Northern District Of Illinois
Local Rules
LR16.1.3. Form of Pretrial Memorandum for Use in Employment Discrimination Cases
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
___________ DIVISION
) | Civil Action No. | |
) | ||
) | Judge [Insert name of assigned judge] | |
v. |
) | |
) | ||
) |
Part
A.
Plaintiff’s Summary of Damages
1.
Lost Wages and Benefits: [For each year for which damages are claimed,
indicate (A) the total wages and benefits that would have been earned working
for defendant but for the discrimination, (B)
the total wages, benefits, and other income earned in substitute employment that
plaintiff was able to obtain, (C) additional wages and benefits defendant
maintains plaintiff could have earned, and (D) the difference between (A) and
the total of [(B) + (C)].
A
B
C
D
Amounts Lost
Amounts Earned
Additional
Due to
in Substitute
Amounts Could
Difference
Year[1]
Discrimination
Employment
Have Earned
(A-(B+C))
19_____ __________
__________
__________
__________
19_____ __________
__________
__________
__________
Total
Lost Wages & Benefits:
$__________
2.
(a)
Attorneys Fees (to date):
$__________
(b)
Costs (to date):
$__________
3.
Do you claim:
(a)
Pain, suffering, emotional injury, etc.?
Yes
¨
No ¨
If yes, how much?
$__________
(b)
Punitive or liquidated (double) damages?
Yes
¨
No ¨
If yes, how much?
$__________
(c)
Pre-judgment interest?[2]
Yes
¨
No ¨
If yes, how much?
$__________
4.
Do you claim any other kinds of damage?
Yes
¨
No ¨
If yes, what kind and how
much?
_________________________________
$__________
5.
Total Amount Claimed:
$__________
Part
B.
Defendant’s Summary of Damages, Assuming Liability [This portion is to be completed in good faith even though defendant
disputes liability.]
1.
[For each year for which damages are claimed, indicate (A) the total
wages and benefits that would have been earned working for defendant but for
the discrimination, (B) the total wages, benefits, and other income earned in
substitute employment that plaintiff was able to obtain, (C) additional wages
and benefits defendant maintains plaintiff could have earned, (D) other
amounts received, such as disability or pension payments, and (E) the
difference between (A) and the total of (B) + (C) + (D).]
A
B
C
D
E
Amounts
Amounts
Additional
Lost
Earned in
Amounts
Other
Due to
Substitute
Could Have
Amounts
Difference
Year[1]
Discrimination Employment
Earned
Received (A-(B+C+D))
19_____ __________
__________ __________
__________
__________
19_____ __________
__________ __________
__________
__________
Total Lost Wages & Benefits:
$__________
2.
Does the defendant dispute the amount claimed for attorney’s fees and
costs?
Yes
¨
No ¨
If yes, explain, giving estimated amount due:
______________________________________________________________________________
___________________________________________________________
$__________
3.
Does the defendant dispute the amount claimed for pain, suffering,
emotional injury, etc?
Yes
¨
No ¨
If yes, explain, giving estimated amount due:
______________________________________________________________________________
___________________________________________________________
$__________
4.
Does the defendant dispute the claim for pre-judgment interest?
Yes
¨
No ¨
If yes, explain, giving estimated amount due:
______________________________________________________________________________
___________________________________________________________
$__________
5.
Does the defendant dispute the claim for punitive damages?
Yes
¨
No ¨
If yes, explain, giving estimated amount due:
______________________________________________________________________________
___________________________________________________________
$__________
6.
Does the defendant dispute any other claims for damages made by the
plaintiff?
Yes
¨
No ¨
If yes, explain, giving estimated amount due:
______________________________________________________________________________
___________________________________________________________
$__________
7. Total amount owed, assuming liability: $__________