Please be advised that the Court will hear emergency motions only in exceptional circumstances after making a preliminary determination of whether an actual emergency exists.

Emergency matters must be of such a nature that a delay in hearing them would cause serious harm to one or more of the parties. Requests to set a hearing on an emergency motion shall be made to the courtroom deputy with as much advance notice as possible. All reasonable efforts must be made to give actual notice to opposing counsel.

Please be advised that the Court will hear emergency motions only in exceptional circumstances after making a preliminary determination of whether an actual emergency exists.

Emergency matters must be of such a nature that a delay in hearing them would cause serious harm to one or more of the parties. Requests to set a hearing on an emergency motion shall be made to the courtroom deputy with as much advance notice as possible. All reasonable efforts must be made to give actual notice to opposing counsel.

Every case has an assigned Magistrate Judge. In civil cases, the parties may consent to have the assigned Magistrate Judge try the case. In many cases, consent to refer the entire case to the Magistrate Judge may offer significant efficiencies and greater certainty in scheduling the trial. All counsel in civil cases should inform their clients of this option and discuss it with opposing counsel.

Magistrate Judge Consent Form

Every case has an assigned Magistrate Judge. In civil cases, the parties may consent to have the assigned Magistrate Judge try the case. In many cases, consent to refer the entire case to the Magistrate Judge may offer significant efficiencies and greater certainty in scheduling the trial. All counsel in civil cases should inform their clients of this option and discuss it with opposing counsel.

Magistrate Judge Consent Form

Unless directed by the Court, counsel and pro se litigants must not communicate with the Court about the merits of the case by letter, phone, or email (excluding submitting a proposed order). All communications must be made in the form of a motion, brief, or a status report, properly noticed and served on opposing counsel.

If a party has questions about scheduling, the status of motions, or the logistics of trial, contact the Courtroom Deputy.

Unless directed by the Court, counsel and pro se litigants must not communicate with the Court about the merits of the case by letter, phone, or email (excluding submitting a proposed order). All communications must be made in the form of a motion, brief, or a status report, properly noticed and served on opposing counsel.

If a party has questions about scheduling, the status of motions, or the logistics of trial, contact the Courtroom Deputy.

The Court requires the parties in all newly filed cases to file a Joint Initial Status Report approximately 75 days after the filing of the complaint. The Joint Initial Status Report is the “discovery plan” required by Rule 26(f). The Joint Initial Status Report shall provide the information listed in the template below. The Joint Initial Status Report should not exceed seven pages. If the defendant(s) has not been served with process by that date, plaintiff's counsel is instructed to file an individual status report indicating the status of service of process by the same deadline.

Joint Initial Status Report Under Rule 26(f)

The Court requires the parties in all newly filed cases to file a Joint Initial Status Report approximately 75 days after the filing of the complaint. The Joint Initial Status Report is the “discovery plan” required by Rule 26(f). The Joint Initial Status Report shall provide the information listed in the template below. The Joint Initial Status Report should not exceed seven pages. If the defendant(s) has not been served with process by that date, plaintiff's counsel is instructed to file an individual status report indicating the status of service of process by the same deadline.

Joint Initial Status Report Under Rule 26(f)

Motion Calls/Courtesy Copies

Until further notice, due to the COVID-19 Emergency, Judge Valderrama will not be holding motions calls. Parties are not to schedule motion presentment hearings or deliver courtesy copies to the courthouse.

Conferral with Opposing Party

Before filing a motion, the movant’s counsel must ask opposing counsel whether there is an objection to the motion. The motion should clearly indicate whether it is opposed or unopposed. This requirement does not apply to: motions to withdraw as counsel, motions to dismiss, motions to remand, motions for summary judgment, and motions for leave to file a sur-response (where such request is based upon the argument that the opposing party raised new arguments in its reply).

Electronic Filing

The Court strongly recommends counsel to convert any word-processed document (e.g., briefs and memoranda) into a PDF document by printing or publishing it to PDF rather than manually scanning a paper copy into PDF format. The former method of conversion generates searchable optical character recognition (OCR) text; the latter does not. For other filings (including exhibits in support of a motion or any Local Rule 56.1 Statement), the Court also strongly recommends counsel to run an OCR conversion on it before uploading it onto CM/ECF. To do this in Adobe, go to Tools, Text Recognition, In This File, and select All Pages. If you see the message, “Acrobat could not perform recognition (OCR) on this page because this page contains renderable text,” click “Ignore future errors in this document,” and click OK.

Motion Calls/Courtesy Copies

Until further notice, due to the COVID-19 Emergency, Judge Valderrama will not be holding motions calls. Parties are not to schedule motion presentment hearings or deliver courtesy copies to the courthouse.

Conferral with Opposing Party

Before filing a motion, the movant’s counsel must ask opposing counsel whether there is an objection to the motion. The motion should clearly indicate whether it is opposed or unopposed. This requirement does not apply to: motions to withdraw as counsel, motions to dismiss, motions to remand, motions for summary judgment, and motions for leave to file a sur-response (where such request is based upon the argument that the opposing party raised new arguments in its reply).

Electronic Filing

The Court strongly recommends counsel to convert any word-processed document (e.g., briefs and memoranda) into a PDF document by printing or publishing it to PDF rather than manually scanning a paper copy into PDF format. The former method of conversion generates searchable optical character recognition (OCR) text; the latter does not. For other filings (including exhibits in support of a motion or any Local Rule 56.1 Statement), the Court also strongly recommends counsel to run an OCR conversion on it before uploading it onto CM/ECF. To do this in Adobe, go to Tools, Text Recognition, In This File, and select All Pages. If you see the message, “Acrobat could not perform recognition (OCR) on this page because this page contains renderable text,” click “Ignore future errors in this document,” and click OK.

The Court believes that parties can and should work out most discovery disputes and thus discourages the filing of discovery motions. The Court will not consider any discovery motion unless the movant has complied with the meet-and-confer requirement of Local Rule 37.2. This applies not only to motions to compel, but also applies to motions to quash discovery or for protective orders against discovery. The motion must state with specificity when and how the movant complied with Local Rule 37.2. Remember that compliance with Local Rule 37.2 requires a good-faith effort to resolve discovery disputes and also requires that the conferral take place face-to-face or by telephone. The exchange of correspondence will almost never be good enough to comply with Local Rule 37.2.

All parties should be fully prepared to argue any discovery motion on the date that it is presented. The Court most often will rule on discovery motions after hearing argument at the motion call and without further briefing (though sometimes it is plain that briefing is needed). If after hearing argument, the Court believes that the motion requires briefing, the Court normally will set an expedited briefing schedule so that the matter can be resolved promptly.

Parties must immediately notify the Court if they are withdrawing (or narrowing) any previously filed discovery motions.

Discovery Sequence

Remember that there is generally no particular sequence in which discovery must occur, and that one party’s failure or inability to respond to discovery will not excuse any other party’s prompt compliance. Remember too that the pendency of a motion, such as a motion to dismiss, does not necessarily operate as a stay of discovery, although very often one or both parties might be justified in asking for a stay.

Discovery Continuances

Judge Valderrama sets realistic discovery deadlines at the initial status hearing, based on a close review of the pleadings and the initial status report. The parties must issue discovery and respond to discovery as needed to meet the discovery deadlines, which means planning ahead so that there is no last-minute scramble as the deadline approaches. Also, any motion to extend discovery must be presented in writing (after conferral with the other side), filed in advance of the fact discovery deadline, and must demonstrate good cause for the extension.

Judge Valderrama generally will not set a case for trial until it is really ready for trial (that is, all discovery is done, dispositive motions denied, and settlement efforts exhausted). That means that the parties get a real trial date, not a placeholder, which allows the parties and witnesses to better plan and allows the Court’s trial calendar to be a real one, with no double-booking, very rare continuances, and very rare last-minute settlements.

Limit on the Number of Requests to Admit

The Court sets a limit of 25 requests to admit, under Federal Rule of Civil Procedure 36, per side. Per “side” means parties represented by the same counsel.

The Court believes that parties can and should work out most discovery disputes and thus discourages the filing of discovery motions. The Court will not consider any discovery motion unless the movant has complied with the meet-and-confer requirement of Local Rule 37.2. This applies not only to motions to compel, but also applies to motions to quash discovery or for protective orders against discovery. The motion must state with specificity when and how the movant complied with Local Rule 37.2. Remember that compliance with Local Rule 37.2 requires a good-faith effort to resolve discovery disputes and also requires that the conferral take place face-to-face or by telephone. The exchange of correspondence will almost never be good enough to comply with Local Rule 37.2.

All parties should be fully prepared to argue any discovery motion on the date that it is presented. The Court most often will rule on discovery motions after hearing argument at the motion call and without further briefing (though sometimes it is plain that briefing is needed). If after hearing argument, the Court believes that the motion requires briefing, the Court normally will set an expedited briefing schedule so that the matter can be resolved promptly.

Parties must immediately notify the Court if they are withdrawing (or narrowing) any previously filed discovery motions.

Discovery Sequence

Remember that there is generally no particular sequence in which discovery must occur, and that one party’s failure or inability to respond to discovery will not excuse any other party’s prompt compliance. Remember too that the pendency of a motion, such as a motion to dismiss, does not necessarily operate as a stay of discovery, although very often one or both parties might be justified in asking for a stay.

Discovery Continuances

Judge Valderrama sets realistic discovery deadlines at the initial status hearing, based on a close review of the pleadings and the initial status report. The parties must issue discovery and respond to discovery as needed to meet the discovery deadlines, which means planning ahead so that there is no last-minute scramble as the deadline approaches. Also, any motion to extend discovery must be presented in writing (after conferral with the other side), filed in advance of the fact discovery deadline, and must demonstrate good cause for the extension.

Judge Valderrama generally will not set a case for trial until it is really ready for trial (that is, all discovery is done, dispositive motions denied, and settlement efforts exhausted). That means that the parties get a real trial date, not a placeholder, which allows the parties and witnesses to better plan and allows the Court’s trial calendar to be a real one, with no double-booking, very rare continuances, and very rare last-minute settlements.

Limit on the Number of Requests to Admit

The Court sets a limit of 25 requests to admit, under Federal Rule of Civil Procedure 36, per side. Per “side” means parties represented by the same counsel.

Unless otherwise ordered, motions for summary judgment must be filed within 45 days of the close of discovery. In order to avoid disruption of the Court's trial schedule, untimely motions for summary judgment will not be considered.

Motions for summary judgment and responses must comply with Local Rules 56.1(a) and 56.1(b), as well as the procedures outlined herein. All statements of undisputed material facts and their responses shall be filed separately from the memoranda of law and shall include the line, paragraph, or page number where the supporting material may be found in the record.

Failure to abide by the Local Rules may result in the Court striking briefs, disregarding statements of fact, deeming statements of fact admitted, and denying summary judgment. See Buttron v. Sheehan, No. 00 C 4451, 2003 WL 21801222 (N. D. Ill. Aug. 4, 2003).

The movant shall not file more than 80 statements of undisputed material facts without prior leave of the Court. The respondent shall be limited to 40 statements of undisputed material facts without prior leave of the Court. In complex cases, the Court may request that the parties submit a timeline of events in addition to the statements of undisputed material facts.

If you are representing yourself, please refer to Local Rule 56.2 - Notice to Pro Se Litigants Opposing Summary Judgment.

Unless otherwise ordered, motions for summary judgment must be filed within 45 days of the close of discovery. In order to avoid disruption of the Court's trial schedule, untimely motions for summary judgment will not be considered.

Motions for summary judgment and responses must comply with Local Rules 56.1(a) and 56.1(b), as well as the procedures outlined herein. All statements of undisputed material facts and their responses shall be filed separately from the memoranda of law and shall include the line, paragraph, or page number where the supporting material may be found in the record.

Failure to abide by the Local Rules may result in the Court striking briefs, disregarding statements of fact, deeming statements of fact admitted, and denying summary judgment. See Buttron v. Sheehan, No. 00 C 4451, 2003 WL 21801222 (N. D. Ill. Aug. 4, 2003).

The movant shall not file more than 80 statements of undisputed material facts without prior leave of the Court. The respondent shall be limited to 40 statements of undisputed material facts without prior leave of the Court. In complex cases, the Court may request that the parties submit a timeline of events in addition to the statements of undisputed material facts.

If you are representing yourself, please refer to Local Rule 56.2 - Notice to Pro Se Litigants Opposing Summary Judgment.

Generally, the Court will not consider substantive arguments contained in footnotes. This includes the distinguishing of cases relied upon by the opposing party. If a party needs a reasonable number of additional pages to fit its arguments in the text of its brief, the party should move for leave to exceed the fifteen (15) page limitation on all memoranda contained in Local Rule 7.1. That said, the fifteen (15) page limitation will be strictly enforced, and a motion for leave to exceed that limit shall not be granted unless warranted. Additionally, as a general rule, the Court disfavors reply briefs that exceed response briefs in length, and will not grant a motion for excess pages for a reply brief to exceed the response brief absent compelling circumstances.

Briefing schedules are generally set by Court order. A motion for extension of time shall not be granted except on a showing of good cause. The circumstances warranting an extension shall be set forth in detail by written motion.

The Court will also consider motions at scheduled status hearings, so long as the notice requirements of Local Rule 5.3 have been met.

Generally, Illinois cases should be cited to using the N.E.2d. reporter.

Generally, the Court will not consider substantive arguments contained in footnotes. This includes the distinguishing of cases relied upon by the opposing party. If a party needs a reasonable number of additional pages to fit its arguments in the text of its brief, the party should move for leave to exceed the fifteen (15) page limitation on all memoranda contained in Local Rule 7.1. That said, the fifteen (15) page limitation will be strictly enforced, and a motion for leave to exceed that limit shall not be granted unless warranted. Additionally, as a general rule, the Court disfavors reply briefs that exceed response briefs in length, and will not grant a motion for excess pages for a reply brief to exceed the response brief absent compelling circumstances.

Briefing schedules are generally set by Court order. A motion for extension of time shall not be granted except on a showing of good cause. The circumstances warranting an extension shall be set forth in detail by written motion.

The Court will also consider motions at scheduled status hearings, so long as the notice requirements of Local Rule 5.3 have been met.

Generally, Illinois cases should be cited to using the N.E.2d. reporter.

Proposed orders should not be filed on the docket, even if the parties agree on the draft order. Instead, counsel must submit proposed orders to the Court by emailing a Microsoft Word version of the draft to Proposed_Order_Valderrama@ilnd.uscourts.gov. A pdf file does not count.

The subject line of the email must include (1) the case name; (2) the case number; (3) the docket number of the corresponding motion; and (4) the title of the order that is proposed as indicated on the Notice of Electronic Filing. Counsel must serve a copy of a proposed order on all other parties by copying them on the email to the Court.

Unless the Court directs otherwise, a party must file a motion asking the Court to enter the proposed order. Submitting a draft to the Court’s proposed order inbox is not a substitute for a motion. Emailing a draft is necessary, but not sufficient.

The Court will consider proposed orders when ruling on motions, but will modify (or disregard altogether) such proposed orders as it deems appropriate, even if all parties agree on the proposed order. Proposed orders (such as stipulated protective orders) require Court approval before they are in effect.

Proposed orders on routine motions – such as motions for extensions of time, or dispositive motions – are unnecessary.

Proposed orders should not be filed on the docket, even if the parties agree on the draft order. Instead, counsel must submit proposed orders to the Court by emailing a Microsoft Word version of the draft to Proposed_Order_Valderrama@ilnd.uscourts.gov. A pdf file does not count.

The subject line of the email must include (1) the case name; (2) the case number; (3) the docket number of the corresponding motion; and (4) the title of the order that is proposed as indicated on the Notice of Electronic Filing. Counsel must serve a copy of a proposed order on all other parties by copying them on the email to the Court.

Unless the Court directs otherwise, a party must file a motion asking the Court to enter the proposed order. Submitting a draft to the Court’s proposed order inbox is not a substitute for a motion. Emailing a draft is necessary, but not sufficient.

The Court will consider proposed orders when ruling on motions, but will modify (or disregard altogether) such proposed orders as it deems appropriate, even if all parties agree on the proposed order. Proposed orders (such as stipulated protective orders) require Court approval before they are in effect.

Proposed orders on routine motions – such as motions for extensions of time, or dispositive motions – are unnecessary.

The Court’s Pre-Trial Standing Orders are set forth in the documents linked below:

Standing Order Governing Civil Bench Trials

Standing Order Governing Civil Jury Trials

Standing Order Governing Criminal Trials

The Court’s Pre-Trial Standing Orders are set forth in the documents linked below:

Standing Order Governing Civil Bench Trials

Standing Order Governing Civil Jury Trials

Standing Order Governing Criminal Trials

The parties' initial submissions of jury instructions with the final pretrial order, and any subsequent submissions prior to the formal jury instruction conference, are to comply with the requirements set forth in this Court's directions concerning final pretrial orders.

The parties are required to meet and confer regarding jury instructions prior to the formal jury instruction conference with the Court, which will occur as soon as possible after the close of the plaintiff or prosecution’s case.

Once the jury instruction conference has been held, it is the parties' responsibility to provide the Court with jury instruction packets to be issued to the jury. The final instructions are to be unnumbered and are not to have titles or reference to the legal authority or pattern instruction on which they are based. They are to be printed single sided without page numbers and are not to be stapled or otherwise bound.

The parties are responsible for ensuring that all of the approved instructions are consistent in style and formatting. The parties are to provide enough copies of the jury instructions for each juror, and five additional copies for counsel and the Court. An electronic copy of the instructions in Microsoft Word format must also be sent to this Court's proposed order inbox.

7th Circuit Pattern Jury Instructions

The parties' initial submissions of jury instructions with the final pretrial order, and any subsequent submissions prior to the formal jury instruction conference, are to comply with the requirements set forth in this Court's directions concerning final pretrial orders.

The parties are required to meet and confer regarding jury instructions prior to the formal jury instruction conference with the Court, which will occur as soon as possible after the close of the plaintiff or prosecution’s case.

Once the jury instruction conference has been held, it is the parties' responsibility to provide the Court with jury instruction packets to be issued to the jury. The final instructions are to be unnumbered and are not to have titles or reference to the legal authority or pattern instruction on which they are based. They are to be printed single sided without page numbers and are not to be stapled or otherwise bound.

The parties are responsible for ensuring that all of the approved instructions are consistent in style and formatting. The parties are to provide enough copies of the jury instructions for each juror, and five additional copies for counsel and the Court. An electronic copy of the instructions in Microsoft Word format must also be sent to this Court's proposed order inbox.

7th Circuit Pattern Jury Instructions

Individuals who make the serious decision to represent themselves are referred to by the Court as pro se litigants. If you are a pro se litigant with a case in this district, the District Court Self-Help Assistance Program may be able to provide you with assistance regarding your case. The help desk attorney operates by appointment only. Appointments are made at the Clerk’s Office Intake Desk on the 20th floor or by calling 312-435-5691. Use of the help desk attorney is not a substitute for an attorney. You should seriously consider trying to obtain professional legal assistance. Below are lists of organizations that may be able to offer you free or low-cost legal assistance or a referral to an attorney if you can afford to pay for legal services.

Free or low-cost legal services
Referral Services

Additional Resources/Information:

• Local Rule 56.2 - Notice to Pro Se Litigants Opposing Summary Judgment
• Filing a Civil Case Without An Attorney: A Guide For The Pro Se Litigant
• Title VII and Section 1981: A Guide for Appointed Attorneys in the Northern District of Illinois
• The Americans With Disabilities Act An Age Discrimination In Employment Act: A Guide for Appointed Attorneys in the Northern District of Illinois

Individuals who make the serious decision to represent themselves are referred to by the Court as pro se litigants. If you are a pro se litigant with a case in this district, the District Court Self-Help Assistance Program may be able to provide you with assistance regarding your case. The help desk attorney operates by appointment only. Appointments are made at the Clerk’s Office Intake Desk on the 20th floor or by calling 312-435-5691. Use of the help desk attorney is not a substitute for an attorney. You should seriously consider trying to obtain professional legal assistance. Below are lists of organizations that may be able to offer you free or low-cost legal assistance or a referral to an attorney if you can afford to pay for legal services.

Free or low-cost legal services
Referral Services

Additional Resources/Information:

• Local Rule 56.2 - Notice to Pro Se Litigants Opposing Summary Judgment
• Filing a Civil Case Without An Attorney: A Guide For The Pro Se Litigant
• Title VII and Section 1981: A Guide for Appointed Attorneys in the Northern District of Illinois
• The Americans With Disabilities Act An Age Discrimination In Employment Act: A Guide for Appointed Attorneys in the Northern District of Illinois

This Court urges parties to undertake settlement negotiations at the earliest practicable point in the litigation. Parties who desire a settlement conference should request one in open court or file a motion requesting one. In bench trials, settlement conferences are usually referred to the magistrate judge.

Parties who participate in a settlement conference with Judge Valderrama must follow the standing instructions for settlement conferences available at the link below.

Standing Order Governing Settlement Conferences

This Court urges parties to undertake settlement negotiations at the earliest practicable point in the litigation. Parties who desire a settlement conference should request one in open court or file a motion requesting one. In bench trials, settlement conferences are usually referred to the magistrate judge.

Parties who participate in a settlement conference with Judge Valderrama must follow the standing instructions for settlement conferences available at the link below.

Standing Order Governing Settlement Conferences

Before submitting notice of settlement, stipulation to dismiss, or motion to voluntarily dismiss pursuant to settlement, counsel should review the following Seventh Circuit cases which discuss the retention of federal jurisdiction to enforce the terms of a settlement agreement: Blue Cross and Blue Shield Ass’n v. American Express Co., 467 F.3d 634, 636 (7th Cir. 2006) and Shapo v. Engle, 463 F.3d 641, 646 (7th Cir. 2006). The parties also may wish to review the article, “What’s an Attorney to Do  Ensuring Federal Jurisdiction Over Settlement Agreements in Light of Recent Seventh Circuit Cases,” by Judge Denlow, which may be accessed at: _assets/_documents/_forms/_judges/DENLOW/FederalJurisdiction.pdf. Generally speaking, Seventh Circuit decisions hold that dismissals “with prejudice” leave the Court without jurisdiction to enforce a settlement agreement.

Before submitting notice of settlement, stipulation to dismiss, or motion to voluntarily dismiss pursuant to settlement, counsel should review the following Seventh Circuit cases which discuss the retention of federal jurisdiction to enforce the terms of a settlement agreement: Blue Cross and Blue Shield Ass’n v. American Express Co., 467 F.3d 634, 636 (7th Cir. 2006) and Shapo v. Engle, 463 F.3d 641, 646 (7th Cir. 2006). The parties also may wish to review the article, “What’s an Attorney to Do  Ensuring Federal Jurisdiction Over Settlement Agreements in Light of Recent Seventh Circuit Cases,” by Judge Denlow, which may be accessed at: _assets/_documents/_forms/_judges/DENLOW/FederalJurisdiction.pdf. Generally speaking, Seventh Circuit decisions hold that dismissals “with prejudice” leave the Court without jurisdiction to enforce a settlement agreement.

When proposing an injunction, please pay special attention to the text of Rule 65(d). The Seventh Circuit requires an injunction to be on a separate document. See, e.g., MillerCoors LLC v. Anheuser-Busch Companies, LLC, 942 F.3d 922, 922 (7th Cir. 2019); Auto Driveaway Franchise Systems, LLC v. Auto Driveaway Richmond, LLC, 928 F.3d 670, 676 (7th Cir. 2019) ("We interpret Rule 65(d)(1)(C) to require than an injunction must be embodied in a standalone separate document."); City of Chicago v. Sessions, 2018 WL 4268814, at *2 (7th Cir. August 10, 2018). So, do not include an injunction in the body of a proposed order that covers anything else. Every injunction should stand on its own.

An injunction must not “refer[] to the complaint or other document” when “describ[ing] in reasonable detail . . . the act or acts restrained or required.” Fed. R. Civ. P. 65(d)(1)(C). An injunction should not incorporate any other document by reference. See BankDirect Capital Finance, LLC v. Capital Premium Financing, Inc., 912 F.3d 1054, 1057 (7th Cir. 2019); DuPuy v. Samuels, 465 F.3d 757, 758 (7th Cir. 2006); MillerCoors, 2019 WL 5280872, at 922 (noting that Rule 65(d)(1)(C) “requires every injunction to be set forth without referring to any other document”).

When proposing an injunction, please pay special attention to the text of Rule 65(d). The Seventh Circuit requires an injunction to be on a separate document. See, e.g., MillerCoors LLC v. Anheuser-Busch Companies, LLC, 942 F.3d 922, 922 (7th Cir. 2019); Auto Driveaway Franchise Systems, LLC v. Auto Driveaway Richmond, LLC, 928 F.3d 670, 676 (7th Cir. 2019) ("We interpret Rule 65(d)(1)(C) to require than an injunction must be embodied in a standalone separate document."); City of Chicago v. Sessions, 2018 WL 4268814, at *2 (7th Cir. August 10, 2018). So, do not include an injunction in the body of a proposed order that covers anything else. Every injunction should stand on its own.

An injunction must not “refer[] to the complaint or other document” when “describ[ing] in reasonable detail . . . the act or acts restrained or required.” Fed. R. Civ. P. 65(d)(1)(C). An injunction should not incorporate any other document by reference. See BankDirect Capital Finance, LLC v. Capital Premium Financing, Inc., 912 F.3d 1054, 1057 (7th Cir. 2019); DuPuy v. Samuels, 465 F.3d 757, 758 (7th Cir. 2006); MillerCoors, 2019 WL 5280872, at 922 (noting that Rule 65(d)(1)(C) “requires every injunction to be set forth without referring to any other document”).

Notice of Appeal from the United States Bankruptcy Court Bankruptcy must be filed within 14 days of the entry of judgment by the Bankruptcy Court. Any motions to extend time must be filed within the 14-day period. Appellant's Opening Brief is due 30 days after docketing of the record, responses are due 30 days thereafter and replies are due within 14 days of the response. Briefs are limited to 15 pages each.

Notice of Appeal from the United States Bankruptcy Court Bankruptcy must be filed within 14 days of the entry of judgment by the Bankruptcy Court. Any motions to extend time must be filed within the 14-day period. Appellant's Opening Brief is due 30 days after docketing of the record, responses are due 30 days thereafter and replies are due within 14 days of the response. Briefs are limited to 15 pages each.

Judge Valderrama follows the Local Patent Rules for the Northern District of Illinois in all patent cases, unless ordered otherwise.

Local Patent Rules

LPR Appendix A

LPR Appendix B

Estimated Patent Case Schedule

Judge Valderrama follows the Local Patent Rules for the Northern District of Illinois in all patent cases, unless ordered otherwise.

Local Patent Rules

LPR Appendix A

LPR Appendix B

Estimated Patent Case Schedule

The Court suspends Local Rule 5.2(f), which requires in many instances that paper courtesy copies of filings be delivered to the judge. No courtesy copies may be submitted for filings unless the parties receive case-specific requests for copies from the presiding judge.

The Court suspends Local Rule 5.2(f), which requires in many instances that paper courtesy copies of filings be delivered to the judge. No courtesy copies may be submitted for filings unless the parties receive case-specific requests for copies from the presiding judge.

There is a presumption that the public will have access to all court filings. When warranted, the parties should file a proposed order which specifies the categories of documents or other matters which may be subject to the order (e.g., trade secrets, medical records, personnel files, and the like), and file a motion that explains why a protective order is necessary as to each category. The Court will then independently review the motion and determine if the order should be signed.

The Court will not sign a protective order that provides that items designated as confidential may, for that reason, be filed with the Court under seal. Rather, any protective order that contemplates under-seal filing must provide that no documents may be filed under seal absent a motion showing good cause for sealing a portion of the record. The mere fact that information has been designated as confidential by a party is insufficient to permit filing under seal. A party seeking to file material under seal must set forth in its motion the reasons why the record should be sealed.

If the Court permits a portion of a document to be filed under seal, the party filing the document must also file a redacted public-record version that includes the entire document except for the portions filed under seal. The issuance of a protective order in light of this Standing Order will constitute the Court’s determination, as required by Rule 26(c), that good cause existed for the issuance of a protective order. The parties should review the Model Confidentiality Order contained in the Local Rules.

Model Confidentiality Order

There is a presumption that the public will have access to all court filings. When warranted, the parties should file a proposed order which specifies the categories of documents or other matters which may be subject to the order (e.g., trade secrets, medical records, personnel files, and the like), and file a motion that explains why a protective order is necessary as to each category. The Court will then independently review the motion and determine if the order should be signed.

The Court will not sign a protective order that provides that items designated as confidential may, for that reason, be filed with the Court under seal. Rather, any protective order that contemplates under-seal filing must provide that no documents may be filed under seal absent a motion showing good cause for sealing a portion of the record. The mere fact that information has been designated as confidential by a party is insufficient to permit filing under seal. A party seeking to file material under seal must set forth in its motion the reasons why the record should be sealed.

If the Court permits a portion of a document to be filed under seal, the party filing the document must also file a redacted public-record version that includes the entire document except for the portions filed under seal. The issuance of a protective order in light of this Standing Order will constitute the Court’s determination, as required by Rule 26(c), that good cause existed for the issuance of a protective order. The parties should review the Model Confidentiality Order contained in the Local Rules.

Model Confidentiality Order

Counsel should send an executed copy of the plea agreement or plea declaration to the courtroom deputy at Analeah_Charles@ilnd.uscourts.gov at least two full business days ahead of the change of plea hearing.

Counsel should send an executed copy of the plea agreement or plea declaration to the courtroom deputy at Analeah_Charles@ilnd.uscourts.gov at least two full business days ahead of the change of plea hearing.

Judge Valderrama strongly encourages attorneys and their clients to provide substantive speaking opportunities to less experienced attorneys during the following Court proceedings: motion and status hearings, settlement conferences, claim-construction hearings, pretrial conferences, evidentiary hearings, and sentencings. To that end, Judge Valderrama allows more than one attorney per side to speak during any proceeding if the attorneys let Judge Valderrama know at the beginning of the hearing that a less experienced attorney is speaking under the supervision of a lead attorney. So lead attorneys may not only confer with the newer attorney to suggest additional argument or examination questions, they also may jump in as reasonably necessary to deliver additional argument or even to conduct additional witness examination. The Court also strongly encourages less experienced attorneys to conduct witness examinations or other proceedings at trial such as opening statements or closing arguments; however, the Court must balance the benefits of experience for newer litigators with efficiency and fairness considerations. Therefore, although conferral with the trial team is always permitted during an examination (and indeed, encouraged when necessary), the examination of a witness and objections with respect to that witness are limited to one attorney on the trial team. A second attorney on the trial team shall not examine the witness or object to that witness’ examination without leave of Court.

Judge Valderrama strongly encourages attorneys and their clients to provide substantive speaking opportunities to less experienced attorneys during the following Court proceedings: motion and status hearings, settlement conferences, claim-construction hearings, pretrial conferences, evidentiary hearings, and sentencings. To that end, Judge Valderrama allows more than one attorney per side to speak during any proceeding if the attorneys let Judge Valderrama know at the beginning of the hearing that a less experienced attorney is speaking under the supervision of a lead attorney. So lead attorneys may not only confer with the newer attorney to suggest additional argument or examination questions, they also may jump in as reasonably necessary to deliver additional argument or even to conduct additional witness examination. The Court also strongly encourages less experienced attorneys to conduct witness examinations or other proceedings at trial such as opening statements or closing arguments; however, the Court must balance the benefits of experience for newer litigators with efficiency and fairness considerations. Therefore, although conferral with the trial team is always permitted during an examination (and indeed, encouraged when necessary), the examination of a witness and objections with respect to that witness are limited to one attorney on the trial team. A second attorney on the trial team shall not examine the witness or object to that witness’ examination without leave of Court.