Initial Status Report for New Case; Initial Status Report for Reassigned Case; Sample Civil Questionnaire 1; Sample Civil Questionnaire 2; Estimated Patent Case Schedule; Pretrial Procedures in Civil Cases; Pretrial Procedures in Criminal Cases; Law Clerk Hiring Information

=== Initial Status Report for New Case ===

[CASE CAPTION] INITIAL STATUS REPORT FOR NEW CASE This case has been assigned to the calendar of Judge LaShonda A. Hunt. The parties are directed to meet pursuant to Federal Rule of Civil Procedure 26(f) and conduct a planning conference, and file a joint Initial Status Report for New Case, containing the following information: I. The Nature of the Case: A. B. C. D. Identify (names and contact information) for all attorneys of record for each party, including the lead trial attorney. Briefly describe the nature of the claims asserted in the complaint and any counterclaims and/or third-party claims. Briefly identify the major legal and factual issues in the case. State the relief sought by any of the parties. II. Jurisdiction: Explain why the Court has subject matter jurisdiction over the plaintiff(s)’ claim(s). A. B. Identify all federal statutes on which federal question jurisdiction is based. If jurisdiction over any claims is based on diversity or supplemental jurisdiction: 1. 2. State whether/why the amount in controversy exceeds the jurisdictional threshold or whether there is a dispute regarding the amount in controversy (and, if so, the basis of that dispute). Identify the state of citizenship of each named party. For unincorporated associations, LLCs, partnerships, and other business entities that are not corporations, the state(s) in which any individual members of the business unit are citizens must be identified. NOTE 1: Individuals are citizens of the state where they are domiciled; that may or may not be the state where they currently reside. See Heinen v. Northrop Grumman Corp., 671 F.3d 669, 670 (7th Cir. 2012). NOTE 2: A supplement to the statement of the basis for federal jurisdiction shall be filed within 14 days of any change in the information provided in the Initial Status Report. III. Status of Service: Identify any defendants that have not been served. IV. Consent to Proceed Before a United States Magistrate Judge: Confirm that counsel have advised the parties that they may proceed before a Magistrate Judge if they consent unanimously and advise whether there is, or is not, unanimous consent. V. Motions: A. B. Briefly describe any pending motions. State whether the defendant(s) anticipate responding to the complaint by filing an Answer or by means of motion. VI. Case Plan: A. Submit a proposal for a discovery plan, including the following information1: 1. 2. 3. 4. 5. 6. 7. The general type of discovery needed; A date for Rule 26(a)(1) disclosures; First date by which to issue written discovery; Deadline to amend pleadings and join parties; A fact discovery completion date; An expert discovery completion date, including dates for the delivery of expert reports; and Whether either party anticipates filing dispositive motions. Please note that a schedule is typically set once all discovery is complete. B. With respect to trial, indicate the following: 1. 2. Whether a jury trial is requested; and The probable length of trial. VII. Status of Settlement Discussions: A. B. Indicate whether any settlement discussions have occurred; Describe the status of any settlement discussions; and 1 For patent cases, the proposed schedule should follow the schedule set forth in the Local Patent Rules. C. Whether the parties request a settlement conference.

=== Initial Status Report for Reassigned Case ===

[CAPTION] INITIAL STATUS REPORT FOR REASSIGNED CASE This case has been reassigned to the calendar of Judge LaShonda A. Hunt. To familiarize the Court with the issues in the case, counsel shall confer, prepare, and file a joint status report. The report shall not exceed five pages (single-spaced). If defense counsel has not yet filed an appearance, plaintiff’s counsel should prepare the status report. The report shall provide the following information in the exact format below: I. Nature of the Case A. B. C. D. Identify the attorneys of record for each party. State the basis for federal jurisdiction. If based on diversity, state the domicile of all parties. See Heinen v. Northrop Grumman Corp., 671 F.3d 669 (7th Cir. 2012). If any party is a partnership or a limited liability company and the basis of jurisdiction is diversity, counsel must identify the name and domicile(s) of each and every partner/member of each such entity. See Belleville Catering Co. v. Champaign Market Place LLC, 350 F.3d 691 (7th Cir. 2003); Cosgrove v. Bartolotta, 150 F.3d 729 (7th Cir. 1998); Carden v. Arkoma Assoc., 494 U.S. 185 (7th Cir. 1990). Briefly describe the nature of the claims asserted in the complaint and the counterclaims and/or third-party claims and/or affirmative defenses. Describe the relief sought by the plaintiff(s) and provide an estimate of damages, if any. E. List the names of any parties who have not yet been served. II. Discovery and Pending Motions A. B. C. D. Briefly describe all pending motions, including the date the motion was filed and the briefing schedule, if any. What is the current discovery schedule? Briefly describe all fact and expert discovery that the parties have conducted, including any electronic discovery. Describe any discovery that the parties still need to complete and indicate whether the parties anticipate completing discovery by the current deadline. Briefly summarize all substantive rulings issued in the case. (For each ruling, include the date and the docket number.) E. Briefly describe any anticipated motions, including whether any party intends to move for summary judgment. Please note that a dispositive motion schedule will typically not be set until all discovery is complete. III. Trial A. Have any of the parties demanded a jury trial? B. What is the trial date (if any)? If there is no trial date, when will the parties be ready for trial? C. Have the parties filed a final pretrial order? If so, when? If not, when is the deadline for the filing? D. Estimate the number of trial days. IV. Settlement, Referrals, and Consent A. B. C. D. Have any settlement discussions taken place? If so, what is the status? Has this case been referred to the Magistrate Judge for discovery supervision and/or a settlement conference? Do the parties request a settlement conference at this time before this Court or the Magistrate Judge? Have counsel informed their respective clients about the possibility of proceeding before the assigned Magistrate Judge for all purposes, including trial and entry of final judgment? Do all parties unanimously consent to that procedure? V. Other A. B. Is there anything else that the plaintiff(s) wants the Court to know? Is there anything else that the defendant(s) wants the Court to know?

=== Sample Civil Questionnaire 1 ===

[Used in a Fourth Amendment case] CONFIDENTIAL QUESTIONNAIRE FOR PROSPECTIVE JURORS Name:_______________________________________ Age:_______ Are you a U.S. Citizen? ____ [This trial is expected to last X weeks. If the length of the trial would cause a significant, unavoidable hardship, please explain in detail the nature of the hardship. You should understand that simple inconvenience is not grounds for disqualification from jury duty] [for use with trials longer than 1 week] ___________________________________________________________________________________ 1. List all cities or suburbs where you have lived for the last ten years (if Chicago, please identify what part of Chicago, for example, South Side, Rogers Park, etc.): __________________________________ 2. Do you own your home or rent it? _____________________________________________________ 3. Have you or a close relative ever served in the military? If so explain. ________________________ 4. Your level of education/degrees, and where obtained: _____________________________________ 5. What is your current occupation and employer, and how long have you worked there? ___________________________________________________________________________________ 6. What other jobs and employers have you had during your working life? _______________________ ___________________________________________________________________________________ 7. Please provide employment information for your spouse or any others who live with you, and any adult children (even if not living with you): ________________________________________________ 8. Do you regularly read any magazines or newspapers (whether in print or online)? If so, what are they? _______________________________________________________________________________ 9. Do you regularly watch or listen to television or radio news programs? If so, who are your favorite hosts? ______________________________________________________________________________ 10. What are your hobbies? _____________________________________________________________ 11. What social, civic, religious, profession, or other organizations do you or have you participated in? What is or was your role in the organization? If you no longer participate, why? ___________________ ___________________________________________________________________________________ 12. Are you acquainted with any of the following individuals: [NAME PARTIES] If so, please state the nature and extent of your relationship. _____________________________________________________ ___________________________________________________________________________________ 13. Do you know or have you ever had any dealings with the following law firms or attorneys: [NAME FIRMS and LAWYERS]? ______________________________________________________________ 14. Have you, your friends or family members worked for the [DEFENDANT] or any other governmental entity (state, federal, city or county)? If yes, please identify your relationship to that person. What was their position? _________________________________________________________ ___________________________________________________________________________________ 15. Are any of your close family members or friends lawyers? If so, what type of law do they practice? ___________________________________________________________________________________ 16. Do you have any friends or family members who are police officers? If so, is there anything about your relationship with that person which would impact your ability to judge a police officer’s actions in this case? ___________________________________________________________________________ Continued on the Reverse Side>>> 17. Do you belong to or support any organization, which favors changing the law in order to limit an injured victim’s right to recover? If so, what organization(s)? _________________________________ CONFIDENTIAL 18. Have you or any close family had any interactions with police on a professional level? If so, please explain, including whether that interaction positive, negative, or neutral? _________________________ ___________________________________________________________________________________ 19. Do you have any feelings or opinions regarding law enforcement or police officers that could affect your ability to be fair to all parties in this case? If yes, please explain. ____________________________ ___________________________________________________________________________________ 20. Have you or a close friend or close relative ever been arrested, charged with a crime, or convicted of a crime? Please provide details, and state whether that fact would affect your ability to be fair to either side in the case. Follow-up questions can take place outside the presence of other jurors, if you prefer. ___________________________________________________________________________________ 21. Have you or a close friend or close relative even been the victim of a crime? If yes, please explain. _ 22. Have your or a close friend or close relative ever witnessed a crime? If yes, you will be asked to explain during later questioning. _________________________________________________________ 23. Do you have any philosophical or religious beliefs that would prevent you from sitting in judgment of another person? ______________________________________________________________________ 24. Do you watch any TV programs or Internet programs or shows about police investigations or the court system? If so, which programs? _____________________________________________________ 25. Have you or a close friend or member of your family ever applied for a job with or worked for a police department, law enforcement agency, or security related business? _________________________ ___________________________________________________________________________________ 26. Have you ever studied criminal justice or taken any law enforcement trainings or classes? ___________________________________________________________________________________ 27. Do you or any of your close family members or friends belong to or work with any neighborhood watch groups or any groups that focus on crime prevention or enforcement of the law? ______________ 28. A law enforcement officer’s testimony is not entitled to any greater or lesser weight, simply because they are law enforcement officers, than any other witness. In general, would you be inclined to give greater, lesser, or the same weight to the testimony of a law enforcement officer than you would to an ordinary citizen? ______________________________________________________________________ 29. Do you believe that people should have the right to sue police officers and be awarded monetary compensation if the evidence shows that their rights have been violated by police officers? ___________ 30. Are you willing to fully compensate the plaintiffs for the damages requested if the evidence shows that the plaintiffs’ rights have been violated, and will you base any award of damages on the evidence in this case and not on sympathy? __________________________________________________________ 31. Similarly, if Plaintiffs fail to prove the things they are required to prove under the law, can you put any feelings of sympathy aside and send the Plaintiffs away with no money? ______________________ ___________________________________________________________________________________ 32. Have you or any of your family or close friends ever been involved in a lawsuit? If so, what was the nature of the lawsuit and your involvement if any? Were you satisfied with the outcome? ____________ ___________________________________________________________________________________ 33. Have you or a family member ever testified in court, or in a deposition? ______________________ 34. Have you ever served on a jury before? If so, what type of case was it? Did you reach a verdict? Were you the foreperson for that jury? ____________________________________________________ 35. Are there any facts or circumstances you believe that the court or the parties should know that might affect your ability to serve as a fair and impartial juror in this case? ___________________________________________________________________________________ CONFIDENTIAL

=== Sample Civil Questionnaire 2 ===

[Used in an Employment Discrimination case] CONFIDENTIAL QUESTIONNAIRE FOR PROSPECTIVE JURORS Name: __________________________________________ Age: ___________________ Are you a U.S. Citizen? ____ [This trial is expected to last X weeks. If the length of the trial would cause a significant, unavoidable hardship, please explain in detail the nature of the hardship. You should understand that simple inconvenience is not grounds for disqualification from jury duty.] [for use with trials longer than 1 week] ____________________________________________________________________ 1. List all cities or suburbs where you have lived for the last ten years (if Chicago, please identify what part of Chicago, for example, South Side, Rogers Park, etc.): ___________________________________ 2. Do you own your home or rent it?: ____________________________________________________ 3. What is your level of education, degrees earned, and where obtained?: ________________________ 4. What is your current occupation and employer, and how long have you worked there? ___________ 5. What other jobs and employers have you had during your adult working life? __________________ ____________________________________________________________________________________ 6. Please provide employment information for your spouse and others who live with you, and any adult children (even if not living with you). ____________________________________________________ 7. Have you ever managed or supervised and/or hired or fired other employees? If yes, please explain, and state whether you have taken part in an investigation of any employee for misconduct. If yes, did you ever have to fire someone for lying or covering up a lie? _______________________________________ ____________________________________________________________________________________ ____________________________________________________________________________________ 8. Have you ever been terminated from a job? If yes, please explain. Do you believe the termination was improper? How did the termination affect you? __________________________________________ ____________________________________________________________________________________ 9. Have you, a close friend, or a family member ever been involved in a lawsuit? If so, what was the nature of the lawsuit and your (his or her) involvement? _______________________________________ ____________________________________________________________________________________ 10. Have you, a close friend, or a family member ever been accused by a co-worker of harassment or discrimination in the workplace? Please explain. ____________________________________________ ____________________________________________________________________________________ 11. Have you, a close friend, or a family member ever complained of unfair employment practices either internally to the employer or through a government agency, such as the Illinois Department of Human Rights or the Equal Employment Opportunity Commission? If yes, what was the basis of the complaint? Were you satisfied with the outcome? _____________________________________________________ ____________________________________________________________________________________ 12. Have you been accused of misconduct or error at work that resulted in an investigation? If yes, please explain. Do you believe the investigation was fair and objective? Were you satisfied with the outcome? ____________________________________________________________________________________ Continued on back >>> CONFIDENTIAL 13. Do any of your past or present employers have anti-harassment/discrimination policies? If yes, what kind of training did you receive regarding these policies? ______________________________________ ____________________________________________________________________________________ 14. Have you ever worked in what you considered to be a male or female dominated workplace? If yes, please explain. Did you observe women or men being treated differently than each other in this environment? ________________________________________________________________________ 15. How often do you read, listen, or watch the news? Where do you get your news? _______________ 16. Have you ever commented in writing, such as online or in a letter to the editor, regarding news stories you feel strongly about? If yes, please give the most recent examples. ____________________________ ____________________________________________________________________________________ 17. Do you like watching TV shows or movies about police investigations or the legal system? _______ Which shows do you most enjoy? ________________________________________________________ 18. What civic groups or organizations do you belong to or participate in? ________________________ 19. Do you hold any religious, philosophical, moral or other beliefs that would make it difficult for you to judge the conduct of another person? ______________________________________________________ 20. Do you have any friends of family members who are or have ever been employed by a police department or law enforcement agency? If so, is there anything about your relationship with that person which would impact your ability to judge a police officer’s actions in this case? ____________________ ____________________________________________________________________________________ 21. Have you, a close friend, or a family member ever been arrested, charged with or convicted of a crime, or had any other encounter or involvement with a member of law enforcement other than a traffic offense? If yes, please state: (1) the individual’s relationship to you; (2) the nature of the circumstance; and (3) the disposition of any charge. Would this fact affect your ability to be fair to either side in the case? _______________________________________________________________________________ 22. If you answered yes to question 21, please state whether that experience left you with any feelings or opinions regarding law enforcement or police officers that could affect your ability to be fair to all parties in this case? If yes, you will be asked to explain during later questioning. _________________________ 23. This trial involves alleged claim of harassment, discrimination, and retaliation that includes testimony by both sides about the use of profanity and conduct of a sexual nature. Will this kind of testimony make you uncomfortable? ___________________________________________________________________ 24. Have you ever been in a situation where a supervisor was abusing their power? If yes, please explain. ____________________________________________________________________________________ 25. Have you even been in a situation where a subordinate or coworker made untrue statements about working conditions to try to protect their job, or to try to cover up the fact that they violated work policy? If yes, please explain. __________________________________________________________________ ____________________________________________________________________________________ 26. If plaintiff proves that defendants intentionally discriminated against her, would you have any reservations about awarding her punitive damages—i.e., damages intended to punish the defendants for their conduct? Conversely, if plaintiff does not prove that punishment is warranted, could you find for plaintiff without awarding such damages? __________________________________________________ 27. Are there any facts or circumstances you believe that the court or the parties should know that might affect your ability to serve as a fair and impartial juror in this case? ______________________________ CONFIDENTIAL

=== Estimated Patent Case Schedule ===

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS ESTIMATED PATENT CASE SCHEDULE Event Scheduled Time Total Time After Complaint Service of Complaint Answer or Other Response to Complaint Joint Scheduling Order (LPR 1.2) 7 days After Rule 26(f) conference Initial Disclosures of Both Parties (with no patent infringement counter-claim) / Commencement of Fact Discovery (LPR 2.1, LPR 1.3) 14 days After Answer or other Responsive Pleading Initial Infringement Contentions (LPR 2.2) 14 days After Initial Disclosures Initial Non-Infringement, Unenforceability and Invalidity Contentions (LPR 2.3) 14 days After Initial Infringement Contentions Initial Response To Invalidity Contentions (LPR 2.5) Final Infringement, Unenforceability and Invalidity Contentions (LPR 3.1) 14 days After Initial Non-infringement and Invalidity Contentions 21 weeks After Initial Infringement Contentions Final Non-infringement, Enforceability and Validity Contentions (LPR 3.2) 28 days After Final Infringement Contentions Exchange of Claim Terms Needing Construction and Proposed Construction (LPR 4.1) 14 days After Final Non-infringement Contentions Opening Claim Construction Brief (LPR 4.2(a 35 days After Exchange of Claims Terms 7 weeks (assumes 30-day extension) 9 weeks 11 weeks 13 weeks 15 weeks 32 weeks 36 weeks 38 weeks 43 weeks UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS ESTIMATED PATENT CASE SCHEDULE Event Scheduled Time Total Time After Complaint Responsive Claim Construction Brief (LPR 4.2(c 28 days After Opening Claim Construction Brief Reply Claim Construction Brief (LPR 4.2(d 14 days After Responsive Claim Construction Briefs Joint Claim Construction Chart (LPR 4.2(f 7 days After Reply Claim Construction Brief Claim Construction Hearing (LPR 4.3) 28 days After Reply Claim Construction Brief Claim Construction Ruling Six weeks (?) Close of Fact Discovery (LPR 1.3) 42 days After Claim Construction Ruling Expert Reports of Parties with Burden of Proof (LPR 5.1(b 21 days After Close of Fact Discovery Rebuttal Expert Reports (LPR 5.1) 35 days After Initial Expert Reports Completion of Expert Witness Depositions (LPR 5.2) 35 days After Rebuttal Expert Reports Final Day for Filing Dispositive Motions (LPR 6.1) 28 days After Close of Expert Discovery 47 weeks 49 weeks 50 weeks 53 weeks 59 weeks 65 weeks 68 weeks 73 weeks 78 weeks 82 weeks Case Ready for Trial 20 weeks After Filing Dispositive Motions 102 weeks

=== Pretrial Procedures in Civil Cases ===

PRETRIAL PROCEDURES FOR CIVIL CASES BEFORE JUDGE HUNT Unless otherwise ordered, the following procedures will govern pretrial proceedings in civil cases before Judge Hunt. Once discovery is complete and settlement discussions are exhausted, the Court will schedule a pretrial status hearing with lead counsel for the purpose of setting a firm trial date and deadlines for pretrial submissions. Parties are encouraged to continue discussing resolution of the case on their own and should feel free to contact my courtroom deputy at any time to request a referral to the assigned magistrate judge for a settlement conference. However, the trial date will not be continued unless the parties have settled the case or demonstrated extraordinary and unanticipated circumstances that constitute good cause. I. Schedule The following is a typical pretrial filing schedule. The parties should inform the Court at the pretrial status hearing if they require a different schedule. The Court will enter a trial scheduling order shortly after the pretrial status hearing. Event Motions in Limine Responses to Motions in Limine Final Pretrial Order Final Pretrial Conference Final Pretrial Conference Follow-Up (If Necessary) Date 3 Weeks Prior to Trial 2 Weeks Prior to Trial 2 Weeks Prior to Trial 1 Week Prior to Trial At Least 4 Days Before Trial II. Motions in Limine and Daubert Proceedings The Court discourages the filing of “boilerplate” motions in limine or motions that address matters not in dispute. The parties are directed to meet and confer on all motions in limine before filing them and determine which motions, if any, are unopposed and do not need to be filed. As explained below, unopposed motions in limine should be briefly described in the final pretrial order. Unless otherwise ordered, all opposed motions in limine must be filed in accordance with the schedule set by the Court. Parties filing multiple motions in limine should submit their initial motions and the supporting exhibits in one document for the Court. Responses to motions in limine should also be submitted in one document. Absent prior leave of Court, motions in limine (not including exhibits) are limited to a total of 20 pages per side (not per motion) and responses (not including exhibits) are likewise limited to a total of 20 pages per side. No replies are to be filed unless ordered by the Court. The above page limitations do not apply to motions challenging the admissibility of Federal Rule of Evidence 702 expert testimony pursuant to Daubert v. Merrell Dow Pharmaceuticals, Inc. Such Daubert motions should be filed separately and as soon as reasonably possible but no later 1 than two (2) months prior to the final pretrial conference. The parties may request at the pretrial status hearing that the Court also set a Daubert motion schedule. As with motions in limine, the parties are required to meet and confer before the filing of any Daubert motion to ensure that the opinions sought to be barred will be offered at trial. Seeking to bar an opinion the other side has no intention of soliciting is a waste of the parties’ and the Court’s time. The Court, upon request of a party or on its own, may conduct a Daubert hearing to allow the parties to examine the challenged expert in open court, in order to develop his or her qualifications and/or testimony for purposes of evaluating admissibility. The Court notes, however, that there is no requirement for Daubert hearings, and given the time commitments on the parties, the Court, and the expert witness, the Court encourages the parties to request a hearing only if they believe it is truly necessary to properly address the issues raised in a Daubert motion. If a party anticipates the need for a Daubert hearing, they are encouraged to notify the Court as soon as possible to ensure adequate time for scheduling the hearing prior to trial. III. Final Pretrial Order In all civil trials before Judge Hunt, the parties shall jointly prepare and file a final pretrial order. Plaintiff’s counsel has the responsibility to prepare the initial draft of the final pretrial order and must provide a draft to defendant’s counsel no later than twenty-one days before the date the final pretrial order is due. Defendant’s counsel must respond in writing to plaintiff’s draft by no later than fourteen days before the final pretrial order is due, including any objections, changes, and additions to plaintiff’s draft, as well as defendant’s portions of the draft pretrial order (e.g., defendant’s witness list, exhibit list, and objections to exhibits and deposition testimony listed by plaintiff). The parties must meet and confer by no later than seven days before the final pretrial order is due to discuss their respective drafts and to reach agreement to the extent possible. Any non-compliance with these requirements may subject a party and/or its counsel to imposition of sanctions. The final pretrial order must include the following information: 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). A list of the names of all people who will be sitting at counsel table, including parties, consultants, legal and technical assistants, etc. should also be provided. 3. Case Statement. Provide a concise agreed statement of the case (no more than one or two short paragraphs) to be read by the Court to the jury pool during jury selection. The statement must describe the nature of the case, claims (plus counterclaims and crossclaims, if any) and defenses. This is a neutral description of the case, with just enough information to introduce 2 the case to the jury and to ask potential jurors whether they happen to know anything about the case. Example: This is a breach for contract case. The plaintiff is a widget seller called Seller Company. The defendant is a widget purchaser called Purchaser Company. Seller Company alleges that Purchaser Company breached their contract by failing to pay for widgets. Purchaser Company denies Seller Company’s allegations. 4. Trial Length. State the estimated number of trial days, including jury selection, opening statements, and closing arguments. A typical trial day will begin around 9:00 a.m. and end around 4:30 p.m. with about an hour for a lunch break. Trial counsel must be present by 8:45 a.m. to discuss any preliminary matters. The Court will provide as much advance notice as possible of any changes to this schedule. The Court presumptively seats an 8-person jury, with all 8 jurors deliberating. The parties may recommend a different number of jurors be selected, subject to Federal Rule of Civil Procedure 48(a). Parties often underestimate the number of trial days necessary and/or fail to proceed efficiently once the trial begins. The Court strongly recommends that the parties carefully consider the time necessary for each part of trial and plan accordingly. Although the Court will not preclude any party from presenting their case, the Court sets aside only the trial days estimated by the parties and expects the trial to conclude within that time period absent exigent circumstances. 5. Stipulations and Uncontested Facts. In numbered paragraphs, state any stipulations and uncontested facts. No later than 10 business days before the pretrial order is due, the parties much 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 parties must propose a method for presenting the stipulated facts to the jury (e.g., read into record, included in final jury instructions, etc.) 6. Witness Description Lists. Each party shall provide a list of witnesses, including expert witnesses, divided into (a) witnesses who will be called at trial; (b) witnesses who may be called to testify at trial; and (c) 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 including a brief summary of the legal and/or factual basis for presenting the testimony in that manner, as opposed to in-person). For each witness, provide a concise (2 or 3 sentences) description of the witness and the witness’ role in the case and estimate the amount of total time (including direct, cross, and redirect) required for each witness. Witnesses who are not on the lists are barred from testifying unless the proponent shows good cause for the failure to disclose the witness. The names of witnesses on the lists will be read to the jury during jury selection to ensure that potential jurors do not personally know any witnesses. 7. 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 due date. The opposing party must serve objections to designations (including a concise basis for the objection, like the Exhibit Chart discussed below) 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 3 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 parties should include any objected-to portions of the designated deposition testimony in the exhibit binders submitted to the Court per the instructions below. Unless the parties agree otherwise, one of Judge Hunt’s law clerks will be made available to read the deposition testimony into the record. By the morning of the trial day during which the deposition testimony will be read, the party offering the testimony must provide the Court with two copies of the transcript with designated portions highlighted. 8. Exhibits and Exhibit Charts. The parties must submit exhibit charts, one for plaintiff’s exhibits and another for defendant’s exhibits, which states the following: (a) the exhibit number; (b) the date of the document or exhibit, if applicable; (c) a brief, neutral description of the exhibit; (d) a concise statement of the exhibit’s relevance; (e) whether there is an objection to admission of the exhibit, and if so, a concise statement of the basis for the objection; and (f) a concise response to the objection, if any. The chart’s format shall be substantially similar to the example below (landscape orientation is encouraged). No. PX1/DX1 02/15/06 Date Description Relevance 2005 Performance Review Proves record of satisfactory job performance Objection R. 402 relevance; R. 403 confusion. Plaintiff fired in 2011. Response Past performance is relevant to affirmative defense and will not lead to confusion. In addition to substantive exhibits and any 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). Any substantive exhibit not objected to shall be deemed admissible into evidence by operation of the Final Pretrial Order without any need for foundation testimony unless the exhibit is not referred to during trial testimony or otherwise published to the jury. There is no need to list every conceivable exhibit that can possibly be used, and parties are discouraged from over- designating exhibits, because we will examine exhibits one-by-one during the final pretrial conference, and plainly inadmissible exhibits, or exhibits that parties will not likely use, will needlessly consume time. Therefore, the parties should submit a list of trial exhibits they definitely intend to introduce. At the same time, the parties must limit objections to only good-faith objections. Frivolous and boilerplate objections will waste time, because in preparation for the pretrial conference, the Court will review, as much as possible, the exhibits and the objections— routine objections that will likely be resolved at trial (e.g., foundation) need not be included. The parties shall stipulate to the authenticity of exhibits whenever possible. 4 During the trial, for clarity for the jury and the record, the offering party must still move to admit the exhibit into evidence before publishing it to the jury. The Court will ask whether there is any “further” objection so that any pretrial objection is preserved. 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 earlier produced to the opposing side during discovery. Within one business day of filing the final pretrial order, the parties must submit to chambers one set of exhibit binders containing copies of all objected-to substantive exhibits. In addition, the parties must upload electronic copies of all exhibits anticipated to be used at trial through a link that will be provided by chambers. Exhibits that will be used only for impeachment purposes or to refresh memories need not be included. After the final pretrial conference and rulings on exhibits, unless otherwise ordered by the Court, by no later than five business days before trial, the parties must submit two sets of exhibit binders. In addition, the parties must upload any exhibits not previously uploaded to the link provided by chambers. All paper exhibits should be printed double-sided and placed in three ring binders with appropriate cover sheets, exhibits lists, and number tabs. All exhibits should be numbered (e.g., PX1, DX1, etc.) All electronic exhibits should be saved in standard file formats, named consistent with the exhibit number and brief description (e.g., PX1 Contract.pdf) and be saved “read-only” and/or locked for editing. Any exhibit in .pdf format should undergo Optical Character Recognition (OCR) and be text-searchable. If the parties anticipate a voluminous number of final trial exhibits, they should contact my courtroom deputy before submitting them. The Court wants to avoid the needless copying of hundreds or thousands of documents in multiple boxes where electronic media may suffice. IMPORTANT NOTE ON PRESENTING EXHIBITS DURING TRIAL Judge Hunt’s courtroom (1460) has evidence presentation equipment allowing exhibits (including video and audio files) to be projected and displayed to witnesses, the Court, counsel, and the jury. The jurors have individual screens in the juror box. The Court expects trial counsel to use this system. As early as possible prior to trial (not less than three weeks), counsel must contact Alexander Zeier, the Courtroom Technology Administrator, to schedule a training session. Mr. Zeier can be reached at (312) 435-6045. Counsel must certify in the final pretrial order that they have completed the required training session. After the close of evidence, the parties must be prepared to meet and confer and each provide the Court with exhibit binders for Plaintiff and Defendant and a USB storage device containing all admitted exhibits. The parties will be required to certify on the record that they have reviewed and agree that the binders and USB storage device contain the admitted exhibits. The jury will have access to electronic copies of the exhibits through a “blank” laptop (no internet connection or unnecessary applications) connected to a large external screen/monitor. 5 9. 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. 10. Motions in Limine. As noted above, motions in limine will be filed separately. Each party must provide a list that very briefly 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 and Jury Questionnaire. Judge Hunt will always ask routine biographical questions (a typical list is available on her website). 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 12 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 in order to attempt to agree on as many jury instructions and verdict forms as possible and shall submit a single set of instructions and forms to the Court. Where applicable, the Court uses the Seventh Circuit’s Pattern Instructions, bearing in mind that statutory and binding case law govern over the pattern instructions. If the parties wish to modify an applicable Seventh Circuit Pattern Instruction, the party proposing the modification must submit a comparison document to the Court showing the modification to the pattern instruction. If Illinois law provides the applicable standards for a particular claim, the Illinois Pattern Instructions should be used for the substantive elements of the particular cause of action. The proposed jury instructions must state, on an instruction-by-instruction basis, the following information: (1) the proponent of the instruction, (2) the legal authority for the instruction, and (3) 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. 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. Once the instructions are finalized, one of the parties should prepare a table of contents for the instructions. 13. Trial Briefs. Judge Hunt does not require trial briefs in jury trials. Parties who wish to file a trial brief must seek leave of court to do so. For bench trials, the Court may require separate trial briefs on a case-by-case basis. 14. Signature. The Pretrial Order must be signed (electronically) by counsel for each party. The Final Pretrial Order must be e-mailed to [email protected] in a format compatible with Microsoft Word, with two courtesy copies (in three-ring binders and tabs) delivered to my courtroom deputy’s office (Room 1428) within one day after filing. The 6 Final Pretrial Order must also be filed on the docket by selecting “Other Filings” and then “Other Documents” and choosing the Proposed Pretrial Order event in CM/ECF. IV. Final Pretrial Conference The purpose of the final pretrial conference will be to provide guidance to the parties in their final preparations for trial, to avoid surprises, and to simplify the issues for trial. At the conference, Judge Hunt 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 must attend the conference and should be fully prepared and with authority to discuss all aspects of the case, including all previous efforts to settle the case and whether further discussions are possible. The Court will endeavor to cover all pretrial matters in a single hearing but will continue the conference as necessary depending on the amount and complexity of pretrial matters. Dated: February 10, 2025 ENTERED: ________________________________ LASHONDA A. HUNT United States District Judge 7

=== Pretrial Procedures in Criminal Cases ===

PRETRIAL PROCEDURES FOR CRIMINAL CASES BEFORE JUDGE HUNT Unless otherwise ordered, the following procedures will govern pretrial proceedings in criminal cases before Judge Hunt. I. Schedule The following is a typical pretrial filing schedule. Once set, trial dates are firm and will generally be continued absent extraordinary and unanticipated circumstances set forth in a timely- filed and properly-noticed motion. Event Motions in Limine Responses to Motions in Limine Final Pretrial Order Final Pretrial Conference II. Motions in Limine Date 4 Weeks Before Trial 3 Weeks Before Trial 2 Weeks Before Trial 1 Week Before Trial The parties are directed to meet and confer on all motions in limine before filing them. As explained below, unopposed motions in limine should be briefly described in the final pretrial order. All opposed motions in limine must be filed according to the schedule set by the Court. Parties filing multiple motions in limine should submit their initial motions and the supporting exhibits in one document for the Court. Responses to motions in limine should also be submitted in one document. Absent prior leave of Court, motions in limine (not including exhibits) are limited to a total of 20 pages per side (not per motion) and responses (not including exhibits) are likewise limited to a total of 20 pages per side. No replies are to be filed unless ordered by the Court. III. Final Pretrial Order In all criminal trials before Judge Hunt, the parties shall jointly prepare and file a final pretrial order containing the following: 1. Trial Attorneys. List all attorneys trying the case, as well as contact information (business address, telephone number, and e-mail address). 2. Case Statement. Provide a concise joint statement of the case, which the Court will read to the jury pool during voir dire. After reading the case statement, Judge Hunt may also read the third paragraph of Pattern Instruction 1.02: “The indictment is simply the formal way of telling the defendant what crimes he is accused of committing. It is not evidence that the defendant is guilty. It does not even raise a suspicion of guilt.” 1 3. Trial Length. State the estimated number of trial days, including jury selection and deliberation, premised on six-hour trial-testimony days (the six hours already accounts for lunch and breaks). Be prepared to provide estimated sub-totals for the government’s case and the defense case (if any is anticipated) and to propose time limits for opening statements and closing arguments at the final pretrial conference. A typical trial day will begin around 9:00 a.m. and end around 4:30 p.m. with about an hour for a lunch break. Trial counsel must be present by 8:45 a.m. to discuss any preliminary matters. The Court will provide as much advance notice as possible of any changes to this schedule. 4. Stipulations and Uncontested Facts. In numbered paragraphs, set forth any stipulations and uncontested facts. 5. Witness Lists. Each party shall provide a list of witnesses, including expert witnesses, divided into (a) witnesses who will be called at trial; (b) witnesses who may be called to testify at trial; and (c) 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 including a brief summary of the legal and/or factual basis for presenting the testimony in that manner, as opposed to in-person). For each witness, provide a concise (2 or 3 sentences) description of the witness and the witness’ role in the case. The names of witnesses on the lists will be read to the jury during jury selection to ensure that potential jurors do not personally know any witnesses. 6. Exhibit Lists. The parties must submit exhibit charts, one for the Government’s exhibits and another for defendant’s exhibits, which states the following: (a) the exhibit number; (b) the date of the document or exhibit; (c) a brief, neutral description of the exhibit; (d) a concise statement of the exhibit’s relevance; (e) whether there is an objection to admission of the exhibit, and if so, a concise statement of the basis for the objection; and (f) a concise response to the objection, if any. The chart’s format shall be substantially similar to the example below (landscape orientation is encouraged). No. PX1/DX1 02/15/06 Date Description Relevance 2005 Performance Review Proves record of satisfactory job performance Objection R. 402 relevance; R. 403 confusion. Plaintiff fired in 2011. Response Past performance is relevant to affirmative defense and will not lead to confusion. Any substantive exhibit not objected to shall be deemed admissible into evidence by operation of the Final Pretrial Order without any need for foundation testimony unless the exhibit is not referred to during trial testimony or otherwise published to the jury. During the trial, for clarity for the jury and the record, the offering party must still move to admit the exhibit into evidence before publishing it to the jury. The Court will ask whether there is any “further” objection so that any pretrial objection is preserved. 2 Note: There is no need to list every conceivable exhibit that can possibly be used. The parties should submit a list of trial exhibits they definitely intend to introduce. 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 earlier produced to the opposing side during discovery. Within one business day of filing the final pretrial order, the parties must submit to chambers one exhibit binder containing copies of all objected-to substantive exhibits. In addition, the parties must use the link that will be provided by the Court to upload all proposed exhibits (whether objected to or not). Exhibits that will be used only for impeachment purposes or to refresh memories need not be included. After the final pretrial conference and rulings on exhibits, no later than business days before trial, the parties must submit two sets of exhibit binders containing the final, pre- marked exhibits along with exhibit lists. In addition, the parties must upload any exhibits not previously uploaded to the link provided by chambers. All paper exhibits should be printed double-sided and placed in three ring binders with appropriate cover sheets, exhibits lists, and number tabs. All exhibits should be numbered (e.g., PX1, DX1, etc.) All electronic exhibits should be saved in standard file formats, named consistent with the exhibit number and brief description (e.g., PX1 Contract.pdf) and be saved “read-only” and/or locked for editing. Any exhibit in .pdf format should undergo Optical Character Recognition (OCR) and be text-searchable. If the parties anticipate a voluminous number of final trial exhibits, they should contact my courtroom deputy before submitting them. The Court wants to avoid the needless copying of hundreds or thousands of documents in multiple boxes where electronic media may suffice. IMPORTANT NOTE ON PRESENTING EXHIBITS DURING TRIAL Judge Hunt’s courtroom (1460) has evidence presentation equipment allowing exhibits (including video and audio files) to be projected and displayed to witnesses, the Court, counsel, and the jury. The jurors have individual screens in the juror box. The Court expects trial counsel to use this system. As early as possible prior to trial (not less than three weeks), counsel must contact Alexander Zeier, the Courtroom Technology Administrator, to schedule a training session. Mr. Zeier can be reached at (312) 435-6045. After the close of evidence, the parties will be expected to meet and confer and jointly provide the Court with exhibit binders and a USB storage device containing all admitted exhibits. The parties will be required to certify on the record that they have reviewed and agree that the binders and USB storage device contain the admitted exhibits. The jury will have access to electronic copies of the exhibits through a “blank” laptop (no internet connection or unnecessary applications) connected to a large external screen/monitor. 7. Motions in Limine. As noted above, motions in limine will be filed separately. Each party must provide a list that very briefly summarizes its motions in limine and indicates 3 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. 8. Voir Dire Questions and Jury Questionnaire. To the extent possible, the Court prefers that most questions asked of potential jurors be included in a written questionnaire (of no more than 3 pages) as it encourages reflection and candor. Judge Hunt will always ask routine biographical questions (a typical list is available on her website). Any additional questions sought by the parties must be listed in the final 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 12 proposed disputed questions, unless a motion is filed before the pretrial conference that explains good cause for proposing more than the limit. 9. Jury Instructions/Verdict Forms. The parties are instructed to meet and attempt to agree on jury instructions and a verdict form. The Court uses the Seventh Circuit’s Pattern Instructions, bearing in mind that statutory and binding case law govern over the pattern instructions. If the parties wish to modify an applicable Seventh Circuit Pattern Instruction, the party proposing the modification must submit a comparison document to the Court showing the modification to the pattern instruction. The parties should concentrate their efforts on the substantive jury instructions related to the merits. The parties must submit all agreed and proposed jury instructions with the final pretrial order. Each proposed instruction must indicate the proponent of the instruction and whether the instruction is agreed or disputed. The bottom of each instruction must identify the supporting legal authority. If an instruction is disputed, the grounds for the objection (and any proposed modification or alternate instruction) must be concisely stated on the same page immediately following the disputed instruction. The party proposing the instruction may then state concisely the reasons supporting the instruction as proposed. The same instructions apply to proposed verdict forms. 10. Submission and Filing. The Final Pretrial Order must be e-mailed to [email protected] in a format compatible with Microsoft Word, with two courtesy copies (in three-ring binders and tabs) delivered to my courtroom deputy’s office (Room 1428) within one business day after filing. The Final Pretrial Order must also be filed on the docket by selecting “Other Filings” and then “Other Documents” and choosing the Proposed Pretrial Order event in CM/ECF. IV. Final Pretrial Conference The purpose of the final pretrial conference will be to avoid surprises and to simplify trial. At the conference, Judge Hunt will address any pending motions in limine, objections to witnesses and exhibits, and contested jury instructions, and will discuss trial procedures and scheduling matters. Lead trial counsel fully prepared and with authority to discuss all aspects of the case must attend. 4 The Court will endeavor to cover all pretrial matters in a single hearing but will continue the conference as necessary depending on the amount and complexity of pretrial matters. Dated: February 10, 2025 ENTERED: ________________________________ LASHONDA A. HUNT United States District Judge 5

=== Law Clerk Hiring Information ===

Judge Hunt Hiring Information Judge Hunt is not accepting applications for law clerks or externs at this time. All postings for law clerk positions will be made through OSCAR. All law clerk application materials must be submitted through OSCAR. Please do not send any application materials to chambers as they will not be accepted.