The parties are advised that a status report is intended to make the Court aware of potential issues. It does not take the place of a properly supported motion. Any disputes requiring adjudication MUST be raised by motion.

Upon assignment of cases to Magistrate Judge Maria Valdez, the parties may be ordered to file an initial status report. The report must comply with the following Order Setting Initial Status Report for Cases Assigned to Judge Valdez: 

   ** • Order Setting Initial Status Report

In cases where no discovery deadlines have been set, counsel may also be ordered to file an Agreed Scheduling Order:

     • Agreed Scheduling Order

The parties are advised that a status report is intended to make the Court aware of potential issues. It does not take the place of a properly supported motion. Any disputes requiring adjudication MUST be raised by motion.

Upon assignment of cases to Magistrate Judge Maria Valdez, the parties may be ordered to file an initial status report. The report must comply with the following Order Setting Initial Status Report for Cases Assigned to Judge Valdez: 

   ** • Order Setting Initial Status Report

In cases where no discovery deadlines have been set, counsel may also be ordered to file an Agreed Scheduling Order:

     • Agreed Scheduling Order

In-court status hearings in civil cases will generally be set on Wednesday at 10:30 a.m.

Civil motion hearings will generally be heard on Wednesday at 10:00 a.m.

Criminal motions are heard on Tuesday and Thursday at 11:00 a.m.

Arraignments are heard on Tuesday, Wednesday and Thursday at 11:00 a.m.

 
FILING OF DOCUMENTS:
No civil motions may be noticed for presentment. After a motion is filed, the Court will set a date for a hearing and/or a briefing schedule.

Service of motions must be accomplished no later than 4:00 p.m. the day after a motion is filed. Absent leave of Court, all memoranda of law must comply with the 15-page limitation set forth in Local Rule 7.1. No courtesy copies shall be delivered unless specifically requested by the Court. Any proposed or draft order must be submitted in compliance with the section entitled “Submitting a Proposed Order, Agreed or Otherwise, for Electronic Entry by the Judge,” infra.

TELEPHONIC OR REMOTE APPEARANCE:

 The Court believes that status and motion hearings are substantive matters that require in-person participation and finds it difficult to have meaningful hearings by telephone or video. As a result, telephonic or remote appearances are not allowed in status or motion hearings. If extraordinary circumstances exist, a party may contact the Courtroom Deputy, Lisa Provine, in advance to seek permission to participate by phone.

In-court status hearings in civil cases will generally be set on Wednesday at 10:30 a.m.

Civil motion hearings will generally be heard on Wednesday at 10:00 a.m.

Criminal motions are heard on Tuesday and Thursday at 11:00 a.m.

Arraignments are heard on Tuesday, Wednesday and Thursday at 11:00 a.m.

 
FILING OF DOCUMENTS:
No civil motions may be noticed for presentment. After a motion is filed, the Court will set a date for a hearing and/or a briefing schedule.

Service of motions must be accomplished no later than 4:00 p.m. the day after a motion is filed. Absent leave of Court, all memoranda of law must comply with the 15-page limitation set forth in Local Rule 7.1. No courtesy copies shall be delivered unless specifically requested by the Court. Any proposed or draft order must be submitted in compliance with the section entitled “Submitting a Proposed Order, Agreed or Otherwise, for Electronic Entry by the Judge,” infra.

TELEPHONIC OR REMOTE APPEARANCE:

 The Court believes that status and motion hearings are substantive matters that require in-person participation and finds it difficult to have meaningful hearings by telephone or video. As a result, telephonic or remote appearances are not allowed in status or motion hearings. If extraordinary circumstances exist, a party may contact the Courtroom Deputy, Lisa Provine, in advance to seek permission to participate by phone.

a.     Discovery Motions

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 hear or consider any discovery motions unless the parties have complied with the meet and confer requirement under Local Rule 37.2 . Any discovery motion must state with specificity when and how the movant complied with Local Rule 37.2 . In addition, the motion must briefly summarize the substance of the parties' discussions.

Parties are reminded that compliance with Local Rule 37.2 requires a good faith effort to resolve discovery disputes and, other than in exceptional circumstances, timely communication that takes place face to face or by telephone conference is required. The mere exchange of correspondence will not normally be sufficient to comply with Local Rule 37.2 .

All parties must be fully prepared to orally argue any discovery motion on the date that it is scheduled to be heard. The Court most often will decide most discovery motions after oral argument at the motion call and without briefing. If after 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.

All discovery disputes should be brought to the Court’s attention well before the relevant discovery deadline passes. The parties may not raise a discovery dispute with the Court after the discovery deadline unless they meet the relevant legal standard necessary to extend the schedule. If the parties informally agree to conduct discovery after the discovery deadline but do not move for an extension, any discovery disputes raised after the expiration of the deadline will be deemed waived.

 

b.     Joint Motions to Extend Deadlines or Hearing Dates

 

Where the parties by agreement wish to move a deadline or a hearing date that does not affect the dispositive motion deadline or any other deadline set by the District Judge, the parties shall do so by filing an agreed or joint motion which (1) sets forth the deadline or date the parties seek to move; (2) sets forth the new deadline or date requested; and (3) states that the request to move the deadline does not affect any dates set by the District Judge. The Court will ordinarily grand such motions by minute order and without a hearing within approximately 24 hours of the filing of the motion. Parties seeking to move a hearing date must consult this Court's Standing Order governing Status and Motion Practice when choosing a new date. If the parties request a date that is outside this Court's standard schedule, the motion cannot be granted without a hearing.

 

c.     Summary Judgment

Motions for summary judgment and responses must comply with Local Rules 56.1(a) and 56.1(b) as amended, as well as the procedures outlined herein. The statements of undisputed material fact and 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, or denying summary judgment. See, e.g., Cichon v. Exelon Generation Co., 401 F.3d 803, 809-10 (7th Cir. 2005); Ammons v. Aramark Uniform Servs., Inc., 368 F.3d 809, 816-18 (7th Cir. 2004); Smith v. Lamz, 321 F.3d 680, 682-83 (7th Cir. 2003); Malec v. Sanford, 191 F.R.D. 581, 582-87 (N.D. Ill. 2000) (comprehensive overview of summary judgment procedure in the Northern District of Illinois).

The movant shall not file more than 80 statements of undisputed material fact without prior leave of court. The respondent shall be limited to 40 statements of undisputed material fact absent prior leave of court.

d. Motions in Limine

A motion in limine must be filed as a separate document from the Pretrial Order. (See also Final Pretrial Order, infra.) Each motion in limine must be filed as a separate motion and each must cite authority supporting the relief sought.

Many motions in limine can be avoided by stipulation of counsel. Therefore, each motion in limine must also contain a statement of efforts to reach an accord regarding that motion containing the recitations that Local Rule 37.2 requires for discovery motions. Any motion in limine not containing such a statement is subject to being stricken.

e.     All Motions

          1.     The Court will apply the meet and confer requirement to all motions that a party files. Every motion filed must cite legal authority supporting the motion and the relief sought. The body of any motion must state if the motion is joint, or if the other parties have authorized the movant to state that the parties either agree to the motion or have no objection to it. Every motion must state with specificity what the parties did to comply with the meet and confer requirement.

In particular, with respect to any motions for summary judgment, the Court requires the moving party and the opposing party to meet and confer, during which time the opposing party should advise the moving party of factual matter or legal authority that it believes would defeat the motion. After this consultation, if the movant still wishes to file the motion, the movant should do so and the Court will address it.

          2.      All motion briefs shall focus on the particular dispute(s) remaining at issue at the conclusion of the meet and confer process and should avoid discussion of historical or resolved matters. Briefs should also avoid voluminous supporting documentation and only include those portions of exhibits containing factual information necessary to the ruling on the motion.

          3.      Lawyers appearing before the court should work to achieve their client’s objectives expeditiously and as economically as possible in a civil and professional manner. Written materials submitted to the court should always be factual and concise, accurately state current law, and fairly represent the parties’ positions without unfairly attacking the opposing party or opposing counsel. A lawyer should at all times be civil, courteous, and accurate in communicating with adversaries, whether in writing or orally. Failure to follow these guidelines could result in sanctions.

a.     Discovery Motions

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 hear or consider any discovery motions unless the parties have complied with the meet and confer requirement under Local Rule 37.2 . Any discovery motion must state with specificity when and how the movant complied with Local Rule 37.2 . In addition, the motion must briefly summarize the substance of the parties' discussions.

Parties are reminded that compliance with Local Rule 37.2 requires a good faith effort to resolve discovery disputes and, other than in exceptional circumstances, timely communication that takes place face to face or by telephone conference is required. The mere exchange of correspondence will not normally be sufficient to comply with Local Rule 37.2 .

All parties must be fully prepared to orally argue any discovery motion on the date that it is scheduled to be heard. The Court most often will decide most discovery motions after oral argument at the motion call and without briefing. If after 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.

All discovery disputes should be brought to the Court’s attention well before the relevant discovery deadline passes. The parties may not raise a discovery dispute with the Court after the discovery deadline unless they meet the relevant legal standard necessary to extend the schedule. If the parties informally agree to conduct discovery after the discovery deadline but do not move for an extension, any discovery disputes raised after the expiration of the deadline will be deemed waived.

 

b.     Joint Motions to Extend Deadlines or Hearing Dates

 

Where the parties by agreement wish to move a deadline or a hearing date that does not affect the dispositive motion deadline or any other deadline set by the District Judge, the parties shall do so by filing an agreed or joint motion which (1) sets forth the deadline or date the parties seek to move; (2) sets forth the new deadline or date requested; and (3) states that the request to move the deadline does not affect any dates set by the District Judge. The Court will ordinarily grand such motions by minute order and without a hearing within approximately 24 hours of the filing of the motion. Parties seeking to move a hearing date must consult this Court's Standing Order governing Status and Motion Practice when choosing a new date. If the parties request a date that is outside this Court's standard schedule, the motion cannot be granted without a hearing.

 

c.     Summary Judgment

Motions for summary judgment and responses must comply with Local Rules 56.1(a) and 56.1(b) as amended, as well as the procedures outlined herein. The statements of undisputed material fact and 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, or denying summary judgment. See, e.g., Cichon v. Exelon Generation Co., 401 F.3d 803, 809-10 (7th Cir. 2005); Ammons v. Aramark Uniform Servs., Inc., 368 F.3d 809, 816-18 (7th Cir. 2004); Smith v. Lamz, 321 F.3d 680, 682-83 (7th Cir. 2003); Malec v. Sanford, 191 F.R.D. 581, 582-87 (N.D. Ill. 2000) (comprehensive overview of summary judgment procedure in the Northern District of Illinois).

The movant shall not file more than 80 statements of undisputed material fact without prior leave of court. The respondent shall be limited to 40 statements of undisputed material fact absent prior leave of court.

d. Motions in Limine

A motion in limine must be filed as a separate document from the Pretrial Order. (See also Final Pretrial Order, infra.) Each motion in limine must be filed as a separate motion and each must cite authority supporting the relief sought.

Many motions in limine can be avoided by stipulation of counsel. Therefore, each motion in limine must also contain a statement of efforts to reach an accord regarding that motion containing the recitations that Local Rule 37.2 requires for discovery motions. Any motion in limine not containing such a statement is subject to being stricken.

e.     All Motions

          1.     The Court will apply the meet and confer requirement to all motions that a party files. Every motion filed must cite legal authority supporting the motion and the relief sought. The body of any motion must state if the motion is joint, or if the other parties have authorized the movant to state that the parties either agree to the motion or have no objection to it. Every motion must state with specificity what the parties did to comply with the meet and confer requirement.

In particular, with respect to any motions for summary judgment, the Court requires the moving party and the opposing party to meet and confer, during which time the opposing party should advise the moving party of factual matter or legal authority that it believes would defeat the motion. After this consultation, if the movant still wishes to file the motion, the movant should do so and the Court will address it.

          2.      All motion briefs shall focus on the particular dispute(s) remaining at issue at the conclusion of the meet and confer process and should avoid discussion of historical or resolved matters. Briefs should also avoid voluminous supporting documentation and only include those portions of exhibits containing factual information necessary to the ruling on the motion.

          3.      Lawyers appearing before the court should work to achieve their client’s objectives expeditiously and as economically as possible in a civil and professional manner. Written materials submitted to the court should always be factual and concise, accurately state current law, and fairly represent the parties’ positions without unfairly attacking the opposing party or opposing counsel. A lawyer should at all times be civil, courteous, and accurate in communicating with adversaries, whether in writing or orally. Failure to follow these guidelines could result in sanctions.

A party requiring immediate relief may file an emergency motion in very limited circumstances and may not be filed without prior leave. To qualify as an "emergency," a motion must arise from an unforeseen circumstance that arises suddenly and unexpectedly and requires immediate action in order to avoid serious or irreparable harm to one or more of the parties. If the matter does not fully meet the standard, it will be set for a hearing in the ordinary course. Requests for an emergency motion shall be made to the Courtroom Deputy prior to filing the motion. A party seeking to present an emergency motion must make all reasonable efforts to provide the opposing party with actual notice of the motion. A party requiring immediate relief may file an emergency motion in very limited circumstances and may not be filed without prior leave. To qualify as an "emergency," a motion must arise from an unforeseen circumstance that arises suddenly and unexpectedly and requires immediate action in order to avoid serious or irreparable harm to one or more of the parties. If the matter does not fully meet the standard, it will be set for a hearing in the ordinary course. Requests for an emergency motion shall be made to the Courtroom Deputy prior to filing the motion. A party seeking to present an emergency motion must make all reasonable efforts to provide the opposing party with actual notice of the motion.

Before requesting that the Court enter a restricting order, commonly referred to as a protective order, to preserve the confidentiality of materials disclosed in discovery, or filing a confidential document under seal, counsel shall carefully review the following:

• Fed. R. Civ. P. 26(c);
• Local Rules 5.7, 5.8, and 26.2, as amended;
• The decisions of the Seventh Circuit in Jepson, Inc. v. Makita Electric Works, Ltd, 30 F.3d 854 (7th Cir. 1994), Citizens First Nat'l Bank v. Cincinnati Ins. Co., 178 F.3d 943 (7th Cir. 1999), and Union Oil Co. v. Leavell, 220 F.3d 562 (7th Cir. 2000); and
• In a case that is before the Court on referral for discovery supervision, any standing order or instructions from the District Judge regarding protective orders and restricting orders.

The Court will not enter a protective order, even if agreed, that does not comply with the requirements set out by the Seventh Circuit (and, for cases on referral, the assigned District Judge). If the protective order anticipates that any documents or confidential materials submitted to the court are to be filed under seal, the proposed protective order must include, at a minimum, the following:

•  A carefully-drafted definition of the categories of documents or other materials to be protected (e.g., personnel files, medical information, personal identity information, trade secrets, confidential financial matters, etc.), with an explanation of why confidentiality is necessary as to each category, consistent with the Seventh Circuit's descriptions of what is protectable;
• A provision that no document may be filed under seal absent an order by the court granting a motion, filed and noticed for hearing prior to the due date of the particular filing, showing good cause for sealing that particular document or portion of document;
• A procedure for the use of confidential documents at the depositions of witnesses, and a listing of the persons who may be given access to confidential materials;
• A provision that parties are ordered to retain copies of all documents containing confidential information which are provided under the protective order;
• A provision stating that nothing in the order shall be construed to affect the admissibility of any document, material or information at any trial or hearing; any request for confidentiality, closure or sealing of any hearing or trial must be made to the judge then presiding;
• An explicit procedure under which a party or interested member of the public can challenge the confidential designation of particular documents that have been filed under seal; and
• Instructions for the disposition of the documents designated as confidential following the conclusion of the case.

Please note that any designation of materials as "confidential" must be made in good faith by counsel, not by the client, and each page of confidential material must be clearly marked "confidential," "protected," or otherwise restricted.

The foregoing are minimum requirements. Counsel should, in addition, anticipate possible areas of future dispute and attempt to set out agreed procedures in advance to deal with them, appropriate to the nature of the case.

Before requesting that the Court enter a restricting order, commonly referred to as a protective order, to preserve the confidentiality of materials disclosed in discovery, or filing a confidential document under seal, counsel shall carefully review the following:

• Fed. R. Civ. P. 26(c);
• Local Rules 5.7, 5.8, and 26.2, as amended;
• The decisions of the Seventh Circuit in Jepson, Inc. v. Makita Electric Works, Ltd, 30 F.3d 854 (7th Cir. 1994), Citizens First Nat'l Bank v. Cincinnati Ins. Co., 178 F.3d 943 (7th Cir. 1999), and Union Oil Co. v. Leavell, 220 F.3d 562 (7th Cir. 2000); and
• In a case that is before the Court on referral for discovery supervision, any standing order or instructions from the District Judge regarding protective orders and restricting orders.

The Court will not enter a protective order, even if agreed, that does not comply with the requirements set out by the Seventh Circuit (and, for cases on referral, the assigned District Judge). If the protective order anticipates that any documents or confidential materials submitted to the court are to be filed under seal, the proposed protective order must include, at a minimum, the following:

•  A carefully-drafted definition of the categories of documents or other materials to be protected (e.g., personnel files, medical information, personal identity information, trade secrets, confidential financial matters, etc.), with an explanation of why confidentiality is necessary as to each category, consistent with the Seventh Circuit's descriptions of what is protectable;
• A provision that no document may be filed under seal absent an order by the court granting a motion, filed and noticed for hearing prior to the due date of the particular filing, showing good cause for sealing that particular document or portion of document;
• A procedure for the use of confidential documents at the depositions of witnesses, and a listing of the persons who may be given access to confidential materials;
• A provision that parties are ordered to retain copies of all documents containing confidential information which are provided under the protective order;
• A provision stating that nothing in the order shall be construed to affect the admissibility of any document, material or information at any trial or hearing; any request for confidentiality, closure or sealing of any hearing or trial must be made to the judge then presiding;
• An explicit procedure under which a party or interested member of the public can challenge the confidential designation of particular documents that have been filed under seal; and
• Instructions for the disposition of the documents designated as confidential following the conclusion of the case.

Please note that any designation of materials as "confidential" must be made in good faith by counsel, not by the client, and each page of confidential material must be clearly marked "confidential," "protected," or otherwise restricted.

The foregoing are minimum requirements. Counsel should, in addition, anticipate possible areas of future dispute and attempt to set out agreed procedures in advance to deal with them, appropriate to the nature of the case.

Counsel should be aware that amendments to Local Rule 26.2 in April 2006 changed certain aspects of the way documents designated as confidential must be dealt with in filings with the court. First, pursuant to amended L.R. 26.2(b), no document may be filed under seal without a prior order of the court specifying the particular document or portion of a document to be filed under seal. This amendment changed the rule by making clear that only the particular document that has been previously determined by the court to be deserving of protection may be filed under seal, regardless of the existence of any protective order. Thus, parties are not to file briefs or compilations of exhibits as restricted or under seal unless the court has expressly so ordered, with respect to the particular briefs or exhibits. See Committee Comments to L.R. 26.2. Second, pursuant to L.R. 26.2(c) and (d), the amended rule now offers Judges two options regarding how to handle documents designated as confidential when those documents are submitted for consideration in connection with a motion, brief or other matter. The two options are as follows:

1. Filing the confidential document with the Clerk=s Office. Under this option, the confidential documents must be filed with the Clerk=s Office, and each confidential document presented for filing must include a copy of a restricting order entered by the Judge for that specific document or portion of document. The attorney or party submitting the confidential document must file it in a sealed enclosure that conspicuously states on the face of the enclosure the attorney=s or party=s name and address, including email address if the attorney is registered as a Filing User of electronic case filing, the caption of the case, and the title of the document. See L.R. 26.2(c). The final paragraph of the restricting order shall provide: (1) the identity of the persons, if any, who are to have access to the confidential materials without further order of court; and (2) instructions for the disposition of the restricted documents following the conclusion of the case. See L.R. 26.2(b).

2. Submitting the confidential document in chambers and filing a redacted copy with the Clerk=s Office. Under this option, documents designated as confidential shall not be filed with the Clerk=s Office. Rather, any such documents requiring the court=s review shall be submitted to chambers in camera in a sealed envelope bearing the caption of the case, case number, the title of the motion or response to which the submitted confidential information pertains, and the name and telephone number of counsel submitting the documents. The producing party must file a redacted copy of all documents containing confidential information with the Clerk=s Office for the record. In addition, the producing party must maintain the original documents intact for any further review. See L.R. 26.2(d).

In cases where a protective order is within the scope of the District Judge=s referral, Judge Valdez will enforce the filing practice of the referring District Judge.

In consent cases, Judge Valdez follows the first option discussed above. Counsel seeking to file documents previously designated as restricted pursuant to a protective order must therefore use the following procedure:

If a party intends to file a motion or other paper with the court which contains information designated as confidential by the other party or a non-party pursuant to a protective order between the parties, the filing party shall give reasonable notice of that intention to the designating party. A party seeking to file its own confidential information under seal, or a designating party given notice that a party intends to file the designating party=s confidential information, shall file and notice for hearing a Motion to File Under Seal prior to the due date of the particular filing. The Motion to File Under Seal must demonstrate good cause by including a specific description of the document (or categories of documents) that the party seeks to file under seal and explaining why confidentiality is necessary, consistent with the Seventh Circuit=s descriptions of what is protectable. The movant=s counsel shall bring a copy of the document or documents to the hearing for examination by the court.

Counsel should be aware that amendments to Local Rule 26.2 in April 2006 changed certain aspects of the way documents designated as confidential must be dealt with in filings with the court. First, pursuant to amended L.R. 26.2(b), no document may be filed under seal without a prior order of the court specifying the particular document or portion of a document to be filed under seal. This amendment changed the rule by making clear that only the particular document that has been previously determined by the court to be deserving of protection may be filed under seal, regardless of the existence of any protective order. Thus, parties are not to file briefs or compilations of exhibits as restricted or under seal unless the court has expressly so ordered, with respect to the particular briefs or exhibits. See Committee Comments to L.R. 26.2. Second, pursuant to L.R. 26.2(c) and (d), the amended rule now offers Judges two options regarding how to handle documents designated as confidential when those documents are submitted for consideration in connection with a motion, brief or other matter. The two options are as follows:

1. Filing the confidential document with the Clerk=s Office. Under this option, the confidential documents must be filed with the Clerk=s Office, and each confidential document presented for filing must include a copy of a restricting order entered by the Judge for that specific document or portion of document. The attorney or party submitting the confidential document must file it in a sealed enclosure that conspicuously states on the face of the enclosure the attorney=s or party=s name and address, including email address if the attorney is registered as a Filing User of electronic case filing, the caption of the case, and the title of the document. See L.R. 26.2(c). The final paragraph of the restricting order shall provide: (1) the identity of the persons, if any, who are to have access to the confidential materials without further order of court; and (2) instructions for the disposition of the restricted documents following the conclusion of the case. See L.R. 26.2(b).

2. Submitting the confidential document in chambers and filing a redacted copy with the Clerk=s Office. Under this option, documents designated as confidential shall not be filed with the Clerk=s Office. Rather, any such documents requiring the court=s review shall be submitted to chambers in camera in a sealed envelope bearing the caption of the case, case number, the title of the motion or response to which the submitted confidential information pertains, and the name and telephone number of counsel submitting the documents. The producing party must file a redacted copy of all documents containing confidential information with the Clerk=s Office for the record. In addition, the producing party must maintain the original documents intact for any further review. See L.R. 26.2(d).

In cases where a protective order is within the scope of the District Judge=s referral, Judge Valdez will enforce the filing practice of the referring District Judge.

In consent cases, Judge Valdez follows the first option discussed above. Counsel seeking to file documents previously designated as restricted pursuant to a protective order must therefore use the following procedure:

If a party intends to file a motion or other paper with the court which contains information designated as confidential by the other party or a non-party pursuant to a protective order between the parties, the filing party shall give reasonable notice of that intention to the designating party. A party seeking to file its own confidential information under seal, or a designating party given notice that a party intends to file the designating party=s confidential information, shall file and notice for hearing a Motion to File Under Seal prior to the due date of the particular filing. The Motion to File Under Seal must demonstrate good cause by including a specific description of the document (or categories of documents) that the party seeks to file under seal and explaining why confidentiality is necessary, consistent with the Seventh Circuit=s descriptions of what is protectable. The movant=s counsel shall bring a copy of the document or documents to the hearing for examination by the court.

In the event that a party withholds otherwise discoverable information on the ground of privilege, the withholding party generally must provide a log of the documents withheld on the ground of privilege. See Fed. R. Civ. P. 26(b)(5) and Advisory Committee Comments to 1993 Amendments. Any privilege log must be detailed enough to enable other parties to assess the applicability of the privilege asserted, and should include: (1) the name and capacity of each individual from whom or to whom a document and any attachments were sent (including which persons are lawyers); (2) the date of the document and any attachments; (3) the type of document; (4) the Bates numbers of the documents; (5) the nature of the privilege asserted; and (6) a description of the subject matter in sufficient detail to determine if legal advice was sought or revealed, or if the document constitutes work product. See Allendale Mut. Ins. Co. v. Bull Data Systems, Inc., 145 F.R.D. 84, 88 (N.D. Ill. 1992). The Court reminds the parties that the meet and confer requirements of Local Rule 37.2 apply to privilege disputes, just as they do to other discovery disputes In the event that a party withholds otherwise discoverable information on the ground of privilege, the withholding party generally must provide a log of the documents withheld on the ground of privilege. See Fed. R. Civ. P. 26(b)(5) and Advisory Committee Comments to 1993 Amendments. Any privilege log must be detailed enough to enable other parties to assess the applicability of the privilege asserted, and should include: (1) the name and capacity of each individual from whom or to whom a document and any attachments were sent (including which persons are lawyers); (2) the date of the document and any attachments; (3) the type of document; (4) the Bates numbers of the documents; (5) the nature of the privilege asserted; and (6) a description of the subject matter in sufficient detail to determine if legal advice was sought or revealed, or if the document constitutes work product. See Allendale Mut. Ins. Co. v. Bull Data Systems, Inc., 145 F.R.D. 84, 88 (N.D. Ill. 1992). The Court reminds the parties that the meet and confer requirements of Local Rule 37.2 apply to privilege disputes, just as they do to other discovery disputes

All settlement conferences will take place on video, via Webex. All parties must read and comply with the Court's Instructions for Settlement Conference and any communications from chambers personnel.

Instructions for Settlement Conference

All settlement conferences will take place on video, via Webex. All parties must read and comply with the Court's Instructions for Settlement Conference and any communications from chambers personnel.

Instructions for Settlement Conference

Final Pretrial Order
Final Pretrial Order

Click here to open Standard Voir Dire Questions to Jurors document. Click here to open Standard Voir Dire Questions to Jurors document.

When appropriate, the parties may submit to the Court a Proposed Order for the judge to consider, modify if necessary, and enter electronically. All Proposed Orders must be attached to an e-mail sent to the e-mail address of the assigned judge, Proposed_Order_Valdez@ilnd.uscourts.gov. The subject line of the e-mail must include the case number and name, the docket number of the corresponding motion, if any, and the title of the order that is proposed. Clean versions of all such documents must be submitted to the court in a format compatible with Microsoft Word. Any Proposed Order must also be served on all parties.

Submitting a Proposed Order electronically is not a substitute for filing a motion. A Proposed Order may only be submitted after the corresponding motion has been filed unless the Court has given prior leave to submit an order without motion.

The Court will not read or consider any motion or correspondence sent to the Proposed Order Inbox without prior authorization.

When appropriate, the parties may submit to the Court a Proposed Order for the judge to consider, modify if necessary, and enter electronically. All Proposed Orders must be attached to an e-mail sent to the e-mail address of the assigned judge, Proposed_Order_Valdez@ilnd.uscourts.gov. The subject line of the e-mail must include the case number and name, the docket number of the corresponding motion, if any, and the title of the order that is proposed. Clean versions of all such documents must be submitted to the court in a format compatible with Microsoft Word. Any Proposed Order must also be served on all parties.

Submitting a Proposed Order electronically is not a substitute for filing a motion. A Proposed Order may only be submitted after the corresponding motion has been filed unless the Court has given prior leave to submit an order without motion.

The Court will not read or consider any motion or correspondence sent to the Proposed Order Inbox without prior authorization.

Standing Order in Social Security Cases

Standing Order in Social Security Cases

Counsel must never contact the Courtroom Deputy or chambers on any matter that can be answered by reviewing the Court’s website and Standing Orders. Any messages seeking information that is available on the website will not be returned.

 

It is never appropriate to email chambers staff of Judge Valdez without prior permission of the Court. Counsel should also ordinarily not call chambers for any reason. Should an extraordinary circumstance require a telephone call to chambers, counsel for all parties should be on the call. Ex parte telephone calls to chambers on case-related matters should never occur unless it is impossible or impracticable to have all counsel for all parties on the call. When counsel or their agents call chambers ex parte absent an extraordinary circumstance, chambers staff have been instructed to inform the person calling that case-related matters may not be discussed ex parte by telephone. Anything that counsel or their agents should not say ex parte directly to the judge cannot be said to her chambers staff.

 

In the event it is necessary to communicate with chambers by telephone, anyone calling chambers should conduct themselves in the same manner as if they were speaking directly to the judge.

Counsel must never contact the Courtroom Deputy or chambers on any matter that can be answered by reviewing the Court’s website and Standing Orders. Any messages seeking information that is available on the website will not be returned.

 

It is never appropriate to email chambers staff of Judge Valdez without prior permission of the Court. Counsel should also ordinarily not call chambers for any reason. Should an extraordinary circumstance require a telephone call to chambers, counsel for all parties should be on the call. Ex parte telephone calls to chambers on case-related matters should never occur unless it is impossible or impracticable to have all counsel for all parties on the call. When counsel or their agents call chambers ex parte absent an extraordinary circumstance, chambers staff have been instructed to inform the person calling that case-related matters may not be discussed ex parte by telephone. Anything that counsel or their agents should not say ex parte directly to the judge cannot be said to her chambers staff.

 

In the event it is necessary to communicate with chambers by telephone, anyone calling chambers should conduct themselves in the same manner as if they were speaking directly to the judge.

For consent cases in which judicial approval of settlement is statutorily required, the parties' motion for approval must include a calculation of the amount of damages claimed and the damages paid; and a statement of how the parties reached the settlement values, including fees and costs. A copy of the settlement agreement must also be filed as an exhibit. 

For consent cases in which judicial approval of settlement is statutorily required, the parties' motion for approval must include a calculation of the amount of damages claimed and the damages paid; and a statement of how the parties reached the settlement values, including fees and costs. A copy of the settlement agreement must also be filed as an exhibit.