Hon. Andrea R. Wood

• [Motion Practice]
• Until further notice, parties should not notice motions for presentment. Parties may request a hearing for motions that they believe cannot be decided based on written submissions alone or that would otherwise benefit from a court hearing. The request must be made in the motion itself or by joint e-mail to the courtroom deputy. For any motion the parties believe would benefit from briefing, the parties should jointly e-mail the Courtroom Deputy within 2 business days of the filing of the motion to request a briefing schedule. Please be advised that the Court may set a motion hearing or a briefing schedule for any motion without a request from the parties. Motions for Extensions of Time A party seeking an extension of time must contact all other parties in the case to determine whether they object to the extension. Any motion for extension of time must indicate whether it is the first or subsequent extension request, shall include the reasons for the request, any previous relief granted, and whether any other party objects to the extension. Joint, Agreed, and Uncontested Motions Joint, uncontested, and agreed motions should be so identified in both the title and body of the motion. If the motion is scheduled for a hearing, counsel for all parties are expected to be present regardless of whether the motion is opposed. Other Requirements Counsel should not respond to motions by correspondence with the Court. The Court strongly encourages counsel to convert electronic filings created with word-processing software into .pdf documents by printing or publishing to .pdfs, rather than manually scanning paper copies into .pdfs. The former method of conversion generates searchable optical character recognition (OCR) text; the latter does not.

Courtesy Copies Unless the Court directs otherwise, no courtesy copies may be submitted for filing. If the Court orders a party to provide paper courtesy copies, please deliver those copies to the drop-box outside the Courtroom Deputy’s office (Room 2140). Discovery Motion Practice 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 hear or consider any discovery motion unless the movant has complied with the “meet and confer” requirement of Local Rule 37.2. The 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 communication that takes place face to face or by telephone. The exchange of correspondence will not normally be sufficient 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 often will rule on discovery motions after hearing argument at the motion call and without 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. Parties are reminded to notify the Court immediately if they are withdrawing any previously filed discovery motions. Parties are reminded that there is no “order” 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. In addition, unless provided for under applicable law, the pendency of a dispositive motion does not, in itself, operate to stay discovery. Electronic Discovery Disputes If the parties have reached an impasse regarding the discovery of voluminous records from a database, server, computer, service provider or similar electronic storage facility (ESF), before a motion to compel is filed, the parties are required to meet and confer with an IT representative of the ESF to be searched in order to determine the most effective way to retrieve the requested material. The party seeking the discovery must also bring its IT specialist to this meeting in order to discuss the proper format for the retrieval of the records. This electronic discovery conference may take place in person or by telephone, and both sides should be prepared to discuss specifically the parameters of both the search and the ESF. For information regarding the Voluntary E-Mediation Program, please refer to: http://www.discoverypilot.com/content/e-mediation-program Emergency Motions Please be advised that the Court will hear emergency motions only in exceptional circumstances after making a preliminary determination of whether an actual emergency exists. Source ↗

Initial Status Report For Reassigned 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. Consent to Proceed Before Magistrate Judge Correspondence with the Court Unless the Court directs otherwise, counsel and pro se litigants must not communicate with the Court about the merits of a case by letter, phone, or email (excluding the submission of a proposed order). All communications and requests for relief must be made in the form of a motion, brief, or a status report, and served on opposing counsel. Courtesy Copies Unless the Court directs otherwise, no courtesy copies may be submitted for filing. If the Court orders a party to provide paper courtesy copies, please deliver those copies to the drop-box outside the Courtroom Deputy’s office (Room 2140). Discovery Motion Practice 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 hear or consider any discovery motion unless the movant has complied with the “meet and confer” requirement of Local Rule 37.2. The 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 communication that takes place face to face or by telephone. The exchange of correspondence will not normally be sufficient 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 often will rule on discovery motions after hearing argument at the motion call and without 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. Parties are reminded to notify the Court immediately if they are withdrawing any previously filed discovery motions. Parties are reminded that there is no “order” 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. In addition, unless provided for under applicable law, the pendency of a dispositive motion does not, in itself, operate to stay discovery. Electronic Discovery Disputes If the parties have reached an impasse regarding the discovery of voluminous records from a database, server, computer, service provider or similar electronic storage facility (ESF), before a motion to compel is filed, the parties are required to meet and confer with an IT representative of the ESF to be searched in order to determine the most effective way to retrieve the requested material. Source ↗

Motion practice : Until further notice, parties should not notice motions for presentment. Parties may request a hearing for motions that they believe cannot be decided based on written submissions alone or that would otherwise benefit from a court hearing. The request must be made in the motion itself or by joint e-mail to the courtroom deputy. For any motion the parties believe would benefit from briefing, the parties should jointly e-mail the Courtroom Deputy within 2 business days of the filing of the motion to request a briefing schedule. Please be advised that the Court may set a motion hearing or a briefing schedule for any motion without a request from the parties. Telephone hearings : Judge Wood holds most status hearings by telephone. Parties may consult the Court's daily call sheet to see if a hearing will be held telephonically or in person. Whether a hearing will take place telephonically or in person will also be stated in the docket entry setting the hearing. When participating in a hearing telephonically, do not use a speakerphone. A handset or headset should be used to ensure the clarity of audio input. If available, a landline is preferable to a cellphone. Participants should be in a quiet place, not in a vehicle, outdoors, or in a public area. While waiting for a case to be called, participants should mute their telephones to eliminate potentially disruptive background noise and feedback on the line while other matters are being heard. In addition, during a hearing participants should mute their telephones except when speaking. Parties are advised to consult the Court’s Best Practices for Remote Participation in Telephone / Videoconference Court Proceedings for additional guidance on participating in court hearings remotely. To ensure access to public court proceedings, members of the public and media may call-in to listen to telephonic hearings. Information on how to do so will be included on the docket and/or the call sheet. Counsel of record will receive a courtesy email the morning of the hearing is scheduled with instructions to join the call. NOTICE Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Important Information This page contains important information about Judge Wood’s case management procedures. These procedures have been designed to facilitate the prompt, efficient, and equitable disposition of cases on Judge Wood’s docket. Please take the time to familiarize yourself with these procedures in addition to the Local Rules for this District. When Judge Wood’s procedures differ from the Local Rules, please follow the procedures outlined here. Source ↗

Motion practice : Until further notice, parties should not notice motions for presentment. Parties may request a hearing for motions that they believe cannot be decided based on written submissions alone or that would otherwise benefit from a court hearing. The request must be made in the motion itself or by joint e-mail to the courtroom deputy. For any motion the parties believe would benefit from briefing, the parties should jointly e-mail the Courtroom Deputy within 2 business days of the filing of the motion to request a briefing schedule. Please be advised that the Court may set a motion hearing or a briefing schedule for any motion without a request from the parties. Telephone hearings : Judge Wood holds most status hearings by telephone. Parties may consult the Court's daily call sheet to see if a hearing will be held telephonically or in person. Whether a hearing will take place telephonically or in person will also be stated in the docket entry setting the hearing. When participating in a hearing telephonically, do not use a speakerphone. A handset or headset should be used to ensure the clarity of audio input. If available, a landline is preferable to a cellphone. Participants should be in a quiet place, not in a vehicle, outdoors, or in a public area. While waiting for a case to be called, participants should mute their telephones to eliminate potentially disruptive background noise and feedback on the line while other matters are being heard. In addition, during a hearing participants should mute their telephones except when speaking. Parties are advised to consult the Court’s Best Practices for Remote Participation in Telephone / Videoconference Court Proceedings for additional guidance on participating in court hearings remotely. To ensure access to public court proceedings, members of the public and media may call-in to listen to telephonic hearings. Information on how to do so will be included on the docket and/or the call sheet. Counsel of record will receive a courtesy email the morning of the hearing is scheduled with instructions to join the call. NOTICE Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court-issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the Court. Important Information This page contains important information about Judge Wood’s case management procedures. These procedures have been designed to facilitate the prompt, efficient, and equitable disposition of cases on Judge Wood’s docket. Please take the time to familiarize yourself with these procedures in addition to the Local Rules for this District. When Judge Wood’s procedures differ from the Local Rules, please follow the procedures outlined here. Source ↗

Motions for summary judgment and responses must comply with Local Rules 56.1(a) and 56.1(b), as well as the procedures outlined herein. All statements of undisputed material facts and their responses shall be filed separately from the memoranda of law and shall include the line, paragraph or page number where the supporting material may be found in the record. The Local Rules are not mere technicalities. Failure to abide by the Local Rules may result in the Court striking briefs, disregarding statements of fact, deeming statements of fact admitted and denying summary judgment. See Cracco v. Vitran Exp., Inc., 559 F.3d 625, 632 (7th Cir. 2009). The movant shall not file more than 80 statements of undisputed material facts without prior leave of the Court. The respondent shall be limited to 40 statements of undisputed material facts without prior leave of the Court. In complex cases, the Court may request that the parties submit a timeline of events in addition to the statements of undisputed material facts. If you are representing yourself, please refer to Local Rule 56.2 - Notice to Pro Se Litigants Opposing Summary Judgment. Source ↗