Procedures verified June 26, 2026
Judge John F. Kness -- United States District Court, Northern District of Illinois
2125, Everett McKinley Dirksen United States Courthouse, 219 S. Dearborn St., Chicago, IL 60604
description
Motions decided on papers — no hearings held
warning
Key Traps — Where Counsel Gets Caught
- 1. CRITICAL BRIEFING SCHEDULE TRAP: When parties agree on a briefing schedule, the moving party must file a SEPARATE docket entry setting forth the agreed schedule. The briefing schedule may NOT be embedded in the motion itself, nor communicated by email or other unfiled communication. Agreed schedules are binding on the parties unless the Court orders otherwise.
- 2. Motions to dismiss have their own separate Standing Order with a fixed briefing schedule: response due 28 days from filing; reply due 14 days after response. Non-movant may amend as of right within 21 days per FRCP 15(a)(1)(B). If non-movant elects not to amend, the 28/14 day schedule applies.
- 3. Motions to amend pleadings must include a redlined version of the proposed amended pleading as an exhibit. Failure to comply may result in the motion being stricken.
- 4. No motion call. Do not notice motions for presentment.
- 5. No courtesy copies unless Court orders them. Do not deliver speculatively.
- 6. Daubert motions must be filed at least 60 days before trial.
- 7. Emergency motions: standard is 'serious AND irreparable harm' (Local Rule 77.2). Higher threshold than typical emergency standards.
- 8. Rule 30(b)(6) depositions: presumptive limit of 10 topics (subtopics count). Government agencies acting in enforcement capacity cannot be deposed under Rule 30(b)(6) without leave of Court.
- 9. Injunctions must be on a standalone separate document with no reference to any other document.
- 10. Requests for admission: limit of 25 per side.
- 11. Modification of agreed briefing schedule requires a motion showing good cause per FRCP 6(b) -- parties cannot modify by consent alone.
Quick Reference
| Topic | Rule |
|---|---|
| Motion Days | No motion call. Litigants are neither required nor permitted to notice motions for in-person presentment. If the Court determines that a hearing by electronic or other means is required, Court staff will notify the parties accordingly. Motions should instead be filed on the docket. [Judge Kness -- Notice of Filing vs. Notice of Motion] |
| Motion Limit | 15 pages maximum per Local Rule 7.1. [Judge Kness -- Motions and Memoranda of Law] |
| Reply Limit | Not separately specified; follow LR 7.1 default. |
| Chambers Copies | ✗ Not required Unless the Court directs otherwise, courtesy copies will not be accepted. Do not prepare them and do not try to deliver them. If the Court... |
| Tentative Rulings | Not issued. Court rules on papers. |
| Remote Appearances | No in-person hearings scheduled by default. If the Court determines a hearing is required, Court staff will notify parties. Hearing format (electronic or otherwise) determined by the Court. |
| Discovery | Discovery disputes handled by this judge. LR 37.2 meet-and-confer required (in-person or by phone; email/letters not normally sufficient). Motion must state with specificity when and how compliance occurred. E-discovery ESI impasse: must include IT representative of party that served request and IT representative of the party that received request. Boilerplate discovery objections are inadequate and disregarded. Limit of 25 requests for admission per side. |
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
No motion call. Litigants are neither required nor permitted to notice motions for in-person presentment. If the Court determines that a hearing by electronic or other means is required, Court staff will notify the parties accordingly. Motions should instead be filed on the docket. [Judge Kness -- Notice of Filing vs. Notice of Motion]
Notice Period
N/A -- no presentment. Motions are simply filed.
Motion Page / Word Limit
15 pages maximum per Local Rule 7.1. [Judge Kness -- Motions and Memoranda of Law]
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). Footnotes to be used sparingly and only when necessary; footnotes may never be used to circumvent page limits. Court may strike non-compliant filings.
Footnote Policy
Footnotes to be used sparingly and only when necessary; may never be employed to exceed page limits. Court may strike any filing that does not comply.
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At Filing
Chambers Copies
✗ Not required
Unless the Court directs otherwise, courtesy copies will not be accepted. Do not prepare them and do not try to deliver them. If the Court orders courtesy copies, deliver to drop-box outside Courtroom Deputy's office (Room 2132). Do not bring to Chambers. Print from ECF so copies include ECF header.
Proposed Orders
Do not file proposed orders on the docket. Email Word format to Proposed_Order_Kness@ilnd.uscourts.gov. Subject line must include case number and name, docket number of corresponding motion (if any), and title of the order proposed. Serve on all other parties. Orders should only be filed by the Judge. [Judge Kness -- Proposed Orders]
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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
No automatic oral argument. Court rules on papers. If a hearing is determined necessary, Court staff will notify parties.
Remote Appearances
No in-person hearings scheduled by default. If the Court determines a hearing is required, Court staff will notify parties. Hearing format (electronic or otherwise) determined by the Court.
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Background Rules
Chambers Contact
Unless the Court directs otherwise, counsel and pro se litigants must not communicate with the Court about the merits of the case by letter, phone, or email (excluding proposed order submissions). All communications must be in the form of a motion, brief, or status report. For scheduling, motion status, or trial logistics: contact Courtroom Deputy Ellen Reyes at Ellen_Reyes@ilnd.uscourts.gov or (312) 582-3254.
Discovery Referral
Discovery disputes handled by this judge. LR 37.2 meet-and-confer required (in-person or by phone; email/letters not normally sufficient). Motion must state with specificity when and how compliance occurred. E-discovery ESI impasse: must include IT representative of party that served request and IT representative of the party that received request. Boilerplate discovery objections are inadequate and disregarded. Limit of 25 requests for admission per side.
Discovery Dispute Procedure No-presentment
LR 37.2 required. In-person or phone meet and confer (email/letters not normally sufficient). ESI impasse: conference in person or by phone with IT representatives of both parties required before filing. If other party does not respond promptly to a meet-and-confer request, that failure can be documented. Pendency of a motion to dismiss does not stay discovery. [Judge Kness -- Other Discovery]
Ex Parte Applications
Not separately specified. Follow General Order procedures.
Settlement Notification
Court strongly encourages settlement conference with assigned Magistrate Judge. If parties request a settlement conference with Judge Kness, detailed procedures apply: (1) demand letter from plaintiff at least 7 business days before conference; (2) offer letter from defendant at least 3 business days before conference; defendant emails copies of both letters to proposed order inbox 3 business days before conference. Parties with full settlement authority must attend in person.
Lead Counsel
Not specified.
Under Seal Filings
Court will not enter a protective order suggesting that confidential-designated material may be filed under seal by designation alone. Any protective order contemplating under-seal filing must require a good cause motion. When under-seal filing is permitted, must file a redacted public-record version alongside the sealed document. Parties must meet and confer about who should file any motion to seal when a party wishes to file a document publicly that another party has marked confidential.
Continuances & Calendar Conflicts
Any party seeking to modify an established briefing schedule must file a motion explaining why good cause exists per FRCP 6(b). Extensions by agreement alone are not permitted -- must file a motion.
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AI & Style Preferences
AI Disclosure Requirement
Not specified.
Additional Notes
No-presentment model. KEY TRAP: Agreed briefing schedules must be a separate docket entry -- not in the motion body, not by email. MTD briefing: 28-day response, 14-day reply (fixed by standing order). Daubert motions 60 days before trial. Emergency motions require 'serious AND irreparable harm' standard per LR 77.2. Injunctions must be standalone documents.
Sources & Currency
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Procedures verified June 26, 2026.
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