• Theresa Kinney
  (312) 435 - 5668
  Room 1914

• Marc Krickbaum
• Fred Yarger

• Lois LaCorte
  (312) 435-5558
  Room 1918

The Court will set all newly filed cases for status approximately 60 days after the filing of the complaint. At the initial status conference, parties should be prepared to discuss: (1) the nature and scope of the case; (2) settlement opportunities and settlement discussions to date; (3) initial discovery parameters and discovery taken to date; and (4) the scheduling of future conferences and, as appropriate, motions.

At least three business days before the initial status conference, the parties are directed to file a joint written status report of not more than five pages. Initial Status Report for Newly Filed Cases. (Note: This report need not be filed in mortgage foreclosure cases. Those cases will be set for status conference as discussed in the Initial Status Report for Newly Filed Cases)

Please note that the procedures for Initial Status Conferences outlined above do not apply to cases reassigned to Judge Filip from other District Courts upon Judge Filip's taking the bench in March 2004. Parties in all such cases will be notified of status conferences and will be required to complete the status report form included in the Order Requiring Status Report and Setting Status Hearing for Cases Newly Assigned to Judge Filip, consistent with the instructions provided therein.

All parties are reminded of their obligations to make the disclosures required by Rule 26 of the Federal Rules of Civil Procedure and Local Rule 26.1 of the Northern District of Illinois.

Parties must file all motions (the original and two copies) with the Clerk of the Court at least three (3) full business days before presentment. Please drop one courtesy copy of all motions in the box outside of the courtroom deputy's office, located at Room 1914. If that drop box is unavailable, courtesy copies may be dropped in the mail slot of chambers, located at Room 1978. All motions must be noticed for a date certain.

Please identify all joint, uncontested, or agreed motions in the title and body of the motion. Unless the court has told a party it need not appear, counsel for all parties are expected to be present whether or not the motion is agreed. After 4:00 PM on the afternoon prior to the hearing date, counsel should check the Call Sheet posted on this Court's webpage to determine whether an appearance is necessary. Counsel also may call Theresa Kinney, the courtroom deputy, at (312) 435-5668. If an appearance is not required, the movant is directed to notify the respondent(s) accordingly.

Counsel should not respond to motions by correspondence with the Court.

The Court encourages parties to work out discovery disputes and discourages the filing of discovery motions. The Court will not hear or consider any discovery motions (e.g., motions for discovery and/or production of documents under Fed. R. Civ. P. 26-37) unless the parties have complied with Local Rule 37.2.

In any motion for discovery or production of documents, the movant shall state when and how the movant complied with Local Rule 37.2. Parties are reminded that compliance with Local Rule 37.2 requires a good faith effort to resolve discovery disputes through communications and negotiations that take place in person or over the telephone. The mere exchange of correspondence will not normally be sufficient to satisfy Local Rule 37.2.

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

Parties are reminded that there is no requirement that discovery occur in any particular order, and that one party's failure or inability to respond to discovery will not excuse any other party's prompt compliance.

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

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. 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. The movant shall not file more than 100 statements of undisputed material fact without prior leave of Court. The respondent shall be limited to 50 statements of undisputed material fact absent 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 fact.

The following briefing schedule will apply if cross motions for summary judgment will be filed. Defendant's summary judgment motion will be due on the dispositive motion filing deadline. Plaintiff's combined cross motion and response to the defendant's motion will be due three (3) weeks thereafter. Defendant's reply in support of its motion and response to the plaintiff's cross motion will be due three (3) weeks thereafter. Plaintiff's reply in support of its cross motion shall be due two (2) weeks thereafter. Ruling to be by mail. 

Final pretrial orders are to be filed in open court. Filing dates not previously set in court may be obtained from the courtroom deputy. Motions in limine are due three weeks before trial or at the time of filing the final pretrial order, whichever is sooner. 

The Court urges parties to explore settlement possibilities at the earliest practicable point in the litigation. Parties who believe that a settlement conference may be productive should request one individually, in open court, or by telephone from the courtroom deputy. Standing Order Regarding Settlement Conferences

Too often litigants are unaware of the efficiencies and potential cost savings to be gained by having their cases tried before a United States Magistrate Judge. The Court strongly encourages counsel to inform their clients of this option, and to discuss it with opposing counsel. Magistrate Judge Consent Form

Briefs on appeal from the United States Bankruptcy Court must be filed within 15 days of the entry of judgment by the Bankruptcy Court. Any motions to extend time must be filed during the 15-day period. Briefs are limited to 15 pages each.

With regard to protective orders, all material sought to be protected should be described in sufficient detail to justify such protection (e.g., "trade secrets," "personnel files"). Parties cannot and will not be given total discretion to mark whatever material they choose to be protected or kept confidential.

The Court will not require the inclusion of an express finding of good cause in such orders. Instead, the Court will review such orders carefully before signing them. The Court's issuance of the protective order will constitute the determination, as required by Fed. R. Civ. P. 26(c), that good cause existed for issuance of the order.

Issuance of any protective order will not be given preclusive effect as a determination of good cause for Rule 26(c) purposes if at a future time a party or an interested member of the public moves for relief from the limitations of the protective order. See Citizens First Nat'l Bank of Princeton v. Cincinnati Insurance Co., 178 F.3d 943, 946 (7th Cir. 1999). At that time the Court will engage in an appropriate assessment of the interests between privacy and public access to make a determination of good cause as to the challenged document(s) in light of the facts then before the Court. See Jepsen, Inc. v. Makita Elec. Works, Ltd., 30 F.3d 854, 859 (7th Cir. 1994).

1. All Arraignments/bonds/detention hearings will be set before the designated Magistrate with the following schedule to be set :

16.1 conference	7 Business days from Arraignment
Status	Set Status hearing before pretrial motions are due on Friday at 1:30pm.
Pretrial Motions	10 Business days after 16.1 conference
Response	10 Business days after pretrial motions
Reply	7 Business days after response

2. Counsel is requested to contact the judge’s courtroom deputy at least one day in advance of a change of plea hearing if the plea is not going forward. In addition, a draft copy of the proposed plea agreement should be delivered to the judge’s chambers or to courtroom deputy, Room 1732, at least one day in advance of the date of the hearing. 

Proposed Orders are technically not to be "filed." Rather, they are to be "submitted" to the judge to consider, to modify, if appropriate, and to enter electronically. For example, proposed orders such as stipulated protective orders require court approval before actually being given full effect. To prevent confusion, such proposed orders must be attached to an e-mail sent to the e-mail address of the assigned judge, Proposed_Order_Filip@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 as indicated on the Notice of Electronic Filing (NEF). All such documents must be submitted to the court in a format compatible with WordPerfect, which is a "Save As" option in most word processing software. Such proposed orders should also be served on all parties.