Unless otherwise specified by Judge Lefkow, in preparing the Final Pretrial Order, follow the form specified in the final pretrial order appended to Local General Rule 16.1 and Form Local Rule 16.1.1.
(A) All instructions contained within the Final Pretrial Order must be followed. The submissions in the pretrial materials will be binding on the parties at trial. If any counsel believes that any of the instructions allow for any part of the Pretrial Order to be deferred until after the submission date, counsel shall file a motion seeking leave of court for such deferral.
(B) To prepare the pretrial materials required for the Final Pretrial Order, counsel for all parties are directed to meet in order to (1) reach any possible stipulations narrowing the issues of law and fact; (2) identify non-stipulated issues of law and fact; and (3) identify documents that will be offered in evidence.
(C) Plaintiff has the responsibility to initiate conferences, to prepare the initial draft of pretrial materials, and to ensure that timely completion occurs. Defendant has the responsibility to work cooperatively with opposing counsel to the same end, and where counterclaims or affirmative defenses are pled, the defendant has the initiating responsibility and plaintiff the responding responsibility.
Counsel’s meeting shall be held sufficiently in advance of the submission date to permit thorough preparation of the pretrial materials.
(D) The judge will issue an order in advance of the pretrial order due date, similar to that reproduced below:
"Plaintiff shall serve a draft of the final pretrial order on defendant by [date]. Defendant shall serve a draft of the final pretrial order on plaintiff by [date]. Any pretrial materials, including the Joint Final Pretrial Order, and any motions in limine, fully briefed, are due by [date]. Parties shall indicate in the pretrial order which motions in limine are disputed and which are not. The parties are directed to bring with them to the pretrial conference copies of any disputed exhibits.