Order Setting Initial Status Report; Agreed Scheduling Order; In; Final Pretrial Order; Standing Order in Social Security Cases

=== Order Setting Initial Status Report ===

MAGISTRATE JUDGE MARIA VALDEZ 219 S. DEARBORN ST., COURTROOM 1041 CHICAGO, IL 60604 TELEPHONE: 312-435-5690 x3 FAX: 312-554-8941 INITIAL STATUS REPORT Upon assignment of cases to Magistrate Judge Maria Valdez by consent or referral, a status report date may be set by means of a minute order. The joint status report shall generally not exceed three pages and shall contain the following information: CONSENT CASES: 1. 2. 3. 4. 5. A brief summary of the claims asserted in the complaint and any counterclaim or third-party complaint. A brief statement of the relief sought, including an itemization of damages. The status of any pending motions. Any current dates for discovery cut-off, pretrial order or trial. If none have been set, attach to the initial status report a Rule 16(b) scheduling order. A description of the discovery that has been completed, including the specific number of depositions that have been taken, and a description of the future discovery that is contemplated. 6. Whether a jury has been demanded. 7. The status of settlement discussions, if any. The caption in consent cases should list only the name of the magistrate judge, not the name of the district judge formerly assigned to the case. REFERRAL CASES: 1. 2. 3. 4. 5. A brief summary of the claims asserted in the complaint and any counterclaim or third-party complaint. A brief statement of the relief sought, including an itemization of damages. A brief description of the matter referred to the magistrate judge or alternatively, attach a copy of the referral order. The status of any briefing on the matters referred. If the case has been referred for discovery matters, a description of the discovery that has been completed and the future discovery contemplated, including identifying: (a) the depositions that have been taken; (b) the depositions that have been scheduled and the dates set; and (c) any other discovery contemplated. 6. Whether the parties will consent to trial before a magistrate judge. 7. Any dates or deadlines established by the district judge for discovery cut-off, submission of pretrial order or trial. If no discovery dates have been set, attach to the initial status report a completed Rule 16(b) scheduling order. The status of settlement negotiations, if any. In referral cases, list both the district judge and the magistrate judge in the caption and circle the name of the judge for whom the filing is intended. 8. 9. ENTERED: 8/28/2024 ___________________________ HON. MARIA VALDEZ United States Magistrate Judge

=== Agreed Scheduling Order ===

Rule 16b Scheduling Order United States District Court For The Northern District of Illinois Eastern Division Plaintiff(s), v. Defendant(s). Case No.: Magistrate Judge Maria Valdez PROPOSED SCHEDULING ORDER 1. Pre-Discovery Conference and Disclosures A. B. The parties advise the Court that they have / have not (circle one) had a conference pursuant to Rule 26(f). The parties affirm their understanding of the requirements under Rule 26(f) including the requirement to discuss any discovery issues about electronically stored information (ESI) that may pertain to this case. The parties advise the Court that initial disclosures have / have not (circle one) been made pursuant to Rule 26(a)(1). If they have not been made all disclosures required by Rule 26(a)(1) shall be made on or before ________________________. 2. Discovery The following time limits and deadlines shall be applicable: A. B. C. D. E. F. G. Any amendments to pleadings or actions to join other parties shall be filed on or before _____________. (It is recommended that any joinder or amendments be made early in the discovery process so as to avoid the need to prolong discovery as to new parties or new issues.) All written discovery shall be propounded no later than 45 days before the close of fact discovery, unless the requesting party has obtained prior leave of court. The cutoff of fact discovery is ______________. Any party with the burden of proof shall disclose its expert testimony pursuant to Rule 26(a)(2) on or before ______________. The parties may depose the other side's expert disclosed pursuant to Rule 26(a)(2) at any time prior to ___________. The parties shall disclose any rebuttal expert at any time prior to ______________. The parties shall have until ______________ to depose the opposing party's rebuttal expert. 3. Prospects of Settlement A. Counsel are to discuss settlement at the scheduling conference and to report on the status of settlement discussions. B. The parties are to report on the earliest date on which they would be prepared to attend a settlement conference (with clients) with the Court and what discovery, if any, they believe may be needed to meaningfully assess settlement. [Sections 4 through 6 to be filled out only if the parties have consented to have the case tried before Judge Valdez] 4. A. B. Motions Any dispositive motions to be filed on or before ______________. (Ordinarily this date will be 30 days following the close of fact discovery.) Any Daubert motions to be filed on or before _______________. (Ordinarily this date will be 30 days following the close of expert discovery.) 5. A. Final Pretrial Order and Conference The final pretrial order shall be filed on or before ______________. B. The final pretrial conference will be held on ______________ at ________.m. 6. Trial The case will be ready for trial by ______________ and is expected to take ______trial days. Dated: ___________________ ENTERED: ___________________________ HON. MARIA VALDEZ United States Magistrate Judge

=== Standing Order in Social Security Cases ===

MAGISTRATE JUDGE MARIA VALDEZ 219 South Dearborn Street Chicago, IL 60604 Courtroom 1041 Chambers 1058 Web Site: http://www.ilnd.uscourts.gov Courtroom Deputy - Lisa Provine Room 1036 (312) 408-5135 Telephone: (312) 435-5690 Fax Number: (312) 554-8941 STANDING ORDER IN SOCIAL SECURITY CASES For cases coming before the Court for review of the decision of the Commissioner of Social Security denying benefits pursuant to 42 U.S.C. § 405(g), the Court hereby adopts the following procedures: A. BRIEFING SCHEDULE If a briefing schedule has not already been set by the District Judge, one will be set in a minute order after the case is reassigned. The opening brief will generally be due within 60 days of the filing of the administrative record; the responsive brief will be due 45 days thereafter; and the reply, if any, will be due 14 days thereafter. B. BRIEFING GUIDELINES 1. Plaintiff’s Opening Brief. In preparing a Social Security brief, Plaintiff should consider the following: a. b. Include only those facts that relate to the issues presented. It is not necessary to include Plaintiff’s entire medical history if it is not relevant to the issues raised. It is not necessary to spend several pages repeating the well- recognized standards for the five-part test. Cite cases that you believe accurately state the legal principles you wish the Court to apply. Make the Court aware of any relevant contrary authority. c. Attach a copy of the ALJ’s decision as an exhibit to the brief. 2. Commissioner’s Response Brief. In responding to Plaintiff’s brief, the Commissioner should do the following: a. b. c. Consider whether a voluntary remand is appropriate under the law of this district and circuit. If so, please contact Plaintiff’s counsel and prepare the necessary stipulation. Supplement Plaintiff’s facts where needed for the issues presented. Do not feel compelled to repeat the facts. Cite to those portions of the record that constitute substantial evidence in support of the ALJ’s decision. SO ORDERED. ENTERED: DATE: September 3, 2024 ___________________________ HON. MARIA VALDEZ United States Magistrate Judge 2