Judge Manish S. Shah
Individual Rules, Standing Orders & Policies
Communication
Document Filing Requirements11 rules
Motions in limine must include meet-and-confer statement about opposing party's evidence intentions.
Any motion in limine 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
Unobjected exhibits are deemed admitted without foundation testimony.
Any exhibit not objected-to shall be deemed admitted by operation of the Final Pretrial Order without any need for foundation testimony, unless the exhibit is not referred to or published during trial.
DocumentProposed Pretrial 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.
DocumentProposed Pretrial Order
The Proposed Pretrial Order must be: • e-mailed to Proposed_Order_Shah@ilnd.uscourts.gov in Microsoft Word format; • filed on the docket by selecting the Proposed Pretrial Order event in CM/ECF;
DocumentProposed Pretrial Order
The parties shall jointly prepare and file an initial status report, containing the following information:
DocumentInitial Status Report
Before the settlement conference, plaintiff’s counsel must send a settlement proposal with an itemized demand and explanation, and defendant’s counsel must respond with a written offer and explanation in time for a response.
Before the settlement conference and with enough time for a response, plaintiff’s counsel shall submit a letter to defendant’s counsel that proposes a settlement and itemizes damages and any other relief sought. The letter must provide a brief explanation of why such a settlement is appropriate. Defendant’s counsel shall submit a written offer to plaintiff’s counsel with a brief explanation of defendant’s response to plaintiff’s demand and an offer from defendant.
DocumentSettlement Letter
Parties with ultimate settlement authority must attend in person, subject to specified insurer and corporate representative requirements; telephone availability is not an alternative unless the Court approves extenuating circumstances in advance.
Parties with ultimate settlement authority must be physically present at the conference. An insured party shall appear by a representative of the insurer who is authorized to negotiate, and who has authority to settle the matter up to the limits of the opposing party’s existing settlement demand or offer. An uninsured corporate party shall appear by a representative authorized to negotiate, and who has authority to settle the matter up the amount of the opposing party’s existing settlement demand or offer. The availability of a client by telephone is not an ===== PAGE 2 ===== acceptable alternative except in extenuating circumstances that must be approved by the Court in advance.
DocumentSettlement Conference Attendance
Judge Shah does not require trial briefs in jury trials. Parties who wish to file a trial brief must seek leave of court to do so.
DocumentTrial Brief
The Court will require the participants to agree that any statements made by any party or attorney at the settlement conference are inadmissible at trial.
DocumentSettlement Conference Participant Agreement
The parties must confer in good faith to arrive at as many stipulations and uncontested facts as possible. The parties will be responsible for presenting stipulations to the jury during trial.
DocumentProposed Pretrial Order
Objected-to exhibits may be submitted to chambers by email to proposed order shah@ilnd.uscourts.gov. Large files can be submitted via
DocumentProposed Pretrial Order
Filing & Service rules
Electronic Filing Rules
These letters should not be filed on the docket.
These letters should not be filed on the docket.
Civil cases
Page 1 | Exchange of Pre-Conference Demand And Offer
Filing Bundling Requirements
Motions in limine must be filed in consolidated filings; responses due one week after filing; no replies without leave.
Motions in limine must also be filed separately on the docket. Each party must file all of its motions in limine in one consolidated filing (or a few consolidated filings). Unless otherwise ordered, responses are due one week after the motion’s filing, and no replies may be filed without leave of court.
Page 4 | 10. Motions in Limine
Pre-Motion Conference Requirements
Responses to motions in limine due one week after filing; no replies without leave.
Unless otherwise ordered, responses are due one week after the motion’s filing, and no replies may be filed without leave of court.
Page 4 | 10. Motions in Limine
Parties must conduct Rule 26(f) planning conference.
The parties are directed to meet pursuant to Federal Rule of Civil Procedure 26(f) and conduct a planning conference.
Civil cases
Propose briefing schedule for pending motions.
Identify all pending motions and propose a briefing schedule if one has not been set.
Civil cases
Chambers Communication Rules
If the letter exchange does not achieve settlement, both letters must be emailed to Judge Shah before the settlement conference.
If settlement is not achieved through this exchange of letters, the letters must be submitted to Judge Shah before the settlement conference, by email to Proposed_Order_Shah@ilnd.uscourts.gov.
Civil cases
Page 1 | Exchange of Pre-Conference Demand And Offer