Communications with Chambers for case related matters: The Court strongly prefers email communication with the courtroom deputy. If you have questions about a case assigned to Judge Jantz, please read through the procedures on this website before contacting the courtroom deputy. Additionally, if the parties resolve an issue that is scheduled for a hearing or that is otherwise under consideration by Judge Jantz by motion or otherwise, counsel should email the courtroom deputy as soon as possible. Opposing counsel must be copied on all emails. Counsel may jointly contact the Courtroom Deputy at Anthony_Squillante@ilnd.uscourts.gov

Standing Order on Confidentiality or Protective Orders and Filing Material Under Seal Confidentiality or Protective Orders A. Confidentiality Agreements Among Parties (No Court Order Necessary) Parties may agree among themselves to limit disclosure of unfiled discovery information to certain specified persons during the litigation. Court approval of such an agreement or a court order is not necessary. Such an agreement may well address most of the parties’ confidentiality concerns since only a small subset of discovery is typically ever filed in the public court record or used during a court proceeding. B. Confidentiality Orders Entered by the Court If the parties seek a further protective order entered by the Court, they must base the proposed order on the model protective order approved by the full Court and set forth in the Local Rules: Form LR 26.2 Model Confidentiality Order . Any changes to the model order that the parties propose must be shown by redlining that indicates both the deletions and additions to the model text. For the redlined version, counsel should also include brief comments with any proposed changes explaining why the changes are sought . Counsel shall email copies of the redlined version and the clean Word version of the proposed order to the Court’s proposed order inbox (Proposed_Order_Jantz@ilnd.uscourts.gov), with CC to counsel for all parties. The subject line of the e-mail must include the case number and name and the title of the proposed confidentiality/protective order. Submitting a proposed order electronically is not a substitute for filing a motion. A proposed order may only be submitted after the corresponding motion has been filed unless the Court has given prior leave to submit a proposed order without a motion. The Court’s issuance of a protective order will constitute the determination, as required by Federal Rule of Civil Procedure 26(c), that good cause exists for the issuance of the order. However, issuance of any protective order will not be given preclusive effect as a determination of good cause for Rule 26(c) purposes if, at a future time, a party or an interested member of the public moves for relief from the limitations of the protective order. In the event of such a motion, the Court will engage in an appropriate assessment of the interest between privacy and public access to make a determination of good cause as to the challenged document(s) in light of the facts then before the Court. C. Filing Material Under Seal Please note that under Local Rule 26.2 , no documents may be filed under seal without a prior order of the Court specifying the particular document to be filed. As an alternative to filing under seal, Local Rule 26.2 allows individual judges, at their discretion, to order parties to retain copies of confidential documents in lieu of filing them with the Clerk of Court, to file a redacted copy with the Clerk of Court, and to provide the judge with a complete copy for in camera use. In referral cases, Judge Jantz will enforce the practice of the referring District Judge. In consent cases, Judge Jantz will consider using the alternative options permitted by LR 26.2 in appropriate cases. The Court generally will not approve the filing of entire pleadings or briefs under seal. Parties must arrive at the most limited sealing and redaction of documents consistent with their confidentiality obligations. If material is to be filed under seal, the motion to seal must demonstrate good cause by including a specific description of each document or category of information to be sealed and explaining why confidentiality is necessary. In any case in which Judge Jantz permits a portion of a document to be filed under seal, the party filing the document must also file a public-record version that includes the entire filing except for the portions that are being filed under seal. D. Use of Medical Records in Litigation The Court reminds counsel that the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and its regulations create a procedure for obtaining authority to use medical records in litigation, including requesting a qualified protective order. See 45 C.F. R. § 164.512(e). A “qualified protective order” means an order that: (1) prohibits the parties from using or disclosing the protected health information for any purpose other than the litigation for which such information was requested; and (2) requires the return to the covered entity or destruction of the protected health information (including all copies made) at the end of the litigation. 45 C.F.R. § 164.512(e)(1)(v). See Sample HIPAA Order

Standing Order on Discovery Motions and Motions to Compel The Court believes that parties can and should work out most discovery disputes and thus discourages the filing of discovery motions or motions to compel, which add extra time and costs for both parties. 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 to motions to quash discovery or for protective orders re 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, by telephone, or by video. The exchange of emails or other correspondence will almost never be sufficient to comply with Local Rule 37.2. A meet and confer is not in good faith if a party merely sticks to its original position or refuses to consider a compromise or a narrowed approach. Parties are expected to meet and confer within two business days of any request to meet and confer on a subject, absent good cause for delay; a failure to do so may be deemed a forfeiture of the party’s position with respect to the requested discovery. A party’s failure to meet and confer in good faith may result in the imposition of sanctions, including but not limited to an order to pay the opposing party’s expenses. See Federal Rule of Civil Procedure 37(a)(5), (b). If a hearing is set on a discovery motion, all parties should be fully prepared to argue any discovery motion on the date that it is presented. If the Court sets a hearing on a motion, the Court may rule on the discovery motion during or after the hearing and without further briefing. 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. Any motions to compel must identify and attach the specific discovery requests at issue, as well as the opposing party’s response ( i.e. , motions must not simply identify specific “categories” of documents or discovery that the movant seeks). Motions to compel must also include arguments supporting the relevance and proportionality of the requested discovery and a recitation of the parties’ meet and confer efforts. Motions to compel may be summarily stricken for a failure to comply with these rules. Moreover, parties must not seek overbroad requests in the hope that the Court will tailor the resolution on its own; each discovery request will be adjudicated based on the totality of the request, so parties should appropriately narrow their requests ahead of time. Failure to do so may result in denial of the motion to compel with prejudice; the Court will not tailor a discovery request for the party when it could have done it on its own. Parties must immediately notify the Court if they are withdrawing (or narrowing) any previously filed discovery motion. Any motion to extend discovery deadlines must be presented in writing (after conferral with the other side), filed in advance of the discovery deadline, and must present the opposing party’s position and demonstrate good cause for the extension. With particular respect to electronic discovery disputes, if the parties have reached an impasse regarding the discovery of records from a database, server, computer, service provider or similar electronic storage facility (ESF), before filing a motion to compel , the parties are required to meet and confer with an IT representative for each party in order to determine the most effective and feasible ways to retrieve the requested material, as well as the proper format for the retrieval of the records. This electronic discovery conference must take place in person, by telephone, or by video, and both sides should be prepared to discuss specifically the parameters of both the search(es) and the ESF.