Northern District of Illinois Adjournment & Extension Requirements

Exchange voir dire questions 5 business days before deadline; confer 2 business days before.

Source text: Each side shall provide the other with proposed voir dire questions 5 business days before the due date of the Joint Pretrial Statement, and confer by 2 business days before the due date in order to generate this section of the Statement.

Serve proposed stipulations 5 business days before pretrial conference.

Source text: No later than 5 business days before the pretrial conference, the parties must serve on each other proposed stipulations.

Serve uncontested facts 2 business days before due date.

Source text: No later than 2 business days before the due date, the uncontested facts as possible.

Exchange exhibit charts 10 business days before deadline; return with objections 5 business days before.

Source text: The parties must exchange their respective proposed exhibit charts 10 business days before the deadline for filing the charts, and the objecting side must return the chart with the objection column filled in 5 business days before the deadline.

Settlement conferences can only be rescheduled by court order with 14-day advance written motion and supporting affidavit.

Source text: No conference, once scheduled, shall be rescheduled except by court order pursuant to written motion made and noticed not less than 14 days in advance of the conference. The motion shall fully explain the reasons for the requested extension and be supported by an affidavit/declaration justifying the need for the continuance.

Expedited transcript requests must be made 7 days before trial.

Source text: Any requests for daily or other expedited transcripts must be made directly to Judge Kness’s court reporter at least 7 days before the start of trial.

Opposing party must serve objections and counter-designations 14 business days before pretrial order due date.

Source text: The opposing party must serve objections to designations (including a concise basis for the objection, like the Exhibit Chart) and also state the opposing party’s counter-designations (including counter-designations conditioned on an objection being overruled) 14 business days in advance of the pretrial order’s due date.

Pretrial motions must be filed by Court-ordered date or specified deadline.

Source text: Any Pretrial Motions (including any motions under Federal Rules of Criminal Procedure 12(b)(1), (3), or (4); any motion to quash/suppress, dismiss, or sever; any motion for bill of particulars; any motion to admit co-conspirator statements via a Santiago Proffer; any motion for discovery/testing/inspection; any motion for authorization of an expert/investigator, or any other motion for CJA funding in excess of the statutory caps) must be filed by the date ordered by the Court, or if no

Plaintiff's letter due 14 business days before; defendant's letter due 7 business days before settlement conference.

Source text: Unless the Court sets a different schedule, plaintiff's counsel shall deliver copies of plaintiff's settlement letter to defendant's counsel and to Judge Ellis' classroom deputy (Room 1720) at least fourteen (14) business days before the settlement conference, and defendant's counsel shall deliver copies of defendant's settlement letter to plaintiff's counsel and to Judge Ellis' classroom deputy (Room 1720) at least seven (7) business days before the settlement conference.

Requests for expedited transcripts must be made at least 7 days before trial.

Source text: Any requests for daily or other expedited transcripts and real-time reporting must be made at least seven (7) days prior to trial.

Pretrial Order drafting schedule: plaintiff draft 21 days before due, defendant response 14 days before due, meet-and-confer 7 days before due.

Source text: Plaintiff’s counsel has the responsibility to prepare the initial draft of the Pretrial Order and must provide a draft to defendant’s counsel no later than twenty-one (21) days before the date the Pretrial Order is due. Defendant’s counsel must respond in writing to plaintiff’s draft by no later than fourteen (14) days before the Pretrial Order is due, including any objections, changes, and additions to plaintiff’s draft, as well as defendant’s portions of the draft Pretrial Order (e.g., defendant’s witness list, exhibit list, and objections to exhibits and deposition or other prior testimony listed by plaintiff). The parties must meet and confer by no later than seven (7) days before the Pretrial Order is due to discuss their respective drafts and to reach agreement to the extent possible.

Final pretrial conference scheduled at least 3 weeks before trial.

Source text: The Court will set a date for the final pretrial conference at least three weeks before trial.

Contact Systems Department at least 2 weeks before trial for technology assistance.

Source text: Contact the Systems Department within the Clerk’s Office at least two weeks before trial if you need assistance with understanding how to operate the courtroom display technology equipment.

Requests for expedited transcripts must be made at least 7 days before trial.

Source text: Any requests for daily or other expedited transcripts and real-time reporting must be made at least seven (7) days prior to trial.

Government must provide Pretrial Order draft 21 days before due date.

Source text: The government has the responsibility to prepare the initial draft of the Pretrial Order and must provide a draft to defendant’s counsel no later than twenty-one (21) days before the date the Pretrial Order is due.

Defendant must respond to Pretrial Order draft 14 days before due date.

Source text: Defendant’s counsel must respond in writing to the government’s draft by no later than fourteen (14) days before the Pretrial Order is due, including any objections, changes, and additions to the draft, as well as defendant’s portions of the draft Pretrial Order (e.g., defendant’s witness list, exhibit list, and objections to exhibits and deposition or other prior testimony).

Parties must meet and confer 7 days before Pretrial Order due date.

Source text: The parties must meet and confer by no later than seven (7) days before the Pretrial Order is due to discuss their respective drafts and to reach agreement to the extent possible.

Initial response to non-infringement/invalidity contentions due within 14 days.

Source text: Within fourteen (14) days after service of the Initial Non-Infringement and Invalidity Contentions under LPR 2.3, each party claiming patent infringement shall serve upon all parties its "Initial Response to Non-Infringement and Invalidity Contentions."

Declaratory judgment cases must comply with LPR 2.3/2.4 within 28 days if no infringement claim.

Source text: In a case initiated by a complaint for declaratory judgment in which a party files a pleading seeking a judgment that a patent is not infringed, is invalid, or is unenforceable, LPR 2.2 and 2.3 shall not apply unless a party makes a claim for patent infringement. If no claim of infringement is made, the party seeking a declaratory judgment must comply with LPR 2.3 and 2.4 within twenty-eight (28) days after the Initial Disclosures.

Final non-infringement/enforceability validity contentions due within 28 days of final infringement contentions.

Source text: Not later than 28 days after the due date for Final Infringement Contentions under LPR 3.1:

Initial expert disclosures due 28 days after claim construction ruling or close of discovery.

Source text: within twenty-eight (28) days after the claim construction ruling or the close of discovery after the claim construction ruling, whichever is later, each party shall make its initial expert witness disclosures required by Federal Rule of Civil Procedure 26 on issues for which it bears the burden of proof;

Rebuttal expert disclosures due 28 days after initial expert reports.

Source text: within twenty eight (28) days after the date for initial expert reports, each party shall make its rebuttal expert witness disclosures required by Federal Rule of Civil Procedure 26 on the issues for which the opposing party bears the burden of proof.

Expert depositions must be completed within 28 days after rebuttal disclosures.

Source text: Depositions of expert witnesses shall be completed within twenty-eight (28) days after exchange of expert rebuttal disclosures.

Exchange voir dire questions 5 business days before due date; confer 2 business days before.

Source text: Each side shall provide the other with proposed voir dire questions five business days before the due date of the Joint Pretrial Statement and shall confer by two business days before the due date in order to generate this section of the Statement.

Serve proposed stipulations 5 business days before pretrial conference; responses due 2 business days before.

Source text: No later than five business days before the pretrial conference, the parties must serve on each other proposed stipulations. No later than two business days before the pretrial conference, the parties must serve on each other their responses to the proposed stipulations.

Exchange exhibit charts 10 business days before deadline; return with objections 5 business days before.

Source text: Because of the need to work together to create the charts (because of the objection column), the parties must exchange their respective proposed exhibit charts 10 business days before the deadline for filing the charts, and the objecting side must return the chart with the objection column filled in five business days before the deadline.

Settlement conference rescheduling requires written motion filed 10 days in advance with full explanation.

Source text: Absent exigent circumstances, no conference shall be rescheduled except by court order pursuant to a written motion electronically filed and emailed to the Courtroom Deputy not less than 10 days in advance of the conference. The motion shall fully explain the reasons for the requested continuance.

Pretrial Order drafting timeline: 21 days (plaintiff draft), 14 days (defendant response), 7 days (meet-and-confer).

Source text: Plaintiff’s counsel has the responsibility to prepare the initial draft of the Pretrial Order and must provide a draft to defendant’s counsel no later than twenty-one (21) days before the date the Pretrial Order is due. Defendant’s counsel must respond in writing to plaintiff’s draft by no later than fourteen (14) days before the Pretrial Order is due, including any objections, changes, and additions to plaintiff’s draft, as well as defendant’s portions of the draft Pretrial Order (e.g., defendant’s witness list, exhibit list, and objections to exhibits and deposition testimony listed by plaintiff). The parties must meet and confer by no later than seven (7) days before the Pretrial Order is due to discuss their respective drafts and to reach agreement to the extent possible.

Parties rescheduling a settlement conference must inform the Courtroom Deputy as soon as possible.

Source text: If the parties must reschedule, have concluded that a settlement conference is not necessary or helpful at this time, or have otherwise resolved the case, they should inform Judge Bass Ehler’s Courtroom Deputy as soon as possible.

Daubert motions must be filed 60 days before trial unless court sets different schedule.

Source text: Unless the Court affirmatively sets a different schedule, any Daubert motions are to be filed no later than sixty (60) days prior to trial.

Motions in limine must be filed 21 days before trial; responses due 14 days before trial.

Source text: Unless the Court affirmatively sets a different schedule, motions in limine shall be filed no later than twenty-one (21) days before trial and responses no later than fourteen (14) days before trial.

Requests for expedited transcripts must be made 7 days before trial.

Source text: Any requests for daily or other expedited transcripts and real-time reporting must be made at least seven (7) days prior to trial so that an appropriate court reporter can be assigned to the trial.

Final pretrial conference must be scheduled at least 3 weeks before trial.

Source text: The Court will set a date for the final pretrial conference at least three weeks before trial.

Requests for expedited transcripts or real-time reporting must be made at least 7 days before trial.

Source text: Any requests for daily or other expedited transcripts and real-time reporting must be made at least seven days prior to trial so that an appropriate court reporter can be assigned to the trial.

Parties must meet and confer 7 days before Pretrial Order due date.

Source text: The parties must meet and confer by no later than seven days before the Pretrial Order is due to discuss their respective drafts and to reach agreement to the extent possible.

No continuances for settlement conferences without motion showing extreme hardship.

Source text: The Court sets aside a significant block of time for each settlement conference. Because of the volume of settlement conferences conducted by Judge Valdez, once a settlement conference date has been agreed upon, no continuance will be granted without a motion showing extreme hardship.

Written responses/requests for hearing due 12 days after TRO entry; hearing cancelled if none received.

Source text: Any written response to, or request for a hearing on, the anticipated motion for preliminary injunction must be received by 10:30 AM on [12 days after entry of TRO.] If no written response or request for a hearing is received by the deadline, the tentative preliminary injunction hearing will be stricken (that is, cancelled), and the court will rule on the papers.

Telephonic rescheduling requests for settlement conferences are not allowed except in exigent circumstances.

Source text: Telephonic requests to reschedule a settlement conference will not be entertained in the absence of exigent circumstances.

No recess requests before cross-examination; proceed immediately unless natural recess timing.

Source text: (xi) Do not ask for a recess before cross-examination. If the direct examination should end at about the time the court would recess anyway, e.g., lunch time, a recess will be taken. Otherwise, be prepared to commence cross-examination immediately upon conclusion of the direct.

Pretrial order due dates will not be extended for busy schedules.

Source text: Due dates for the submission of draft pretrial orders will not be extended absent circumstances beyond counsel’s control; a busy schedule is not such a circumstance.

Parties lacking full settlement authority may face sanctions including attorney's fees.

Source text: If a conference must be adjourned or continued so that a party may obtain additional authority up to the plaintiff’s demand, that party may be sanctioned, including, but not limited to, being required to pay the opposing party’s attorney’s fees incurred by the need to reconvene.

Failure to attend settlement conference without authorization may result in monetary sanctions.

Source text: Counsel are cautioned that failure to attend a settlement conference without authorization may result in the imposition of monetary sanctions against them.

Expedited transcript requests must be made at least 7 days before trial.

Source text: Any requests for daily or other expedited transcripts and real-time reporting must be made at least seven (7) days prior to trial so that an appropriate court reporter can be assigned to the trial.

Parties may seek exceptions to attendance rules by filing a motion.

Source text: A party who believes it has good cause for the Court to alter these rules should raise that issue by motion.

Early summary judgment motions permitted at judge's discretion.

Source text: This Rule does not preclude a party from moving for summary judgment at an earlier stage of the case if circumstances warrant. It is up to the trial judge to determine whether to consider an "early" summary judgment motion.