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Motion Practice

Civil motions are heard on Tuesdays and Wednesdays at 9:45 a.m.  Criminal motions are heard on Wednesdays at 9:45 a.m. The original motion should be filed no later than the third business day preceding the day the motion is to be heard.  Motions may also be noticed in conjunction with a set hearing, but the three-day notice requirement still applies.  Original filings shall not be accepted in chambers, however, a courtesy copy should be delivered to chambers within 24 hours after filing. If the filing totals 50 or more pages, the courtesy copy should be bound and tabbed as provided in Local Rule 5.2(d) for “judge’s paper copies.” Courtesy copies need not be delivered in an envelope unless the pleading contains under-seal material. If the document is electronically filed, the courtesy copy must include the printed CM/ECF header at the top of every page. 







Joint, uncontested or agreed motions should be so identified. The movant in all motions may contact the minute clerk (Ruth O'Shea - (312) 435-5814) the afternoon prior to the hearing date to determine whether an appearance is necessary. If an appearance is not necessary, it is the obligation of the movant to notify the respondent(s) accordingly.







Trial dates and discovery cutoff dates will not be reset except by written motion. Motions to extend a discovery cutoff date or to reset a trial date, whether uncontested or contested, will normally require a court appearance.







Prior to filing any motion to compel, to dismiss, or for summary judgment, the moving party shall first serve the nonmoving party with a concise letter summarizing the legal and factual grounds for the motion, with references to supporting authorities, and make a sincere effort to resolve issues relating to the motion. Any filed motion must contain a statement of compliance with this rule or the motion will automatically be denied without prejudice.







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







All attorneys who appear in court are responsible for writing down future dates set by the Court. The Clerk's office will no longer be mailing out minute orders reiterating dates on matters where the parties have appeared and have been informed of a new date in open court, nor will chambers provide such information. Parties needing information on set dates may obtain the information in person in the Clerk's office.



For any word-processed filing (e.g., briefs and memoranda), counsel shall convert the document into a .pdf document by printing or publishing to .pdf, rather than manually scanning a paper copy into .pdf, in order to generate searchable optical character recognition (OCR) text. For any filing of any kind (including exhibits in support of a motion or any Local Rule 56.1 Statement), counsel must run an OCR conversion on it before uploading it onto CM/ECF. To do this in Adobe, go to Tools, Text Recognition, In This File, and select All Pages. If you see the message, “Acrobat could not perform recognition (OCR) on this page because this page contains renderable text,” click “Ignore future errors in this document,” and click OK.




A. Emergency Motions







Emergency matters must be of such a nature that a delay in hearing them would cause serious harm to one or more of the parties. The emergency motion should be filed with as much advance notice as possible, and a courtesy copy shall be delivered to chambers. The Court will review the motion and will notify moving party when the Court will hear the motion.  All reasonable efforts must be made to give actual notice to opposing counsel.







B. Summary Judgment Motions







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.







In complex and fact intensive cases, the parties are encouraged, and may be directed by the Court, to file a summary or chronology of relevant dates and events, in addition to their Rule 56.1 submissions.







C. Discovery Motions







Discovery motions shall not be heard without an affidavit pursuant to Rule 37.2 of the Local Rules.







D. Motions To Reconsider







Motions for reconsideration should not be routinely filed and will generally be granted only in a narrow set of circumstances.See, e.g., Jefferson v. Security Pacific Financial Services, Inc., 162 F.R.D. 123 (N.D. Ill. 1995); Young v. Murphy 161 F.R.D. 61 (N.D. Ill. 1995).



Note: The court does not control nor can it guarantee the accuracy, relevance, timeliness, or completeness of this information. Neither is it intended to endorse any view expressed nor reflect its importance by inclusion in this site.
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