Rule 26(f) Planning Report; Preparation of Final Pretrial Order; General Voir Dire Questions

=== Rule 26(f) Planning Report ===

Report of Parties’ Planning Meeting [Caption and Name of Parties] 1. 2. Meeting. Pursuant to FED. R. CIV. P. 26(f), a meeting was held on (date) at (place) and was attended by : Pretrial Schedule. The parties jointly propose to the court the following discovery plan: [Use separate paragraphs or subparagraphs as necessary if parties disagree.] Plaintiff(s) to amend pleadings by (date). Plaintiff(s) to add any additional parties by (date). Defendant(s) to amend pleadings by (date). Defendant(s) to add any additional parties by (date). 3. Discovery. Discovery will be needed on the following subjects: (brief description of subjects on which discovery will be needed). (a) Disclosures pursuant to Pursuant to FED. R. CIV. 26(a)(1) to be made by (date). Fact discovery to be commenced in time to be completed by (date). (b) The parties expect they will need approximately (#) depositions. (c) Reports from retained experts under Rule 26(a)(2) due: Date for plaintiff to comply with FRCP(26)(a)(2): Date for defendant to comply with FRCP(26)(a)(2): All expert discovery to be completed by (date). (d) All potentially dispositive motions should be filed by (date). [Note: The court will not consider a summary judgment motion until the parties have first discussed settlement. Any motion for summary judgment must be accompanied by a statement signed by lead counsel for both parties certifying that they have engaged in good faith settlement efforts.] (e) (f) Final pretrial order: Plaintiff to prepare proposed draft by (date); parties to file joint final pretrial order by (date). The case should be ready for trial by (date) and at this time is expected to take approximately (length of time). 4. Settlement. At least 14 days prior to the Rule 16(b) scheduling conference, plaintiff(s) is directed to make a written settlement demand to the defendant(s). At least 7 days prior to the scheduling conference defendant(s) is to respond in writing to the plaintiff(s) settlement demand. 5. Consent. Parties (do) (do not) consent unanimously to jurisdiction by the assigned Magistrate Judge. Date: ______________________________ /signed by all counsel

=== Preparation of Final Pretrial Order ===

PREPARATION OF FINAL PRETRIAL ORDER FOR CIVIL CASES BEFORE JUDGE BUCKLO The parties shall jointly prepare and submit, on the date set by the court, a Final Pretrial Order containing the following , absent prior modification by the court: 1. Jurisdiction: matter jurisdiction, and if jurisdiction is disputed, the nature and basis of the dispute. statement of subject concise A 2. Claims. A concise statement (1 or 2 short paragraphs) of the claim (s) of the plaintiff(s), defense(s) of defendant(s), and all counterclaims and cross claims. In a jury trial, this statement will be read to the jury during voir dire. 3. Relief sought. An itemization of damages and other relief sought. 4. Witnesses. A list of names and addresses of all witnesses: (a) who will be called; (b) who may be called; and (c) whose deposition will be used. In a jury trial, this list will be read to the jury during Any witness not listed in the final pretrial order voir dire. will be precluded from testifying absent a showing of good cause, except that each party reserves the right to call such rebuttal witnesses (who are not presently identifiable) as may be necessary. a. Objections. A statement of any objections to the calling of any witness. Objections not made in the final pretrial order will be deemed waived absent a showing of good cause. b. Expert witnesses. A statement of the subject(s) of each expert witness'expertise, and a statement of any objections to the calling or qualifications of the witness (Daubert objections must be noted in the final pretrial order but should be set forth in a separate motion in limine.) Objections not made in the final pretrial order will be deemed waived absent a showing of good cause. c. Depositions. For each witness whose deposition will be used, a chart containing the following information: (a) a listing, by page and line, of the testimony that each side seeks to present; (b) a concise statement of objections to any testimony and the basis for the objection; and (c) a concise statement of the asserted basis of admissibility. Objections not made in the final pretrial order will be deemed waived absent a showing of good cause. 5. Exhibits. A schedule of all exhibits a party may introduce at trial, as well as any demonstrative exhibits or evidence, identified by trial exhibit number , with a brief description of each exhibit. Any exhibit not listed in the final pretrial order will be excluded from evidence absent a showing of good cause. a. exhibit. deemed waived absent a showing of good cause. Objections. Objections not made in the final pretrial order will be A statement of any objections to each b. Copies for court. A bench book of each party's exhibits is to be delivered to the court at the start of trial . c. Exhibits to be displayed to jury. If any exhibit is to be displayed to the jury, the party intending to display the exhibit must make sufficient copies for all jurors or must use an enlargement or projection of the exhibit. 6. Type and length of trial. A statement of whether the trial will be a bench trial or jury trial, and a realistic estimate of the length of the trial. 7. Settlement History. A statement briefly summarizing the history and current status of settlement negotiations. 8. Proposed findings and conclusions. For a bench trial, proposed findings of fact and conclusions of law. also submit via email its proposed findings and conclusions. At trial, each party shall 9. Proposed voir dire. For a jury trial, proposed voir dire. Judge Bucklo has her own set of general voir dire questions, which can be obtained from chambers or this court's web page. These questions need not be duplicated in the final pretrial order. The parties are to submit any proposed objections, modifications, and additions to these general questions , as well as any proposed voir dire specific to the case. 10. Proposed jury instructions. For a jury trial, proposed jury instructions. For general instructions, please use the Seventh Circuit’s Pattern Civil Jury Instructions, which can be found on that Court's website, www.ca7.uscourts.gov. In diversity cases where Illinois law provides the rule of decision, the use of IPI instructions as to issues of substantive law is required. a. Joint instructions. The parties shall submit one set of jury instructions. Where there is disagreement, the objection, with citation to authority, shall be listed immediately following the instruction. If necessary, a competing instruction shall be placed with the instruction upon which there is disagreement. b. Electronic submission. At trial, the parties shall submit via email their joint set of jury instructions which incorporates the court's c hanges. Other Items to be Submitted Prior to Final Pretrial Conference Any motions in limine must be filed and served along with the final pretrial order. The motions should not be bound with the final pretrial order. (14) days thereafter. Any responses must be filed and served no later than fourteen Trial briefs are not expected by the court and will not be accepted absent prior leave of court. 2 Any requests for daily or other expedited transcripts must be made directly to Judge Bucklo 's court reporter at least seven (7) days prior to trial . Instructions for Compiling 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 (21) days before the date the final pretrial order is due. Defendant's counsel must respond in writing to plain ti ff’s draft no later than fourteen (14) days before the final pretrial order is due, including any objections, changes, and additions to plaintiff's draft, of the draft pretrial order (e.g., defendant’s witness and exhibit lists, and objections to exhibits and deposition testimony listed by plaintiff). The parties must meet and confer no later than seven (7) days before the final pretrial order is due to discuss their respective drafts and to reach agreement to the extent possible. It is then the responsibility of plaintiff's counsel, with full cooperation from defendant’s counsel, to assemble the final pretrial order for filing. as well as defendant's portions The final pretrial order should be submitted to the court with a cover document setting forth the case caption and the title FINAL PRETRIAL ORDER. The cover document must (a) recite that each of the foregoing categories of materials is included; (b) must state that “This order will control the course of the trial and may not be amended except by consent of the parties, or by order of the court to prevent manifest injustice"; and (c) must be signed by counsel for each of the parties and contain a space for the court’s signature. Final Pretrial Conference pending A final pretrial conference will be held before trial. The court will and address exhibits, and contested jury instructions, and it will discuss trial procedures and scheduling. Trial counsel and with authority to discuss all aspects of the case must attend. fully prepared in limine, objections witnesses motions to July 19, 2017 (revised) ENTER ORDER: Elaine E . Bucklo United States District Judge 3

=== General Voir Dire Questions ===

GENERAL VOIR DIRE QUESTIONS ASKED BY JUDGE BUCKLO Please tell us: 1. 2. 3. 4. 5. 6. 7. 8. 9. your name; the neighborhood or town in which you live and any other places you may have lived in the past ten years; your present employment or self-employment, giving the name of your employer if you are not self-employed, the business in which the employer is engaged and what you do as part of that business, the length of your employment; and if you have had other employment in the past ten years, please give us the same information; what your education has been; whether you are married; and if your spouse is employed outside the home, please give us the same employment information I have just referred to covering the past ten years; the ages of your children and the type of work they do if they are adults; your reading habits; your outside interests or hobbies; the names of any organizations of which you are a member; and 10. whether you have previously served as a juror and, if so, how long ago.