Judge Thomas Donnelly
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Complaint, Proof of Service
Courtesy copies
- By 8 45 Am and 3 00 Pm
- Email by 8 45 Am Hard Copy by 3 00 Pm
Motion
- Email • Upon Filing
Motion, Notice of Motion
- Email • Upon Filing
Communication
Chambers5 contacts
Clerk2 contacts
Document Format Requirements3 rules
Motions for default judgment and the supporting materials must be clearly labeled in a text-searchable PDF with bookmarks and sent via email and hard copy, placed in the bin outside Courtroom 2510. Failure to comply may result in dismissal for want of prosecution. Electronic copies may be provided via email, USB drive, or online link.
- File type
Formatting
- •Text-searchable PDF with bookmarks
Orders tendered for the court's consideration shall be tendered in both PDF and Word formats within the hour of court appearance when appearing via Zoom. Failure to tender the order in a timely manner may result in the court entering its own.
- File type
- Proposed order
Formatting
- •Also required in Word format
Courtesy copies must be delivered electronically in an organized, searchable format with exhibits attached and marked; filenames must state the filing date (YYYY-MM-DD) and document identification.
- Courtesy copy
Formatting
- •Exhibits properly attached and marked
Court's wording
Courtesy copies of all documents shall be delivered to the court electronically (e.g., email attachment, cloud-based storage, or USB thumb drive) in an organized and searchable format with exhibits properly attached and marked. Any electronic files submitted to the court shall state in the filename (1) the date the document was filed in the form YYYY-MM-DD; and (2) identification of what the document is.
Document Filing Requirements20 rules
You must tender an (a) affidavit with proof of service on Defendants; (b) affidavit of damages including documents showing amount due; and (c) affidavit of attorney's fees with contemporaneous billing records and costs.
All motions to compel must articulate the attorney's actual efforts at personal consultation and reasonable attempts to resolve differences with opposing counsel. See Ill. S. Ct. R. 201(k) (eff. July 30, 2014). Failure to articulate the attorney's efforts will result in the motion being stricken.
Motions for default judgement must include at the top of the packet: Return of Service, Prove-Up Affidavit(s) that lay a foundation for the attached documents or records, and, if applicable, an Attorney Fee Affidavit(s) with contemporaneous business records attached.
- Document
- Default judgment
Must include
- •Certificate of service
with an accompanying cover letter containing the case name, the case number and the date and time of the clerk status.
- Document
- Cover letter
Include
- •Case number
These matters may be entered off call. Please provide a proposed order to accompany the filed motion and request for entry via email.
- Document
- Motion
Include
- •Proposed order
At the clerk status, the movant is obligated to deliver copies of all the briefs, pleadings, relevant documents and the most recent complaint, with an accompanying cover letter containing the case name, the case number, date and time of the clerk status, and
- Document
- Clerk status packet
Include
- •Case number
The memoranda should include a short statement of the issues, the damages, the status of settlement negotiations, and any additional information which will help the court hold a meaningful settlement conference.
The following information and documents shall be delivered: (A) Estimated number of trial days (B) Statement of the case (C) Witness list (D) Stipulations (E) Motions in Limine (F) Evidence depositions
Please tender a draft order granting permission to bring equipment into the building for the court's consideration.
Trial materials must include exhibit lists/exhibits, Ill. S. Ct. R. 213 disclosures, identification of objects and demonstrative evidence, and, when appropriate, a short trial brief.
- Document
- Trial materials
Include
- •Exhibit list
Court's wording
(G) Exhibit lists and/or Exhibits (H)Ill. S. Ct. R. 213 disclosures (I) Identification of objects and demonstrative evidence to be used at trial (photographs, slides, pictures, videotapes, exhibition of injuries, and courtroom demonstrations) (J) When appropriate, short trial brief with attention to primary contested issues of fact, unusual issues of law and authority;
Courtesy copies shall be accompanied by a cover letter or cover email containing the case number, caption, court date, and a statement that the delivery is pursuant to this order. The movant shall copy all parties of record to this correspondence.
- Document
- Courtesy copy
Must include
- •Caption
- •Case number
If the parties have settled and agree on the material terms, please tender an agreed dismissal order with the court to retain jurisdiction to enforce the settlement. Please also strike any and all upcoming dates (specify the court date(s) in the order).
Affidavits of Engagement must include the case name, number, and the trial judge.
Foundation. An affidavit shall set forth the foundation for any document attached. If the affiant offers a document for its truth, the affiant shall establish it is
Basis. An affidavit shall state whether it is grounded upon personal knowledge, attached documents, or both. The affidavit shall explain how the affiant knows the facts.
Orders tendered for the court's consideration shall be tendered in both PDF and Word formats within the hour of court appearance when appearing via Zoom or the court may enter its own.
In collection cases, the plaintiff shall submit a ledger accompanied by an affidavit establishing that it is a business record.
A record of regularly conducted shall be accompanied by a certification that it (1) was made at or near the time of the occurrence of the matters set forth by a person with knowledge of these matters, (2) the document was kept in the regular course of business, and (3) was made regularly.
An attorney's fee award requires an affidavit establishing reasonableness based on seven listed factors, with contemporaneous billing records attached that provide detailed entry descriptions of services, provider, duration, and hourly rate.
Court's wording
An affidavit shall establish the reasonableness of the amount sought. It must include: (1) the skill and standing of the attorneys, (2) the nature of the case and the novelty and/or difficulty of the issues and work involved, (3) the value and importance of the matter, (4) the degree of responsibility required, (5) the usual and customary charges for comparable services, (6) the benefit to the client, and (7) whether there is a reasonable connection between the fees and the amount involved in the litigation.4 Contemporaneous billing records shall be attached. The records must provide detailed billing entry descriptions specifying the services performed, who performed it, how long it took, and the hourly rate charged using facts based on contemporaneous time records.
The court awards costs without stating a dollar amount, using language such as 'plus costs,' because more costs may accrue post-judgment.
Court's wording
The court shall award "costs" without a stating a dollar amount because more costs may accrue post judgment; e.g., "The court enters a default judgement in favor of Acme, Inc., and against Jones, Inc., in the amount of $222,222.00 plus costs."
Filing & Service rules
Filing Timing and Cure Windows
Any response to a motion must be filed by a date specified in the order.
_________________ shall file any response to the motion(s) on or before ________________, with a copy thereof to be immediately served upon all parties entitled to notice pursuant to rule;
Civil cases
Page 1 | Briefing Schedule Order
Any reply must be filed by a date specified in the order.
________ shall file any reply on or before _____________, with a copy thereof to be immediately served upon all parties entitled to notice pursuant to rule;
Civil cases
Page 1 | Briefing Schedule Order
Parties may request an interpreter two weeks before their scheduled hearing; a court-appointed interpreter may not be available, so parties may need to arrange one separately.
Parties may request an interpreter two weeks before their scheduled hearing. Please be advised that, due to staffing, a court-appointed interpreter may not be available. The parties may need to arrange for an interpreter separately. If you have submitted a request, but later arrange for your own, please alert the court.
Page 6 | GENERAL REMINDERS
Service and Proof of Service Rules
Any reply must be immediately served on all parties entitled to notice.
________ shall file any reply on or before _____________, with a copy thereof to be immediately served upon all parties entitled to notice pursuant to rule;
Civil cases
Page 1 | Briefing Schedule Order
Any response to a motion must be immediately served on all parties entitled to notice.
_________________ shall file any response to the motion(s) on or before ________________, with a copy thereof to be immediately served upon all parties entitled to notice pursuant to rule;
Civil cases
Page 1 | Briefing Schedule Order
Parties must notify opposing counsel when confidential memoranda are delivered to the court.
Parties shall notify opposing counsel of delivery of confidential memoranda to the court.
Page 4 | Settlement Conferences
Courtesy Copy Requirements
The movant must deliver courtesy copies of all briefs, pleadings, relevant documents, and the most recent complaint to the court at the clerk status, with a cover letter, via email by 8:45 AM and hard copy by 3:00 PM; failure to do so may result in the motion being stricken.
At the clerk status, the movant is obligated to deliver copies of all the briefs, pleadings, relevant documents and the most recent complaint, with an accompanying cover letter containing the case name, the case number and the date and time of the clerk status. Submissions should be made via email by 8:45 AM and hard copy by 3:00 PM. Please review the court’s Standing Order for any change to this order. Failure to provide the court with a complete set of courtesy copies may result in the motion being stricken.
Civil cases
Page 1 | Briefing Schedule Order
Piggybacked motions require courtesy copies (file-stamped motion and Notice of Motion) via email and hard copy, or the motion may be stricken.
Parties may piggyback motions on this date by noticing motions, tendering a file stamped copy of the motion and a Notice of Motion with the previously scheduled court date via email and hard copy. Failure to provide the court with a complete set of courtesy copies may result in the motion being stricken.
Page 2 | Case Management/Status
Contested motions require courtesy copies upon filing via email and hard copy, or the motion may be stricken.
Courtesy copies due upon filing via email and hard copy, unless otherwise ordered. Failure to provide the court with a complete set of courtesy copies may result in the motion being stricken.
Page 2 | Contested Motions
For the initial intake date, parties must tender courtesy copies of the complaint, proof of service, and appearances via email and hard copy, or the motion may be stricken.
In preparation for the initial date, parties must tender courtesy copies of the complaint, any proof of service, and any filed appearances via email. Courtesy copies tendered via email and hard copy. Failure to provide the court with a complete set of courtesy copies may result in the motion being stricken.
Page 3 | Initial Intake
Courtesy copy submissions should be made via email by 8:45 AM and hard copy by 3:00 PM.
Submissions should be made via email by 8:45 AM and hard copy by 3:00 PM.
Page 3 | Court Schedule
Courtesy copies of pending motions in transferred matters shall be tendered via email and hard copies.
Courtesy copies of any pending motions shall be tendered via email and hard copies.
Page 3 | Initial Intake
Motions are heard on Thursdays at 9:30 AM with courtesy copies to the court via email in text-searchable PDF format with bookmarks and hard copies, or the motion may be stricken.
As scheduled through Odyssey, the Clerk's electronic filing system, (you may not pick your own date), heard on Thursdays at 9:30 AM with courtesy copies to the court via email in text-searchable PDF format with bookmarks and hard copies. Failure to provide the court with a complete set of courtesy copies may result in the motion being stricken.
Page 3 | Motions
For transferred matters, parties must tender courtesy copies of the last five orders, all pleadings, and all pending motions.
For established matters that have been transferred by the Presiding Judge in 2403, parties must tender courtesy copies of (1) the last five orders entered in the case; (2) copies of all pleadings, such as complaint, answer, counterclaim, and defenses; and (3) copies of all motions presently pending.
Page 3 | Initial Intake
Piggy-backed motions require courtesy copies to the court via email in text-searchable PDF format with bookmarks and hard copies, or the motion may be stricken.
Piggy-backed and noticed onto the next court date with courtesy copies to the court via email in text-searchable PDF format with bookmarks and hard copies. Failure to provide the court with a complete set of courtesy copies may result in the motion being stricken.
Page 3 | Motions
Pre-trial memoranda courtesy copies must be sent to the court at least three days before the settlement conference via email in text-searchable PDF format with bookmarks and hard copies to the bin outside Courtroom 2510.
Courtesy copies of pre-trial memoranda shall be sent to the court at least three days before via email in text-searchable PDF format with bookmarks and hard copies delivered to the bin outside Courtroom 2510.
Page 4 | Settlement Conferences
Courtesy copies of trial materials must be sent to the court via email in text-searchable PDF format with bookmarks and hard copies, due 14 days before trial.
Courtesy copies of trial materials shall be sent to the court via email in text- searchable PDF format with bookmarks and hard copies. Materials are due 14 days before
Page 4 | Trials/Trial Materials
For default judgment/prove-ups, tender courtesy copies of the motion and prove-up documents via email in text-searchable PDF format and hard copies, or the motion may be stricken.
Tender courtesy copies of the motion and prove-up documents to the court via email in text-searchable PDF format and hard copies. Failure to provide the court with a complete set of courtesy copies may result in the motion being stricken.
Page 4 | Default Judgment/Prove-Ups
The court requires both electronic and physical courtesy copies; failure to provide a complete set may result in the motion being stricken.
The court requires both electronic and physical copies delivered. Electronic copies can be provided via email, USB drive, or online link. Hard copies can be sent via USPS, FedEx, UPS or using a courier service or dropped off in the bin outside Courtroom 2510. Failure to provide the court with a complete set of courtesy copies may result in the motion being stricken.
Page 5 | GENERAL REMINDERS
Courtesy copies should be tendered via email in text-searchable PDF format with bookmarks at the time of assignment.
Courtesy copies should be tendered via email in text-searchable PDF format with bookmarks at the time of assignment.
Page 3 | Initial Intake
All electronic courtesy copies must be in text-searchable PDF format with bookmarks.
All electronic courtesy copies shall be in text-searchable PDF format with bookmarks.
Page 8 | AFFIDAVITS FOR PROVE UP OF DAMAGES – DEFAULT JUDGMENT
Sealing & Redaction Procedures
Confidential memoranda must be sent to the court via email without including opposing counsel, plus hard copies.
Confidential memoranda shall be sent to the court via email without inclusion of opposing counsel and hard copies.
Page 4 | Settlement Conferences
Filing Bundling Requirements
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.
Page 6 | GENERAL REMINDERS
Pre-Motion Conference Requirements
Emergency motions require chambers pre-approval by emailing a copy of the motion by 3:00 PM the day before presenting.
Pre-approval to appear must be obtained from chambers by submitting a copy of the emergency motion via email for review no later than 3:00 PM the day prior.
Page 2 | Emergency Motions
Adjournment & Extension Requirements
Trial continuances are disfavored; motions must comply with Supreme Court Rule 231, Affidavits of Engagement must include case name, number and trial judge, a served subpoena copy is required when a material witness is unavailable, and eleventh-hour motions may be denied.
Trial continuances are not favored. Motions not in compliance with Supreme Court Rule 231 may not be granted. Affidavits of Engagement must include the case name, number, and the trial judge. If a material witness is unavailable, a copy of the served subpoena must be included. Motions based on the unavailability of expert witnesses shall be brought with due diligence. Eleventh-hour motions may be denied.
Page 7 | Trial continuances
Parties needing to reschedule hearings must contact the court to obtain a new date.
If parties need to reschedule, please contact the court to obtain a new date.
Page 6 | GENERAL REMINDERS
Chambers Communication Rules
All participants are prohibited from sending private, direct messages (ex parte communications) to the Court.
All participants are prohibited from sending private, direct messages to the Court.
Page 8 | VIDEOCONFERENCING PROTOCOL
Counsel must email chambers before filing routine motions, which may be entered off-call.
Routine Motions Mondays through Thursdays 8:45 am. Please email ccc.chancerycalendar8@cookcountyil.gov before filing, as many may be entered off-call.
Page 1 | Court Schedule
Written communications with court staff must list the case name and docket number and copy all parties and attorneys of record; email is preferred.
All emails written communications with court staff must list the case name and docket number. All parties and attorneys of record must be copied on all written communications with court staff. Email communications are preferred.
Page 5 | GENERAL REMINDERS
Chambers may be contacted by email (preferred) or by phone.
Email: ccc.chancerycalendar8@cookcountyil.gov (preferred) (312) 603-6032
Page 1 | Court Schedule
Parties should email court personnel to schedule set-up of trial equipment.
Parties should correspond with the court's personnel via email to schedule set-up of any trial equipment (e.g., projectors, screens, computer monitors, etc.).
Page 4 | Trials/Trial Materials
Substantive questions should be directed to chambers by email at ccc.chancerycalendar8@cookcountyil.gov.
For substantive questions, email ccc.chancerycalendar8@cookcountyil.gov.
Page 8 | VIDEOCONFERENCING PROTOCOL