Judge Robert W. Gettleman
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Exhibits
- Before Trial
Binding: Three Ring Binder
Pretrial Order
- 2 copies
Page & Word Limits6 rules
Counsel are to confer, prepare and file a brief, joint1 status report, not to exceed five pages.
Joint Status Report
5 pages
Applies to: Attorney
Within 2 weeks of filing a “Schedule A” case, plaintiff shall file a memorandum, not to exceed 10 pages:
Memorandum
10 pages
Hague Convention on the Service Abroad of Judicial and Extra-Judicial Documents in Civil and Commercial Matters, before or upon filing a motion for default judgment, plaintiff shall file a memorandum, not to exceed five pages, addressing:
Memorandum
5 pages
Within 2 weeks of filing a "Schedule A" case, plaintiff shall file a memorandum, not to exceed 10 pages addressing the following topics:
Memorandum
10 pages
shall file a memorandum, not to exceed five pages, addressing:
Memorandum
5 pages
Summary judgment statements limited to 80 (a)(2) or 40 (b)(3)(B) facts.
Unless otherwise ordered, no statement filed pursuant to L.R. 56.1(a)(2) may contain more than 80 statements of uncontested fact, and no statement filed under L.R. 56.1(b)(3)(B) may contain more than 40 statements of additional fact.
Summary Judgment Statement
Document Format Requirements2 rules
3. Bind the original copy at the top, pursuant to Local Rule 5.2(d), but submit one extra copy to chambers bound on the side in a three-ring binder.
4. Include an index to each binder at the front of the binder. All subsections of the pretrial order should be tabbed for easy access by the reader.
Document Filing Requirements30 rules
7. Motions in limine shall be submitted under separate cover at the time the pretrial order is filed, and will generally be decided at or before the final pretrial conference.
DocumentMotion In Limine
It is the duty of the plaintiff's attorney to prepare the first draft of jury instructions, keeping in mind that the parties are expected to agree on all instructions other than those about which there is a genuine, material dispute.
DocumentJury Instructions
In jury trials, follow the cited jury-instruction requirements: present agreed instructions whenever possible, identify each instruction’s proponent and authority, number instructions, and make written objections with supporting citations; failure to object may waive an objection.
For jury trials, the court will insist on strict compliance with footnote 10 of paragraph 2(I) of the final pretrial order Form 16.1.1. This provision reads as follows: "Agreed instructions shall be presented by the parties whenever possible. Whether agreed or unagreed, each marked copy of an instruction shall indicate the proponent and supporting authority and shall be numbered. All objections to tendered instructions shall be in writing and include citations of authorities. Failure to object may constitute a waiver of any objection." (Emphasis in original.)
DocumentJury Instructions
The voir dire materials must include a short case description, expected-witness list, and names of people who may be mentioned at trial.
a. A short description of the case to be read to the venire panel, along with a list of the witnesses expected to testify and the names of people who may be mentioned at the trial;
DocumentVoir Dire Materials
b. Proposed voir dire questions. Upon request, Judge Gettleman’s chambers will provide counsel with the court’s standard voir dire questions; counsel are directed to suggest any variations or additions they believe are appropriate for their case.
DocumentVoir Dire Questions
b. Arrange in the order to be given.
DocumentProposed Jury Instructions
Place contested instructions in their proposed order and require the opposing party to state objection grounds and, when appropriate, tender an alternative; supporting materials may be included as described and must be included in the proposed-instructions binder.
d. Place contested instructions in the order they would be given if accepted, and for each such instruction the party opposing it must succinctly state the grounds for objection and, if appropriate, tender an alternate instruction. The parties may be able to accomplish this by highlighting, bracketing or redlining the challenged portion of an instruction and indicating alternate language within the body of the instruction. The proposing party may also submit the reasons supporting the instruction as tendered. These objections and supporting materials shall be included in the binder of proposed
DocumentProposed Jury Instructions
a. Unless otherwise ordered, use the Seventh Circuit Jury Instructions and, where Illinois law applies, use the Illinois Pattern Instructions.
DocumentProposed Jury Instructions
b. Personal Jurisdiction. Plaintiff must demonstrate the basis for this court's exercise of personal jurisdiction over each defendant.
DocumentMemorandum
a. Joinder. Plaintiff must demonstrate that defendants are properly joined under Federal Rule of Civil Procedure 20.
DocumentMemorandum
each defendant, and how that service complies with the Hague Convention on the Service Abroad of Judicial and Extra-Judicial Documents in Civil and Commercial Matter ("Hague Convention") and the Federal Rules of Civil Procedure.
DocumentMemorandum
If plaintiff claims it has no address information for a defendant, the memorandum must describe the diligent efforts undertaken to learn that defendant's mailing address.
b. if plaintiff asserts that it possesses no address information for a particular defendant, the efforts that plaintiff undertook to learn the defendant’s mailing address, see id. (When “a plaintiff asserts that it possesses no address information for a defendant….the court will not accept [that] assertion until it satisfies itself that plaintiff has made reasonably diligent efforts to learn the defendant’s mailing address.”).
DocumentMemorandum
a. whether plaintiff has address information for each defendant, see Santana, 2026 WL 2546903, at *3 (“When plaintiffs…have address information for a defendant, the court will presume that the defendant’s address is known for purposes of the Hague Convention.”);
DocumentMemorandum
c. the basis for this court’s exercise of personal jurisdiction over each defendant.
DocumentMemorandum
All memoranda in support of, or in opposition to, motions for summary judgment must contain a statement of facts section citing to and supported by the pertinent L.R. 56.1 statements.
DocumentSummary Judgment Memorandum
All material sought to be protected should be described in sufficient detail to justify such protection (e.g., "trade secrets," "personnel files," etc.). Parties should not be given total discretion to mark whatever material they choose to be protected or kept confidential.
DocumentProtective Order Motion
Rebuttal information required by Fed. R. Civ. P. 26(a)(2) must be provided no later than 30 days before the discovery cut-off date, unless otherwise ordered.
Each bench book should include an index of the exhibits, and exhibit should be tabbed for easy access by the court.
DocumentExhibit Bench Book
5. One copy of all deposition excerpts that the parties intend to read into the record should be submitted under separate cover prior to trial as set by the court at or before the final pretrial conference.
DocumentDeposition Excerpts
All objections to portions of deposition transcripts should be identified by marking such portions in a manner that will inform the court as to the nature of the objection and the offering party's response.
DocumentDeposition Excerpts
Any objections to exhibits and responses thereto should be appended to each exhibit.
DocumentExhibit Bench Book
All parties shall confer in good faith to accomplish this goal.
DocumentJury Instructions
c. Again, all instructions should be agreed except for those about which there is a genuine, good faith dispute.
DocumentProposed Jury Instructions
The court will use its standard prefatory instructions unless it approves a proposed variation, and encourages including an elements instruction at this stage.
a. This court will use its standard prefatory instructions, unless counsel suggest and the court approves a variation thereof. The court encourages including a version of the “elements” instruction to the jury at this stage.
DocumentPrefatory Jury Instructions
Make sure to tailor your proposed instructions to the parties in the case as well as the factual and legal issues to be presented.
DocumentJury Instructions
If any party wishes to communicate anything to the court that the party does not wish to share with other parties, the letter should include such information in a footnote or addendum, clearly stating that such information has not been shared with the other parties.
DocumentSettlement Letter
Seven days prior to the settlement conference, or on such other date as the court may direct, the parties will submit letters to Judge Gettleman conforming to the following directions:
DocumentSettlement Letter
Each party shall send a copy of that party's letter to all other parties;
DocumentSettlement Letter
All settlement letters will be discarded by Judge Gettleman at the close of the case.
DocumentSettlement Letter
8. The parties may submit pretrial briefs in non-jury as well as jury trials.
DocumentPretrial Brief
Filing & Service rules
Electronic Filing Rules
Jury instructions should be submitted both in hard copy and electronically filed with the clerk.
Jury instructions should be submitted in hard copy and also electronically filed with the clerk.
Civil cases
Page 5 | Jury Instructions and Voir Dire
Filing Timing and Cure Windows
Plaintiff must file the Schedule A memorandum within 2 weeks of filing the case.
Within 2 weeks of filing a "Schedule A" case, plaintiff shall file a memorandum, not to exceed 10 pages addressing the following topics:
Civil cases
Page 1 | 2. Plaintiff's memorandum within 2 weeks of filing
Service and Proof of Service Rules
The court will not accept a plaintiff's assertion that it lacks a defendant's address information unless the plaintiff has made reasonably diligent efforts to learn the defendant's mailing address.
When "a plaintiff asserts that it possesses no address information for a defendant….the court will not accept [that] assertion until it satisfies itself that plaintiff has made reasonably diligent efforts to learn the defendant's mailing address."
Civil cases
Page 2 | Service requirements under the Hague Convention and Federal Rules of Civil Procedure
Where the Hague Convention applies, it sets out the exclusive permitted methods of service, and the Hague Service Convention prohibits service by email in China.
See Kangol LLC v. Hangzhou Chuanyue Silk Imp. & Exp. Co., 177 F.4th 793, 800 (7th Cir. 2026) (explaining that where the Hague Convention applies, "it sets out the permitted methods of service and excludes all others," and holding "that the Hague Service Convention prohibits service by email in China.").
Civil cases
Page 2 | Service requirements under the Hague Convention and Federal Rules of Civil Procedure
The Hague Convention applies to service abroad in civil or commercial matters and does not apply where the defendant's address is unknown; when a plaintiff has address information for a defendant, the court presumes the address is known for Hague Convention purposes.
The Hague Convention states that "[t]he present Convention shall apply in all cases, in civil or commercial matters, where there is occasion to transmit a judicial or extrajudicial document for service abroad. This Convention shall not apply where the address of the person to be served with the document is not known." Art. 1, 20 U.S.T., at 362. "When plaintiffs…have address information for a defendant, the court will presume that the defendant's address is known for purposes of the Hague Convention."
Civil cases
Page 2 | Service requirements under the Hague Convention and Federal Rules of Civil Procedure
Courtesy Copy Requirements
Deliver the original and one copy of the proposed final pretrial order to chambers.
2. Deliver an original and one copy of the proposed final pretrial order to chambers.
Civil cases
Page 1 | Standing Order for Final Pretrial Order, Selection of Jurors and Jury Instructions for Trials Before Judge Gettleman
Submit one three-ring-binder exhibit bench book for each party to chambers before trial on the schedule set at or before the final pretrial conference.
6. One bench book of exhibits (in a three-ring binder) for each party should be submitted to chambers in advance of trial, pursuant to a schedule to be set at or before the final pretrial conference.
Civil cases
Page 1 | Standing Order for Final Pretrial Order, Selection of Jurors and Jury Instructions for Trials Before Judge Gettleman
Sealing & Redaction Procedures
Court approval required before filing any document under seal or as restricted.
No filing under seal, or any other designation as a restricted document, is to be permitted without previously-obtained court approval (see Citizens First Nat'l Bank v. Cincinnati Ins. Co., 178 F.3d 943 (7th Cir. 1999)).
Parties cannot amend protective order provisions regarding court approval or document return without court approval.
If the protective order contains any provision that would permit its amendment by agreement of the parties without requiring court approval, that power of amendment cannot extend to the subjects covered in paragraphs 1 and 2.
After the case is closed in the District Court (this requirement differs from L.R.26.2(e), which speaks of the case's "final disposition including appeals"), the parties may obtain the return of any previously-sealed or previously-restricted documents by a motion filed within a specified time period after the case is closed. Counsel are free to agree on that specified time period, but they should not designate more than a 63-day period. Any documents that are not so withdrawn will become part of the public case file, and the protective order must so provide.
After the case is closed in the District Court (this requirement differs from L.R.26.2(e), which speaks of the case's "final disposition including appeals"), the parties may obtain the return of any previously-sealed or previously-restricted documents by a motion filed within a specified time period after the case is closed. Counsel are free to agree on that specified time period, but they should not designate more than a 63-day period. Any documents that are not so withdrawn will become part of the public case file, and the protective order must so provide.
Pre-Motion Conference Requirements
Daubert motions due 60 days before trial or 10 days before discovery cut-off.
Any motions concerning expert qualifications filed pursuant to Daubert v. Merrill Dow Pharmaceuticals, 509 U.S. 579 (1993), and its progeny, shall be filed at least 60 days prior to trial, or 10 days prior to the discovery cut-off date, whichever is earlier.
Discovery motions require L.R. 37.2 statement; interrogatory limit of 25 without leave.
Civil discovery motions shall not be heard without a statement pursuant to L.R. 37.2 and Fed. R. Civ. P. 37(a)(1)(A). In addition, no party shall serve on any other party more than 25 interrogatories in the aggregate without leave of court.
Unless the court has already set a schedule, the parties should ask the court to set a briefing schedule for motions in limine before submitting the final pretrial order.
Accordingly, unless already set by the court, the parties should ask the court to set an appropriate briefing schedule for motions in limine in advance of the submission of the final pretrial order.
Civil cases
Page 2 | Standing Order for Final Pretrial Order, Selection of Jurors and Jury Instructions for Trials Before Judge Gettleman