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Motion Requirements

a. 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).

In light of the April 20, 2006 revisions to Local Rule 56.1 , 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.

b. 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 presented. 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.

c. 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.

d. All Motions

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 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.

The Court will apply the meet and confer requirement to all motions that a party files. The previous comments on compliance with the meet and confer requirement will be applied with respect to all other motions. 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. Any motion must state with specificity what the parties did to comply with the meet and confer requirement.




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