Judge Mary M. Rowland
Individual Rules, Standing Orders & Policies
- Rules last changed:
Communication
Phone
Document Format Requirements1 rule
The Proposed Pretrial Order must be e-mailed in Word format to: Proposed_Order_Rowland@ilnd.uscourts.gov.
- File type
- Word
- Proposed pretrial order
Document Filing Requirements50 rules
All jury instructions must be submitted with final pretrial order, indicating proponent and agreement status.
Court's wording
The parties must submit all agreed and proposed jury instructions with the final pretrial order. Each proposed instruction must indicate the proponent of the instruction and whether the instruction is agreed or disputed.
The bottom of each instruction must identify the legal authority supporting the instruction.
In addition, parties are advised that at the close of evidence at trial they will be expected to file a final exhibit list on the docket.
Disputed jury instructions must include objection grounds and proposed modifications on same page.
- Document
- Jury instructions
Must include
- •Proposed modifications
Court's wording
If an instruction is disputed, the grounds for the objection (and any proposed modification or alternate instruction) must be concisely stated on the same page immediately following the disputed instruction.
Joint proposed voir dire document must include all parties' questions and objections.
- Document
- Joint proposed voir dire
Must include
- •Proposed voir dire questions
Court's wording
To propose questions to be included in the written questionnaire distributed to the venire, the parties must file a joint proposed voir dire document that includes both: (a) each party’s proposed voir dire questions; and (b) each party’s objections, if any, to the voir dire questions proposed by the other parties.
Medicare conditional payment letter required if client received/will receive Medicare payments related to case.
Court's wording
Please consider whether your client has received or will be receiving conditional payments from Medicare to pay for treatment related to this case. If so, you must bring a conditional pay letter from Medicare to the settlement conference.
Counsel are cautioned that failure to attend a settlement conference without authorization may result in the imposition of monetary sanctions against them.
The parties shall jointly prepare and submit a final pretrial order containing the following:
A statement of the basis alleged for the Court’s jurisdiction and, if jurisdiction is disputed, the nature and basis of the dispute.
The pretrial order must provide separate plaintiff and defendant exhibit lists with prefixed exhibit numbers, document dates, descriptions, and whether each exhibit is objected to.
Court's wording
Separate lists of plaintiff’s and defendant’s exhibits, which each state: (a) the exhibit number of the document (preceded by “PX” for plaintiff’s exhibits and “DX” for defendant’s exhibits); (b) the date of the docu- ment; (c) a brief description of the document; (d) whether there is an objection to
A statement of whether the case will be a bench trial or jury trial, and a realistic estimate of the length of the trial.
All expert witnesses who will or may be called must be included on the witness list.
All objections to the calling of any witnesses, and the reasons for the objections, must be stated in the pretrial order.
The pretrial order must list trial exhibits and identify each joint exhibit by JX number, document date, and brief description.
Include
- •Exhibit list
Court's wording
Lists of the trial exhibits (including demonstratives, summaries or other specially prepared exhibits), which are to be prepared in the following manner: A list of any joint exhibits, which states: (a) the exhibit number for the document (preceded by “JX”); (b) the date of the document;
The pretrial order must include separate plaintiff and defendant witness lists with names and addresses, categorized by expected, possible, and prior-testimony witnesses, and identify transcript or video presentation.
Court's wording
Separate lists for plaintiff and defendant providing the names and addresses of witnesses, including experts, divided into the following three categories: (a) witnesses who will be called to testify at trial; (b) witnesses who may be called to testify at trial; and (c) witnesses whose testimony will be pre- sented by deposition or other prior testimony (indicating whether the presenta- tion will be by transcript or video).
An unlisted witness is precluded absent good cause, except that a party may call necessary rebuttal witnesses not presently identifiable as such.
Court's wording
Any witness not listed in the pretrial order will be precluded from testifying absent a showing of good cause, except that each party reserves the right to call such rebuttal witnesses (who are not presently identifiable as rebuttal witnesses) as may be necessary.
In numbered paragraphs, set forth any stipulations and uncontested facts, as well as any stipulations regarding the presentation or admissibility of evidence.
The pretrial order must include a concise joint case statement identifying the parties and trial attorneys, case nature, claims, and defenses.
Court's wording
A concise joint statement of the case, which includes the names of the parties and the attorneys who will be representing them at trial; the nature of the case; the claims, counterclaims and cross-claims; and the de- fenses raised to those claims.
For each witness presented by deposition or other prior testimony, the pretrial order must identify proposed testimony by page and line, objections and their basis, and the asserted basis for admissibility.
Court's wording
For wit- nesses who will be presented by deposition or other prior testimony, the pretrial order must include the following information for each such witness: (a) the tes- timony that each side seeks to present, by page and line; (b) a concise statement of objections to any testimony and the basis for the objections; and (c) a concise statement of the asserted basis of admissibility.
An itemization of damages and other relief sought.
A list of the attorneys trying the case, including business addresses and telephone numbers.
Plaintiff’s counsel must prepare the initial draft of the pretrial order and provide a draft to de- fendant’s counsel by no later than twenty-one (21) calendar days before the date the pretrial order is due to be filed.
After the pretrial conference and rulings on exhibits, parties must submit to the Court on two thumb drives the final, pre-marked exhibits along with ex- hibit lists.
10. Proposed Findings and Conclusions. In a bench trial, proposed findings of fact and conclusions of law. The parties shall confer about and submit any agreed proposed findings of fact and conclusions of law. Each party also shall submit its separate proposed findings of fact and conclusions of law.
9. List of motions in limine: each party must provide a list summarizing its mo- tions in limine.
The Proposed Pretrial Order must also be filed on the docket with a cover page with the case caption and the title "Proposed Pretrial Order."
- Document
- Proposed pretrial order
Must include
- •Caption
The parties are required to meet and confer to discuss their respective drafts, and should attempt to reach agreement to the maximum extent possible.
Defendant’s counsel must respond in writing to the draft by no later than fourteen (14) calendar days before the pretrial order is due.
At least one week before the pretrial conference, the parties must submit an exhibit binder containing copies of the objected-to exhibits.
It is then the responsibility of the plaintiff’s counsel – with full cooperation from defendant’s counsel – to assemble the pretrial order and file it.
The parties must file a joint document that includes both (a) each party’s proposed voir dire questions, and (b) each party’s ob- jections, if any, to the voir dire questions proposed by other parties.
The parties must meet and confer in order to attempt to agree on jury instructions and the verdict forms.
The parties must exchange any proposed variations or additions to these general voir dire questions and must meet and confer to attempt to resolve any disagreements about the questions.
Every motion in limine must include a statement confirming consultation with the opposing party and that the disputed evidence is actually intended to be offered.
Court's wording
Any motion in limine filed by a party must be ac- companied by a statement that the party has conferred with the opposing party and has determined that the matter upon which a ruling is sought is actually in dispute – that is, that the opposing party actually intends to offer the evidence that the movant seeks to exclude.
Joint documents of proposed voir dire, jury instructions and verdict forms must be filed on the docket and also submitted in Word format to Judge Rowland’s proposed or- der mailbox (Proposed_Order_Rowland@ilnd.uscourts.gov).
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 proposed voir dire and jury instructions are to be prepared and submitted according to the following schedule, which may be varied only by Court order:
Motions in limine and supporting memoranda must be filed separately from the pretrial order as separate docket entries.
In a jury trial, proposed voir dire questions and jury instructions are not to be in- cluded in the Proposed Pretrial Order, but are to be separately filed.
In a jury trial, the parties should specify the number of jurors the parties recommend be selected (subject to Rule 48(a)).
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.
The same principles apply to proposed verdict forms.
The parties should compile and set forth the complete text of all proposed instructions and identify: the proponent of the instruction, the Seventh Circuit Pattern Instruction if applicable, the legal authority for the instruction, and whether there is an objection to the instruction.
Finally, parties should familiarize themselves with the Court’s Jury Evidence Recording System (JERS) protocol. Attorney Instructions are available here: https://www.ilnd.uscourts.gov/_assets/_documents/_forms/_courtroomtech/JERS_Attorney_Instructions.pdf.
You should expect Medicare to demand at least 60% of its conditional payments to your client to resolve the case.
Attorneys must pre-register with Medicare to request conditional payment letters.
- Document
- Medicare conditional payment letter
Must include
- •Proof of representation
Court's wording
Your client may access their payments directly by logging to his MyMedicare.gov account. As his attorney, you may request such a letter but must pre-register to do so by submitting proper proof of representation or consent to release this information.
In a jury trial, these lists will be read to the jury during voir dire.
In a jury trial, this statement will be read by the Court to the jury during voir dire.
11. Settlement discussions: parties should report whether any recent settlement discussions have occurred and the prospect of settlement before trial begins.
If the meet-and-confer process results in agreement that certain matters are inadmissible, that agreement should be memorialized in a stipulation to be provided in the pretrial order or at the final pretrial conference.
Filing & Service rules
Electronic Filing Rules
When filing the Proposed Pretrial Order in CM/ECF, the filer should select “Other Filings,” then “Other Documents,” and choose the Proposed Pretrial Order event.
In CM/ECF, the filer should select “Other Filings” and then “Other Documents,” and choosing the Proposed Pretrial Order event.
Civil cases
Page 3 | Instructions for Compiling and Submitting the Pretrial Order
Filing Timing and Cure Windows
The general schedule sets listed motion, response, pretrial-material, and conference deadlines, but the Court sets case-specific dates and alone may vary deadlines.
In each case, the Court will set specific dates, however, generally the schedule prior to the trial date will proceed as follows: (a) motions in limine and Daubert motions due 4 weeks prior to trial; (b) responses to motions in limine and Daubert motions due 3 weeks prior to trial; (c) pretrial order, proposed voir dire, and proposed jury instructions due 3 weeks prior to trial; and (d) the final pretrial conference will be held 2 weeks pri- or to trial. Deadlines may be varied only by the Court.
Civil cases
Page 1 | I. SCHEDULE
Filing Bundling Requirements
Motions in limine must be filed separately from joint pretrial statement.
Motions in limine and supporting memoranda must be filed separately from the joint pretrial statement as separate docket entries.
Criminal cases
Replies to motions in limine are not permitted unless ordered by the Court.
No replies will be filed unless ordered by the Court.
Criminal cases
Responses to motions in limine should also be submitted in one document.
Responses to motions in limine should also be submitted in one document.
Criminal cases
Parties encouraged to consolidate multiple motions in limine into fewer filings.
To the extent reasonable, parties should file multiple motions in one filing (or a few consolidated filings) to reduce the number of filings.
Criminal cases
When reasonable, parties should consolidate multiple motions into one or a few filings to reduce filing volume.
To the extent reasonable, parties should file multiple motions in one filing (or a few consolidated filings) to reduce the number of filings.
Civil cases
Page 4 | III. MOTIONS IN LIMINE
Pre-Motion Conference Requirements
The parties must meet and confer on all motions in limine before filing.
The parties shall meet and confer on all motions in limine before filing them.
Civil cases
Page 4 | III. MOTIONS IN LIMINE
Unless the court orders otherwise, responses to motions in limine are due one week after filing, and replies require leave of court.
Unless otherwise ordered, responses are due one week after the motion’s filing, and no replies may be filed without leave of court.
Civil cases
Page 4 | III. MOTIONS IN LIMINE
Judge Rowland discourages boilerplate motions in limine and motions addressing matters that are not in dispute.
Judge Rowland discourages the filing of “boilerplate” motions in limine or motions that address matters not in dispute.
Civil cases
Page 4 | III. MOTIONS IN LIMINE
Chambers Communication Rules
Joint documents must be filed on docket and emailed in Word format to specific mailbox.
Joint documents of the joint pretrial statement, proposed voir dire, jury instructions and verdict forms must be both filed on the docket and also submitted in Word format to Judge Rowland’s proposed order mailbox: Proposed_Order_Rowland@ilnd.uscourts.gov.
Criminal cases
Parties must contact Court systems department 3 weeks before trial for evidence presentation needs.
At least three weeks prior to trial, the parties shall contact the Court’s systems department (312-435-6045) to coordinate any specific evidence presentation needs.
Criminal cases
The parties must contact the Court’s systems department at least three weeks before trial to coordinate specific evidence-presentation needs.
At least three weeks prior to trial, the parties shall contact the Court’s systems department (312-435-6045) to coordinate any specific evidence presentation needs.
Civil cases
Page 5 | VI. TRIAL BRIEFS, EVIDENCE PRESENTATION, AND EXHIBITS
If the parties are required to reschedule or if they have concluded that a settlement conference is not necessary, they should inform chambers as soon as possible.
If the parties are required to reschedule or if they have concluded that a settlement conference is not necessary, they should inform chambers as soon as possible.
Civil cases
Page 4 | F. TOPICS TO BE DISCUSSED