Northern District of Illinois Pre-Motion Conference Requirements

CRITICALCivil cases

Parties must meet and confer on all motions in limine before filing, and state if there is no objection.

The parties must meet and confer on all motions in limine before the motions are filed. If there is no objection, but the movant wishes to file a motion memorializing the issue and non-objection, then the motion must state that there is no objection.

CRITICALCriminal cases

Motions in limine must be thoroughly briefed; the Court will set a briefing schedule.

The motions in limine must be briefed as thoroughly as possible (the Court will set a briefing schedule in each case).

CRITICALCivil cases

A final pretrial conference will be held before trial to address motions in limine, witness and exhibit objections, and contested jury instructions, and trial counsel fully prepared with authority to discuss all aspects of the case must attend.

A final pretrial conference will be held before trial. The court will address pending motions in limine, objections to witnesses and exhibits, and contested jury instructions, and it will discuss trial procedures and scheduling. Trial counsel fully prepared and with authority to discuss all aspects of the case must attend.

CRITICALCivil cases

The parties must confer before filing any motion in limine.

The parties must confer on all motions in limine before filing them.

CRITICALCivil cases

The parties must confer on every motion in limine before filing it.

The parties must confer on all motions in limine before filing them.

CRITICALCivil cases

A party disputing a Confidential/Highly Confidential designation must give written notice identifying the disputed materials and proposing a new designation, and the parties must meet and confer before involving the Court.

If a party disputes a producer's designation of information as Confidential or Highly Confidential, the party shall notify the producer in writing of the basis for the dispute, identifying the specific document[s] or thing[s] as to which the designation is disputed and proposing a new designation for such materials. The party and the producer shall then meet and confer to attempt to resolve the dispute without involvement of the Court.

CRITICALCivil cases

Failure to meet the telephonic-hearing requirements results in personal appearances unless the Court grants a motion for leave to appear telephonically.

If the Court determines that any of these requirements has not been met, it will bar counsel from appearing telephonically and thereafter require counsel to personally appear. Barred counsel will only be allowed to appear telephonically after a motion seeking leave to appear telephonically has been filed, presented, heard and granted.

CRITICALCivil cases

The parties must meet and confer under FRCP 26(f) and conduct a planning conference before filing the joint Initial Status Report.

The parties are directed to meet pursuant to Federal Rule of Civil Procedure 26(f) and conduct a planning conference.

CRITICALCivil cases

Counsel for both sides must meet and confer to try to resolve instruction disagreements no later than 10 calendar days before trial.

By no later than ten (10) calendar days before trial, plaintiff’s counsel and defendant’s counsel must meet and confer to attempt to resolve any disagreements about instructions.

CRITICALCivil cases

The parties must meet and confer at least seven days before the Pretrial Order is due to discuss their drafts and seek agreement where possible.

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.

CRITICALCivil cases

The parties must comply with Local Rule 37.2 before filing any motion, including a motion in limine.

The parties are reminded that the Court’s Case Management Procedures require compliance with Local Rule 37.2 before filing any motions, including motions in limine.

CRITICALCivil casesProposed or draft document; may not be in force

Meet-and-confer required before filing motions in limine.

The parties must confer on all motions in limine before filing them.

CRITICALCivil cases

Parties must conduct Rule 26(f) planning conference.

If the parties have not already done so, they are directed to meet pursuant to Federal Rule of Civil Procedure 26(f) and conduct a planning conference.

CRITICALCivil cases

Before filing motions in limine, the parties must meet and confer to identify any unopposed motions that need not be filed.

The parties are directed to meet and confer on all motions in limine before filing them and determine which motions, if any, are unopposed and do not need to be filed.

CRITICALCivil cases

Replies may not be filed unless the Court orders otherwise.

No replies are to be filed unless ordered by the Court.

CRITICALCivil cases

Before filing a Daubert motion, the parties must meet and confer to confirm that the challenged opinions will be offered at trial.

As with motions in limine, the parties are required to meet and confer before the filing of any Daubert motion to ensure that the opinions sought to be barred will be offered at trial.

CRITICALCivil cases

The parties must confer in good faith about stipulations and uncontested facts no later than 5 business days before the pretrial order due date.

No later than 5 business days before the due date, the parties must confer in good faith to arrive at as many stipulations and uncontested facts as possible.

CRITICAL

Responses to motions in limine due one week after filing; no replies without leave.

Unless otherwise ordered, responses are due one week after the motion’s filing, and no replies may be filed without leave of court.

CRITICALCivil cases

Parties must conduct Rule 26(f) planning conference.

The parties are directed to meet pursuant to Federal Rule of Civil Procedure 26(f) and conduct a planning conference.

CRITICALCivil cases

Propose briefing schedule for pending motions.

Identify all pending motions and propose a briefing schedule if one has not been set.

CRITICALCivil cases

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.

CRITICALCivil cases

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.

CRITICALCivil cases

A reply in support of a motion in limine may be filed only with leave of Court.

Any replies in support of motions in limine will be accepted only with leave of Court.

CRITICAL

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.

CRITICAL

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.

CRITICALCivil cases

Parties must meet and confer on all motions in limine before filing.

The parties are directed to meet and confer on all motions in limine before filing them.

CRITICALCriminal cases

Meet and confer required before filing motions in limine.

The parties are directed to meet and confer on all motions in limine before filing them.

CRITICALCriminal cases

Motions in limine due 3 weeks before pretrial order; responses due 1 week before.

Unless otherwise ordered, all motions in limine must be filed three weeks before the filing of the pretrial order. Responses are due one week before the filing of the pretrial order.

CRITICALCivil cases

Motions in limine must be filed 3 weeks before pretrial order; responses due 1 week before.

Unless otherwise ordered, all motions in limine must be filed three weeks before the filing of the pretrial order. Responses are due one week before the filing of the pretrial order. No replies will be filed unless ordered by the Court.

CRITICALCivil cases

Parties must meet and confer on jury instructions before filing pretrial order.

The parties are instructed to meet and attempt to agree on jury instructions and to file proposed instructions before filing the pretrial order.

CRITICALCivil cases

Final pretrial conference 1-3 weeks before trial; lead counsel must attend.

A Final Pretrial Conference will be held approximately one to three weeks before trial. The purpose of this conference will be to avoid surprises and to simplify the trial. At the conference, the Court will address any pending motions in limine, objections to witnesses and exhibits, contested jury instructions, trial procedures, and scheduling matters. Lead trial counsel fully prepared and with authority to discuss all aspects of the case must attend.

CRITICALCivil cases

Motions in limine must be filed with the pretrial order or on a court-specified date, and the parties must meet and confer before filing them.

All motions in limine must be filed with the pretrial order or on the date specified by the Court. The parties are directed to meet and confer on all motions in limine before filing them.

CRITICALCriminal cases

Substantial exhibit objections must be filed as motions in limine.

Any substantial objection to an exhibit shall be filed as a motion in limine.

CRITICALCivil cases

Meet and confer required before filing motions in limine; unopposed motions should be described in final pretrial order.

The parties are directed to meet and confer on all motions in limine before filing them and determine which motions, if any, are unopposed and do not need to be filed. Unopposed motions in limine should be briefly described in the final pretrial order.

CRITICAL

Parties challenging confidentiality designation must confer directly with designating party in good faith before judicial intervention.

A party challenging the designation of Confidential Information must do so in good faith and must begin the process by conferring directly with the designating party.

CRITICALCivil cases

For disputes about the scope of preservation efforts, the parties must meet and confer and explain their positions; unresolved issues should be raised promptly with the Court.

If there is a dispute concerning the scope of a party's preservation efforts, the parties or their counsel must meet and confer and fully explain their reasons for believing that additional efforts are, or are not, reasonable and proportionate, pursuant to Rule 26(b)(2)(C). If the parties are unable to resolve a preservation issue, then the issue should be raised promptly with the Court.

CRITICALCivil cases

Before seeking discovery about another party’s preservation and collection efforts, a party must confer with that party about the need for the discovery and alternative ways to obtain the information.

Accordingly, prior to initiating such discovery a party shall confer with the party from whom the information is sought concerning: (i) the specific need for such discovery, including its relevance to issues likely to arise in the litigation; and (ii) the suitability of alternative means for obtaining the information.

CRITICALCivil cases

Counsel primarily responsible for representing each party at the settlement conference must participate in the status hearing or call.

Counsel primarily responsible for representing the parties during the settlement conference must participate in this status hearing or call.

CRITICALCivil cases

Parties must meet and confer on all motions in limine before filing; absent prior leave, each side is limited to 5 total motions in limine.

The parties must meet and confer on all motions in limine before filing any such motion. Absent prior leave of court, each side is limited to a total of five (5) motions in limine.

CRITICALCivil cases

Discovery motions should not be noticed for presentment in accordance with Local Rule 5.3(b). The Court will review the motion and determine whether a hearing is necessary. Response briefs should not be filed absent order of the Court. If the Court determines a hearing is necessary, it will be scheduled by chambers and will either be in person, videoconference, or telephone depending on the circumstances. All parties must be fully prepared to argue the motion on the date of the hearing. The Court ordinarily will decide discovery motions on the date of the hearing and without briefing.

Discovery motions should not be noticed for presentment in accordance with Local Rule 5.3(b). The Court will review the motion and determine whether a hearing is necessary. Response briefs should not be filed absent order of the Court. If the Court determines a hearing is necessary, it will be scheduled by chambers and will either be in person, videoconference, or telephone depending on the circumstances. All parties must be fully prepared to argue the motion on the date of the hearing. The Court ordinarily will decide discovery motions on the date of the hearing and without briefing.

CRITICALCivil cases

An individual party must personally participate unless the parties agree otherwise and the Court grants leave.

Absent agreement of the parties and leave of court, if a party is an individual, that individual must personally participate.

CRITICALCivil cases

A corporation or governmental entity must have a non-record-counsel representative authorized to negotiate and settle personally participate.

If a party is a corporation or governmental entity, a representative of that corporation or governmental entity (other than counsel of record) with authorization to negotiate and authority to settle the case must personally participate.

CRITICALCivil cases

Individuals with settlement authority must personally participate in the entire settlement conference, except in the rarest circumstances.

Except in the rarest of circumstances, individuals with settlement authority on behalf of the parties are ordered to personally participate in the entire settlement conference.

CRITICALCivil cases

If insurance may pay any portion of the settlement, an insurer representative with authority to discuss financial contributions and other terms must attend.

In addition, if there is a potential for insurance coverage to pay any portion of the settlement, an insurer representative must attend with authority to discuss financial contributions and other terms.

CRITICALCivil cases

Having an authorized client or representative available by telephone is not a substitute for attendance unless unusual and extenuating circumstances apply and the Court approves in advance.

Having a client or representative with authority reachable by telephone during the settlement conference is not an acceptable alternative, except under the most unusual and extenuating circumstances (and must be approved by the Court ahead of time in those cases).

CRITICALCivil cases

Without good cause, noncompliance will result in an order requiring reimbursement of the opposing party’s attorney fees and costs for preparing for and attending the conference.

Failure to comply with this provision without good cause will result in an ===== PAGE 4 ===== order requiring the party in violation to reimburse the opposing party’s attorney fees and costs related to preparing for and appearing at the settlement conference.

CRITICAL

Motions in limine must be filed separately, 21 days before pretrial order, with responses due 14 days before.

The actual motions in limine are not to be bound with the final pretrial order, but must be submitted separately according to the following schedule: If no briefing schedule has been set, motions in limine shall be filed no later than twenty-one (21) days before the pretrial order is to be filed and responses no later than fourteen (14) days before the pretrial order is to be filed.

CRITICALCivil cases

The parties must confer on every motion in limine before filing it.

The parties must confer on all motions in limine before filing them.

CRITICALCivil cases

The parties must meet and confer to try to agree on as many jury instructions and verdict forms as possible.

The parties must meet and confer in order to attempt to agree on as many jury instructions and verdict forms as possible.

CRITICALCivil cases

Before seeking judicial intervention, a party challenging a confidentiality designation must confer directly and in good faith with the designating party, explain the basis for the challenge, and the designating party must respond within 5 business days.

A party challenging the designation of Confidential Information must do so in good faith and must begin the process by conferring directly with the designating party. When conferring, the challenging party must explain the basis for needing to use the challenged information in litigation and for its belief that the confidentiality designation is not proper and give the designating party an opportunity to reconsider and explain the basis for the designation. The designating party must respond to the challenge within 5 business days.

WARNINGCriminal cases

Parties should raise exhibit objections at the pretrial conference to resolve them before trial.

During the pretrial conference, the parties should raise any objections to exhibits that can be resolved before trial, in order to promote an expeditious trial and to avoid sidebars.

WARNINGCriminal cases

Parties must confer to try to agree on jury instructions and the verdict form.

The parties must confer in order to attempt to agree on as many jury instructions as possible, as well as the verdict form.

WARNINGCivil cases

The parties will argue all motions in limine at the Final Pretrial Conference unless the Court directs otherwise.

Unless otherwise directed by the Court, the parties will argue all motions in limine at the Final Pretrial Conference.

WARNINGCivil cases

Replies are prohibited unless the Court grants leave.

No replies will be permitted absent leave of Court.

WARNINGCriminal cases

Parties must meet and confer on all motions in limine before filing.

The parties are directed to meet and confer on all motions in limine before filing them. As explained below, unopposed motions in limine should be briefly described in the final pretrial order.

WARNINGCivil cases

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.

WARNINGCivil cases

Replies on motions in limine may not be filed unless the Court orders otherwise.

No replies will be filed unless ordered by the Court.

WARNINGCivil cases

Replies to motions in limine are not permitted unless ordered by the Court.

No replies should be filed unless ordered by the Court.

WARNINGCivil cases

The Court usually directs parties to confer about discovery scheduling before the initial status hearing.

The Court usually will direct the parties to confer in advance of the hearing about discovery scheduling.

WARNINGCivil cases

Parties should not notice discovery motions for presentation or hearing when filing them.

The Court has continued its practice, adopted during the COVID-19 pandemic, of not having parties notice their discovery motions for presentation or for motion hearing at the time of filing of the motion.

WARNINGCivil cases

The Court may deny a motion promptly without a hearing or additional briefing.

discretion, the Court may deny the motion promptly without a hearing and without any further briefing.

WARNINGCivil cases

A contested motion that does not strictly comply with Rule 37.2 may be denied without prejudice.

If the contested motion does not comply strictly with Rule 37.2 (all counsel are advised to review that rule carefully), the motion may be denied without prejudice.

WARNINGCivil cases

The Court may deny relief on a contested motion that states no grounds for relief or seeks relief plainly unwarranted under the circumstances.

If the Court determines that the contested motion does not state grounds for relief, or that the requested relief is plainly unwarranted under the circumstances of the case at that time and in the Court's substantial

WARNINGCivil cases

After required conferral, the movant should file a contested motion without noticing a hearing date.

For contested motions, after required conferral, the movant should file the motion without noticing it for a hearing date.

WARNINGCivil cases

For a contested motion with grounds for relief and a straightforward disputed issue, the Court may order a prompt hearing with oral argument and no further briefing.

If the contested motion states grounds for relief and the Court deems the disputed issue straightforward, the Court may order a prompt hearing with oral argument and no further briefing, so that the parties may present their positions more efficiently and inexpensively simply by appearing for a brief motion hearing.

WARNINGCivil cases

If a motion cannot be heard reasonably promptly, the Court may order prompt additional briefing and decide it on the papers.

If the motion cannot be heard reasonably promptly, the Court may order prompt additional briefing and decide the motion on the papers.

WARNINGCivil cases

After a hearing, the Court may order additional briefing if it determines briefing is necessary before deciding the motion.

If a hearing is held and the Court is persuaded that additional briefing is necessary before a decision, the Court may order additional briefing.

WARNINGCivil cases

For complex issues requiring briefing, the Court may order additional briefing and either decide the motion on the papers or hold a hearing after briefing is complete.

If the Court's review of the motion indicates that it raises more complex issues that will not lend themselves to a fair airing at a motion hearing without additional briefing, the Court may order additional briefing and may decide the motion on the papers or set the motion for a hearing after briefing is completed.

WARNINGCivil cases

The Court ordinarily will not initially adjust a schedule entered by the district court, but may do so on oral motion at the initial status hearing for good cause.

In the event that the district court already has entered a schedule, the Court ordinarily will not adjust it initially, except perhaps on oral motion at the initial status hearing and for good cause.

WARNINGCivil cases

For a referral that includes discovery supervision, the magistrate judge is likely to order a prompt, in-person initial status hearing on a floating status call date.

Upon a district court referral including discovery supervision, the magistrate judge is likely to order a prompt, in-person, initial status hearing on a floating status call date.

WARNINGCivil cases

The Court ordinarily will not schedule a settlement conference until all parties express a wish to participate; when the referral also includes discovery supervision, discovery usually continues until all parties wish to negotiate.

The Court ordinarily will not seek to schedule a settlement conference unless and until all parties have stated that they wish to participate in a settlement conference, and where the referral also includes discovery supervision, discovery usually will proceed until all parties wish to attempt to negotiate a resolution.

WARNINGCivil cases

The Court ordinarily will not stay discovery during settlement discussions unless mediation or settlement is scheduled or the Court is persuaded the discussions are serious or advanced.

The Court will not ordinarily stay discovery pending settlement discussions unless a mediation or settlement is scheduled, or unless the Court otherwise is persuaded of the serious or advanced nature of settlement discussions.

WARNINGCivil cases

After the parties mutually agree to a settlement conference and notify court staff, or upon a requested express settlement referral, the Court will promptly schedule a telephonic pre-settlement conference to confirm interest and readiness.

Once the parties mutually agree that they wish to engage in a settlement conference and have so advised court staff, or upon a referral for the express purpose of a settlement conference at the parties’ request, the Court promptly will schedule a pre-settlement telephonic conference to confirm mutual interest and readiness for a settlement conference (including whether the

WARNINGCivil cases

An unanswered email without a requested face-to-face or telephone conference does not satisfy Local Rule 37.2.

The Court does not consider an unanswered email, where no face-to-face or telephonic conference was requested, to be in compliance with the local rule.

WARNINGCivil cases

The Court prefers that parties first attempt to resolve deposition disputes under Local Rule 37.2 and present unresolved disputes by motion.

The Court generally prefers that parties resolve their deposition disputes consistent with Local Rule 37.2 and then present the dispute to the Court by motion if the dispute cannot be resolved.

WARNINGCivil cases

A motion that does not comply with Local Rule 37.2 risks denial without prejudice.

But filing a motion not in compliance with Local Rule 37.2 risks having the motion denied without prejudice.

WARNINGCivil cases

The Court strongly prefers in-person settlement conferences and permits remote participation only in hardship cases or other exceptional circumstances.

The Court's current strong preference is for in-person settlement conferences, with remote participation allowed only in hardship cases or other exceptional circumstances.

WARNINGCivil cases

The second pre-settlement telephonic conference generally occurs after all mediation statements are submitted and before the settlement conference.

The second pre-settlement telephonic conference will generally take place after all mediation statements are in but before the settlement conference.

WARNINGCivil cases

Counsel who fail to attend a confirmed settlement conference may be sanctioned.

Counsel are cautioned that failure to attend a confirmed settlement conference may result in the imposition of sanctions against them.

WARNINGCivil cases

Bring discovery disputes to the Court well before the cutoff; after the cutoff, parties must show the dispute could not have been raised earlier.

All discovery disputes requiring Court intervention should be brought to the Court’s attention well before the relevant discovery cutoff. Parties raising a discovery dispute after the cutoff must demonstrate that the dispute could not have been raised before the deadline.

WARNINGCivil cases

The corporate or governmental entity representative’s attendance obligation applies even when an insurer will bear all settlement obligations.

That attendance obligation exists whether or not the financial obligations of settlement will be borne exclusively by an insurer.

WARNINGCivil cases

The insurer-representative attendance requirement does not apply if the insurer disclaimed coverage or agreed in advance to pay its limits.

This requirement of attendance does not apply if the insurer has disclaimed coverage or agreed to pay its limits in advance of the settlement conference.

WARNINGCivil cases

The parties are expected to discuss ratification-related limitations with the Court during a pre-conference call.

The parties will be expected to discuss the limitations arising from these requirements in a pre-conference call with the Court.

INFOCivil cases

Motions in limine typically due with final pretrial order, with briefing to follow Court's schedule.

In most cases, motions in limine will be due on the same date as the final pretrial order, with response and reply briefs to follow according to the schedule set by the Court.

INFOCivil cases

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.

INFOCivil cases

Daubert motions should be filed separately and as soon as reasonably possible.

Such Daubert motions should be filed separately and as soon as reasonably possible, preferably well in advance of the final pretrial conference and the deadline for motions in limine.

INFOCivil cases

Most agreed or unopposed motions will be granted promptly without a hearing.

Most of these motions will be granted promptly without a hearing.

INFOCivil cases

The Court will promptly review contested motions and determine how to proceed.

The Court will review the motion promptly, and one of the following scenarios will occur:

INFOCivil cases

The Court has no standing hearing dates for discovery motions and independently decides whether a hearing is necessary.

The Court has not set aside standing dates and times for the hearing of discovery motions because the Court's practice is to determine on its own whether a hearing is even necessary, and the Court continually keeps its weekly calendar open for settlement conferences at the parties' convenience.

INFOCivil cases

If the Court has a question about an agreed or unopposed motion, it will schedule a hearing when available.

If the Court has a question, the Court will schedule a hearing at a date and time when the Court is available.

INFOCivil cases

The Court may decide whether to order a reply.

The Court may or may not order a reply.

INFOCivil cases

At the initial status hearing, the Court will entertain oral motions concerning an agreed or contested discovery schedule or other relief if the parties conferred in advance or already addressed proposed scheduling.

In that event, or if the parties already have addressed proposed discovery scheduling, the Court will entertain oral motions to enter an agreed or contested discovery schedule or for other relief.

INFOCivil cases

The Court may decide a discovery dispute without Local Rule 37.2 compliance when requiring compliance may be futile or inefficient.

Nonetheless, in some cases, the Court may exercise its discretion in favor of deciding a discovery dispute where requiring Local Rule 37.2 compliance may be futile, or where doing so may be inefficient.

INFOCivil cases

The Court will decide summary judgment motions in matters before the magistrate judge on consent.

The Court will decide summary judgment motions in matters before the magistrate judge on consent.

INFOCivil cases

Motions to strike or to deem Local Rule 56.1 facts admitted are disfavored.

Motions to strike or to have Local Rule 56.1 statement of facts deemed admitted are disfavored.

INFOCivil cases

After referral, if the parties indicate they are prepared to participate in settlement, the Court usually schedules a telephonic pre-settlement conference.

Upon a referral for settlement, when the parties have indicated that they are prepared to participate in a settlement conference with the magistrate judge, the Court usually will schedule a telephonic pre-settlement conference.

INFOCivil cases

The settlement conference may be held in person at the courthouse or remotely via WebEx.

The settlement conference can take place in person in the courthouse or remotely via WebEx.

INFOCivil cases

The parties should discuss their preferred conference format before the scheduling videoconference.

The parties should confer as to the preferred structure before the scheduling videoconference.

CRITICAL

Rule 37 meet-and-confer required before filing motions in limine.

Prior to filing any motions in limine, the parties are to have a Rule 37 meet-and-confer concerning the same; if that process results in agreement that certain matters are admissible or inadmissible, that agreement should be memorialized in a stipulation to be provided to Judge Holleb Hotaling in the Final Pretrial Order or at the final pretrial conference.

INFOCivil cases

Daubert motions should be filed early, separately from other motions.

Such Daubert motions should be filed separately and as soon as reasonably possible, preferably well in advance of the final pretrial conference and the deadline for motions in limine.