Judge John Robert Blakey

Five business days prior to the Final Pretrial Conference, or on the date otherwise set by the Court, each party shall file its response. The response shall consist of a single pleading, not to exceed 30 pages, with each issue separately addressed and listed with the same numbering as the motions in limine.

All other trial-related motions in limine must be filed by the date ordered by the Court, or if no date has been set, then any such motions in limine must be filed at least ten business days prior to the Final Pretrial Conference. Each party shall file its motions in limine within a single pleading not to exceed 30 pages, with each issue separately numbered and argued within the pleading.

Ten business days prior to the Final Pretrial Conference, or on the date otherwise set by the Court, each party shall file its motions in limine within a single pleading not to exceed 30 pages, with each issue separately numbered and argued within the pleading.

Five business days prior to the Final Pretrial Conference, or on the date otherwise set by the Court, each party shall file its response. The response shall consist of a single pleading, not to exceed 30 pages, with each issue separately addressed and listed with the same numbering as the motions in limine.

The Proposed Pretrial Order must be e-mailed to “Proposed_Order_Blakey@ilnd.uscourts.gov” in Word format, with two courtesy copies delivered to chambers.

Counsel for all parties must submit a proposal for discovery and a case management plan, including the following information:

If Plaintiff has failed to complete service of process on all Defendants, then counsel must describe the efforts to perfect service to date and provide an estimate for completion of service consistent with Federal Rule of Civil Procedure 4.

The Court expects the parties to file a joint status report on behalf of all parties. If you are filing an individual report or filing a joint report on behalf of fewer than all parties, explain why.

(4) The need for, and content of, any proposed confidentiality orders, in accordance with the Local Rules for the Northern District of Illinois (parties should start with the model confidentiality order, file a motion seeking entry of the order, and send a redlined version and a clean Word version to proposed_order_blakey@ilnd.uscourts.gov);

In the Pretrial Memorandum, the parties shall state the estimated number of trial days, including jury selection, opening statements, and closing arguments. Generally, to accommodate the venire, the Court will select a jury on day one of trial and start opening statements on day two.

In the Pretrial Memorandum, the parties shall list all of the attorneys trying the case, as well as their contact information (business address, telephone number, and e-mail address). Lead trial counsel shall provide to chambers by telephone his or her cell phone number for use in the event the Court needs to reach the parties during trial.

Along with the Pretrial Memorandum, each party shall also submit a proposed trial exhibit list that includes any summary exhibits and demonstrative exhibits. The list must state the following: (a) the exhibit number/name; (b) a concise description of the exhibit (with any pertinent dates of documents); and (c) a concise statement of the exhibit’s relevance.

Along with the Pretrial Memorandum, the parties shall submit a copy of all agreed exhibits (if any), and also list any factual or testimonial stipulations they intend to enter into evidence and publish to the jury.

In the Pretrial Memorandum, the parties shall provide a neutral and concise agreed statement of the case to be read by the Court to the jury during jury selection. The statement should include a brief description of the nature of the case and the charges and may include (but is not required to include) any defenses. The parties shall refrain from using argumentative or indoctrinating language.

The Pretrial Memorandum 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.

Also, if the parties rely on diversity jurisdiction, state each party’s domicile.

Lead trial counsel with authority to discuss and address all aspects of the case, including the authority to enter into stipulations or settlement (if any), must attend.

List all of the attorneys trying the case, as well as their contact information (business address,

State the jurisdictional basis for each claim.

Note: if any party is a partnership or a limited liability company and the basis of jurisdiction is diversity, counsel must identify the name and domicile(s) of each and every partner of each such entity.

If the parties rely on either diversity jurisdiction or another jurisdictional basis that requires a threshold amount in controversy, then state whether the parties agree that the amount in controversy exceeds that threshold, and include a concise explanation of how the evidence supports that statement.

State the estimated number of trial days, including jury selection, opening statements, and closing arguments, as well as the number of jurors the parties recommend be selected (subject to Rule 48(a)).

The parties shall refrain from using argumentative or indoctrinating language.

If such exhibits are deemed “agreed” at the pretrial conference and accepted by the Court, then any later objections to the admission of these exhibits into evidence at trial shall be rejected as untimely.

Along with the Proposed Pretrial Order, the parties shall submit to chambers a binder including all of the agreed exhibits pre-marked.

Provide a neutral and concise agreed statement of the case to be read by the Court to the jury during jury selection.

The parties must submit an exhibit list that includes summary exhibits and demonstrative exhibits. The list must state the following: (a) the exhibit number; (b) a concise description of the exhibit (with any pertinent dates of documents); (c) a concise statement of the exhibit’s relevance; and (d) whether there is an objection to the exhibit’s admission, and if so, a concise explanation of the objection and the proponent’s theory of admissibility.

The parties also remain free to propose additional factual stipulations during trial, but all stipulations must be in writing and approved by the Court prior to being published to the jury.

Witnesses who are not listed are barred from testifying unless the proponent shows good cause for the failure to disclose the witness.

Any challenges to expert testimony or evidence must be made within the motions in limine.

In the Proposed Pretrial Order, each party must provide a list summarizing its motions in limine.

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.

Motions in limine must be filed separately from the Proposed Pretrial Order by the due date set by the Court.

Plaintiff(s) (and counter/cross-claimants, if applicable) shall itemize damages and other relief sought.

Any additional questions sought by the parties must be listed in the Proposed Pretrial Order, divided into: (a) agreed-upon questions; and (b) proposed questions to which one party objects. A short basis for any objection should accompany the list.

No legal briefs or memorandums of law will be permitted during trial (including briefs or memoranda supporting or opposing motions for judgment as a matter of law) absent prior leave of Court.

Moreover, if an instruction is disputed, the objecting party must concisely state the grounds for the objection, as well as any proposed modification or alternative.

The parties must meet and confer in order to attempt to agree upon jury instructions and the verdict forms.