Northern District of Illinois Document Format Requirements

Format

DOCX

Proposed pretrial orders filed electronically via CM/ECF; email Word copy to judge.

Proposed pretrial orders must be filed electronically using CM/ECF (no need for courtesy copies). To file it, select the appropriate CM/ECF event, “Other Filings” and then “Other Documents,” and choose the Proposed Pretrial Order event. Also email it to Proposed_Order_Chang@ilnd.uscourts.gov in Microsoft Word format.

Required

Always

Format

PDF

JERS accepts specific file types for documents, photos, video, and audio.

JERS accepts these common file types: Documents and Photographs: .pdf, .jpg. Video and Audio Recordings: .avi, .wmv, .mpg, .mp3, .wma, .wav

Required

Always

Exhibits must be named with number_underscore_neutral description format.

To use JERS, both sides must use the following exhibit-naming convention, which also will serve as the file name for the digital file: the exhibit number, followed by an underscore, followed by a neutral description of the exhibit. The convention is thus: Examples: 1_Financial Statement 2009 Annual.pdf 2_Contract 2010 Renewal.pdf 3_Photo Front Door.jpg 4_Audio Dec 11 2013 Phone Call.mp3 5_Video Traffic Stop.wmv

Parties must submit a USB/DVD/CD with all proposed exhibits and 2 sets of exhibit binders with objected-to exhibits only.

the parties must submit to chambers a USB storage device, DVD, or CD with all of the proposed exhibits. In addition to the disc, the parties also must supply 2 sets of exhibit binders containing copies of objected-to exhibits only.

Objecting party must state grounds for objection and proposed modification on the page immediately following the disputed instruction.

if an instruction is disputed, the objecting party must concisely state—on the page immediately following the instruction—the grounds for the objection, as well as any proposed modification or alternative.

Five business days before trial, each party must supply exhibits on USB/DVD/CD and one paper set double-sided in three-ring binders.

five business days before trial, each party shall supply (a) the exhibits in digital format on a USB drive, DVD, or CD; and (b) the exhibits in paper copy (just 1 set), double-sided in three-ring binders.

Electronic exhibits must use JERS format and naming convention.

With regard to creating and naming the electronic versions of the exhibits, the parties must use the exhibit-file format and exhibit-naming convention for the Jury Evidence Recording System (JERS).

Format

PDF

Final trial exhibits must be on password-free USB drive with OCR.

A USB Key/Thumb Drive with no password protection 2 containing a .pdf of each final trial exhibit. The parties must use the exhibit-file format and exhibit-naming convention for JERS. See Exhibit 3. All exhibits must have OCR-text recognition run on them.

Margins

1 in

Final trial exhibits must be double-sided in tabbed three-ring binder.

One binder containing a copy of each final trial exhibit. The exhibits must be printed double-sided and placed in a three-ring binder with tabs separating each exhibit.

Format

PDF

USB key/thumb drive must have no password protection.

A USB Key/Thumb Drive with no password protection 1 containing a .pdf of

Margins

1 in

Objected exhibits must be double-sided in tabbed three-ring binder.

One binder containing a copy of any proposed exhibits to which a party has raised an objection. The exhibits must be printed double-sided and placed in a three-ring binder with tabs separating each exhibit. Unless the parties agree otherwise, the party that is offering an exhibit is responsible for providing the copy of the objected-to exhibit.

Format

PDF

Impeachment/RR exhibits require separate USB folder with chart, no hard copies.

For any exhibits that a party plans to use at trial to impeach a witness or to refresh a witness’s recollection, the party must provide the exhibits on the USB Key/Thumb Drive in a separate folder titled “Impeachment and RR Exhibits.” The party must also include in this folder a separate .pdf exhibit chart of these exhibits in a format similar to the primary exhibit chart, with only columns for exhibit number, date, and description. The party should begin numbering these exhibits at least 50 numbers after its last exhibit on its primary exhibit chart. The party need not provide hard copies of these exhibits in advance of trial.

Required

Always

JERS accepts specific file types for documents, photos, video, and audio.

JERS accepts these common file types: Documents and Photographs: .pdf, .jpg. Video and Audio Recordings: .avi, .wmv, .mpg, .mp3, .wma, .wav

Required

Always

Exhibits must follow specific naming convention: 3-digit number, underscore, neutral description.

To use JERS, both sides must use the following exhibit-naming convention, which also will serve as the file name for the digital file: the exhibit number (3 digits), followed by an underscore, followed by a neutral description of the exhibit. The convention is thus: <exhibit number> <exhibit description>.<file extension>

Required

Always

Physical objects need numbered exhibit designation and one-page PDF stand-in for JERS.

One last thing: a physical object of course will not be imported into JERS, but you should still assign a consecutively numbered exhibit designation to it, along with a neutral description. Then create a one-page .pdf with the exhibit number and neutral description on it, and submit those exhibits as part of the JERS USB Key/Thumb Drive.

Deposition designations must be submitted on USB drives with color-coding.

At least five business days before the pretrial conference, the parties must submit to chambers two USB storage devices with all of the disputed deposition designations. Plaintiff’s designations must be color-coded in blue, and Defendant’s designations must be color-coded in red.

Paper exhibits double-sided in three-ring binders; electronic exhibits named, read-only, OCR'd and text-searchable.

All paper exhibits should be printed double-sided and placed in three ring binders with appropriate cover sheets, exhibits lists, and number tabs. All exhibits should be numbered (e.g., PX1, DX1, etc.) All electronic exhibits should be saved in standard file formats, named consistent with the exhibit number and brief description (e.g., PX1 Contract.pdf) and be saved "read-only" and/or locked for editing. Any exhibit in .pdf format should undergo Optical Character Recognition (OCR) and be text-searchable.

Exhibits must follow JERS naming convention.

The parties must use the exhibit-naming convention for the Jury Evidence Recording System (JERS); the court will provide the parties with an instruction memorandum on how to use JERS and name exhibits.

PDF exhibits must be OCR'd and text-searchable.

Any exhibit in .pdf format should undergo Optical Character Recognition (OCR) and be text-searchable.

Required

Always

JERS accepts specific file types for documents, photos, video, and audio.

JERS accepts these common file types: Documents and Photographs: .pdf, .jpg. Video and Audio Recordings: .avi, .wmv, .mpg, .mp3, .wma, .wav

Required

Always

Exhibits must be named with number_underscore_neutral_description.file_extension format.

To use JERS, both sides must use the following exhibit-naming convention, which also will serve as the file name for the digital file: the exhibit number, followed by an underscore, followed by a neutral description of the exhibit. The convention is thus: <exhibit number> <exhibit description>.<file extension>

Required

Always

Exhibits must use consecutive numbers only, no letters or parts.

Use consecutive numbers to designate exhibits; do not use letters to distinguish exhibits. Also, do not use an “exhibit part,” such as 1A or 2A. Just use consecutive numbers (plus the neutral description).

Exhibits must be tabbed with protruding tabs per Local Rule 5.2.

Significant and supporting exhibits may be attached and are often quite helpful both to the court and to opposing counsel. If exhibits are included, they must be tabbed with protruding tabs in accordance with Local Rule 5.2.

Pretrial Order must be three-hole bound or spiral bound with tabs.

The Pretrial Order either should be placed in a three-hole binder or spiral bound on the left side of the document, with tabs on the right side.

Pretrial Order must have separate, tabbed, numbered sections.

The subjects discussed below should be addressed in separate, tabbed and numbered sections of the Pretrial Order.

Pretrial Order must be three-hole bound or spiral-bound with tabs.

The Pretrial Order either should be placed in a three-hole binder or spiral-bound on the left side of the document, with tabs on the right side.

Plaintiff exhibit file names must begin with numerical characters.

Specific Format: The exhibit name(s) for plaintiff(s) begin with numerical characters.

Defendant exhibit file names must begin with alpha characters.

Specific Format: The exhibit name(s) for defendant(s) begin with alpha characters.

Exhibit file names must follow the format <exhibit number> - <exhibit part>_<exhibit description>.<file extension>.

General Format: <exhibit number> - <exhibit part>_<exhibit description>.<file extension>

Exhibit number and exhibit part fields are capped at 4 characters each, and the exhibit description field is capped at 200 characters.

The maximum number of characters that may be used in the <exhibit number> and the <exhibit part> field is 4 each. The maximum number of characters that may be used in the <exhibit description> field is 200.

Do not include '(ID)' in the exhibit number or description of an electronic copy submitted for use in JERS.

For any exhibit that is marked for identification, do not include “(ID)” in the exhibit number or description of the electronic copy submitted for use in JERS.

Counsel must ensure the electronic version of each exhibit shown to jurors is an exact replica of the admitted evidence.

Counsel are responsible to ensure that the electronic version of each exhibit available for viewing by jurors during deliberations is an exact replica of what was admitted in evidence.

JERS accepts .pdf, .jpg, .avi, .wmv, .mpg, .mp3, .wma, .wav files; .xls files not accepted.

JERS accepts these common file types: Documents and Photographs: .pdf, .jpg. Video and Audio Recordings: .avi, .wmv, .mpg, .mp3, .wma, .wav JERS does NOT except .xls (excel) file types. Spreadsheets will need to be saved as a PDF or provided as a paper document.

Exhibits must be named: exhibit number_underscore_description.file extension.

To use JERS, both sides must use the following exhibit-naming convention, which also will serve as the file name for the digital file: the exhibit number, followed by an underscore, followed, if you wish, by a neutral description of the exhibit (the description is not required; it is optional). The convention is thus: <exhibit number>__<exhibit description>.<file extension>

Multiple parties: coordinate exhibit numbering (A001, B001, etc.).

If there are multiple parties on a particular side, then you must coordinate with your co-plaintiff's or co-defendant's attorney to generate a consecutively numbered set of exhibits. For example, Defendant 1 would be A001, A002, A003, etc.; Defendant 2 would use B001, B002, B003, etc.

Required

Always

Electronic exhibits must use JERS format and naming convention.

With regard to creating and naming the electronic versions of the exhibits, the parties must use the exhibit-file format and exhibit-naming convention for the Jury Evidence Recording System (JERS).

Court reporters must separately bind pages of confidential transcribed deposition testimony and deposition exhibits.

Pages of transcribed deposition testimony or exhibits to depositions that are designated as Confidential Information pursuant to the process set out in this Order must be separately bound by the court reporter and may not be disclosed to anyone except as permitted under this Order;

Required

Always

Format

COMPUTER_OR_TABLET

Cell phones prohibited for videoconference participation.

The Court will not allow any counsel or party to appear using a cell phone. All participants must use a computer or tablet or be in the same room as someone with a computer or tablet.

Pretrial Order must be in three-hole binder or clipped with tabs.

The Pretrial Order either should be placed in a three-hole binder or clipped at the top left corner of the document, with tabs on the right side.

Format

DOCX

Proposed Final Pretrial Order must be in Word format.

In preparation for the final pretrial conference, the parties shall jointly prepare and submit a Proposed Final Pretrial Order containing the below listed items by email to Chambers_BassEhler@ilnd.uscourts.gov in Word format with all counsel included as cc: recipients.

Required

Always

Format

PDF

JERS accepts specific file types for documents, photos, video, and audio.

JERS accepts these common file types: Documents and Photographs: .pdf, .jpg. Video and Audio Recordings: .avi, .wmv, .mpg, .mp3, .wma, .wav

Required

Always

Exhibits must be named with number, underscore, and neutral description.

To use JERS, both sides must use the following exhibit-naming convention, which also will serve as the file name for the digital file: the exhibit number, followed by an underscore, followed by a neutral description of the exhibit. The convention is thus: <exhibit number>__<exhibit description>.<file extension>1

Required

Always

Exhibit numbers must be consecutive without letters or parts.

Use consecutive numbers to designate exhibits; do not use letters to distinguish exhibits. Also, do not use an “exhibit part,” such as 1A or 2A. Just use consecutive numbers (plus the neutral description).

Required

Always

Multiple parties on same side must coordinate exhibit numbering.

If there are multiple parties on a particular side, then you must coordinate with your co-plaintiff’s or co-defendant’s attorney to generate a consecutively numbered set of exhibits.

Required

Always

Physical objects need PDF stand-ins for JERS with exhibit number and description.

One last thing: a physical object of course will not be imported into JERS, but you should still assign a consecutively numbered exhibit designation to it, along with a neutral description. Then create a one-page .pdf with the exhibit number and neutral description on it, and submit those exhibits as part of the JERS disc.

Footnote 1 must be removed from the proposed Agreed Confidentiality Order before submission to the court.

Parties are to delete this footnote when submitting their proposed Order.

Changes to the model Agreed Confidentiality Order must be indicated via redlining with deletions and additions marked.

Any changes to this model order must be shown by redlining showing both deletions and additions.

Footnote 2 must be removed from the proposed order once Section 2 (Confidential Information) is finalized.

Parties are to delete this footnote once the Paragraph is finalized.

Court reporters must separately bind confidential deposition transcript pages and exhibits, which may only be disclosed as permitted by this Order.

Pages of transcribed deposition testimony or exhibits to depositions that are designated as Confidential Information pursuant to the process set out in this Order must be separately bound by the court reporter and may not be disclosed to anyone except as permitted under this Order;

Exhibit binders must have tabs corresponding to exhibit numbers.

The exhibit binders should separate the exhibits with tabs that correspond to the exhibit number.

The exhibit description field is limited to 200 characters.

The exhibit description field is limited to 200 characters.

Exhibit descriptions must use neutral and non-adversarial language.

All exhibits shall be described using neutral and non-adversarial terms.

Counsel should have an electronic copy of newly introduced unlisted exhibits available for the courtroom deputy whenever possible.

For any unlisted exhibit introduced following direct examination of witnesses at trial, counsel should, whenever possible, have an electronic copy available for the courtroom deputy.

Exhibits for manual upload should be provided on a CD/DVD or USB drive and named using the proper naming convention.

The exhibits should be on a CD/DVD or USB drive and named using the proper naming convention referenced above.

Plaintiff/government electronic exhibits must be named beginning with numerical characters using the format <exhibit number> - <exhibit part>_<exhibit description>.<file extension>.

Plaintiff(s)/Government: (Exhibit name(s) begin with numerical characters) General Format: <exhibit number> - <exhibit part>_<exhibit description>.<file extension>

Defendant electronic exhibits must be named beginning with alpha characters using the format <exhibit number> - <exhibit part>_<exhibit description>.<file extension>.

Defendant(s): (Exhibit name(s) begin with alpha characters) General Format: <exhibit number> - <exhibit part>_<exhibit description>.<file extension>

Electronic exhibits in JERS must not display exhibit numbering stickers; the exhibit description replaces the use of stickers.

While exhibit stickers are used for paper/physical exhibits, the electronic exhibits provided for use in JERS should not display the exhibit numbering stickers. The exhibit description given to the electronic version replaces the use of exhibit stickers.

Avoid group exhibits; multi-page documents cannot be separated in JERS.

Try to avoid "group exhibits." A document with multiple pages cannot be separated into subparts once it is entered into the JERS system. If there is a reasonable chance that you will be offering only part of a multiple-page exhibit, use

Exhibit description limited to 200 characters.

The neutral description cannot be more than 200 characters (hopefully, you'll never come close to that limit).

Required

Always

No formal presentations allowed; interactive discussions required.

The Court does not want the parties to prepare formal presentations about their case. Rather, the parties or their representatives should come to the settlement conference prepared to participate in interactive discussions.

The exhibit chart's format must be substantially similar to the provided example, and landscape orientation is encouraged.

The chart’s format shall be substantially similar to the example below (landscape orientation is encouraged).

Required

Always

Format

PDF

JERS allows jury to review digital exhibits on monitors instead of paper copies.

JERS is a computer system that the jury will use to review exhibits on a wide-screen video monitor, rather than reviewing paper copies. The jury room has the JERS computer, a touch-screen monitor for the jury to pick an exhibit to display, and the wide-screen monitor. JERS can display what otherwise would have been on paper (including photos), and JERS also can play audio and video files.

Margins

1 in

Exhibit charts should follow example format with landscape orientation encouraged.

The chart’s format shall be substantially similar to the example below (landscape orientation is encouraged).

Required

Always

Digital exhibit stickers allowed but limited to party designation and exhibit number.

If you’re using litigation-display software that imprints a “digital” exhibit sticker on documentary exhibits, that’s fine, though you should confine the exhibit sticker to the party designation (e.g., Pla or Gov, and Def) and the exhibit number.

Plaintiffs: numbers; defendants: letters. Use leading zeros for >10 exhibits.

It is recommended that plaintiffs use consecutive numbers to designate exhibits and defendants use letters to distinguish exhibits. (However, using consecutive numbers for both parties is acceptable.) In a case in which you will have more than ten exhibits, use leading zeroes when numbering your exhibits (001, 002, etc.). And “exhibit part may be used, such as 001-A.

Required

Always

Margins

1 in

Settlement conference follows traditional mediation format with joint and private sessions.

The Court generally will follow a traditional mediation format, in which the Court initially meets with the participants together and then has private meetings with each side.

Margins

1 in

Exhibit chart format example showing required columns.

No. Date Description Relevance Objection 1 02/15/06 2005 Proves record of R. 402 relevant; R. Performance satisfactory job 403 confusion. Review performance Plaintiff fired in 2011.

Exhibit charts should use landscape orientation.

The chart’s format shall be substantially similar to the example below (landscape orientation is encouraged).

Required

Always

PDF exhibits should be OCR-processed and text-searchable.

Ideally, any exhibit in /pdf format will have undergone Optical Character Recognition (OCR) and be text-searchable.

Parties should use Seventh Circuit Pattern Jury Instructions for jury trials where applicable, unless there is a good reason to not use them.

Judge Bass Ehler refers to the Seventh Circuit Pattern Jury Instructions, and where applicable those instructions should be used absent a good reason for not doing so.

Required

Always

Format

DOCX

Court prefers separate editable Word documents for pretrial items.

The Court prefers the items be separate Word documents that are editable.

Required

Always

Settlement conferences are typically remote via video but can be in-person if requested; format includes joint session followed by private caucuses.

The Court typically conducts settlement conferences remotely via video conferencing; however, the Court will hold a conference in-person if the parties’ request. The Court generally holds a joint session with short opening remarks and questions by the Court, generally with no opening presentations by the parties. This short, joint session will be followed by each party having private caucuses with the Court. The Court expects both the lawyers and the party representatives to be fully prepared to participate openly during these discussions. Statements made by any party during the settlement conference are not to be used in discovery and will not be admissible at trial.

Required

Always

Digital exhibit stickers limited to party designation and number.

If you are using litigation-display software that imprints a “digital” exhibit sticker on documentary exhibits, that is fine, though you should confine the exhibit sticker to the party designation (e.g., Pla or Gov, and Def) and the exhibit number.