Northern District of Illinois Page & Word Limits

Attorney limit

5 pages

Applies to

Joint initial status report

Joint initial status report limited to 5 pages.

Counsel are directed to confer, prepare, and file a joint initial status report, not to exceed five pages.

Attorney limit

10 pages

Applies to

Settlement statement

Settlement statements limited to 10 pages each.

Settlement statements should be no more than 10 pages each.

Limit

200 characters

Required

Always

Applies to

Exhibit name

Neutral description in exhibit names limited to 200 characters.

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

Attorney limit

15 questions

Applies to

Voir dire questions

Each side limited to 15 disputed voir dire questions unless good cause shown.

Each side is limited to 15 proposed disputed questions, unless a motion is filed before the Pre-Trial Conference that explains good cause for proposing more than the limit.

Attorney limit

35 pages

Attorney limit

21 pages

Attorney limit

14 pages

Applies to

Motion in limine

Motions in limine must be e-filed 35 days before Pre-Trial Conference; responses due 21 days; replies due 14 days.

Unless otherwise ordered, all motions in limine shall be e-filed 35 days (5 weeks) before the Pre-Trial Conference; responses are due and shall be e-filed 21 days (3 weeks) before the Pre-Trial Conference; and replies are due and shall be e-filed 14 days (2 weeks) before the Pre-Trial Conference.

Attorney limit

6 pages

Applies to

Settlement letter

Settlement letters limited to 6 pages (excluding exhibits).

Each of these letters should be six pages or fewer, exclusive of exhibits unless prior leave of Court is sought.

Attorney limit

12 pages

Applies to

Disputed questions

Each side limited to 12 proposed disputed questions (good cause exception).

Each side is limited to 12 proposed disputed questions, unless a motion is filed before the pretrial conference that explains good cause for proposing more than the limit.

Attorney limit

30 pages

Applies to

Motion in limine

Motions in limine must be filed 10 business days before final pretrial conference, limited to 30 pages in a single pleading.

All other trial-related motions in limine must be filed by the date ordered by the Court, or if no date has been set, then any such motions in limine must be filed at least ten business days prior to the Final Pretrial Conference. Each party shall file its motions in limine within a single pleading not to exceed 30 pages, with each issue separately numbered and argued within the pleading.

Attorney limit

30 pages

Applies to

Response to motion in limine

Responses to motions in limine must be filed 5 business days before final pretrial conference, limited to 30 pages.

Five business days prior to the Final Pretrial Conference, or on the date otherwise set by the Court, each party shall file its response. The response shall consist of a single pleading, not to exceed 30 pages, with each issue separately addressed and listed with the same numbering as the motions in limine.

Attorney limit

5 pages

Applies to

Initial status report

Initial status report limited to 5 pages and due 3 business days before status conference.

the parties shall jointly prepare and file an initial status report, not to exceed five pages, and file the report at least three business days before the initial status conference set in the case.

Attorney limit

20 pages

Applies to

Motion in limine

Motions in limine limited to 20 pages per side; responses limited to 20 pages per side; no replies unless ordered.

Absent prior leave of Court, motions in limine (not including exhibits) are limited to a total of 20 pages per side (not per motion) and responses (not including exhibits) are likewise limited to a total of 20 pages per side. No replies are to be filed unless ordered by the Court.

Attorney limit

12 questions

Applies to

Voir dire questions

Each side limited to 12 disputed voir dire questions unless good cause motion filed.

Any additional questions sought by the parties must be listed in the final pretrial order, divided into (a) agreed-upon questions and (b) proposed questions to which one party objects. A short basis for any objection should accompany the list. Each side is limited to 12 proposed disputed questions, unless a motion is filed before the pretrial conference that explains good cause for proposing more than the limit.

Attorney limit

15 questions

Applies to

Voir dire questions

Each side limited to 15 proposed disputed voir dire questions.

Each side is limited to 15 proposed disputed questions, unless a motion is filed before the pretrial conference that explains good cause for proposing more than the limit.

Attorney limit

25 pages

Applies to

Motion in limine

Motions in limine limited to 25 pages per side.

Motions in limine are limited to 25 pages per side absent leave of Court.

Attorney limit

3 pages

Applies to

Status report

Joint status report limited to 3 pages.

The joint status report shall generally not exceed three pages and shall contain the following information:

Attorney limit

5 pages

Applies to

Settlement letter

Settlement letters limited to 5 pages; 10 pages requires leave.

The Court expects that each of these letters typically should be five pages or fewer. Parties must obtain leave of Court before submitting letters longer than ten pages.

Attorney limit

1 hours

Applies to

Attorneys only conference

Attorneys-Only conferences limited to 1 hour.

An initial Attorneys-Only Conference, lasting no more than one hour, will most likely be set in advance of a full conference.

Attorney limit

5 pages

Applies to

Rule 26f report

Rule 26(f) report limited to 5 pages, due 2 business days before initial status conference.

counsel are directed to confer, prepare, and file a Rule 26(f) report, not to exceed five pages except in extraordinary circumstances, no later than two business days prior to the initial status conference.

Attorney limit

80 statements

Attorney limit

40 statements

Applies to

Summary judgment statement

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.

Attorney limit

5 pages

Applies to

Joint status report

Joint status report limited to 5 pages.

Counsel are to confer, prepare and file a brief, joint1 status report, not to exceed five pages.

Attorney limit

10 pages

Applies to

Memorandum

Plaintiff must file 10-page memorandum within 2 weeks of filing Schedule A case.

Within 2 weeks of filing a “Schedule A” case, plaintiff shall file a memorandum, not to exceed 10 pages:

Attorney limit

5 pages

Applies to

Memorandum

Plaintiff must file 5-page memorandum before or upon default judgment motion.

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:

Limit

10 pages

Applies to

Memorandum

Plaintiff's initial memorandum in Schedule A cases is limited to 10 pages.

Within 2 weeks of filing a 'Schedule A' case, plaintiff shall file a memorandum, not to exceed 10 pages addressing the following topics: a. Joinder. Plaintiff must demonstrate that defendants are properly joined under Federal Rule of Civil Procedure 20. b. Personal Jurisdiction. Plaintiff must demonstrate that this court can exercise personal jurisdiction over each defendant.

Limit

5 pages

Applies to

Memorandum on default judgment

Plaintiff's memorandum in Schedule A cases with foreign defendants, filed before or upon a default judgment motion, is limited to 5 pages.

In any 'Schedule A' case where defendants are located abroad, in accordance with the Hague Convention, before or upon filing a motion for default judgment, plaintiff shall file a memorandum, not to exceed five pages, addressing: a. whether the addresses of defendants are known; and b. if the addresses of defendants are not known, the efforts that plaintiff undertook to discover defendants' addresses.

Attorney limit

5 pages

Applies to

Joint status report

Joint status report required 3 business days before initial status hearing, max 5 pages.

The parties are directed to file a joint status report at least 3 business days prior to the initial status hearing, not to exceed 5 pages, containing the following information:

Attorney limit

5 pages

Applies to

Joint status report

Joint status report limited to 5 pages.

The parties are directed to file a joint status report not exceeding 5 pages, containing the following information:

Attorney limit

10 pages

Applies to

Trial brief

Trial briefs limited to 10 pages without leave of court.

Any trial briefs shall be limited to 10 pages without leave of court.

Attorney limit

25 claims

Attorney limit

50 claims

Applies to

Initial infringement contentions

Initial infringement contentions limited to 25 claims per patent, max 50 total.

(a) an identification of no more than 25 claims of each patent in suit that are allegedly infringed by the opposing party, but no more than 50 claims total, including for each claim the applicable statutory subsection of 35 U.S.C. § 271;

Attorney limit

10 claims

Attorney limit

20 claims

Applies to

Final infringement contentions

Final infringement contentions must identify max 10 claims per patent, 20 total, within 19 weeks.

(1) Within nineteen (19) weeks after the due date for service of Initial Infringement Contentions, each party claiming patent infringement must serve on all other parties a list identifying no more than 10 claims per patent and no more than 20 claims overall that the party is asserting, each of which must be selected from claims identified in the Initial Infringement Contentions.

Attorney limit

10 claims

Attorney limit

20 claims

Applies to

Final infringement contentions

Final infringement contentions due within 21 weeks; max 10 claims per patent, 20 total.

(2) Within twenty-one (21) weeks after the due date for service of Initial Infringement Contentions, each party claiming patent infringement must serve on all other parties "Final Infringement Contentions" containing the information required by LPR 2.2 (a)-(h). In the Final Infringement Contentions, no Accused Instrumentality may be accused of infringing more than ten (10) claims per patent and twenty (20) claims overall, selected from the claims identified in the Initial Infringement Contentions.

Attorney limit

25 prior_art_references

Applies to

Final invalidity contentions

Final invalidity contentions limited to 25 prior art references unless court orders otherwise.

Final Invalidity Contentions may rely on more than twenty-five (25) prior art references only by order of the Court upon a showing of good cause and absence of unfair prejudice to opposing parties.

Attorney limit

4 prior_art_grounds

Attorney limit

4 non_prior_art_grounds

Attorney limit

8 total_grounds

Applies to

Final unenforceability invalidity contentions

Final invalidity contentions limited to 4 prior art grounds and 4 non-prior art grounds per claim.

For each claim alleged to be invalid, the Final Unenforceability and Invalidity Contentions are limited to four (4) prior art grounds per claim and four (4) non-prior art grounds. No claim asserted to be infringed shall be subject to more than eight (8) total grounds per claim.

Attorney limit

25 pages

Applies to

Opening brief

Opening claim construction brief limited to 25 pages.

Within thirty-five (35) days after the exchange of terms set forth in LPR 4.1(a), the parties opposing infringement shall file their Opening Claim Construction Brief, which may not exceed twenty-five (25) pages absent prior leave of court.

Attorney limit

25 pages

Applies to

Responsive brief

Responsive claim construction brief limited to 25 pages.

Within twenty-eight (28) days after filing of the Opening Claim Construction brief, the parties claiming infringement shall file their Responsive Claim Construction Brief, which may not exceed twenty-five (25) pages absent prior leave of Court.

Attorney limit

15 pages

Applies to

Reply brief

Reply claim construction brief limited to 15 pages.

Within fourteen (14) days after filing of the Responsive Claim Construction Brief, the parties opposing infringement shall file their Reply Claim Construction Brief, which may not exceed fifteen (15) pages absent prior leave of Court.

Attorney limit

10 pages

Applies to

Settlement statement

Settlement statements limited to 10 pages each.

Settlement statements should be no more than 10 pages each.

Attorney limit

15 pages

Applies to

Motion

Motions in limine limited to 15 pages per party (support/opposition) and 15 pages per party (response).

Absent prior leave of Court, motions in limine (not including exhibits) are limited to a total of 15 pages per party (not per motion), and responses (not including exhibits) are likewise limited to a total of 15 pages per party.

Attorney limit

15 pages

Applies to

Motion in limine

Motions in limine limited to 15 pages per party (total, not per motion); responses also limited to 15 pages per party.

Absent prior leave of Court, motions in limine (not including exhibits) are limited to a total of 15 pages per party (not per motion), and responses (not including exhibits) are likewise limited to a total of 15 pages per party.

Attorney limit

2 pages

Applies to

Case statement

Case statement limited to 1-2 paragraphs covering case nature, claims, and defenses.

A concise agreed statement of the case (no more than one or two short paragraphs), including: (a) the nature of the case; (b) the claims, counterclaims and cross-claims; and (c) the defenses raised to those claims.

Attorney limit

2 pages

Applies to

Juror questionnaire

Written juror questionnaire limited to two pages.

To the extent possible, the Court prefers that most questions asked of potential jurors be included in a written questionnaire (of no more than two pages) as it encourages reflection and candor.

Attorney limit

3 sentences

Applies to

Witness description

Witness descriptions limited to two or three sentences maximum.

For each witness, provide a very concise (two or three sentences maximum) description of the witness and the witness’s role in the case.

Attorney limit

15 questions

Applies to

Voir dire questions

Each side limited to 15 proposed disputed voir dire questions unless good cause shown.

For additional questions, the parties must file a list divided into (a) agreed-upon questions and (b) proposed questions to which there is an objection. A short basis for any objection must accompany the list. Each side is limited to 15 proposed disputed questions, unless a motion is filed before the pretrial conference that explains good cause for proposing more than the limit.

Attorney limit

10 pages

Applies to

Settlement statement

Settlement statements limited to 10 pages.

Settlement statements should be no more than 10 pages each.

Attorney limit

15 pages

Applies to

Motion in limine

Motions in limine and responses limited to 15 pages per party total.

Absent prior leave of Court, motions in limine (not including exhibits) are limited to a total of 15 pages per party (not per motion), and responses (not including exhibits) are likewise limited to a total of 15 pages per party.

Attorney limit

10 pages

Applies to

Voir dire questions

Each side limited to 10 disputed voir dire questions unless good cause shown.

Each side is limited to 10 proposed disputed questions, unless a motion is filed before the pretrial conference that explains good cause for proposing more than the limit.

Attorney limit

6 pages

Applies to

Settlement letter

Settlement letters limited to 6 pages double-spaced (excluding exhibits).

Parties must limit settlement letters to six pages double-spaced, exclusive of exhibits, unless they obtain leave of Court, which may be obtained by emailing the Courtroom Deputy.

Attorney limit

15 pages

Applies to

Trial brief

Trial briefs required for bench trials (15 pages max), jury trials only with leave.

Trial briefs are required as part of the Pretrial Order in bench trials. Ordinarily, Judge Gilbert will not accept trial briefs in a jury trial, unless he has granted a prior motion to file such a brief or ordered the filing of a trial brief sua sponte. Any trial briefs shall be limited to 15 pages without leave of court.

Attorney limit

5 motions

Each side limited to 5 motions in limine without leave of court.

Absent prior leave of court, each side is limited to a total of five (5) motions in limine.

Attorney limit

7 pages

Applies to

Settlement letter

Settlement letters are limited to a maximum of 7 pages.

Settlement letters should be no more than 7 pages each.

Attorney limit

5 pages

Applies to

Joint status report

When the Court requires an initial joint status report, the report must not exceed five pages.

The joint status report shall contain the following information and be no more than five pages:

Attorney limit

10 pages

Applies to

Settlement statement

Settlement statements limited to 10 double-spaced pages.

Settlement statements should be no more than 10 double-spaced pages each.

Attorney limit

15 pages

Applies to

Trial brief

Trial briefs limited to 15 pages without court permission.

Any trial briefs shall be limited to 15 pages without leave of court.

Attorney limit

10 pages

Applies to

Settlement position statement

Settlement position statements limited to 10 pages each.

Position statements should be no more than 10 pages each.

Limit

5 pages

Applies to

Settlement letter

Settlement letters are limited to 5 pages, exclusive of exhibits, unless the Court grants leave for more.

As a general rule, parties must limit settlement letters to no more than five (5) pages, exclusive of exhibits, unless they obtain leave of Court.

Attorney limit

5 count

Applies to

Motion in limine

Maximum of five motions in limine per side.

Parties are limited to no more than five motions in limine per side unless otherwise ordered by the court.

Attorney limit

15 pages

Applies to

Voir dire questions

Each side is limited to 15 proposed disputed voir dire questions unless good cause shown.

Each side is limited to 15 proposed disputed questions, unless a motion is filed before the pretrial conference that explains good cause for proposing more than the limit.

Attorney limit

5 pages

Applies to

Settlement letter

Settlement letters should be 5 pages or fewer, but may be longer if necessary.

Each of these letters typically should be five (5) pages or fewer. However, if counsel believes that more pages are required to provide the comprehensive presentation required, the letter may be as long as deemed necessary.

Attorney limit

25 pages

Attorney limit

15 pages

Applies to

Brief

Multiple infringers may justify additional pages or separate briefing.

The presence of multiple alleged infringers with different products or processes shall, in an appropriate case, constitute good cause for allowing additional pages in the Opening, Responsive, or Reply Claim Construction Briefs or for allowing separate briefing as to different alleged infringers.

Attorney limit

10 count

Applies to

Voir dire questions

Each side limited to 10 disputed voir dire questions unless good cause shown.

Each side is limited to 10 proposed disputed questions, unless a motion is filed before the pretrial conference that explains good cause for proposing more than the limit.

Government limit

6 challenges

Defendant limit

10 challenges

Required

Always

Applies to

Peremptory challenges

Government gets 6 peremptory challenges; defendant gets 10.

The government has 6 peremptory challenges and the defendant has 10 peremptory challenges pursuant to Federal Rule of Criminal Procedure 24, unless otherwise requested and approved by the Court.

Applies to

Daubert motion

Daubert motions exempt from page limits.

These limitations do not apply to motions challenging the admissibility of Rule 702 expert testimony pursuant to Daubert v. Merrell Dow Pharmaceuticals, Inc.