judge console · N.D. Ill.
N.D. Ill. · Judge Alexakis · Practice Guide

Hon. Georgia N. Alexakis

All local rules for N.D. Ill., integrated with this judge's published requirements.

Before You File
Contacting chambers
👤 Judge Alexakis — standing order

Important Information Until further notice, any email correspondence regarding Judge Alexakis' cases should be directed to Vanessa Miller ( vanessa_miller@ilnd.uscourts.gov ). If a phone call is necessary, Ms. Miller can be reached at (312) 818-6599. Email correspondence, copying opposing counsel, is strongly recommended and will yield a faster response than a phone call. Please do not email or call with requests for extensions of time; motions should instead be filed. This page and the links to the right contain important information about Judge Alexakis' case management procedures. Please take the time to familiarize yourself with these procedures as well as those in the Local Rules. When there is a conflict, please follow the procedures outlined here. These policies and rules have been designed to facilitate the prompt, efficient, and equitable disposition of civil cases on Judge Alexakis’ docket. The success of her pretrial and trial procedures depends on your familiarity with them, and counsel will be expected to explain to Judge Alexakis any failure to comply with these procedures. Motions Judge Alexakis will not be hearing motions the week of 6/29/2026. Judge Alexakis hears motions on Mondays, Tuesdays, and Thursdays at 9:30 a.m. All motions must be noticed for presentment no later than three business days before the hearing (excluding federal holidays and weekends). For example, absent a holiday, (1) a motion filed on a Monday may be noticed for the upcoming Thursday; and (2) a motion filed on a Thursday may be noticed for the following Tuesday. Parties are expected to appear in person unless Judge Alexakis advises otherwise. Any request to appear by telephone must be made via email to the Courtroom Deputy no later than 24 hours before the motion hearing. Opposing counsel should be copied on this email.

Drafting the Motion
Length limits — motion, opposition, reply
🏛 N.D. Ill. local rule
Motion

15 pages maximum Local Rule 7.1 ↗

Opposition

15 pages maximum Local Rule 7.1 ↗

Reply

15 pages maximum Local Rule 7.1 ↗

Filing & Scheduling
Briefing schedule & hearing date
🏛 N.D. Ill. local rule
Notice period

Presentment model; notice date not more than 14 days after filing Local Rule 5.3 ↗

Hearing days

File by 4:30 PM two business days before presentment; hearing days set per judge Local Rule 78.1 ↗

Proposed orders
🏛 N.D. Ill. local rule

Silent on proposed orders. The local rules do not require a proposed order with motions. Consult the assigned judge's individual practices page on the court website. Local Rule 5.3(a) ↗

The Hearing
Oral argument
🏛 N.D. Ill. local rule

Oral argument at court's discretion; court may rule on papers without hearing Local Rule 78.3 ↗

Discovery
Discovery referral procedure
🏛 N.D. Ill. local rule

Magistrate assigned to each case; LR 37.2 in-person or phone conferral required before filing Local Rule 72.1 ↗

Discovery dispute procedure
👤 Judge Alexakis — standing order

Discovery Meet and Confer Requirement Parties can and should resolve most discovery disputes without judicial intervention. Judge Alexakis will not consider any discovery-related dispute unless the movant has complied, in good faith, with the “meet and confer” requirement of Local Rule 37.2. This applies not only to motions to compel but also motions to quash discovery or motions for protective orders. Any motion must state with specificity when and how the movant complied with Local Rule 37.2, such as through communications that took place in person, by video conference, or by phone. The exchange of emails or letters normally will not be sufficient to comply with Local Rule 37.2. If a party requests a meet-and-confer, the other party must respond promptly and participate in a meet-and-confer in a reasonable time. If parties reach an impasse regarding the recovery of electronically stored information and/or the discovery of voluminous records from a database, server, computer, service provider or similar electronic storage facility, no discovery motion may be filed unless the parties first meet and confer to determine whether the requested material can be retrieved and, if so, the most effective way of doing so. This conference must take place in person, by videoconference, or by phone and must be attended by an IT representative of the party (or, for a putative class, an IT representative of plaintiffs’ counsel) that served the request, an IT representative of the facility to be searched, and an IT representative of the party that received the request. All participants should be prepared to discuss specifically the parameters of both the search and the facility. Discovery Motions All parties should be fully prepared to argue any discovery motion on the date it is presented. Judge Alexakis often will rule on discovery motions after hearing argument at the motion call and without additional briefing. If after hearing argument, Judge Alexakis believes that the motion requires briefing, she normally will set an expedited briefing schedule so that the matter can be resolved promptly. Parties should promptly notify Judge Alexakis, via an email to the Courtroom Deputy, if they are withdrawing, or narrowing, any previously filed discovery motions. Discovery Continuances Parties must issue discovery and respond to discovery as needed to meet the discovery deadlines, which means parties must plan ahead to avoid last-minute scrambles as deadlines approach. Any motion to extend time for the completion of discovery must be presented in writing (after conferral with the other side), be filed well in advance of the relevant discovery deadline, and demonstrate good cause for the extension. Sequence of Discovery Parties are reminded that there is no “order” in which discovery must occur. See Fed. R. Civ. P. 26(d)(3). One party’s failure or inability to respond to discovery will not excuse another party’s prompt compliance. Stay of Discovery The pendency of a motion, such as a motion to dismiss, does not operate as a stay of discovery absent Judge Alexakis’ explicit order. A motion to stay discovery must explain why a stay is appropriate for the specific case. Limit on the Number of Requests To Admit Judge Alexakis sets a limit of 25 requests for admission, pursuant to Rules 26(b)(2) and 36 of the Federal Rules of Civil Procedure. Per “side” means parties represented by the same counsel. Any party may seek relief from this order by way of motion. Boilerplate Objections Objections to written discovery must state with specificity the grounds for objecting. See, e.g., Fed. R. Civ. P. 33(b)(4) (“The grounds for objecting to an interrogatory must be stated with specificity.”); Fed. R. Civ. P. 34(b)(2)(B) (“For each item or category, the response must state with specificity the grounds for objecting to the request, including the reasons.”). That is, the objecting party must offer a particularized reason tailored to each request. A generic assertion that a discovery request is, for example, “overbroad” or “unduly burdensome,” without accompanying detail, is inadequate. To sustain such an objection, Judge Alexakis almost certainly will need specific information from knowledgeable sources regarding the amount and nature of the effort required to comply with the request; the number of documents or amount of data likely to be generated by compliance; and the availability of alternative sources of information.

Know Before You Go
👤 Judge Alexakis — deviations that burn people
  • [Motion Practice and Memoranda of Law]
  • In-Person Presentment Judge Alexakis hears motions on Mondays, Tuesdays, and Thursdays at 9:30 a.m. Motions must be accompanied by a notice of presentment specifying the date and time on which the motion will be presented in-person. If Judge Alexakis already has set a briefing schedule on an anticipated motion, then the movant need not notice the motion for presentment. Motions must be filed no later than the third business day (excluding federal holidays and weekends) before the motion is to be presented. For example, absent a holiday, (1) a motion filed on a Monday may be noticed for the upcoming Thursday; and (2) a motion filed on a Thursday may be noticed for the following Tuesday. The notice of motion must be filed separately on the docket for the hearing to appear on Judge Alexakis’ calendar. Do not attach the notice as an exhibit to the motion. Please review Judge Alexakis’s main page for all dates on which she will be unavailable to hear motions. Parties are expected to appear in person unless Judge Alexakis advises otherwise. Any request to appear by telephone must be made via email to the Courtroom Deputy no later than 24 hours before the motion hearing. Opposing counsel should be copied on this email. Counsel should check the docket after 4 p.m. on the afternoon before the scheduled motion date to see if an appearance is necessary. Meet and Confer Requirement Counsel for a movant must ask opposing counsel whether there is an objection to the motion. If there is an objection, the movant must note that fact in the body of the motion. Joint, uncontested, and agreed motions should be so identified in both the title and the body of the motion. Many of those motions will be granted without appearance. This meet and confer requirement does not apply to dispositive motions typically contested by the parties, including motions to dismiss and motions for summary judgment, or motions that are administrative in nature, such as motions to withdraw as counsel and pro hac vice motions. If in doubt, please confer with opposing counsel before filing a motion. For opposed motions, the movant must confer with the opposing party before filing and, if the non-moving party intends to respond to the motion, the moving party should include an agreed proposed briefing schedule in the motion itself. (See below for additional details on “Briefing Schedules.”) If the non-moving party does not intend to respond to the motion, the motion should say so in lieu of proposing a briefing schedule. Briefing Schedules All opposed motions must be accompanied by an agreed briefing schedule or, if need be, competing proposals for a briefing schedule. If the parties do not propose a briefing schedule, Judge Alexakis will set one, which may be more accelerated than the parties would prefer. In a case of ordinary complexity, the briefing schedules should be approximately as follows: Motion to dismiss: three weeks to respond; two weeks to reply Motions related to preliminary injunctive relief: seven days to respond and/or reply (if allowed) Discovery motions: seven days to respond; replies usually not allowed Motion in limine and Daubert motion: usually set by Judge Alexakis Motion for summary judgment: set by Judge Alexakis, although the parties should plan to file an opening motion approximately six weeks after the close of the relevant discovery period; with four weeks to respond; and two weeks to reply Before filing a motion for summary judgment, parties must review Judge Alexakis’ standing order on “Summary Judgment,” which discusses her in-chambers conference practice. Complex cases may require longer briefing schedules, and Judge Alexakis realizes that counsel have other demands on their time. As a result, within reason, Judge Alexakis usually will defer to parties’ proposed briefing schedules. However, parties must examine their calendars and consult with their opponents to ensure that briefing schedules they propose are realistic and account for the time needed to brief the motion, manage obligations in other cases, and attend to personal matters. Judge Alexakis is reluctant to grant significant extensions to accommodate conflicts that counsel could have foreseen. Motions for Extensions of Time Motions for extension of time shall indicate: (i) the reason for the request; (ii) the number of previous extensions; and (iii) whether any other party objects to the extension. Please do not contact chambers or the Courtroom Deputy to request an extension of time. Discovery cutoff dates generally will not be reset except by written motion. See also Standing Order regarding “Discovery Continuances” under “Discovery” heading. Trial dates are firm and will not be reset except in exceptional circumstances that were unforeseeable at the time the trial date was set. Motions To Dismiss When a motion to dismiss is filed, the nonmoving party has a right to amend its pleading once within 21 days. Fed. R. Civ. P. 15(a)(1)(B). Consistent with the purpose of the Federal Rules “to secure the just, speedy, and inexpensive determination of every action and proceeding,” Fed. R. Civ. P. 1, the nonmoving party is directed to review the motion to dismiss and to consider exercising, as appropriate, its right to amend under Rule 15(a)(1)(B). If the nonmoving party elects to amend its pleading in response to the motion to dismiss, then the moving party (unless otherwise ordered) must, within 21 days of the amended pleading, file either an answer or a renewed motion to dismiss. If the nonmoving party elects not to amend but instead chooses to litigate the motion to dismiss, the nonmoving party (unless agreed or ordered otherwise) must file its response within 21 days of the filing of the motion, and the moving party must file its reply within 14 days of the filing of the response. In its response, the nonmoving party must address whether any deficiencies identified by the motion to dismiss are curable by amendment. Following these steps, Judge Alexakis will take the motion under advisement and will rule in due course following any oral argument that she may in her discretion require. If the parties litigate the motion to dismiss and the moving party prevails, the nonmoving party is advised that Judge Alexakis may dismiss the case with prejudice under the appropriate legal standards. Motions To Strike Motions to strike are strongly disfavored. See Custom Vehicles, Inc. v. Forest River, Inc. , 464 F.3d 725, 727 (7th Cir. 2006) (Easterbrook, J., in chambers). For example, if a party believes that the other side’s brief contains inaccurate facts or that the other side’s Local Rule 56.1 statement (in summary-judgment briefing) contains an unsupported assertion, then the complaining party should so argue in the response or reply brief, or in the responsive Local Rule 56.1 statement. Motions to strike almost always would require Judge Alexakis to decide significant issues (and, indeed, the underlying motion) on the merits and would multiply the briefs (because the other side should be allowed to respond). Id . at 727. Only on very rare occasions is a motion to strike appropriate, such as when an entire brief or Local Rule 56.1 statement is defective. When it is appropriate, the motion must be made very promptly after the filing of the purportedly-offending brief or statement. Motions to strike that are not within the limited boundaries established by Federal Rule of Civil Procedure 12(f) may be summarily denied. Memoranda of Law Unless otherwise ordered by Judge Alexakis, briefs in support of or opposition to a motion should be no more than 15 pages, and reply briefs should be no more than 10 pages. For dispositive motions, response and reply briefs are always permitted. For other types of motions, Judge Alexakis will set dates for response or reply briefs if necessary. Parties may move for leave to file briefs that Judge Alexakis has not requested, but she typically will grant these motions only if there is an unforeseen point raised in an opposing brief. Citations Where counsel has access to both Westlaw and Lexis, Judge Alexakis prefers citations to Westlaw. It is not necessary to attach copies of unpublished opinions if they are available on Westlaw or Lexis. Please attach copies of any cited authorities that are unavailable on Westlaw or Lexis. Briefs and other filings (such as Local Rule 56.1 statements of fact) should cite exhibits by the ECF docket number and page, not exhibit number. Citations of Supplemental Authority Parties wishing to cite supplemental authority after briefing of a motion is closed must file a short motion seeking leave to do so. Any such motion shall be limited to the case title, its assigned number, the court, date of decision, the published citation or a slip copy, and a brief indication of the issue to which the movant believes the case pertains. No responsive comment is allowed unless requested by Judge Alexakis. Searchable Text All electronically filed documents shall be made word searchable before being filed on ECF. 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. Document Format The parties otherwise should adhere to Local Rule 5.2 concerning font size, line spacing, and margins for filed documents. Footnotes are to be used sparingly and only when necessary.
content assembled from published local rules & standing orders · click any section in the rail for the full treatment
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