joint initial status report; here; here

=== joint initial status report ===

MAGISTRATE JUDGE KARYN L. BASS EHLER 219 South Dearborn Street Chicago, Illinois STANDING ORDER FOR INITIAL JOINT STATUS REPORTS This case has been assigned to Magistrate Judge Bass Ehler. In order to make the initial status hearing as productive as possible, the parties are required to file a joint status report at least three business days before the initial status hearing unless otherwise ordered by the Court. Counsel are encouraged to meet in person or by videoconference to discuss the joint status report. Trading dueling draft reports by email without any other communication is discouraged. The joint status report shall contain the following information and be no more than five pages: 1. Description of Claims and Relief Sought. a. Describe the claims and defenses raised by the pleadings. Make sure to include 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. A date to issue written discovery requests. c. 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. The parties need not include expert discovery dates. The Court will set expert discovery deadlines at the conclusion of fact discovery. d. Any existing pretrial or trial dates. 4. Consideration of Issues Concerning Electronically Stored Information (“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. Describe the status of any settlement discussions. b. State whether the parties believe a settlement conference would be productive at this time, and if not, briefly explain why. c. If no settlement discussions have taken place, state why that is so, and what needs to occur before settlement discussions would be appropriate and potentially fruitful (i.e., ruling(s) on pending motion(s), completion of particular discovery, focused damages discovery or analysis, etc.). 6. Magistrate Judge Consent. State whether all parties will consent to have Judge Bass Ehler 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. Note: if all parties do not consent, then please state simply that not all parties consent pursuant to 28 U.S.C. § 636(c); do not identify any particular party by name, whether that party consents or not, in a mixed-consent situation. See Federal Rule of Civil Procedure 73(b)(1). 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. 9. Other Matters. State any other matters that should be brought to the Court’s attention for scheduling purposes. SO ORDERED. ______________________________ Karyn L. Bass Ehler United States Magistrate Judge Dated: May 7, 2026 2

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MAGISTRATE JUDGE KARYN L. BASS EHLER 219 South Dearborn Street Courtroom 1838 Chambers 1828 Chicago, Illinois 60604 (312) 435-5707 STANDING ORDER FOR SETTLEMENT CONFERENCES Judge Bass Ehler believes the parties should fully explore and consider settlement at the earliest opportunity. Early consideration of settlement can prevent unnecessary litigation, allowing the parties to avoid the substantial cost, distraction, and stress inherent in the litigation process. Even for those cases that cannot be resolved through settlement, early consideration of settlement allows the parties to better understand the factual and legal nature of their dispute and streamline the issues to be litigated. Consideration of settlement is a serious matter that requires thorough preparation before the settlement conference. Set forth below are the procedures that Judge Bass Ehler asks the parties to follow and the procedures she will employ in conducting the conference. A. Before the Settlement Conference: Status Hearing and Exchange of Settlement Letters The Court generally will hold an initial status hearing or conference call to set dates for the settlement conference and the exchange of settlement letters. Counsel primarily responsible for representing the parties during the settlement conference must participate in this status hearing or call. Counsel will be expected to identify the individuals who will participate (i.e., not just available via phone) in the settlement conference with settlement authority on behalf of their respective clients, including any insurers, consistent with the requirements of this Standing Order. If a party is claiming an inability or hindrance to pay a judgment, counsel must raise it at this initial hearing and provide verification of that assertion prior to any settlement conference. Consistent with the schedule that is set by the Court, Plaintiff’s counsel must submit a settlement letter to Defendant’s counsel and the Court, describing the nature of the action, the theory of liability, Plaintiff’s demand and its reasoned basis, an itemization of damages, and 1 citation to legal authority supporting the claimed damages. Plaintiff is expected to include a demand that is not what Plaintiff expects to win at trial, but rather a number that takes into account the risk of loss, cost, and time savings from settling before trial. Accordingly, for the purpose of settlement, any demand and/or itemization for punitive damages should not be included in Plaintiff’s demand. For cases involving personal, physical, emotional distress, or similar injuries, Plaintiff should include a list of comparable jury verdicts and/or settlements to support their demand amount. Additionally, Plaintiff should provide a demand that is updated from any prior negotiations, i.e., not just stand on a prior position. Defendant’s counsel must submit a settlement letter to Plaintiff’s counsel and the Court in response to Plaintiff’s demand, describing the theory of defense and Defendant’s offer, including an explanation for it. Defendant is expected to offer a number that does not assume that there will be no liability. As with Plaintiff, Defendant should provide an offer that is updated from any prior negotiations, i.e., not just stand on a prior position. The parties must include in their settlement letters the names of all individuals who will be attending the settlement conference, along with their role. Defendant also must include whether any insurance representative(s) will be involved, and if so, confirm their attendance. Settlement letters should be no more than 7 pages each. All counsel are required to provide the full set of the settlement letters to their clients, who must read them prior to the conference. On occasion, this exchange process itself will lead to a settlement or at least some further progress. Indeed, the parties should have multiple discussions about settlement between the date on which the Court sets the settlement conference and the actual date of the conference. The parties should further establish that each party has the necessary information and documents to engage in meaningful settlement discussions during the conference. In preparing their settlement letters, the parties are encouraged to consider whether there are any areas of agreement; whether there are any creative solutions (e.g., licensing agreement, allowing the use of a trademark, re-employment, trainings, payment plan, etc.); and whether there are any outstanding lien holders, particularly Worker’s Compensation, Medicare, or other medical liens (and in what amount). In some circumstances, after reviewing the settlement letters, the Court may set a telephonic status hearing before the settlement conference to further discuss the settlement positions. The Court may also separately contact counsel for one or both parties and will ask the other party for permission before this happens. Upon submission to the other side, the parties also are required to submit their settlement letters to the Court by e-mail to [email protected], Settlement letters are not to be filed with the Clerk’s Office, will not be made part of the Court’s record, and will not be admissible as evidence. 2 B. Persons Required to Attend the Settlement Conference Individuals with ultimate settlement authority on behalf of the parties must personally participate in the conference, by whatever format the parties and the Court have decided upon (video or in person). If a party chooses to go forward with the settlement conference, it must come with authority to negotiate beyond the offer and demand in the settlement letters, i.e., the party cannot show up to the settlement conference and refuse to move from the position outlined in its settlement letter. An insured party shall appear with a representative of the insurer who is authorized to negotiate and who has full authority to settle the case. If a party is an individual, that individual must personally attend (unless fully indemnified by another party and/or otherwise agreed to by all parties and the Court). If a party is an uninsured corporation or governmental entity, a representative of that corporation or governmental entity with authorization to negotiate and settle the case must personally attend, understandably subject to later Board approval for certain governmental entities. Failure to comply with these provisions may result in sanctions, such as requiring the party in violation to reimburse the opposing party’s attorney’s fees and costs related to preparing for and appearing at the settlement conference. If a party has to “make a call” to get more settlement authority, that constitutes failure to comply with these provisions. In other words, whoever has the final say on settlement authority must actually participate in the settlement conference itself, either in person or by video. C. Conference Format In an effort to make the process as efficient and productive as possible, the Court will discuss with the parties in advance their preference for the conference format, whether it be by video or in person. Both by video and in person, the Court will hold a joint session with short opening remarks and questions by the Court, generally with no opening presentations by the parties. The Court encourages law firms to consider whether other members of their firm would benefit from observing the settlement conference, even if they are not actively participating. This short, joint session will be followed by each party having private caucuses with the Court. The Court expects both the lawyers and the party representatives to be fully prepared to participate openly during these discussions. Statements made by any party during the settlement conference are not to be used in discovery and will not be admissible at trial. D. Prepare for Success If the parties are successful in reaching an agreement, they may be required to detail on the record all material terms of the agreement at the conclusion of the conference, so that the material terms are binding on the parties, even though a more detailed written settlement agreement will follow. 3 E. Cancellation or Rescheduling of the Conference If the parties must reschedule, have concluded that a settlement conference is not necessary or helpful at this time, or have otherwise resolved the case, they should inform Judge Bass Ehler’s Courtroom Deputy as soon as possible. Counsel are cautioned that failure to attend a confirmed settlement conference may result in the imposition of sanctions against them. F. Prohibition on Photographs, Recordings, and Rebroadcasts The parties are reminded that all communications with the Court on settlement, including the settlement conferences, ex parte calls, and hearings, whether by video, phone or in person, cannot be photographed, recorded, or re-broadcast, as with other court proceedings. Any violation of these prohibitions may result in sanctions deemed necessary by the Court. ____________________________________ Karyn L. Bass Ehler United States Magistrate Judge Dated: May 18, 2026 4

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MAGISTRATE JUDGE KARYN L. BASS EHLER 219 South Dearborn Street Courtroom 1386 Chambers 1366 Chicago, Illinois 60604 (312) 435-5707 STANDING ORDER FOR PREPARATION OF PROPOSED FINAL PRETRIAL ORDER FOR CIVIL CONSENT CASES BEFORE JUDGE KARYN L. BASS EHLER A final pretrial conference will be held prior to trial. The purpose of this conference is to avoid surprises and to simplify the trial. At the conference, Judge Bass Ehler 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. In preparation for the final pretrial conference, the parties shall jointly prepare and submit a Proposed Final Pretrial Order containing to [email protected] in Word format with all counsel included as cc: recipients. The subject line of the email should include the case number, case name, and title of the submission. The Proposed Final Pretrial Order (excluding copies of exhibits and deposition transcripts) must also be filed on the docket in CM/ECF. In addition, two courtesy copies organized in a manner that is conducive to facilitating the Court’s review of the materials must be delivered to Chambers. The Court will set a date for filing the Proposed Final Pretrial Order. items by email the below listed Contents of the Proposed Final Pretrial Order 1. Individuals present for trial. A list of all attorneys trying the case, including their business and cell phone numbers and email addresses. A list of the names of all paralegals, consultants, and parties who will be sitting at counsel table should also be provided. 2. Jurisdiction. A concise statement of the basis for federal subject matter jurisdiction, and if jurisdiction is disputed, the nature and basis of the dispute. 1 3. Proposed Statement of the Case. A concise joint statement of the claim(s) of the plaintiff(s), defense(s) of defendant(s), and all counterclaims and cross claims and the defenses to them. In a jury trial, this statement will be read to the jury during voir dire. 4. Relief sought. An itemization of the damages and other relief sought, and a concise explanation of the evidentiary basis for each itemization. 5. Contested Issues. A concise, numbered list of the contested issues of fact and/or law. 6. Witnesses. Separate lists for plaintiff(s) and defendant(s) of the names of all witnesses (including expert witnesses) and their role in the case: (a) who will be called; (b) who may be called; and (c) whose deposition or other prior testimony will be used. In a jury trial, this list will be read to the jury during voir dire. Other than witnesses called solely for impeachment, witnesses not listed in the Pretrial Order will be precluded from testifying absent a showing of good cause for the failure to disclose the witness or if all parties consent. a. Depositions. For any witness testimony proposed to be offered by deposition, the parties shall jointly submit to Chambers by email the deposition transcript(s) with the proposed designations from each party highlighted in different colors and shall also deliver two courtesy copies of the highlighted transcript(s) to Chambers. The deposition transcripts should not be filed on CM/ECF with the Proposed Pretrial Order. The parties shall also jointly submit to Chambers by email a joint chart containing any objections to designated testimony by page and line number and the basis for the objection, as well as the opposing party’s response to such objections. The basis for an objection and the response shall be stated as succinctly as possible with appropriate citations to evidentiary rules or case law. Objections not made in the joint chart will be deemed waived absent a showing of good cause. 7. Exhibits. Each party shall submit to Chambers by email with all counsel included as cc: recipients a chart of all exhibits the party may introduce at trial, as well as any demonstrative exhibits, including a trial exhibit number, the date of the exhibit, a brief description of the exhibit, a concise statement of the basis for any objection to admission of the exhibit, and a concise statement of the asserted basis for admissibility. Exhibits that will be used for impeachment purposes only need not be included in the exhibit list. The parties shall stipulate to the authenticity of exhibits whenever possible. Objections not made in the Pretrial Order will be deemed waived. The parties shall also submit two courtesy copies of the exhibits to Chambers. The exhibits should not be filed on CM/ECF with the Proposed Pretrial Order. 8. Proposed voir dire questions. For a jury trial, Judge Bass Ehler often uses a written questionnaire as the initial basis for voir dire. Counsel will be given copies of the completed questionnaires before jury selection begins. In addition to those questions, any proposed voir dire special to the case as well as any objection to that question should be included in the Proposed Final Pretrial Order. Each side is limited to 10 proposed disputed questions. 2 A motion must be filed before the pretrial conference to show good cause for additional proposed questions beyond that limit. 9. Proposed jury instructions / verdict forms. For a jury trial, the parties are directed to meet and agree on proposed jury instructions and verdict forms to the maximum extent possible and to file the jury instructions and verdict forms with the Proposed Final Pretrial Order, noting any objections as needed. The parties should also jointly submit proposed jury instructions and verdict forms to Chambers by email with all counsel included as cc: recipients. The parties should concentrate their efforts on the substantive jury instructions related to the merits of the case. The proposed jury instructions must state, on an instruction-by-instruction basis, the proponent of the instruction, the legal authority for the instruction, any objection to the instruction, the basis for the objection, and any proposed modification or alternative instruction. The same principles apply to proposed verdict forms. Judge Bass Ehler refers to the Seventh Circuit Pattern Jury Instructions, and where applicable those instructions should be used absent a good reason for not doing so. 10. Stipulations. A listing of any stipulations agreed to by the parties, including stipulations regarding the presentation or admissibility of evidence. 11. Settlement status. A statement summarizing the current status of settlement negotiations. Motions in limine The Court will set a separate schedule for the filing of motions in limine when it sets dates for the filing of the Proposed Final Pretrial Order. Judge Bass Ehler discourages the filing of “boilerplate” motions in limine or motions that address matters not in dispute. The parties must meet and confer on all motions in limine before filing any such motion. Absent prior leave of court, each side is limited to a total of five (5) motions in limine. Date: 5/28/26 Karyn L. Bass Ehler United States Magistrate Judge 3