print

In accordance with Local Rule 5.4, all filings in cases assigned to Judge Gottschall shall be with the Clerk of the Court.

Court staff are prohibited from communicating with attorneys and parties about substantive matters, whether by telephone or email.  Such matters are to be addressed only in court filings or on-the-record hearings.  If communication is necessary for scheduling, administrative, or emergency purposes, the court strongly prefers email communication to Chambers_Gottschall@ilnd.uscourts.gov with a copy to all parties and counsel of record. 

(Note: This email address is not to be used for filings, proposed orders, or any communication regarding substantive matters.)

print

Parties and counsel are reminded that, unlike Rule 7.1(a)(1) of the Fed. R. Civ. P., the definition of “affiliate” in Local Rule 3.2 does not distinguish between privately and publicly held ownership interests.  Thus, all affiliates meeting Local Rule 3.2(a) must be identified, including privately held interests.  Collectanea J. Ltd. v. Defs. Identified on Sched. A, 2024 WL 4604532, at *1 n.1 (N.D. Ill. Oct. 29, 2024). 

Until there is compliance with Local Rule 3.2, the court cannot adjudicate any motion or other request for judicial action. 

print

Courtesy copies are no longer required.  Please do not send courtesy copies to chambers unless specifically requested in a particular case.  When a courtesy copy is requested, the party submitting it must:

• attach a cover letter identifying the case name, case number, and the docket number of the filing(s).

• print single-sided on white 8.5 x 11-inch paper.

• bind and tab the paper copy. 

            Acceptable binding methods include secure staples, comb binding, and three-ring binders. 

            Unacceptable binding methods include binder clips, paper clips and rubber bands.

• deliver the courtesy copies to the courtroom deputy, Room 2516A.

print

In most cases commenced by the filing of a complaint, the court will set a deadline to file a joint initial status report within approximately sixty days after the complaint is filed.  The deadline in a case removed from state court is ordinarily thirty days after removal.  Requests to extend the deadline to file a joint initial status report must be made by motion filed in the docket, rather than by contacting court staff.

The court requires that plaintiff's counsel schedule a preliminary meeting with opposing counsel, approximately fourteen days prior to the initial status report deadline, to explore settlement opportunities and identify areas of agreement.  Plaintiff's counsel shall advise opposing counsel to review Judge Gottschall’s case procedures located on the court’s website at:

/judge_display.php?LastName=Gottschall. The court recognizes that in some cases counsels’ preliminary meeting may take place before defendants have filed an answer to the complaint.  However, the court expects all defendants who have been served to participate in this process regardless of whether they have filed an answer.

The joint initial status report serves as the report of the parties’ Rule 26(f) planning conference and must:

1. Identify the attorney(s) of record for each party (including the lead attorney).  List only the attorney’s name and, if applicable, law firm name;
2. State the basis for this court’s subject matter jurisdiction;
3. Identify —

(a) Any party who has not been served in accordance with Rule 4 and indicate when service is expected to be completed;

(b) Any party who has not filed a notice of affiliates required by Local Rule 3.2; and

(c) Any party who has not filed a jurisdictional disclosure statement required by Rule 7.1(a).

  4. Describe the nature and scope of the case in no more than one paragraph;

5. Identify settlement opportunities; and

6. Propose a discovery schedule complying with Rule 16(b)(3) and a deadline for     filing the next status report (45-60 days).  A suggested format follows:

(a) Deadline to join parties:                                        [proposed date];

(b) Deadline to amend pleadings:                              [proposed date];

(c) Deadline to complete fact discovery:                    [proposed date];

(d) Deadline to complete expert discovery:               [proposed date];

(e) Deadline to file dispositive and other motions:     [proposed date]; and

(f) Deadline to file the next status report:                   [proposed date].

print

Every status report except the joint initial status report must:

1.         Address the progress of discovery.

2.         Address settlement efforts.

3.         Propose an agreed schedule for the next 45 to 60 days.

4.         Propose a deadline for filing the next status report.

print

1. Presentment Hearings: Motions should not be noticed for presentment. If a motion has not been addressed within three business days, counsel may send a message to Chambers_Gottschall@ilnd.uscourts.gov.

2.         Unopposed Motions: Unopposed and agreed motions must include the word “unopposed” in the motion’s title. 

3.         Emergency Motions: Emergency motions must be “of such a nature that the delay” in hearing them “would cause serious and irreparable harm to one or more parties.”  Local Rule 77.2.  Before filing an emergency motion, counsel must notify Judge Gottschall’s courtroom deputy by phone.  A time-sensitive motion must include the word “emergency” in its title.

4.         Requesting a Hearing: Any party may request a hearing, preferably by teleconference, by filing a separate motion to set a hearing.  The motion should explain why a hearing is desired.

5.         Discovery Motions: Regarding the filing of motions for discovery and production of documents under Rules 26–37 of the Federal Rules of Civil Procedure, the court will not hear or consider any discovery motion unless the parties have complied with Local Rule 37.2.  Parties are strongly encouraged to work out discovery disputes without resorting to motion practice. 

print

Except in “Schedule A” cases when a temporary restraining order or preliminary injunction is requested, counsel need not submit a proposed order unless the court requests one.

print

Failure of the parties to heed the requirements of Federal Rule of Civil Procedure 56 and Local Rule 56.1 greatly complicates this court’s consideration of motions for summary judgment.  Because these motions are frequently important and helpful in avoiding unnecessary trials and in focusing and/or reducing the issues at trial, the court provides the following clarifications and refinements of Local Rule 56.1.

1. The parties' memoranda of law must comply with Local Rule 56.1(g). The memoranda “must cite directly to specific paragraphs in the Local Rule 56.1 statements or responses.” Local Rule 56.1(g). Direct citations to evidentiary material such as a deposition, affidavit, or exhibit are prohibited. All arguments must be located in the legal memoranda only (as opposed to the fact statements).
2. The paragraphs of a Local Rule 56.1(d) fact statement must be limited to actual facts; argument masquerading as fact will not be considered. All argument on factual and legal issues must be addressed in the legal memoranda. To avoid unnecessary disputes about “facts,” as opposed to the reasonable inferences to be drawn from them, the parties should refrain from including inferences in Local Rule 56.1(d) fact statements. The reasonableness of inferences to be drawn from the facts must be addressed in the legal memoranda, rather than by asserting them as “facts” in a Local Rule 56.1(d) fact statement.  “Loading up” a Local Rule 56.1(d) fact statement with inferences may cause the fact statement to be stricken.
3. “A response [to a fact statement] may not assert legal arguments except to make an objection, including objections based on admissibility, materiality, or absence of evidentiary support.”  Local Rule 56.1(e)(2).  Local Rule 56.1 does not contemplate speaking objections.  Legal argument in support of objections should be contained in the relevant memorandum of law.  No legal argument should be contained in a Local Rule 56.1(e) response to a fact statement.  If the responding party does not dispute a fact, but rather the inference to be drawn therefrom, the fact should be listed as admitted, and the inference should be argued in a memorandum of law.
4. All citations to affidavits, declarations, deposition transcripts, and other evidentiary materials must be specific as to the paragraph or page and line whenever possible.  See Local Rule 56.1(d)(2) and (e)(3). Avoid ambiguous citations to exhibits.  For instance, if two depositions of the same person are in the summary judgment record, each citation should include the date of the deposition.  Similarly, if two affidavits of Jane Smith are on file, include the affidavit’s date in each citation to the “Aff. of J. Smith.” A citation to an email message should include the date and time of the message.

The Court strongly encourages all filings to include hyperlinks to any cases or docket entries referred to.  If possible, the Court prefers hyperlinks to exhibits as well but recognizes that this may entail more time and expense.  To the extent possible, the Court prefers any citation to exhibits, cases, and docket entries to be hyperlinked.

For directions on how to include hyperlinks in filings visit: http://www.ned.uscourts.gov/internetDocs/cmecf/hyperlinking_attorneys_word.pdf

print

The Clerk has been directed to enter this standing order in all “Schedule A” cases assigned to Judge Gottschall in order to promote the case’s just, speedy, and inexpensive resolution.  A motion or proposed order that does not comport with the following will be rejected unless, if applicable, the accompanying memorandum of law includes a good faith argument for revisiting or modifying the pertinent decision(s).