the opposing party’s counter-designations (including counter-designations conditioned on an objection being overruled) 14 business days in advance of the pretrial order’s due date.
Civil cases · Proposed or draft document; may not be in force
Page 4 | Deposition Designations
Expedited transcript requests must be made 7 days before trial.
Any requests for daily or other expedited transcripts must be made directly to Judge Kness’s court reporter at least 7 days before the start of trial.
Civil cases · Proposed or draft document; may not be in force