Northern District of Illinois Pre-Motion Conference Requirements

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.

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).

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

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

Required

Always

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.

Required

Always

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.

Propose briefing schedule for pending motions.

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

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.

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.

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.

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.

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.

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.

Required

Always

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.

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.

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.

Substantial exhibit objections must be filed as motions in limine.

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

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.

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.

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.

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.

Parties challenging confidentiality designation must meet and confer in good faith with the designating party before filing a motion.

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.

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.

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.

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.

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

No replies should be filed unless ordered by the Court.

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.

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.

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.