Example of a HIPAA Protective Order; Judge Appenteng's Standing Order for Initial Joint Status Report; Judge Appenteng’s Standing Order for Settlement Conference; here; Standing Order Governing Pretrial Procedures and Final Pretrial Order

=== Example of a HIPAA Protective Order ===

, , IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION Plaintiff, v. Defendant. Case No. QUALIFIED PROTECTIVE ORDER Pursuant to Rule 26(c) of the Federal Rules of Civil Procedure and 45 C.F.R. § 164.512(e)(1), the Court finds good cause for the issuance of a qualified protective order and ORDERS as follows: 1. The parties and their attorneys are hereby authorized to receive, subpoena, and transmit “protected health information” pertaining to Plaintiff to the extent and subject to the conditions outlined herein. 2. For the purposes of this qualified protective order, “protected health information” shall have the same scope and definition as set forth in 45 C.F.R. §§ 160.103 and 160.501. Protected health information includes, but is not limited to, health information, including demographic information, relating to either (a) the past, present, or future physical condition of an individual; (b) the provision of care to an individual; or (c) the payment for care provided to an individual, which identifies the individual or which reasonably could be expected to identify the individual. 3. All “covered entities” (as defined by 45 C.F.R. § 160.103) are hereby authorized to disclose protected health information pertaining to Plaintiff, to attorneys representing Plaintiff and Defendant in the above-captioned litigation. 4. The parties and their attorneys shall be permitted to use or disclose the protected health information of Plaintiff for purposes of prosecuting or defending this action including any appeals of this case. This includes, but is not necessarily limited to, disclosure to their attorneys, experts, consultants, court personnel, court reporters, copy services, trial consultants, and other entities involved in the litigation process. 5. Prior to disclosing Plaintiff’s protected health information to persons involved in this litigation, counsel shall inform each such person that Plaintiff’s protected health information may not be used or disclosed for any purpose other than this litigation. Counsel shall take all other reasonable steps to ensure that persons receiving Plaintiff’s protected health information do not use or disclose such information for any purpose other than this litigation. 6. Within 45 days after the conclusion of the litigation including appeals, the parties, their attorneys, and any person or entity in possession of protected health information received from counsel pursuant to paragraph four of this Order, shall return Plaintiff’s protected health information to the covered entity or destroy any and all copies of protected health information pertaining to Plaintiff, except that counsel are not required to secure the return or destruction of protected health information submitted to the court. 2 7. This order does not control or limit the use of protected health information pertaining to Plaintiff that comes into the possession of the parties or their attorneys from a source other than a “covered entity” as that term is defined in 45 CFR § 160.103. 8. Nothing in this order authorizes counsel for the Defendant to obtain medical records or information through means other than formal discovery requests, subpoenas, depositions, pursuant to a patient authorization, or other lawful process. 9. This Order does not authorize either party to seal court filings or court proceedings. The Court will make a good cause determination for filing under seal if and when the parties seek to file Plaintiff’s protected health information under seal. SO ORDERED. Dated: Dated: Jeannice W. Appenteng United States Magistrate Judge 3

=== Judge Appenteng's Standing Order for Initial Joint Status Report ===

MAGISTRATE JUDGE JEANNICE W. APPENTENG 219 South Dearborn Street Chicago, Illinois Courtroom 1858 Chambers 1870 Chicago, Illinois (312) 435-5667 STANDING ORDER FOR INITIAL JOINT STATUS REPORTS This case has been assigned to Magistrate Judge Appenteng. By minute order the Court has set a deadline for the parties to file a joint status report. The joint status report shall contain the following information: 1. Description of Claims and Relief Sought. a. Describe the claims and defenses raised by the pleadings, including the basis for federal jurisdiction. b. State the relief sought, including an itemization of damages. 2. Referral Cases. Describe the matter(s) referred to the magistrate judge. 3. Discovery Schedule. Identify any existing discovery deadlines. If no discovery schedule exists and the case is referred for discovery supervision, the parties should confer and submit the following information: a. The deadline for Fed. R. Civ. P. 26(a)(1) disclosures. b. c. d. A date to issue written discovery requests. A fact discovery completion date. For claims involving medical conditions, fact discovery ordinarily includes treating physician depositions. The parties shall indicate whether the proposed date includes treating physician depositions. If there will be expert discovery, an expert discovery completion date, including dates for the delivery of expert reports and rebuttal reports, if any (or summaries for non-retained expert testimony). 4. Consideration of Issues Concerning ESI. State whether the parties anticipate or are engaged in ESI discovery, and, if so, what agreements have been reached regarding ESI and whether there are any areas of disagreement. Please note the Court has adopted the Principles of the Seventh Circuit Electronic Discovery Pilot Program and the parties should be familiar with them. In a patent case, the Court will apply the Local Patent Rules for Electronically Stored Information. 5. Settlement. a. b. Describe the status of any settlement discussions. State whether the parties believe a settlement conference would be productive at this time, and if not, briefly explain why. 6. Magistrate Judge Consent. State whether all parties will consent to have Judge Appenteng conduct all further proceedings in this case, including trial and entry of final judgment, in accordance with 28 U.S.C. § 636(c) and Federal Rule of Civil Procedure 73. 7. Pending Motions. Indicate the status of any pending motions. 8. Trial. In consent cases, state whether a jury trial is requested, the date when the parties expect to be ready for trial, and the probable length of trial. 2 9. Other Matters. State any other matters that should be brought to the Court’s attention for scheduling purposes. SO ORDERED. Dated: March 18, 2025 ______________________________ Jeannice W. Appenteng United States Magistrate Judge 3

=== Judge Appenteng’s Standing Order for Settlement Conference ===

MAGISTRATE JUDGE JEANNICE W. APPENTENG 219 South Dearborn Street Chicago, Illinois Courtroom 1350 Chambers 1356 Chicago, Illinois (312) 435-5667 STANDING ORDER FOR SETTLEMENT CONFERENCES The Court encourages the parties to fully consider settlement at the earliest reasonable opportunity in the case. For those cases that can be resolved through settlement, early consideration of settlement allows the parties to avoid the substantial amounts of time and money that are typically part of litigation. Even if the case cannot be settled, early consideration of settlement often can result in focusing the issues to be litigated, which again can save the parties considerable time and money. A settlement conference requires serious and thorough preparation. This Order sets out the procedures the parties are to follow in preparing for the settlement conference, and the procedures that the Court typically will employ in conducting the conference. Failure to comply with the procedures set forth in this Order may result in the unilateral cancellation of the settlement conference by the Court. Counsel are directed to provide a copy of this Order to their clients and discuss these procedures with them before the settlement conference. A. Initial Status Hearing and Joint Status Report on Settlement Upon referral of a case for a settlement conference, the Court will generally hold an initial telephonic status hearing to set dates for the settlement conference and for the parties to exchange pre-conference settlement letters. Counsel primarily responsible for representing the parties must participate in this initial status hearing. Counsel should come prepared to discuss the availability of the attorneys and decisionmakers who will participate in the settlement conference, consistent with the requirements of this order. Prior to the initial status hearing, the Court will direct the parties to submit a joint status report addressing the following issues: (1) whether the parties have the necessary information to conduct meaningful settlement discussions; (2) the earliest anticipated date when all parties will be ready to participate in a productive settlement conference; (3) whether the parties have engaged in previous settlement discussions and the current status of those discussions; (4) the individuals who will be present at the settlement conference on behalf of their respective parties, consistent with the requirements of this order; and (5) whether there are outstanding lien holders or third parties who must provide information or should participate in the settlement conference. B. Pre-Settlement Conference Letters and Further Discussions The parties are required to exchange settlement letters before the conference. Settlement conferences are likely to be more productive if the parties have had a written exchange of their settlement positions. The letters also provide the Court with information it needs to assist the parties in exploring settlement. Each party shall email a copy of its letter to the Court’s chambers on the same day that it is provided to opposing counsel. The subject line of the email shall include the case name, case number, and the date of the settlement conference. The email address for the submission of settlement letters to the Court is [email protected]. These letters are not electronically filed on the court docket, will not be made part of the Court’s record, and will not be admissible as evidence. Plaintiff’s settlement letter must set forth the following information: (a) the nature of the case; (b) a brief summary of the evidence and legal principles that support plaintiff’s theory of liability, damages, and any other relief; (c) an itemization of damages; (d) a settlement demand; and (e) any additional information plaintiff believes would be helpful to the Court in assisting the parties to resolve the dispute. Plaintiff’s settlement demand must be all inclusive and specify each element of monetary and non-monetary relief that plaintiff seeks to settle the case. For example, a settlement demand stating that plaintiff seeks $20,000, a reasonable accommodation, and her reasonable attorney’s fees and costs is non-compliant because it does not specify the particular accommodation and the specific fees and costs that are sought. Finally, plaintiffs are expected to submit a demand that is not what they expect to win at trial, but rather a number that takes into account the risk 2 that plaintiff might lose the case and cost savings from settling before dispositive motions are filed and/or trial. Settlement demands that state the maximum relief that plaintiff might recover at trial are unproductive. Defendant’s settlement letter must set forth the theory of defense and shall include the following information: (a) any point(s) in plaintiff’s letter with which the defendant agrees; (b) any point(s) in plaintiff’s letter with which defendant disagrees; (c) a settlement offer that is responsive to the monetary and non-monetary elements of relief that plaintiff seeks in its settlement demand; and (d) any additional information defendant believes would be helpful to the Court in assisting the parties to resolve the dispute. Defendants are expected to make a settlement offer that does not assume that there will be no liability. All parties shall include within their letters the names and titles of the individuals they anticipate will be attending the settlement conference. Parties must limit settlement letters to six pages, exclusive of exhibits, unless they obtain leave of Court, which may be obtained by emailing the Courtroom Deputy. Parties must submit courtesy copies of any submissions (inclusive of exhibits) longer than ten pages. The parties should invest sufficient time and effort when preparing their settlement letters because the Court finds that thoughtful and detailed letters are critical to productive settlement discussions. Parties are forewarned that failure to account for the risks and costs associated with proceeding with litigation in their settlement positions may result in the Court unilaterally canceling the settlement conference to avoid wasting the parties’ time and money, as well as Court resources. Counsel are required to provide the full set of settlement letters to their clients to read prior to the conference. On occasion, this exchange process itself will lead to a settlement. The fact that a settlement conference has been scheduled does not mean that the parties should stop engaging in settlement discussions among themselves. Indeed, the parties should have multiple discussions about settlement between the date the Court sets the settlement conference and the date of the settlement conference. In most cases, the Court will hold a second telephonic conference to discuss the information in the letters. During the telephone conference, the Court will seek to identify any issues or disputes that can be addressed or resolved prior to the settlement conference and will review the offers with the parties. The Court will also assess whether the parties continue to believe that a settlement conference will be productive. The Court may also separately contact counsel for one or both parties but will let the other party or parties know if/when this happens. 3 C. Persons Required to Attend the Settlement Conference Parties with full settlement authority are required to attend the conference. If a party is an individual, that individual must attend. If a party is a corporation or governmental entity, a representative of that corporation or governmental entity (in addition to counsel of record) with full settlement authority must attend. “Full settlement authority” means the authority to negotiate and agree to a binding settlement agreement at any level up to the settlement demand of the opposing party. If a party requires approval by an insurer to settle, then a representative of the insurer with full and complete settlement authority must attend. The Court strongly believes that the presence of the individuals with a stake in the outcome of the settlement conference, and their participation in the settlement discussions and in the compromise that occurs at the conference, materially increases the chances of settlement. The Court will not permit a party, party representative, or an insurance representative merely to be available by telephone during the conference. In addition, absent Court permission, failure to attend or attendance without full settlement authority may result in sanctions. If a conference must be adjourned or continued so that a party can obtain additional authority to reach a settlement that was reasonably within the realm of possibility for the case, that party may be sanctioned, including being required to pay the opposing party’s attorney’s fees and costs incurred by the need to reconvene. See Fed.R.Civ.P.16(c)(1), 16(f)(1)(A) and (B), and 16(f)(2). D. Conference Format Unless the parties request that a settlement conference take place in-person in the courthouse, the settlement conference will proceed remotely via videoconference, as set forth in this order. The Court generally will follow a mediation format, which will begin with a joint session consisting of short opening remarks and questions by the Court, and no opening statements by counsel or the parties. The opening joint session will be followed by each party having private caucuses with the Court. The Court expects the lawyers and the parties or their representatives to be fully prepared to participate in these discussions. The Court encourages all parties to be willing to reassess their previous positions and to be willing to explore creative means for resolving the dispute. The Court encourages the parties and counsel to consider providing opportunities to junior lawyers to substantively participate in the settlement conference. 4 E. Videoconference Procedures If the settlement conference is by videoconferencing technology, the Court’s staff will hold a test run with the parties at least 30 minutes prior to the conference. All attorneys and party representatives must log on at that time. All attorneys are responsible for themselves and their clients in ensuring an error-free settlement conference. This includes functioning cameras, speakers, and microphones without static or interference. The Court will not allow any counsel or party to appear using a cell phone. All participants must use a computer or tablet or be in the same room as someone with a computer or tablet. The Court uses the Cisco Webex platform for videoconferences. Any counsel may email the Courtroom Deputy for a test run several days before the conference if they are concerned about the technology. F. Confidentiality The pre-conference letters and the settlement conference are governed by Local Rule 83.5 relating to Confidentiality of Alternative Dispute Resolution Proceedings. Any statements made by any party during the settlement conference will not be admissible at trial. The Court expects the parties to address each other with courtesy and respect, and also to speak frankly and openly about their views of the case in this confidential setting. G. Failure to Appear and Cancellation of the Conference Counsel and the parties are cautioned that failure to attend a settlement conference may subject a party to sanctions. Absent exigent circumstances, no conference shall be rescheduled except by court order pursuant to a written motion electronically filed and emailed to the Courtroom Deputy not less than 10 days in advance of the conference. The motion shall fully explain the reasons for the requested continuance. If the parties conclude that a settlement conference is no longer necessary, they should inform the Court via email to the Courtroom Deputy as soon as possible. SO ORDERED. ______________________________ Jeannice W. Appenteng United States Magistrate Judge Dated: November 2, 2023 5

=== here ===

MAGISTRATE JUDGE JEANNICE W. APPENTENG 219 South Dearborn Street Chicago, Illinois Chambers 1870 Chicago, Illinois (312) 435-5667 STANDING ORDER FOR SETTLEMENT CONFERENCES The Court encourages the parties to fully consider settlement at the earliest reasonable opportunity in the case. For those cases that can be resolved through settlement, early consideration of settlement allows the parties to avoid the substantial amounts of time and money that are typically part of litigation. Even if the case cannot be settled, early consideration of settlement often can result in focusing the issues to be litigated, which again can save the parties considerable time and money. A settlement conference requires serious and thorough preparation. This Order sets out the procedures the parties are to follow in preparing for the settlement conference, and the procedures that the Court typically will employ in conducting the conference. Failure to comply with the procedures set forth in this Order may result in the unilateral cancellation of the settlement conference by the Court. Counsel are directed to provide a copy of this Order to their clients and discuss these procedures with them before the settlement conference. A. Setting a Settlement Conference Date Upon referral of a case for a settlement conference and prior to scheduling a settlement conference, the parties will exchange pre-conference settlement letters. The required content of these letters is set forth in detail below. After considering the parties’ settlement positions, the Court’s staff will contact the parties with available dates for a full settlement conference or a preliminary attorneys-only conference. B. Pre-Settlement Conference Letters and Further Discussions Settlement conferences are likely to be more productive if the parties have had a written exchange of their settlement positions. The letters also provide the Court with information it needs to assist the parties in exploring settlement. Each party shall email a copy of its letter to the Court’s chambers on the same day that it is provided to opposing counsel. The subject line of the email shall include the case name, case number, and the date of the settlement conference. The email address for the submission of settlement letters to the Court is [email protected]. These letters are not electronically filed on the court docket, will not be made part of the Court’s record, and will not be admissible as evidence. Plaintiff’s settlement letter must set forth the following information: (a) the nature of the case; (b) a brief summary of the evidence and legal principles that support plaintiff’s theory of liability, damages, and any other relief; (c) an itemization of damages; (d) a settlement demand; and (e) any additional information plaintiff believes would be helpful to the Court in assisting the parties to resolve the dispute. Plaintiff’s settlement demand must be all inclusive and specify each element of monetary and non-monetary relief that plaintiff seeks to settle the case. For example, a settlement demand stating that plaintiff seeks $20,000, a reasonable accommodation, and her reasonable attorney’s fees and costs is non-compliant because it does not specify the particular accommodation and the specific fees and costs that are sought. Finally, plaintiffs are expected to submit a demand that is not what they expect to win at trial, but rather a number that takes into account the risk that plaintiff might lose the case and cost savings from settling before dispositive motions are filed and/or trial. Settlement demands that state the maximum relief that plaintiff might recover at trial are unproductive. Defendant’s settlement letter must set forth the theory of defense and shall include the following information: (a) any point(s) in plaintiff’s letter with which the defendant agrees; (b) any point(s) in plaintiff’s letter with which defendant disagrees; (c) a settlement offer that is responsive to the monetary and non-monetary elements of relief that plaintiff seeks in its settlement demand; and (d) any additional information defendant believes would be helpful to the Court in assisting the parties to resolve the dispute. Defendants are expected to make a settlement offer that does not assume that there will be no liability. 2 All parties shall include within their letters the names and titles of the individuals they anticipate will be attending the settlement conference. Parties must limit settlement letters to six pages double-spaced, exclusive of exhibits, unless they obtain leave of Court, which may be obtained by emailing the Courtroom Deputy. Parties must submit courtesy copies of any submissions (inclusive of exhibits) longer than ten pages. The parties should invest sufficient time and effort when preparing their settlement letters because the Court finds that thoughtful and detailed letters are critical to productive settlement discussions. Parties are forewarned that failure to account for the risks and costs associated with proceeding with litigation in their settlement positions may result in the Court unilaterally canceling the settlement conference to avoid wasting the parties’ time and money, as well as Court resources. Counsel are required to provide the full set of settlement letters to their clients to read prior to the conference. On occasion, this exchange process itself will lead to a settlement. The fact that a settlement conference has been scheduled does not mean that the parties should stop engaging in settlement discussions among themselves. Indeed, the parties should have multiple discussions about settlement between the date the Court sets the settlement conference and the date of the settlement conference. In most cases, the Court will hold a telephone conference with one or both parties to discuss the information in the letters. Prior to any ex parte communications, the Court will make the parties aware and offer an opportunity to object to such communications. During the telephone conference, the Court will seek to identify any issues or disputes that can be addressed or resolved prior to the settlement conference and will review the offers with the parties. The Court will also assess whether the parties continue to believe that a settlement conference will be productive. C. Persons Required to Attend the Settlement Conference Parties with full settlement authority are required to attend the conference. If a party is an individual, that individual must attend. If a party is a corporation or governmental entity, a representative of that corporation or governmental entity (in addition to counsel of record) with full settlement authority must attend. “Full settlement authority” means the authority to negotiate and agree to a binding settlement agreement at any level up to the settlement demand of the opposing party. If a party requires approval by an insurer to settle, then a representative of the insurer with full and complete settlement authority must attend. 3 The Court strongly believes that the presence of the individuals with a stake in the outcome of the settlement conference, and their participation in the settlement discussions and in the compromise that occurs at the conference, materially increases the chances of settlement. The Court will not permit a party, party representative, or an insurance representative merely to be available by telephone during the conference. In addition, absent Court permission, failure to attend or attendance without full settlement authority may result in sanctions. If a conference must be adjourned or continued so that a party can obtain additional authority to reach a settlement that was reasonably within the realm of possibility for the case, that party may be sanctioned, including being required to pay the opposing party’s attorney’s fees and costs incurred by the need to reconvene. See Fed.R.Civ.P.16(c)(1), 16(f)(1)(A) and (B), and 16(f)(2). D. Conference Format Unless the parties request that a settlement conference take place in-person in the courthouse, the settlement conference will proceed remotely via videoconference, as set forth in this order. The Court generally will follow a mediation format, which will begin with a joint session consisting of short opening remarks and questions by the Court, and no opening statements by counsel or the parties. The opening joint session will be followed by each party having private caucuses with the Court. The Court expects the lawyers and the parties or their representatives to be fully prepared to participate in these discussions. The Court encourages all parties to be willing to reassess their previous positions and to be willing to explore creative means for resolving the dispute. E. Videoconference Procedures If the settlement conference is by videoconferencing technology, the Court’s staff will hold a test run with the parties 15 to 30 minutes prior to the conference. All attorneys and party representatives must log on at that time. All attorneys are responsible for themselves and their clients in ensuring an error-free settlement conference. This includes functioning cameras, speakers, and microphones without static or interference. The Court will not allow any counsel or party to appear using a cell phone. All participants must use a computer or tablet or be in the same room as someone with a computer or tablet. The Court uses the Cisco Webex platform for videoconferences. 4 Any counsel may email the Courtroom Deputy for a test run several days before the conference if they are concerned about the technology. Video Settlement Conference Attire: It has become necessary for the Court to include the following, given conduct observed at settlement conferences. Attorneys are expected to dress professionally and conservatively to demonstrate respect for the court. This typically means wearing a suit or similar business attire. F. Confidentiality The pre-conference letters and the settlement conference are governed by Local Rule 83.5 relating to Confidentiality of Alternative Dispute Resolution Proceedings. Any statements made by any party during the settlement conference will not be admissible at trial. The Court expects the parties to address each other with courtesy and respect, and also to speak frankly and openly about their views of the case in this confidential setting. G. Failure to Appear and Cancellation of the Conference Counsel and the parties are cautioned that failure to attend a settlement conference may subject a party to sanctions. Absent exigent circumstances, no conference shall be rescheduled except by court order pursuant to a written motion electronically filed and emailed to the Courtroom Deputy not less than 10 days in advance of the conference. The motion shall fully explain the reasons for the requested continuance. If the parties conclude that a settlement conference is no longer necessary, they should inform the Court via email to the Courtroom Deputy as soon as possible. SO ORDERED. Dated: May 12, 2025 ______________________________ Jeannice W. Appenteng United States Magistrate Judge 5

=== Standing Order Governing Pretrial Procedures and Final Pretrial Order ===

MAGISTRATE JUDGE JEANNICE WILLIAMS APPENTENG 219 South Dearborn Street Courtroom 1858 Chambers 1870 Chicago, IL (312) 435-5667 Standing Order Governing Pretrial Procedures and Final Pretrial Orders for Civil Cases This Standing Order sets forth the Court’s pretrial procedures and the requirements for submitting a Proposed Pretrial Order for the Court’s consideration. Final Pretrial Conference A final pretrial conference will be held approximately two weeks before trial. The purpose of this conference will be to avoid surprises and to simplify the trial. At the conference, Judge Appenteng will address pending motions in limine, objections to witnesses and exhibits, and contested jury instructions, and will discuss trial procedures and scheduling. Lead trial counsel with authority to discuss all aspects of the case must attend. Motions in Limine and Daubert Motions Motions in limine should be used sparingly to conserve the parties’ resources. The Court discourages the filing of “boilerplate” motions in limine or motions that address matters not in dispute. Any motion in limine filed by a party must be accompanied by a statement that the party has conferred with the opposing party and the opposing party actually intends to offer the evidence that the movant seeks to exclude, or actually opposes admission of the evidence that the movant seeks to include. If the meet-and-confer process results in agreement over evidentiary issues, that agreement may be memorialized in a stipulation entered into at the final pretrial conference. Motions in limine must be filed on the docket by the due date set by the Court, which is separate from the date for the filing of the proposed pretrial order. The Court will set response dates. No replies may be filed without leave of Court. A party must consolidate separate motions in limine into a single filing (meaning the same ECF entry). The parties must also consolidate their responses to motions in limine into a single response brief (meaning the same ECF entry). Separately filed motions or separately filed responses to each motion are not permitted. Absent prior leave of Court, motions in limine (not including exhibits) are limited to a total of 15 pages per party (not per motion), and responses (not including exhibits) are likewise limited to a total of 15 pages per party. These limitations do not apply to motions challenging the admissibility of Rule 702 expert testimony pursuant to Daubert v. Merrell Dow Pharmaceuticals, Inc. Any Daubert motions shall be filed no later than 35 days and responses no later than 21 days before the final pretrial conference. Final Proposed Pretrial Order Prior to the final pretrial conference, the parties shall jointly prepare and submit a proposed pretrial order containing the sections and information described below. The Court will set a date for filing the proposed pretrial order. Proposed pretrial orders must be filed on the docket by selecting “Other Filings” and then “Other Documents,” and choosing the proposed pretrial order event in CM/ECF. Courtesy copies are not necessary, however, the proposed pretrial order must be e- mailed to [email protected] in Microsoft Word format. Judge Appenteng does not require trial briefs. Parties who wish to file a trial brief must seek leave of Court to do so. 1. Jurisdiction. State the jurisdictional basis for each claim. If the parties rely on either diversity jurisdiction or another jurisdictional basis that requires a threshold amount, then state whether the parties agree that the amount in controversy exceeds the amount and include a concise explanation of how the evidence supports that statement. 2. Trial Attorneys. List all attorneys trying the case, as well as contact information (business address, telephone number, and e-mail address). 3. Case Statement. Provide a concise agreed statement of the case. This is a neutral description of the case. The statement must describe the nature of the case, claims, and defenses. In a jury trial, this statement will be read by the Court to the jury pool during jury selection. Accordingly, the statement needs only enough information to introduce the case to the jury and to ask potential jurors whether they happen to know anything about the case. 2 4. Damages Itemization. Plaintiff (and counter/cross-claimants, if any) shall itemize damages and other relief sought and provide a concise explanation of the evidentiary basis for each itemization. 5. Trial Length / Number of Jurors. State the estimated number of trial days, including jury selection, opening statements, and closing arguments, premised on six-hour to six and one-half hour trial-testimony days (these time periods already account for lunch and breaks). Propose estimated time limits for (a) opening statements per side; (b) closing arguments per side (including an initial close and rebuttal for the plaintiff); and (c) the total number of hours of witness examination per side. Also, state the number of jurors that the parties recommend (subject to Federal Rule of Civil Procedure 48(a . 6. Stipulations and Uncontested Facts. In numbered paragraphs, state any stipulations and uncontested facts. No later than 10 business days before the proposed pretrial order’s due date, the parties must serve on each other proposed stipulations and uncontested facts. No later than 5 business days before the due date, the parties must confer in good faith to arrive at as many stipulations and uncontested facts as possible. The Court encourages ample stipulations where possible as a good way to conserve the parties’ resources. 7. Witness Description Lists. Each party shall provide a list of the witnesses, including expert witnesses, divided into (a) witnesses who will be called; (b) witnesses whose testimony will be presented by deposition or other prior testimony (indicating whether the presentation will be by reading a transcript or playing a video); and (c) witnesses who might be called or whose testimony might be presented. For each witness, provide a concise (2 or 3 sentences) description of the witness and the witness’s role in the case. For example: “George Washington is Plaintiff’s cousin. Washington witnessed the arrest of Plaintiff where Defendants allegedly used excessive force.” Or: “John Adams is Defendant’s Chief Operating Officer. Adams made promises concerning the timing of payments under the contract.” Witnesses who are not on the lists are barred from testifying unless the proponent shows good cause for the failure to disclose the witness. In a jury case, the names of witnesses on the lists will be read during jury selection to ensure that potential jurors do not personally know any witness. The witness lists may be filed as separate ECF documents. If so, the proposed pretrial order shall indicate in this section that the witness list(s) will be filed on the docket simultaneously with the proposed pretrial order. 8. Exhibits and Exhibit Charts. The parties must submit an exhibit chart, one each for Plaintiff’s exhibits and Defendant’s exhibits. The charts must state the following: (a) the exhibit number; (b) the date of the document or exhibit, if applicable; 3 (c) a concise, neutral description of the exhibit; (d) a concise statement of the exhibit’s relevance; and (e) whether there is an objection to the exhibit’s admission, and if so, a concise explanation of the objection and the proponent’s theory of admissibility. The concise explanation of objection and theory of admissibility must be complete (i.e., list each distinct basis for admission or exclusion, such as Rules of Evidence or court opinions) but need not be as exhaustive as a brief would be. Grounds not listed may be waived, except for foundation and authentication. If additional argument on an issue will benefit the Court, it will ask the parties to brief the issue or address it at the final pretrial conference. The chart’s format shall be substantially similar to the example below (landscape orientation is encouraged). No. Date 1 02/15/06 2005 Description Performance Review Relevance Proves record of satisfactory job performance Objection R. 402 relevant; R. 403 confusion. Plaintiff fired in 2011. In addition to substantive exhibits and Rule 1006 summary exhibits, the chart should also include proposed demonstrative exhibits and any exhibits that are likely to be referred to at trial even though not allowed into evidence. For example, deposition transcripts of witnesses likely to be impeached, or documents likely to be used to refresh memory, should be included on the chart (and assigned an exhibit number and description). The exhibit charts may be filed as separate ECF documents. If so, the proposed pretrial order shall indicate in this section that the exhibit chart(s) will be filed on the docket simultaneously with the proposed pretrial order. Any substantive exhibit not objected to shall be deemed stipulated to and admissible into evidence by this Order (note: for the exhibit to be entered into the record for the jury’s consideration, the exhibit still must be referred to during trial testimony or otherwise published to the jury). Unless the parties stipulate to the admissibility of an exhibit, or the Court by this Order deems it admissible, the proponent must be prepared to properly lay foundation and authenticate the document at trial. The parties shall, however, make a good faith effort to stipulate to the authenticity of exhibits whenever possible. Likewise, parties must limit the objections to only good-faith objections. Frivolous and boilerplate objections will waste time, because in preparation for the pre-trial conference, the Court will review, as much as possible, the exhibits and the objections. Do not over-designate exhibits, because we will examine exhibits one-by-one during the pretrial conference, and plainly inadmissible exhibits will needlessly consume time. As noted above, non-objected-to exhibits will be admissible into evidence by operation of this Order, without any need for further foundation testimony 4 (remember, however, that the exhibit must still be referred to during trial testimony or otherwise published to the jury in order for the exhibit to be considered by the jury). But during the trial, for the jury’s sake and for the clarity of the record, still move the exhibit into evidence before publishing it to the jury. The Court will ask whether there is any “further” objection, so any pretrial objection is preserved. At least 5 business days before the final pretrial conference, the parties must submit to chambers 2 sets of exhibit binders containing copies of all the proposed exhibits. Exhibits that will be used for impeachment purposes only need not be included in the binders. The parties also must upload electronic copies of the proposed exhibits using a Box.com link the Court will provide. Requests for the link shall be sent to Courtroom Deputy Kym Lozano at [email protected]. If, due to unforeseen circumstances during trial, a party wishes to introduce an exhibit not previously listed, notice should be given as soon as possible to the opposing side and to the Court so that any objections can be discussed. Absent abuse of this process, an exhibit will not be deemed inadmissible simply because it was not included on the original exhibit list, provided the exhibit/document was produced earlier to the opposing side during discovery. 9. Deposition Designations. If a party proposes to introduce a witness’s testimony via a deposition rather than live testimony, then the offering party must serve the page/line designations of the deposition transcript on the opposing party 10 business days in advance of the pretrial order’s due date. The opposing party must serve objections to designations (including a concise basis for the objection, like the Exhibit Chart) and also state the opposing party’s counter-designations (including counter-designations conditioned on an objection being overruled) 5 business days in advance of the pretrial order’s due date. The parties shall generate a joint chart, in page order, that sets forth the designation, objection, counter-designation if objection overruled, any counter- designations, and any objections to the counter-designations (again, with a concise basis for the objection, like the Exhibit Chart). The designation chart may be filed as a separate ECF document. If so, the proposed pretrial order shall indicate in this section that the designation chart will be filed on the docket simultaneously with the proposed pretrial order. The parties should include any objected-to portions of the designated deposition testimony in the exhibit binders submitted to the Court, and upload them to the Box.com link. 10. Motions in Limine. As noted above, motions in limine will be filed separately. In the proposed pretrial order, each party must provide a list that briefly 5 summarizes its motions in limine and indicates whether they are opposed. For example: “Defendant’s Motion in Limine No.1 to bar reference to Witness A’s drug use (Unopposed); Defendant’s Motion in Limine No. 2 to bar Witness B from trial (Opposed),” etc. 11. Voir Dire Questions. Judge Appenteng will always ask routine biographical questions. Any additional questions sought by the parties must be listed in the proposed pretrial order, divided into (a) agreed-upon questions and (b) proposed questions to which one party objects. A short basis for any objection should accompany the list. Each side is limited to 10 proposed disputed questions, unless a motion is filed before the pretrial conference that explains good cause for proposing more than the limit. 12. Jury Instructions / Verdict Forms. The parties must meet and confer to attempt to agree on as many jury instructions and verdict forms as possible. Where applicable, the Court generally prefers the Seventh Circuit’s Pattern Instructions. The proposed jury instructions must state, on an instruction-by-instruction basis, the following information: the proponent of the instruction, the legal authority for the instruction, and whether there is an objection to the instruction. If an instruction is disputed, the proponent of the instruction should concisely explain the basis for the instruction, if more explanation is required beyond the identified legal authority. Moreover, if an instruction is disputed, the objecting party must concisely state—on the page immediately following the instruction—the grounds for the objection, as well as any proposed modification or alternative. The same principles apply to proposed verdict forms. The proposed pretrial order shall indicate in this section that the proposed jury instructions and verdict forms will be filed on the docket and submitted in Microsoft Word by email to [email protected], simultaneously with the proposed pretrial order. 13. Signature. The proposed pretrial order must be signed (electronically) by counsel for each party. SO ORDERED. ______________________________ Jeannice Williams Appenteng United States Magistrate Judge Dated: April 28, 2026 6