All local rules for N.D. Ill., integrated with this judge's published requirements.
Neither a motion nor brief in support of or in opposition to any motion nor objections to a report and recommendation or order of a magistrate judge or special master, shall exceed 15 pages without prior approval of the court. Local Rule 7.1 ↗
Neither a motion nor brief in support of or in opposition to any motion nor objections to a report and recommendation or order of a magistrate judge or special master, shall exceed 15 pages without prior approval of the court. Local Rule 7.1 ↗
Neither a motion nor brief in support of or in opposition to any motion nor objections to a report and recommendation or order of a magistrate judge or special master, shall exceed 15 pages without prior approval of the court. Local Rule 7.1 ↗
(b) A judge may require a motion or an objection to a magistrate judge’s order to be accompanied by a notice of presentment specifying the date and time on which, and judge before whom, the motion or objection is to be presented. The date of presentment shall be not more than 14 days following the date on which the motion or objection is delivered to the court pursuant to LR 78.1. Local Rule 5.3(b) ↗
Except where a judge fixes a different time in accordance with this rule, the original of any motion shall be filed by 4:30 p.m. of the second business day preceding the date of presentment. A judge may fix a time for delivery longer than that provided by this rule, or elect to hear motions less frequently than daily, or both. Local Rule 78.1 ↗
The court may set a briefing schedule. Oral argument may be allowed in the court’s discretion. Local Rule 78.3 ↗
Any judge wishing to refer a matter in a civil case pending on that judge’s calendar to a magistrate judge may do so following procedures approved by the Executive Committee. Local Rule 72.1 ↗
Discovery & Discovery Motions Discovery Motions The Court believes that parties can and should work out most discovery disputes and thus discourages the filing of discovery motions. The Court will not consider any discovery motion unless the movant has complied with the meet-and-confer requirement of Local Rule 37.2. This applies not only to motions to compel, but also applies to motions to quash discovery or for protective orders against discovery . The motion must state with specificity when and how the movant complied with Local Rule 37.2. Remember that compliance with Local Rule 37.2 requires a good-faith effort to resolve discovery disputes and also requires that the conferral take place face-to-face or by telephone. The exchange of correspondence will almost never be good enough to comply with Local Rule 37.2. All parties should be fully prepared to argue any discovery motion on the date that it is presented. The Court most often will rule on discovery motions after hearing argument at the motion call and without further briefing (though sometimes it is plain that briefing is needed). If after hearing argument, the Court believes that the motion requires briefing, the Court normally will set an expedited briefing schedule so that the matter can be resolved promptly. Parties must immediately notify the Court if they are withdrawing (or narrowing) any previously filed discovery motions. Discovery Sequence Remember that there is generally no particular sequence in which discovery must occur, and that one party’s failure or inability to respond to discovery will not excuse any other party’s prompt compliance. Remember too that the pendency of a motion, such as a motion to dismiss, does not necessarily operate as a stay of discovery, although very often one or both parties might be justified in asking for a stay. Discovery Continuances Judge Chang sets realistic discovery deadlines at the initial status hearing, based on a close review of the pleadings and the initial status report. The parties must issue discovery and respond to discovery as needed to meet the discovery deadlines, which means planning ahead so that there is no last-minute scramble as the deadline approaches. Also, any motion to extend discovery must be presented in writing (after conferral with the other side), filed in advance of the fact discovery deadline, and must demonstrate good cause for the extension. Judge Chang generally does not set a case for trial until it is really ready for trial (that is, all discovery is done, dispositive motions denied, and settlement efforts exhausted). That means that the parties get a real trial date, not a placeholder, which allows the parties and witnesses to better plan and allows the Court’s trial calendar to be a real one, with no double-booking, very rare continuances, and very rare last-minute settlements. The important consequence is that Judge Chang’s trial calendar is rarely occupied very far into the future, because the trial calendar contains only real trial dates, so the parties can get a faster, real trial date when the case is ready to go. It also means, however, that the parties should be alert that the “there is no trial date” excuse to extend discovery is not persuasive to Judge Chang. Limit on the Number of Requests to Admit The Court sets a limit of 25 requests to admit, under Federal Rule of Civil Procedure 36, per side. Per “side” means parties represented by the same counsel.
Digital Courtesy Copies of Sealed Filings Introduction Whenever a party files (or submits to be filed through the pro se online portal) sealed filings on the docket in PDF format, this standing order requires the party to upload the PDF of the filings to a secure Box.com folder assigned to Judge Chang. Because this order applies only to those filings that are filed on the docket, it does not apply to Highly Sensitive Documents that are not filed on the docket under Local Rule 5.8.1. (This digital courtesy-copy requirement is being implemented in light of the removal of direct access to sealed filings in CM/ECF, which in turn rendered unavailable the prior CM/ECF feature that allowed courts to readily view and download multiple sealed filings in a combined PDF.) Electronic filing / OCR searchable text The first step in providing a digital courtesy copy is to follow the instruction in the standing order on Motion Practice, repeated here, to create a searchable OCR filing. With regard to CM/ECF filing, 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. Remember that when filing an entry on CM/ECF, parties generally may alter the text that appears on the docket so that it is more helpful to readers. For example, instead of an exhibit simply being labelled, “Exhibit 1,” the docket text can be edited to say, “Exhibit 1 – Declaration of Abraham Lincoln,” or “Exhibit 1 – Rental Agreement of 07/04/1776,” or whatever is fitting. At the same time, it would make sense to name the PDF file name the same words as the docket text. That would help also in the next step, when combining the PDFs for the digital courtesy copy. Uploading the Digital Courtesy Copy to Box.com To repeat, this digital courtesy-copy requirement only applies to sealed filings. After creating and filing the searchable PDF to the docket under seal, the party must use the Box.com link below to upload the sealed filing. Any PDFs of filings that are part of one overall docket entry must be combined into a single PDF with bookmarks to the start of the previously individual PDFs. For example, if R. 20 is a memorandum in support of a motion, and R. 20-1, 20-2, and 20-3 are three exhibits cited in the motion, then the party should upload a single PDF that combines R. 20, 20-1, 20-2, and 20-3. The Combine files feature in Adobe will automatically insert the bookmarks using the file names for each PDF when creating the single PDF. Important: File-Naming Convention for the Digital Courtesy Copy When a party uploads the digital courtesy copy, the party must use the following file-naming convention. For civil cases, [4-digit case year]_C_[5-digit case number]_ [5-digit docket entry number]_[Case Name]. For example, 2025_C_00123_00032_Washington_v_Adams, is docket entry 32 for that case. Likewise, for criminal cases, the convention is [4-digit case year]_CR_[5-digit case number]_ [5-digit docket entry number]_[Case Name]. For ease of sorting, in both civil and criminal cases, you must use the prefix zeros for the case number and docket entry number. Any questions may be directed to the courtroom deputy, Michael Wing, at Michael_Wing@ilnd.uscourts.gov . But remember to copy the other side on emails send to the courtroom deputy. The digital courtesy copy MUST be filed on the same business day as the under-seal filing. The Box.com link box.com_Digital Courtesy Copy - Sealed Filings for Judge Chang Source ↗
Initial Status Conferences The Court will set all newly filed cases for an initial status hearing around 40 days from the filing of the complaint (cases removed from state court might have a quicker initial status). The Court also will set a deadline for filing a joint initial status report. The status report shall provide information about the case using the format of the template that will be posted on the docket of each case. Consent to Proceed before a Magistrate Judge Too often litigants are unaware of the efficiencies to be gained by having their cases tried before United States Magistrate Judges. The court strongly encourages counsel to inform their clients of this option, and to discuss it with opposing counsel. Magistrate Judge Consent Form Motion Practice Timing All motions must be filed no later than the third business day (excludes federal holidays and weekends) before the day the motion is to be heard. For examples, 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. For civil cases and non-custodial criminal cases, the is Monday through Thursday at 8:30 a.m. For in-custody defendants in criminal cases (and if the motion requires the defendant’s presence), the is Monday through Thursday at 9 a.m. The exception to the 8:30 a.m. and 9 a.m. hearing times is as follows: if there is an already-scheduled status hearing at a different time, then the motion may be noticed for that already-scheduled time. This applies only to the time of the hearing; all other in-advance requirements must be met. If you are a pro se litigant using the Pro Se Filer online portal to submit a filing, then you must take into account the three-business days that it might take for the Clerk’s Office to process and to upload your filing. In other words, if you submit a motion through the online portal then you must add another three business days to the already-required three-business days’ notice. Likewise, if the Court set a filing deadline, then you must submit the filing three business days earlier to account for the processing. The Court sets longer deadlines for pro se litigants to account for the lack of counsel and general lack of access to direct filing on the docket. Courtesy copies Generally, the Court does not accept paper courtesy copies. Please do not prepare them and do not try to deliver them. If you think that a paper courtesy copy would be truly, truly invaluable, then please email (copying the other side) the courtroom deputy for guidance. Having said that, for sealed filings posted on CM/ECF, you must provide a digital courtesy copy via Box.com. Source ↗
Motion Practice Timing All motions must be filed no later than the third business day (excludes federal holidays and weekends) before the day the motion is to be heard. For examples, 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. For civil cases and non-custodial criminal cases, the motion schedule is Monday through Thursday at 8:30 a.m. For in-custody defendants in criminal cases (and if the motion requires the defendant’s presence), the motion schedule is Monday through Thursday at 9 a.m. The exception to the 8:30 a.m. and 9 a.m. hearing times is as follows: if there is an already-scheduled status hearing at a different time, then the motion may be noticed for that already-scheduled time. This applies only to the time of the hearing; all other in-advance requirements must be met. If you are a pro se litigant using the Pro Se Filer online portal to submit a filing, then you must take into account the three-business days that it might take for the Clerk’s Office to process and to upload your filing. In other words, if you submit a motion through the online portal then you must add another three business days to the already-required three-business days’ notice. Likewise, if the Court set a filing deadline, then you must submit the filing three business days earlier to account for the processing. The Court sets longer deadlines for pro se litigants to account for the lack of counsel and general lack of access to direct filing on the docket. Courtesy copies Generally, the Court does not accept paper courtesy copies. Please do not prepare them and do not try to deliver them. If you think that a paper courtesy copy would be truly, truly invaluable, then please email (copying the other side) the courtroom deputy for guidance. Having said that, for sealed filings posted on CM/ECF, you must provide a digital courtesy copy via Box.com. Please see the standing order on Digital Courtesy Copies of Sealed Filings on Judge Chang’s website. Electronic filing / OCR searchable text With regard to CM/ECF filing, 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. Other requirements (including conferral) Before filing a motion, the movant’s counsel (or the movant, if pro se) must ask opposing counsel (or the opposing party, if pro se) whether there is an objection to the motion, and the motion must state that the conferral occurred, or if not, why not. If there is an objection, the movant must note that fact on the first page of the motion and of any separate brief in support. Joint, uncontested, and agreed motions must be so identified in both the title and the body of the motion. Trial dates and discovery deadlines generally will not be reset except by written motion. In addition to the 15-page limit on briefs, Local Rule 7.1, the Court applies the other format requirements of Local Rule 5.2(c) to electronically filed briefs. See Local Rule 5.2(c) for those page-size, font-size, margin, and spacing requirements. Counsel shall not respond to motions by correspondence with the Court. Source ↗
Motion Practice Timing All motions must be filed no later than the third business day (excludes federal holidays and weekends) before the day the motion is to be heard. For examples, 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. For civil cases and non-custodial criminal cases, the motion schedule is Monday through Thursday at 8:30 a.m. For in-custody defendants in criminal cases (and if the motion requires the defendant’s presence), the motion schedule is Monday through Thursday at 9 a.m. The exception to the 8:30 a.m. and 9 a.m. hearing times is as follows: if there is an already-scheduled status hearing at a different time, then the motion may be noticed for that already-scheduled time. This applies only to the time of the hearing; all other in-advance requirements must be met. If you are a pro se litigant using the Pro Se Filer online portal to submit a filing, then you must take into account the three-business days that it might take for the Clerk’s Office to process and to upload your filing. In other words, if you submit a motion through the online portal then you must add another three business days to the already-required three-business days’ notice. Likewise, if the Court set a filing deadline, then you must submit the filing three business days earlier to account for the processing. The Court sets longer deadlines for pro se litigants to account for the lack of counsel and general lack of access to direct filing on the docket. Courtesy copies Generally, the Court does not accept paper courtesy copies. Please do not prepare them and do not try to deliver them. If you think that a paper courtesy copy would be truly, truly invaluable, then please email (copying the other side) the courtroom deputy for guidance. Having said that, for sealed filings posted on CM/ECF, you must provide a digital courtesy copy via Box.com. Please see the standing order on Digital Courtesy Copies of Sealed Filings on Judge Chang’s website. Electronic filing / OCR searchable text With regard to CM/ECF filing, 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. Other requirements (including conferral) Before filing a motion, the movant’s counsel (or the movant, if pro se) must ask opposing counsel (or the opposing party, if pro se) whether there is an objection to the motion, and the motion must state that the conferral occurred, or if not, why not. If there is an objection, the movant must note that fact on the first page of the motion and of any separate brief in support. Joint, uncontested, and agreed motions must be so identified in both the title and the body of the motion. Trial dates and discovery deadlines generally will not be reset except by written motion. In addition to the 15-page limit on briefs, Local Rule 7.1, the Court applies the other format requirements of Local Rule 5.2(c) to electronically filed briefs. See Local Rule 5.2(c) for those page-size, font-size, margin, and spacing requirements. Counsel shall not respond to motions by correspondence with the Court. Source ↗
Motion Practice Timing All motions must be filed no later than the third business day (excludes federal holidays and weekends) before the day the motion is to be heard. For examples, 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. For civil cases and non-custodial criminal cases, the motion schedule is Monday through Thursday at 8:30 a.m. For in-custody defendants in criminal cases (and if the motion requires the defendant’s presence), the motion schedule is Monday through Thursday at 9 a.m. The exception to the 8:30 a.m. and 9 a.m. hearing times is as follows: if there is an already-scheduled status hearing at a different time, then the motion may be noticed for that already-scheduled time. This applies only to the time of the hearing; all other in-advance requirements must be met. If you are a pro se litigant using the Pro Se Filer online portal to submit a filing, then you must take into account the three-business days that it might take for the Clerk’s Office to process and to upload your filing. In other words, if you submit a motion through the online portal then you must add another three business days to the already-required three-business days’ notice. Likewise, if the Court set a filing deadline, then you must submit the filing three business days earlier to account for the processing. The Court sets longer deadlines for pro se litigants to account for the lack of counsel and general lack of access to direct filing on the docket. Courtesy copies Generally, the Court does not accept paper courtesy copies. Please do not prepare them and do not try to deliver them. If you think that a paper courtesy copy would be truly, truly invaluable, then please email (copying the other side) the courtroom deputy for guidance. Having said that, for sealed filings posted on CM/ECF, you must provide a digital courtesy copy via Box.com. Please see the standing order on Digital Courtesy Copies of Sealed Filings on Judge Chang’s website. Electronic filing / OCR searchable text With regard to CM/ECF filing, 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. Other requirements (including conferral) Before filing a motion, the movant’s counsel (or the movant, if pro se) must ask opposing counsel (or the opposing party, if pro se) whether there is an objection to the motion, and the motion must state that the conferral occurred, or if not, why not. If there is an objection, the movant must note that fact on the first page of the motion and of any separate brief in support. Joint, uncontested, and agreed motions must be so identified in both the title and the body of the motion. Trial dates and discovery deadlines generally will not be reset except by written motion. In addition to the 15-page limit on briefs, Local Rule 7.1, the Court applies the other format requirements of Local Rule 5.2(c) to electronically filed briefs. See Local Rule 5.2(c) for those page-size, font-size, margin, and spacing requirements. Counsel shall not respond to motions by correspondence with the Court. Source ↗