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.