Circuit Court of Cook County Filing Bundling Requirements

CRITICAL

A default and a default judgment must be obtained separately and cannot be bundled or decided at the same time.

The Court requires each to be obtained separately and not simultaneously. In other words, a party must first be held in default, then given notice of a separate prove-up date for a default judgment.

CRITICAL

On the clerk's status date, the movant must email a bundled submission of file-stamped PDF copies of all briefs, exhibits, and the operative pleading to the Court.

At or shortly before 9:15 a.m. on the clerk’s status date, the movant shall submit to the Court by email, with a copy to all opposing parties, file-stamped PDF copies of all of the briefs and any exhibits, including a copy of the operative pleading.

CRITICAL

Piggy-backing motions is prohibited without prior leave of the Court.

Parties shall NOT piggy-back motions without prior leave of the Court.

CRITICALCivil cases

The movant must email file-stamped PDF copies of all briefs, exhibits, and the operative pleading together to Calendar 1 before the clerk's status call.

At or shortly before 9:30 a.m. on the clerk’s status date, the Court requires the movant to email Calendar 1 with a copy to all parties of record, file-stamped PDF copies of all of the briefs and any exhibits, including a copy of the operative pleading.

CRITICAL

All motions must be submitted as a single bookmarked/tabbed PDF containing all supporting documents.

All motions must be in ONE Bookmarked/tabbed PDF file with all supporting documents.

CRITICAL

All damages must be proven up together in one motion, not piecemeal.

All parties seeking a determination of damages shall prove up all damages sought together in one motion and shall NOT be brought in a piecemeal fashion without the Court's prior consent to deviate from this requirement.

CRITICAL

(6) All motions shall be in ONE tabbed PDF file with all supporting documents. Each tab shall be clearly titled (e.g., Notice of Motion, Complaint, Service Affidavits, Motion for Default, etc.) and neatly and intuitively organized.

(6) All motions shall be in ONE tabbed PDF file with all supporting documents. Each tab shall be clearly titled (e.g., Notice of Motion, Complaint, Service Affidavits, Motion for Default, etc.) and neatly and intuitively organized.

CRITICAL

Moving for judgment piecemeal against separate litigants is prohibited.

Moving for judgment in a **piecemeal fashion** against separate litigants is strictly **PROHIBITED**.

CRITICAL

A separate motion for foreclosure judgment is required and cannot be integrated into other judgment motions.

A plaintiff seeking a judgment of foreclosure pursuant to 735 ILCS 5/15-1506 **SHALL** file a **separate** motion for entry of judgment of foreclosure with all supporting documents required by law attached thereto. Movants for entry of judgment of foreclosure shall **NOT** integrate a motion for entry of judgment of foreclosure into a motion for summary judgment, default, or any other judgment motion.

CRITICAL

The Court will not enter multiple judgments of foreclosure without prior consent.

The Court will **NOT** enter multiple judgments of foreclosure in one case without the Court's prior consent to proceed in such a piecemeal fashion.

CRITICAL

Motions to confirm multiple judicial sales must be brought together (single or simultaneous), not piecemeal.

If multiple properties are sold via judicial sale in a single case and pursuant to an entered judgment of foreclosure permitting the sale of multiple properties, movants seeking to confirm such sales shall bring all motions to confirm the sales of these properties in either a single motion or multiple motions (one per property) simultaneously. If the Court approves the sales, the Court will enter all orders approving sale in one case concurrently. Parties seeking approval of multiple judicial sales shall NOT bring such motions in a piecemeal fashion without the Court's prior consent.

CRITICALCivil cases

Exhibits should be provided separately in a single packet with a table of contents and tabs.

Exhibits should be provided separately in a single packet with a table of contents and tabs.

CRITICALCivil cases

Contested motions require a briefing schedule order; materials must be delivered in one package for oral argument. Forum Non Conveniens motions get written decision, no oral argument.

Contested motions require the entry of a briefing schedule order which includes a clerk status date. Upon receipt of complete briefs, pleadings, depositions and exhibits from Movant, in one delivery, a hearing will be set for oral arguments. Exception: Motions to Dismiss based upon Forum Non Conveniens will receive a written decision. No oral argument hearing will be set upon receipt of complete briefs, pleadings and exhibits from Movant. If granted the case will be transferred. If denied, a status date and time will be included in the order.

CRITICALCivil cases

Parties should not submit copies of any briefs relating to contested motions until all briefing is complete. Courtesy copies should be one complete set sent electronically to the Calendar R email, and one complete set of physical courtesy copies delivered to Room 2208. In the physical copy all exhibits must be tabbed and all materials must be printed double-sided.

Parties should not submit copies of any briefs relating to contested motions until all briefing is complete. Courtesy copies should be one complete set sent electronically to the Calendar R email, and one complete set of physical courtesy copies delivered to Room 2208. In the physical copy all exhibits must be tabbed and all materials must be printed double-sided.

CRITICALCivil cases

Trial materials must be joint submissions; separate allowed only with good faith disagreement.

must be submitted to the Court by joint submissions no less than thirty (30) days before the scheduled pretrial or trial (whichever is sooner). Separate submissions are permitted only if the parties cannot in good faith agree on joint submissions.

CRITICALCivil cases

Evidentiary hearing materials must be joint submissions; separate allowed only with good faith disagreement.

Separate submissions are permitted only if the parties cannot in good faith agree on joint submissions

CRITICALCivil cases

Admitted trial exhibits must be jointly filed with courtesy copy to chambers.

The parties shall jointly file a complete set of admitted trial exhibits and supply the Court with a courtesy copy thereof.

CRITICAL

All damages must be proven up together in one motion, not piecemeal, without the Court's prior consent.

All parties seeking a determination of damages shall prove up all damages sought together in one motion and shall NOT be brought in a piecemeal fashion without the Court's prior consent to deviate from this requirement.

CRITICAL

The Court will not enter multiple judgments of foreclosure in one case without prior consent.

The Court will NOT enter multiple judgments of foreclosure in one case without the Court's prior consent to proceed in such a piecemeal fashion.

CRITICAL

Requests for a sealed-bid auction must be presented by separate motion.

All requests for a sealed-bid auction must be presented by separate motion.

CRITICAL

Motions to confirm multiple judicial sales must be brought together (single motion or simultaneous motions); piecemeal filing requires prior court consent.

If multiple properties are sold via judicial sale in a single case and pursuant to an entered judgment of foreclosure permitting the sale of multiple properties, movants seeking to confirm such sales shall bring all motions to confirm the sales of these properties in either a single motion or multiple motions (one per property) simultaneously. If the Court approves the sales, the Court will enter all orders approving sale in one case concurrently. Parties seeking approval of multiple judicial sales shall NOT bring such motions in a piecemeal fashion without the Court's prior consent.

CRITICAL

Moving for judgment in a piecemeal fashion against separate litigants is strictly prohibited.

Moving for judgment in a piecemeal fashion against separate litigants is strictly PROHIBITED.

CRITICAL

A plaintiff seeking judgment of foreclosure must file a separate motion with all supporting documents and may not integrate it into a summary judgment, default, or other judgment motion.

A plaintiff seeking a judgment of foreclosure pursuant to 735 ILCS 5/15-1506 SHALL file a separate motion for entry of judgment of foreclosure with all supporting documents required by law attached thereto. Movants for entry of judgment of foreclosure may NOT integrate a motion for entry of judgment of foreclosure into a motion for summary judgment, default, or any other judgment motion.

CRITICAL

Plaintiff must notice up all judgment motions simultaneously.

Plaintiff shall notice up ALL judgment motions (inter alia, motions to dismiss unknown parties or other defendants, default, summary judgment, judgment of foreclosure, appoint selling officer, reformation of mortgage or deed) simultaneously.

CRITICALCivil cases

Sur-replies are not permitted.

No sur-replies will be permitted.

CRITICAL

Contested motions may not be presented at or piggybacked onto a case-management conference.

Contested motions may not be presented at a case management conference, and no motions may be piggy-backed on to a case management conference.

CRITICAL

Motions must be bundled into a single tabbed PDF with all supporting documents.

All motions shall be in ONE tabbed PDF file with all supporting documents. Each tab shall be clearly titled (e.g., Notice of Motion, Complaint, Service Affidavits, Motion for Default, etc.) and neatly and intuitively organized.

WARNINGCivil cases

If multiple motions are submitted, each motion's folder includes its response and reply, and each folder and contents must be zipped into a .zip file.

If there are multiple motions, they shall be contained within a separate folder for each respective motion along with that motion’s response and reply. Each folder and its contents shall be saved within a .zip file.

WARNING

Multiple proposed orders must be submitted together in one PDF attachment.

Multiple proposed orders should all be submitted together in ONE PDF attachment.

WARNING

Proposed orders for each motion should be provided to the Court with the courtesy copy submission and should not be attached to any other document.

Proposed orders for each motion should be provided to the Court with the courtesy copy submission and should not be attached to any other document.

WARNING

Motions to strike briefs, affidfields, or portions of either are decided with the underlying motion without a separate response or reply.

Motions to strike briefs, affidavits, or portions of either, will be taken with the motion without response or reply.

WARNING

Multiple motions must be organized into separate folders, each containing its related motion.

If there are multiple motions, they shall be contained within a separate folder for each respective motion along with that motion.

WARNINGCivil cases

Other than the copy provided to the court for presentment (see 2(b) above), parties should not submit copies of any briefs relating to contested motions until all briefing is complete.

Other than the copy provided to the court for presentment (see 2(b) above), parties should not submit copies of any briefs relating to contested motions until all briefing is complete.

WARNING

Other than copies provided to the Court for presentment (see 2(b)(i) above), parties should not submit copies of any briefs relating to contested motions until all briefing is complete.

Other than copies provided to the Court for presentment (see 2(b)(i) above), parties should not submit copies of any briefs relating to contested motions until all briefing is complete.

WARNINGCivil cases

For contested motions, a hearing is set only upon receipt of the movant's complete briefs, pleadings, depositions and exhibits in one delivery.

Contested motions require the entry of a briefing schedule order which includes a clerk status date. Upon receipt of complete briefs, pleadings, depositions and exhibits from Movant, in one delivery, a hearing will be set for oral arguments.

WARNING

The Court accepts piggybacked motions for presentment onto pre-set court dates; file and notice them but do not spindle, and Illinois Rules of Civil Procedure still apply.

The Court accepts motions “piggybacked” for presentment onto pre-set court dates. File and notice them, but do not spindle. Note the Illinois Rules of Civil Procedure still apply.

WARNING

Multiple motions must each be contained in a separate folder with that motion's response and reply, and each folder saved within a .zip file.

If there are multiple motions, they shall be contained within a separate folder for each respective motion along with that motion's response and reply. Each folder and its contents shall be saved within a .zip file.

INFO

The parties may, by mutual agreement, file a joint pretrial memorandum in lieu of separate filings, or submit agreed memoranda, stipulations, or other pre-trial material.

The parties may, by mutual agreement, submit a joint pretrial memorandum in lieu of separate filings, and may submit agreed memoranda, stipulations and/or other material that may assist in the resolution of factual and/or legal issues prior to trial.

INFO

The parties are strongly encouraged to submit joint or agreed trial materials when possible.

The parties are strongly encouraged to submit joint or agreed Trial Materials to the extent possible.

INFOCivil cases

Motions may be piggy-backed on previously set case management dates without formal scheduling.

Motions may also be “piggy-backed” on a previously set case management date without formal scheduling.

INFOCivil cases

Parties may delay submitting courtesy copies of briefings under a briefing schedule until the Clerk’s Status date.

Once parties have entered into a briefing schedule on a motion, parties can wait to submit courtesy copies of the briefings (e.g. the response and reply) until the Clerk’s Status date.