Courtesy copies are required for exhibits. Details: 1 copy, delivery with filing, by hand delivery. One courtesy copy of all exhibits must be delivered to Courtroom Deputy on pretrial order due date.
Judge Maria Valdez's rules set a pre-motion procedure for motions in limine. Motions in limine must be filed separately, 21 days before pretrial order, with responses due 14 days before.
Judge Maria Valdez's rule states these limits: 5 pages. Settlement letters limited to 5 pages; 10 pages requires leave.
Judge Maria Valdez's rule states these limits: 60 pages; 45 pages; 14 pages. Opening brief due 60 days after filing of administrative record; responsive brief due 45 days after opening brief; reply brief due 14 days after responsive brief.
The rule requires liens disclosure and litigation funding disclosure. Settlement letters must disclose liens or litigation funding sources.
The rule requires written motion. Extension requests for letter schedule must be by written motion.
Parties may contact Judge Maria Valdez's chambers by email only as allowed by the rule. The rule lists email Proposed_Order_Valdez@ilnd.uscourts.gov. Settlement letters must be emailed to court, not filed with clerk.
Judge Maria Valdez's rules specify what an adjournment or extension request must include. The request must include reason for request and extreme hardship. No continuances for settlement conferences without motion showing extreme hardship.
Final pretrial order requires one courtesy copy to be included.
One courtesy copy of all exhibits must be delivered to Courtroom Deputy on pretrial order due date.
Motions in limine must be filed separately, 21 days before pretrial order, with responses due 14 days before.
Proposed findings and conclusions must be filed separately with chambers copy 7 days before bench trial.
Trial briefs not required for jury trials; bench trials only with court approval.
Settlement letters must disclose liens or litigation funding sources.
Settlement letters limited to 5 pages; 10 pages requires leave.
Discovery audio/video/photos relevant to liability/damages must be submitted with settlement letters.
Counsel must provide settlement letters to clients before conference.
Settlement letters must be emailed to court, not filed with clerk.
Extension requests for letter schedule must be by written motion.
Settlement letters must be in good faith; demands for full recovery or zero offers may result in amended letter or closed referral.
Attorneys-Only conferences limited to 1 hour.
Only one lawyer per side may actively participate in Attorneys-Only conferences; others must be muted with camera off.
Settlement conferences held remotely on Webex unless otherwise ordered.
No continuances for settlement conferences without motion showing extreme hardship.
Modifications to standing order procedures require motion; no telephonic requests accepted.
Counsel must discuss and report on settlement status at the scheduling conference.
Parties must report earliest available date for settlement conference and needed discovery.
Initial disclosures under Rule 26(a)(1) must be made by a specified date if not already completed.
Amendments to pleadings or joinder of parties must be filed by a specified deadline.
Written discovery must be propounded no later than 45 days before close of fact discovery.
Parties with burden of proof must disclose expert testimony under Rule 26(a)(2) by a specified date.
Depositions of opposing party's Rule 26(a)(2) expert may be taken prior to a specified date.
Rebuttal expert disclosure must be made prior to a specified date.
Depositions of opposing party's rebuttal expert must be completed by a specified date.
Dispositive motions must be filed by a specified deadline, typically 30 days after close of fact discovery.
Daubert motions must be filed by a specified deadline, typically 30 days after close of expert discovery.
Opening brief due 60 days after filing of administrative record; responsive brief due 45 days after opening brief; reply brief due 14 days after responsive brief.
Opening brief should include only facts relevant to the issues presented.