Procedures verified June 26, 2026
Judge Sara L. Ellis -- United States District Court, Northern District of Illinois
1403
warning
Key Traps — Where Counsel Gets Caught
- 1. MEET-AND-CONFER REQUIRED FOR ALL MOTIONS: Not just discovery -- applies to motions to dismiss, SJ motions, motions in limine, and all other motions. Motion must state with specificity what parties did to comply. For SJ specifically: moving party must send a 2-3 page letter to opposing counsel (not filed with Court) before filing.
- 2. SJ JOINT STATEMENT REQUIRED: Parties must file a JOINT statement of undisputed facts. Separate statements are PROHIBITED and will not be considered. This is a major departure from LR 56.1. Joint statement capped at 120 facts.
- 3. DISCOVERY JOINT MOTION: After LR 37.2 conferral, discovery disputes must be filed as a JOINT motion of no more than 5 pages, side-by-side format, with each party's position and proposed compromise in separate sections. Disputed discovery must be reproduced in full with responses attached.
- 4. LR 5.3(b) notice required for ALL motions. Motions not complying may be stricken.
- 5. Default hearings by telephone -- teleconference number (650) 479-3207, access code 2314 361 1508. Keep line muted unless speaking. Recording prohibited.
- 6. Check judge's main page for blackout dates (periods when she will not hear motions). Check call sheet after 4:00 p.m. day before hearing.
- 7. Courtesy copies triggered at 50 pages (including exhibits) -- higher threshold than many judges. Also required for pretrial orders and exhibits not readable electronically.
- 8. Do NOT file proposed orders directly on the docket or as stand-alone entries. Do not submit proposed orders for routine motions or dispositive motions.
- 9. Court reporter Kelly Fitzgerald uses a Gmail address (kmftranscripts@gmail.com) -- not an @ilnd.uscourts.gov address. Deposit required before any transcript preparation.
- 10. Post-trial jury contact: no contact with jurors after trial without prior Court permission.
Quick Reference
| Topic | Rule |
|---|---|
| Motion Days | Civil status hearings: Tuesday and Wednesday at 9:30 a.m. and Thursday at 1:30 p.m. Civil motions: Tuesday and Wednesday at 9:45 a.m. and Thursday at 1:45 p.m. Criminal motions (including arraignments and changes of plea): Tuesday and Wednesday at 10:00 a.m. and Thursday at 1:45 p.m. Pretrial conferences and sentencings: Monday through Wednesday at 1:30 p.m. All motions must be filed no later than the third business day before the hearing date. Motions must be noticed for a date certain per LR 5.3(b). Check judge's main web page for dates when she will not be available to hear motions. After 4:00 p.m. on the afternoon prior to the hearing date, check the call sheet on Judge Ellis' web page to determine whether appearance is necessary; if not required, movant must notify respondent(s). [Judge Ellis -- Motion Practice] |
| Motion Limit | 15 pages maximum per Local Rule 7.1. [Judge Ellis -- Motion Practice] |
| Reply Limit | Not separately specified; follow LR 7.1 default. |
| Chambers Copies | ✓ Required Courtesy copies required for: (1) all filings that total 50 pages or more including exhibits; (2) pretrial orders (and attendant evidentiary... [Judge Ellis -- Courtesy Copies] |
| Tentative Rulings | Not issued. Court rules on papers. |
| Remote Appearances | Unless otherwise ordered, status hearings and noticed motions proceed by telephone. Teleconference Number: (650) 479-3207; Access Code: 2314 361 1508. All participants must keep lines muted unless speaking. Recording and rebroadcasting prohibited -- violation may result in sanctions. [Judge Ellis -- Notice (Teleconference)] |
| Discovery | Discovery disputes handled by this judge per individual procedures (depart from Local Rules). LR 37.2 compliance required. Face-to-face or telephone conferral required; correspondence normally insufficient. After meet-and-confer, parties must file a JOINT motion of no more than 5 pages setting out each issue in a separate section with each party's position (with legal authority) and proposed compromise side-by-side. Disputed discovery (interrogatories, requests for production, answers/objections) must be reproduced in full in the joint motion with entire disputed responses attached as exhibit. E-discovery impasse: in-person meet and confer with IT representatives before filing. |
Procedural Briefing by Motion Type
C.D. Cal. · Standing Orders
Procedural Requirements
Key Traps
Compare to Other C.D. Cal. Judges
Procedural facts only. Judges shown to illustrate variance in this district.
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Before You File
Motion Days & Times
Civil status hearings: Tuesday and Wednesday at 9:30 a.m. and Thursday at 1:30 p.m. Civil motions: Tuesday and Wednesday at 9:45 a.m. and Thursday at 1:45 p.m. Criminal motions (including arraignments and changes of plea): Tuesday and Wednesday at 10:00 a.m. and Thursday at 1:45 p.m. Pretrial conferences and sentencings: Monday through Wednesday at 1:30 p.m. All motions must be filed no later than the third business day before the hearing date. Motions must be noticed for a date certain per LR 5.3(b). Check judge's main web page for dates when she will not be available to hear motions. After 4:00 p.m. on the afternoon prior to the hearing date, check the call sheet on Judge Ellis' web page to determine whether appearance is necessary; if not required, movant must notify respondent(s). [Judge Ellis -- Motion Practice]
Notice Period
3 business days (excluding federal holidays and weekends) before the day the motion is to be heard. LR 5.3(b) notice required for ALL motions. Motions that do not comply with this requirement may be stricken.
Motion Page / Word Limit
15 pages maximum per Local Rule 7.1. [Judge Ellis -- Motion Practice]
Opposition Limit
15 pages maximum per Local Rule 7.1.
Reply Limit
Not separately specified; follow LR 7.1 default.
Font & Formatting
Per LR 5.2(e). Memoranda must comply with LR 5.2 and 7.1. Attach copies of cited authorities not available on Westlaw or Lexis.
Footnote Policy
Not specified.
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At Filing
Chambers Copies
✓ Required
Courtesy copies required for: (1) all filings that total 50 pages or more including exhibits; (2) pretrial orders (and attendant evidentiary motions and jury instructions if separately filed); (3) all filings that include attachments or exhibits not readable in electronic format. NOT required for: filings that do not meet the above description, including pleadings. Deliver to Courtroom Deputy (not chambers) within 24 hours of filing. Court prefers double-sided copies printed after filing with CM/ECF header stamp on document. Filings with exhibits should include tabs. Voluminous submissions should be bound. [Judge Ellis -- Courtesy Copies]
Proposed Orders
Routine motions (e.g., extensions of time): proposed orders unnecessary. Dispositive motions: do not submit proposed orders. For other proposed orders: do not file on docket as stand-alone entry or as attachment. File a motion asking Court to enter the order. Contemporaneously email proposed order (Word-compatible format) to Proposed_Order_Ellis@ilnd.uscourts.gov. Subject line must include case number and name, docket number of corresponding motion, and title of the order. Serve on all parties. Counterfeit product cases: use template proposed orders; submit clean and redline comparison of TRO, preliminary injunction, or default judgment against templates to Proposed_Order_Ellis@ilnd.uscourts.gov.
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Before the Hearing
Tentative Rulings
Not issued. Court rules on papers.
Prohibition / Ex Parte Contact Re Tentatives
N/A.
Oral Argument
Court most often decides discovery motions after oral argument at motion call without additional briefing. Check call sheet on judge's web page after 4:00 p.m. day before hearing; if no appearance required, movant must notify respondent(s). Supplemental authority requires motion seeking leave to file.
Remote Appearances
Unless otherwise ordered, status hearings and noticed motions proceed by telephone. Teleconference Number: (650) 479-3207; Access Code: 2314 361 1508. All participants must keep lines muted unless speaking. Recording and rebroadcasting prohibited -- violation may result in sanctions. [Judge Ellis -- Notice (Teleconference)]
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Background Rules
Chambers Contact
No communication by letter unless directed by Court. All communications must be motions, briefs, or status reports properly noticed and served. Do not call chambers or courtroom deputy to request extensions of time -- file a motion. Contact Courtroom Deputy Rhonda Johnson at Rhonda_Johnson@ilnd.uscourts.gov with questions about scheduling.
Discovery Referral
Discovery disputes handled by this judge per individual procedures (depart from Local Rules). LR 37.2 compliance required. Face-to-face or telephone conferral required; correspondence normally insufficient. After meet-and-confer, parties must file a JOINT motion of no more than 5 pages setting out each issue in a separate section with each party's position (with legal authority) and proposed compromise side-by-side. Disputed discovery (interrogatories, requests for production, answers/objections) must be reproduced in full in the joint motion with entire disputed responses attached as exhibit. E-discovery impasse: in-person meet and confer with IT representatives before filing.
Discovery Dispute Procedure Calendar-first
DEPARTURE FROM LOCAL RULES: After LR 37.2 meet-and-confer, if unresolved, parties must file a JOINT motion of no more than 5 pages. Each issue in a separate section. Each section must contain: (1) each party's position with legal authority and (2) each party's proposed compromise side-by-side. If dispute concerns specific discovery (interrogatories, RFPs, answers/objections), reproduce the question/request and response in full in that section, and attach entire disputed discovery responses as exhibit. Court most often decides discovery motions after oral argument at motion call without additional briefing. Pendency of a motion does not stay discovery. E-discovery: in-person meet and confer with IT representatives before filing. [Judge Ellis -- Discovery Motions and E-Discovery]
Ex Parte Applications
Not separately specified. All communications must be motions, briefs, or status reports. Do not call chambers or courtroom deputy to request extensions of time.
Settlement Notification
Parties desiring settlement conference: request in open court or by telephone to courtroom deputy. Settlement conferences usually referred to assigned magistrate judge. Standing order for settlement conference procedures on judge's website.
Lead Counsel
Not specified.
Under Seal Filings
All protective orders must be based on Model Confidentiality Order (Form LR 26.2). Any changes to model order must be shown by redlining indicating both deletions and additions, with comments explaining why changes are sought. Filing under seal requires prior court order per LR 26.2.
Continuances & Calendar Conflicts
Motions for extension of time: contact all other parties first to determine if they object. Motion must indicate whether it is first or subsequent extension request, include reasons, prior relief granted, and whether any party objects. Do not call chambers or courtroom deputy for extension requests.
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AI & Style Preferences
AI Disclosure Requirement
Not specified.
Additional Notes
Ellis has two major departures from district norms. First, meet-and-confer extends to ALL motions (not just discovery), with a specific pre-SJ letter protocol. Second, SJ requires a joint statement of undisputed facts -- separate statements are flatly prohibited -- and the joint statement cap is 120 facts (higher than the LR 56.1 default). Discovery disputes must be filed as a joint 5-page motion with side-by-side party positions, not a unilateral motion to compel. Default appearances by phone via standing teleconference line.
Sources & Currency
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Procedures verified June 26, 2026.
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