Northern District of Illinois Service and Proof of Service Rules

CRITICALCivil cases

Applies to

Service on chinese entities

Serving Chinese entities via email is prohibited under the Hague Service Convention.

Serving Chinese entities via email is not permitted. Id. at *6 (the Hague Service Convention "prohibits service by email in China")

CRITICALCivil cases

Applies to

Motion

Third parties not named in the complaint cannot be named in active concert with defendants unless active concert is proven and they receive advance notice and opportunity to be heard.

Third parties not named in the complaint (e.g., Amazon, eBay, DHgate) cannot be named as in active concert or participation with the defendants unless their active concert or participation is proven and they receive advance notice and an opportunity to be heard before the Court enters any order against them. See Fed. R. Civ. P. 65(d)(2); Lake Shore Asset Mgmt. Ltd. v. Commodity Futures Trading Comm’n., 511 F.3d 762 (7th Cir. 2007).

CRITICALCivil cases

Motions seeking electronic service must comport with Kangol; serving Chinese entities via email is not permitted.

Any motion seeking electronic service must comport with Kangol LLC, v. Hangzhou Chuanyue Silk Import & Export Co., Ltd., 2026 WL 1502198 (7th Cir. May 29, 2026). Serving Chinese entities via email is not permitted.

CRITICALCivil cases

Service

Email to opposing party

Plaintiff must separately email Defendant Microsoft Word versions of the Exhibit Chart and Deposition Designation Chart.

Separately, Plaintiff shall e-mail a Microsoft Word version of Plaintiff’s Exhibit Chart and Plaintiff’s Deposition Designation Chart to Defendant.

CRITICALCivil cases

Service

Email to opposing party

Defendant must separately email Plaintiff Microsoft Word versions of Defendant’s Exhibit Chart and Deposition Designation Chart.

Separately, Defendant shall e-mail a Microsoft Word version of Defendant’s Exhibit Chart and Defendant’s Deposition Designation Chart to Plaintiff.

CRITICALCivil cases

Deadline

5 business days

The parties must serve proposed stipulations on each other at least five business days before the joint pre-trial memorandum is due.

No later than 5 business days before the due date of the joint Pre-Trial Memorandum, the parties must serve on each other proposed stipulations.

CRITICALCivil cases

Deadline

5 business days

Each side must provide proposed voir dire questions to the other five business days before the joint memorandum is due and confer by two business days before its due date.

Each side shall provide the other with proposed voir dire questions 5 business days before the due date of the joint Pre-Trial Memorandum, and confer by 2 business days before the due date in order to generate this section of the Pre-Trial Memorandum.

CRITICALCivil cases

Deadline

5 business days

The parties must serve proposed jury instructions on each other at least five business days before the joint memorandum is due and confer by two business days before the due date.

No later than 5 business days before the due date of the joint Pre-Trial Memorandum, the parties must serve on each other proposed jury instructions, and confer by 2 business days before the due date in order to generate this section of the Pre-Trial Memorandum.

CRITICALCivil cases

Service

Email to opposing party

Plaintiff must separately email Defendant Microsoft Word versions of the Exhibit Chart and Deposition Designation Chart.

Separately, Plaintiff shall e-mail a Microsoft Word version of Plaintiff’s Exhibit Chart and Plaintiff’s Deposition Designation Chart to Defendant.

CRITICALCivil cases

Service

Email to opposing party

Defendant must email Plaintiff Microsoft Word versions of its Exhibit Chart and Deposition Designation Chart.

Separately, Defendant shall e-mail a Microsoft Word version of Defendant’s Exhibit Chart and Defendant’s Deposition Designation Chart to Plaintiff.

CRITICALCivil cases

Deadline

5 business days

The parties must serve proposed stipulations on each other at least five business days before the joint Pre-Trial Memorandum is due.

No later than 5 business days before the due date of the joint Pre-Trial Memorandum, the parties must serve on each other proposed stipulations.

CRITICALCivil cases

Deadline

2 business days

A request to use exhibits during opening statements must be made to the opposing party at least two business days before trial begins.

Any request for the use of exhibits during opening statements must be made to the opposing party no later than two business days before the start of trial.

CRITICALCivil cases

Applies to

Expert identification and curriculum vitae

At least ten days before first disclosing Confidential or Highly Confidential information to an expert or consultant, the proposing party must serve the producer with a written identification of the expert and a copy of the expert's curriculum vitae.

At least ten days before the first disclosure of Confidential or Highly Confidential information to an expert or consultant (or member of their staff), the party proposing to make the disclosure must serve the producer with a written identification of the expert or consultant and a copy of his or her curriculum vitae.

CRITICALCivil cases

Applies to

Written objection

A producer with good cause to object (other than challenging the expert's qualifications) must serve a written objection on the disclosing party within ten days after service of the expert identification.

If the producer has good cause to object to the disclosure (which does not include challenging the qualifications of the expert or consultant), it must serve the party proposing to make the disclosure with a written objection within ten days after service of the identification.

CRITICALCivil cases

Applies to

Expert undertaking

The party obtaining the expert's signed undertaking must serve it on all other parties within ten days after execution.

The party obtaining the undertaking must serve it on all other parties within ten days after its execution.

CRITICALCivil cases

Applies to

Deposition transcript

Deposition testimony is designated Confidential or Highly Confidential by stating so on the record at the deposition or by written notice to the opposing party, stenographer, and videographer within 14 days after receipt of the transcript.

A person designates information in deposition testimony as Confidential or Highly Confidential by stating on the record at the deposition that the information is Confidential or Highly Confidential or by advising the opposing party and the stenographer and videographer in writing, within fourteen days after receipt of the deposition transcript, that the information is Confidential or Highly Confidential.

CRITICALCivil cases

Deadline

14 calendar days

Defendant’s counsel must serve plaintiff’s counsel, at least 14 calendar days before trial, a document identifying agreed and disputed instructions with dispute grounds and any modified or additional proposed instructions.

By no later than fourteen (14) calendar days before trial, defendant’s counsel must serve on plaintiff’s counsel a document setting forth: (a) which of plaintiff’s proposed instructions are agreed, (b) which of plaintiff’s proposed instructions are disputed (and the basis for any dispute), and (c) any modified or additional instructions proposed by defendant’s counsel.

CRITICALCivil cases

Deadline

21 calendar days

Unless the Court orders a different schedule, plaintiff’s counsel must serve proposed jury instructions on defendant’s counsel at least 21 calendar days before trial.

Absent an order of the Court setting a different schedule, by no later than twenty-one (21) calendar days before trial, plaintiff’s counsel must serve on defendant’s counsel a set of proposed jury instructions.

CRITICAL

Applies to

Assignment order

Service

Court service

When counsel is assigned to represent a pro se party and the summons and complaint have not yet been served, an order directing service by the U.S. marshal or other appropriate method must accompany the assignment order.

If service of the summons and complaint has not yet been made, an order directing service by the United States marshal or by other appropriate method of service shall accompany the assignment order.

CRITICAL

Applies to

Probation form 12c

When an after-hours arrest warrant petition is granted, the probation officer must provide a copy of the signed Probation Form 12C to the U.S. Marshals Service as proof of the warrant order.

If the petition is granted, the United States Probation Officer shall provide a copy of the signed Probation Form 12C to the United States Marshals Service as proof of the order issuing the warrant.

CRITICAL

Service

Electronic service

Registration as an E-Filer constitutes consent to electronic service of all documents under the Federal Rules of Civil and Criminal Procedure, evidenced by an express consent on the registration form.

Regisfuation as an E-Filer constitutes consent to electronic service of all documents as provided in this General Order and in accordance with the Federal Rules of Civil Procedure and Federal Rules of Criminal Procedure. The Clerk of the Court shall use an electronic and/or paper regisffation form that contains an express consent to service by electronic means in accordance with Fed. R. Civ. P. s(bX2XE) and Fed. R. Crim. P. 49(b).

CRITICAL

Service

Electronic service to all parties

The Clerk electronically transmits a Notice of Electronic Filing to all E-Filers immediately upon entry of an order or judgment, and that electronic transmission constitutes official notice under Fed. R. Civ. P. 77(d) and Fed. R. Crim. P. 49(c).

Immediately upon the enty of an order or judgment in a case assigned to ECF, the Clerk of the Court will kansmit to E-Filers in the case, in electronic form, a Notice of Electronic Filing. Elecfronic transmission of the Notice of Electronic Filing constitutes the notice required by Fed. R. Civ. P.77(d) and Fed. R. Crim. p. a9@).

CRITICAL

Applies to

Electronically filed document

Parties in ECF cases who are neither E-Filers nor represented by an E-Filer and who have not consented to electronic service are entitled to paper copies of electronically filed documents, served in accordance with the Federal Rules and local rules.

Parties to a case assigned to ECF, who are not E-Filers or represented by an E-Filer and who have not otherwise consented to service by electronic means under Fed. R. Civ. P. 5(bX2XD), are entitled to receive a paper copy of any elechonically filed document. Service of such paper copy must be made in accordance with the Federal Rules of Civil Procedure, the Federal Rules of Criminal Procedure, and the local rules of this court.

CRITICAL

Applies to

Electronically filed document

A certificate or affidavit of service (complying with the local rules) must be included with all electronically filed documents whenever service is made on a party who is not an E-Filer or is represented by an E-Filer.

Where service is made as to any party who is not an E-Filer or is represented by an E-Filer, a certificate or affidavit of service must be included with all documents filed electronically. Such certificate or affidavit shall comply with LR

CRITICAL

Applies to

Electronically filed document

Service

Electronic service to all parties

Except for sealed documents filed electronically, the ECF-generated Notice of Electronic Filing constitutes service on all E-Filers in the case under Fed. R. Civ. P. 5(b)(2)(E) and Fed. R. Crim. P. 49(d).

Except where sealed documents are filed electronically, subject to the provisions of Fed. R. Civ. P. 5OX3), the Notice of Electronic Filing constitutes service under Fed. R. Civ. P. 5(bX2)(E) and Fed. R. Crim. P. 49O) as to all E-Filers in a case assigned to ECF.

CRITICALCivil cases

Deadline

10 business days

Parties must serve proposed stipulations and uncontested facts on each other no later than 10 business days before the pretrial order is due.

No later than 10 business days before the pretrial order is due, the parties much serve on each other proposed stipulations and uncontested facts.

CRITICALCivil cases

Deadline

10 business days

When deposition testimony is proposed instead of live testimony, the offering party must serve page-and-line designations 10 business days before the pretrial order due date.

If a party proposes to introduce a witness’s testimony via a deposition rather than live testimony, then the offering party must serve the page/line designations of the deposition transcript on the opposing party 10 business days in advance of the pretrial order due date.

CRITICALCivil cases

Deadline

5 business days

The opposing party must serve designation objections with concise bases and state any counter-designations 5 business days before the pretrial order due date.

The opposing party must serve objections to designations (including a concise basis for the objection, like the Exhibit Chart discussed below) and also state the opposing party’s counter-designations (including counter-designations conditioned on an objection being overruled) 5 business days in advance of the pretrial order’s due date.

CRITICALCivil cases

Applies to

Final unenforceability and invalidity contentions

A party asserting invalidity or unenforceability must serve Final Unenforceability and Invalidity Contentions on all other parties at the same time as the Final Infringement Contentions.

Each party asserting invalidity or unenforceability of a patent claim shall serve on all other parties, at the same time that the Final Infringement Contentions are served, “Final Unenforceability and Invalidity Contentions” containing the information required by LPR 2.3 (b), (c) at the same time.

CRITICALCivil cases

Applies to

Final infringement contentions

A party claiming patent infringement must serve Final Infringement Contentions on all parties within 21 weeks after the due date for service of Initial Infringement Contentions.

A party claiming patent infringement must serve on all parties “Final Infringement Contentions” containing the information required by LPR 2.2 (a)–(h) within twenty-one (21) weeks after the due date for service of Initial Infringement Contentions.

CRITICALCivil cases

Deadline

14 calendar days

A party claiming patent infringement must serve its Initial Infringement Contentions on all parties within 14 days after the LPR 2.1 Initial Disclosure.

A party claiming patent infringement must serve on all parties “Initial Infringement Contentions” containing the following information within fourteen (14) days after the Initial Disclosure under LPR 2.1:

CRITICALCivil cases

Deadline

14 calendar days

A party opposing infringement or asserting invalidity or unenforceability must serve its Initial Contentions on all parties within 14 days after service of the Initial Infringement Contentions.

Each party opposing a claim of patent infringement or asserting invalidity or unenforceability shall serve upon all parties its "Initial Non-Infringement, Unenforceability and Invalidity Contentions" within fourteen (14) days after service of the Initial Infringement Contentions.

CRITICALCivil cases

Deadline

14 calendar days

Applies to

Initial response to invalidity contentions

A party claiming patent infringement must serve its Initial Response to Invalidity Contentions on all parties within 14 days after service of the initial contentions.

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 Invalidity Contentions.”

CRITICALCivil cases

Deadline

28 calendar days

Applies to

Final non infringement contentions

A party asserting non-infringement must serve Final Non-infringement Contentions on all other parties within 28 days after service of the Final Infringement Contentions.

Each party asserting non-infringement of a patent claim shall serve on all other parties “Final Non-infringement Contentions” within twenty-eight (28) days after service of the Final Infringement Contentions, containing the information called for in LPR 2.3(a).

CRITICALCivil cases

Applies to

Final contentions in response

A party asserting patent infringement must serve Final Contentions in Response at the same time as the Final Non-Infringement Contentions are served.

Each party asserting patent infringement shall serve, at the same time the “Final Non-Infringement Contentions” are served, Final Contentions in Response to any “Final Unenforceability and Invalidity Contentions.”

CRITICALCivil cases

Where the Hague Convention applies, it sets out the exclusive permitted methods of service, and the Hague Service Convention prohibits service by email in China.

See Kangol LLC v. Hangzhou Chuanyue Silk Imp. & Exp. Co., 177 F.4th 793, 800 (7th Cir. 2026) (explaining that where the Hague Convention applies, "it sets out the permitted methods of service and excludes all others," and holding "that the Hague Service Convention prohibits service by email in China.").

CRITICALCivil cases

The court will not accept a plaintiff's assertion that it lacks a defendant's address information unless the plaintiff has made reasonably diligent efforts to learn the defendant's mailing address.

When "a plaintiff asserts that it possesses no address information for a defendant….the court will not accept [that] assertion until it satisfies itself that plaintiff has made reasonably diligent efforts to learn the defendant's mailing address."

CRITICAL

Applies to

Notice of designation

Notice of Designation for deposition testimony must be served within 14 days of transcript delivery, or on-record designation is waived.

Within 14 days after delivery of the transcript, a designating party may serve a Notice of Designation to all parties of record identifying the specific portions of the transcript that are designated Confidential Information, and thereafter those portions identified in the Notice of Designation must be protected under the terms of this Order. The failure to serve a timely Notice of Designation waives any designation of deposition testimony as Confidential Information that was made on the record of the deposition, unless the Court orders otherwise.

CRITICAL

Deadline

3 business days

Receiving party must notify designating party in writing within 3 business days of subpoena/order to disclose Confidential Information.

If a receiving party is served with a subpoena or an order issued in other litigation that compels the disclosure of any material or document designated in this action as Confidential Information, the receiving party must notify the designating party in writing immediately and in no event more than 3 business days after

CRITICAL

Receiving party must promptly deliver a copy of the protective order to the party who issued the subpoena or court order.

The receiving party must also deliver a copy of this Order promptly to the party in the other action that caused the subpoena or order to issue.

CRITICAL

Receiving party must immediately provide written notice to the subpoena or court order issuer that requested material is subject to the protective order.

The receiving party also must immediately inform in writing the party who caused the subpoena or order to issue in the other litigation that some or all of the material the subpoena or order seeks is the subject of this Order.

CRITICAL

Applies to

Notice of designation

Notice of Designation for deposition testimony must be served within the presumptive confidentiality period, or all designation is waived.

Within this time period, a party may serve a Notice of Designation to all parties of record as to specific portions of the testimony that are designated Confidential Information, and thereafter only those portions identified in the Notice of Designation shall be protected by the terms of this Order. The failure to serve a timely Notice of Designation shall waive any designation of testimony taken in that deposition as Confidential Information, unless the Court orders otherwise.

CRITICALCivil cases

Deadline

10 business days

Applies to

Stipulations

Parties must serve proposed stipulations and uncontested facts on each other no later than 10 business days before the pretrial order's due date, and confer in good faith no later than 5 business days before the due date.

No later than 10 business days before the proposed pretrial order’s due date, the parties must serve on each other proposed stipulations and uncontested facts.

CRITICAL

The parties must serve the specified documents on each other within 21 days after the order is issued, but must not file them.

By _________________ [21 days from the date this Order is issued], the parties shall serve upon each other (but not file) copies of the following:

CRITICAL

Applies to

Answers to court interrogatories

No earlier than, and by 42 days after the order is issued, Plaintiff must answer the Court’s Interrogatories under oath or penalty of perjury, serve Defendant, and file the answers under the specified title.

By _________________ [42 days from the date this Order is issued], and no earlier, Plaintiff shall answer the Court's Interrogatories (attached to this Order) under oath or penalty of perjury, serve a copy on Defendant, and file the answers with the Court entitled "Notice of Filing Answers to Court's Interrogatories."

CRITICAL

Applies to

Documents referenced in paragraph 1

For qualifying opt-in Plaintiffs in collective actions, the Paragraph 1 document exchange is due within 20 days after filing the opt-in notice, and their interrogatory answers must be filed and served within an additional 20 days.

In collective actions, an exchange of documents as referenced in Paragraph 1 shall occur with respect to opt-in Plaintiffs who join the action before the dissemination of a court- approved opt-in notice. The exchange of documents must occur within twenty days of their filing of opt-in notices with this Court, and such opt-in Plaintiffs must thereafter file and serve their respective answers to the Court's Interrogatories within an additional twenty days.

CRITICALCivil cases

Deadline

10 business days

The parties must serve proposed stipulations and uncontested facts on each other at least 10 business days before the proposed order is due.

No later than 10 business days before the Proposed Final Pretrial Order’s due date, the parties must serve on each other proposed stipulations and uncontested facts.

CRITICALCivil cases

Deadline

10 business days

For deposition testimony offered instead of live testimony, the offering party must serve page-and-line designations 10 business days before the pretrial order is due.

If a party proposes to introduce a witness’ testimony via a deposition rather than live testimony, then the offering party must serve the page/line designations of the deposition transcript on the opposing party 10 business days in advance of the pretrial order’s due date.

CRITICALCivil cases

Deadline

5 business days

The opposing party must serve designation objections with concise grounds and counter-designations 5 business days before the pretrial order is due.

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) 5 business days in advance of the pretrial order’s due date.

CRITICAL

Deadline

42 calendar days

By 42 days after the Order, and no earlier, Plaintiff must answer the Court's Interrogatories under oath or penalty of perjury, serve Defendant, and file the answers under the specified title.

By _________________ [42 days from the date this Order is issued], and no earlier, Plaintiff shall answer the Court's Interrogatories (attached to this Order) under oath or penalty of perjury, serve a copy on Defendant, and file the answers with the Court entitled "Notice of Filing Answers to Court's Interrogatories."

CRITICAL

Deadline

20 calendar days

For qualifying opt-in Plaintiffs in collective actions, the Paragraph 1 document exchange is due within 20 days after filing an opt-in notice, and interrogatory answers must be filed and served within an additional 20 days.

In collective actions, an exchange of documents as referenced in Paragraph 1 shall occur with respect to opt-in Plaintiffs who join the action before the dissemination of a court- approved opt-in notice. The exchange of documents must occur within twenty days of their filing of opt-in notices with this Court, and such opt-in Plaintiffs must thereafter file and serve their respective answers to the Court's Interrogatories within an additional twenty days.

CRITICAL

The parties must serve the specified documents on each other within 21 days of the Order, but must not file them.

By _________________ [21 days from the date this Order is issued], the parties shall serve upon each other (but not file) copies of the following:

CRITICALCivil cases

Applies to

Notice of designation

Under Alternative A, a designating party may serve a Notice of Designation on all parties of record within 14 days after transcript delivery identifying the confidential portions, and failure to serve a timely notice waives the on-record designation unless the Court orders otherwise.

Within 14 days after delivery of the transcript, a designating party may serve a Notice of Designation to all parties of record identifying the specific portions of the transcript that are designated Confidential Information, and thereafter those portions identified in the Notice of Designation must be protected under the terms of this Order. The failure to serve a timely Notice of Designation waives any designation of deposition testimony as Confidential Information that was made on the record of the deposition, unless the Court orders otherwise.

CRITICALCivil cases

Applies to

Notice of designation

Under Alternative B, a party may serve a Notice of Designation on all parties of record within the designation window identifying specific confidential portions, and failure to serve a timely notice waives the designation unless the Court orders otherwise.

Within this time period, a party may serve a Notice of Designation to all parties of record as to specific portions of the testimony that are designated Confidential Information, and thereafter only those portions identified in the Notice of Designation shall be protected by the terms of this Order. The failure to serve a timely Notice of Designation shall waive any designation of testimony taken in that deposition as Confidential Information, unless the Court orders otherwise.

CRITICALCivil cases

Deadline

3 business days

Applies to

Subpoena or order compelling disclosure of confidential information

A receiving party served with a subpoena or order in other litigation compelling disclosure of Confidential Information must notify the designating party in writing immediately and no later than 3 business days after service.

If a receiving party is served with a subpoena or an order issued in other litigation that compels the disclosure of any material or document designated in this action as Confidential Information, the receiving party must notify the designating party in writing immediately and in no event more than 3 business days after

WARNINGCivil cases

Applies to

Confidentiality designation withdrawal

A Confidential or Highly Confidential designation may be withdrawn by written notification to all parties in the case.

A person who has designated information as Confidential or Highly Confidential may withdraw the designation by written notification to all parties in the case.

WARNING

Applies to

Petition for registry funds payment

A claimant seeking payment of registry funds must petition the Court, give notice to the United States attorney, and provide full proof of the right to the funds to obtain an order directing payment.

Any claimant entitled to any such money may, upon petition to the Court and upon notice to the United States attorney and full proof of the right thereto, obtain an order directing payment to him pursuant to 28 U.S.C. §2042.

WARNINGCivil cases

Copies of the complaint letter and declaration must be sent contemporaneously to all other parties, the mediator (if identified), and the Clerk of Court.

Copies of the letter of complaint and declaration must be sent contemporaneously to all other parties, the mediator (if identified) and the Clerk of Court.

WARNINGCivil cases

The mediator must contemporaneously provide copies of the written violation report to all counsel and to the Clerk of Court.

A mediator who perceives a material violation of these ADR Local Rules shall make a written report directly to the ADR Magistrate Judge and contemporaneously provide copies to all counsel and to the Clerk of Court.

WARNINGCivil cases

Applies to

Mediator oath

Service

Email

Mediators must email the executed copy of their oath to the ADR Coordinator.

The mediator is required to email the executed copy of the oath to ADR Coordinator.

WARNING

The Clerk must provide paper-form notice of orders and judgments to persons who are not E-Filers or represented by an E-Filer.

The Clerk of the Court must give notice in paper form to a person who is not an E-Filer or represented by an E-Filer in accordance with the Federal Rules of Civil Procedure, Federal Rules of Criminal Procedure, and the local rules of this court.

WARNINGCivil cases

The Hague Convention applies to service abroad in civil or commercial matters and does not apply where the defendant's address is unknown; when a plaintiff has address information for a defendant, the court presumes the address is known for Hague Convention purposes.

The Hague Convention states that "[t]he present Convention shall apply in all cases, in civil or commercial matters, where there is occasion to transmit a judicial or extrajudicial document for service abroad. This Convention shall not apply where the address of the person to be served with the document is not known." Art. 1, 20 U.S.T., at 362. "When plaintiffs…have address information for a defendant, the court will presume that the defendant's address is known for purposes of the Hague Convention."

WARNINGCivil cases

When unforeseen trial circumstances prompt use of an unlisted exhibit, notice should be given as soon as possible to the opposing side and the Court so objections can be discussed.

If, due to unforeseen circumstances during trial a party wishes to introduce an exhibit not previously listed, notice should be given as soon as possible to the opposing side and to the Court so that any objections can be discussed.

WARNING

Deadline

5 business days

Designating party must respond to confidentiality designation challenge within 5 business days.

The designating party must respond to the challenge within 5 business days.

CRITICALCivil cases

Applies to

Settlement letter

Parties must exchange settlement letters with opposing counsel prior to the settlement conference.

Plaintiff’s counsel must submit a settlement letter to Defendant’s counsel and the Court, describing the nature of the action, the theory of liability, Plaintiff’s demand and its reasoned basis, an itemization of damages, and Defendant’s counsel must submit a settlement letter to Plaintiff’s counsel and the Court in response to Plaintiff’s demand, describing the theory of defense and Defendant’s offer, including an explanation for it.