If moving counsel is aware that there is no objection to a motion, or that the motion is agreed, that information must be stated in the title and body of the motion.

Counsel or a party must appear in person for the presentment of a motion.  Noticing a motion for presentment telephonically does not get around the Court's requirement that motions be presented in person.

For status hearings, the Court may allow the parties to participate telephonically if, in its discretion, the circumstances of the case allow for a telephonic status. Status hearings will be telephonic only if ordered by the Court.  During a telephonic status hearing, counsel shall not operate motor vehicles or heavy machinery during the call.  Likewise, during telephonic status calls, counsel should be in a quiet location.  By way of example, a hallway in the Daley Center, any property of or near the CTA, and counsel’s children’s day care are not considered quiet locations.  Although a golf course might be a quiet location, it is not an appropriate location for a telephonic status hearing.  Before participating in a telephonic status hearing, counsel must first read this Court’s standing order on Telephonic Status Hearings.

A courtesy copy of all motions must be delivered to Operations Specialist Yvonne Pedroza in Room 2200 at least 48 hours before the time of presentment.

Parties must include with their motion or any supporting memorandum copies of any authority that is published only on an electronic database, such as Westlaw and Lexis.  Copies of that authority must be legible.  Absent leave of Court, all motions and memoranda of law must comply with the 15-page limitation set forth in Local Rule 7.1.  Parties must also ensure that a motion or memorandum is double spaced.  Line spacing of 1.5 is no longer permitted under the Local Rules.  The Court requires compliance with Local Rule 5.2, which requires that a judge’s copy must be bound on the left side and must have protruding tabs for exhibits, and further requires a list of exhibits if more than one exhibit is attached.

Judge Johnston will not hear or consider any discovery motion unless there has been a 'meet and confer' meeting between the parties. Any motion for discovery or production of documents, shall state when and how the movant complied with the meet and confer meeting.  Local Rule 37.2.

If a party is seeking to enforce a subpoena on a non-party, the party must provide notice of the motion to that non-party.

Except for discovery motions involving privilege issues, the Court will generally rule on discovery motions on the day of presentment after argument and without further briefing.  But nothing prevents a party from filing a written response to a discovery motion before the motion is set for presentment.

Except to the extent specified by the court on motion of either party, discovery must be completed before the discovery closing date. Discovery requested before the discovery closing date, but not scheduled for completion before the discovery closing date, does not comply with this order.

Discovery issues, including motions to extend discovery, must be presented to the Court before the close of discovery.  In re Sulfuric Acid Antitrust Litigation, 231 F.R.D. 331, 332 (N.D. Ill. 2005).  Indeed, the Court might not consider discovery issues long known to the parties but not brought to the Court's attention until the eve of the close of discovery.  Haviland v. Catholic Health Initiatives-Iowa, 692 F. Supp. 2d 1040, 1044 (S.D. Iowa 2010).