Before requesting entry of a confidentiality order to preserve the confidentiality of materials disclosed in discovery, counsel shall carefully review Federal Rule of Civil Procedure 26(c), which requires that the movant has in good faith conferred or attempted to confer with other affected parties in an effort to resolve the dispute without court action. For agreed confidentiality orders in civil cases, to the extent possible, counsel should use the Model Confidentiality Order developed by the Northern District of Illinois. Any proposed agreed confidentiality order must be provided to Judge Schneider’s proposed order inbox in Word format. A corresponding motion for a confidentiality order should also be filed on the docket, unless the Court has given prior leave to submit a confidentiality order without a motion. If the proposed agreed confidentiality order differs from the model, in addition to a clean Word version of the revised model order, counsel must provide a redlined copy showing any changes. The clean and redlined copies of the confidentiality order shall be submitted to Judge Schneider’s proposed order inbox: Proposed_Order_Schneider@ilnd.uscourts.gov . If the confidentiality order anticipates that any documents or confidential materials submitted to the court are to be filed under seal, the confidentiality order must include, at a minimum a carefully-drafted definition of the materials to be protected, with an explanation of why these documents are entitled to protection. No document shall be filed under seal unless counsel secures a court order allowing the filing of a document under seal. See Local Rule 5.8 . 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. 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). For qualified protective orders, to the extent possible, counsel should use the Example of a HIPAA Protective Order developed by the Northern District of Illinois. Any proposed agreed qualified protective order must be provided to Judge Schneider’s proposed order inbox in Word format. A corresponding motion for a qualified protective order should also be filed on the docket, unless the Court has given prior leave to submit a qualified protective order without a motion. If the proposed qualified protective order differs from the model, in addition to a clean Word version of the revised model order, counsel must provide a redlined copy showing any changes. The clean and redlined copies of the qualified protective order shall be submitted to Judge Schneider’s proposed order inbox: Proposed_Order_Schneider@ilnd.uscourts.gov .

Motion Practice a. Discovery Motions The Court will not hear or consider any discovery motions unless the parties have complied with the meet and confer requirement under Local Rule 37.2. Any discovery motion must state with specificity when and how the movant complied with Local Rule 37.2. Parties are reminded that compliance with Local Rule 37.2 requires a good faith effort to resolve discovery disputes and, other than in exceptional circumstances, communication that takes place face to face or by telephone. The mere exchange of correspondence will not normally be sufficient to comply with Local Rule 37.2. All parties must be fully prepared to orally argue any discovery motion on the date that it is presented. The Court may decide discovery motions after oral argument at the motion call and without briefing. If after 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. b. Other Motions The meet and confer requirement can have the same effect on other disputes that it has in connection with discovery disputes. A candid discussion between the parties prior to filing motions to dismiss, motions for summary judgment, and motions in limine, among others, can limit the scope of such motions or eliminate the need for them to be filed at all. Any joint/agreed/unopposed motion should be so identified in the title and body of the motion. If there is an objection, the movant must note that fact in the body of the motion. Thus, the Court will apply the meet and confer requirement not just to discovery motions, but to all motions that a party wishes to file. The comments above concerning what must be done to comply with the meet and confer requirement will be applied with equal force, and in the same way, with respect to all other motions. c. Motions for Extension of Time No motion for an extension of time to file pleadings or to comply with other time requirements will be entertained by Judge Schneider unless the movant includes in the motion a statement (1) that the movant has sought the other side's agreement to the extension and (2) specifying the result of that request. A motion for extension of time shall prominently identify the current deadline. In addition, the motion must indicate (1) the reason for the extension request, and (2) the number of previous extensions. Rev. 01/16/25