MAGISTRATE JUDGE MICHAEL F. IASPARRO
327 South Church Street, Courtroom 3200
Rockford, IL 61101
STANDING ORDER GOVERNING PROPOSED FINAL PRETRIAL ORDERS
This Standing Order sets forth the requirements that the parties must meet in submitting a Proposed
Final Pretrial Order for the Court’s consideration in consent cases.
Proposed final pretrial orders must be filed electronically using CM/ECF (no need for courtesy
copies). To file it, select the appropriate CM/ECF event, “Other Filings” and then “Other
Documents,” and choose the Proposed Pretrial Order event. Also email it to Judge Iasparro’s
proposed order inbox in Microsoft Word format:
[email protected].
1. JURISDICTION
State the jurisdictional basis for each claim. If the parties rely on either diversity jurisdiction or
another jurisdictional basis that requires a threshold amount, then state whether the parties agree
that the amount in controversy exceeds the amount and include a concise explanation of how the
evidence supports that statement.
2. TRIAL ATTORNEYS
List all of the attorneys trying the case, as well as contact information (business address, telephone
number, and email address).
3. CASE STATEMENT
Provide a concise agreed statement of the case to be read by the Court to the jury pool during jury
selection. The statement must describe the nature of the case, claims, and defenses. This is a neutral
description of the case, with just enough information to introduce the case to the jury and to ask
potential jurors whether they happen to know anything about the case.
4. TRIAL LENGTH/ NUMBER OF JURORS
State the estimated number of trial days, including jury selection and deliberations, premised on
six-hour trial-testimony days (the six hours already accounts for lunch and breaks). Propose
estimated time limits for:
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(a) opening statements per side;
(b) closing arguments per side (including an initial close and rebuttal for the plaintiff); and
(c) the total number of hours of witness examination per side.
Also, state the number of jurors that the parties recommend (subject to Federal Rule of Civil
Procedure 48(a)).
5. STIPULATIONS AND UNCONTESTED FACTS
In numbered paragraphs, state any stipulations and uncontested facts. No later than 10 business
days before the Proposed Final Pretrial Order’s due date, the parties must serve on each other
proposed stipulations and uncontested facts. No later than 5 business days before the due date, the
parties must confer in good faith to arrive at as many stipulations and uncontested facts as possible.
6. WITNESS DESCRIPTION LISTS
Each party shall provide a list of witnesses, including expert witnesses, divided into: (a) witnesses
who will be called; and (b) witnesses who might be called. The lists should include even those
witnesses whose testimony will not be presented in court (e.g., a video deposition). For each
witness, provide a very concise (2 or 3 sentences) description of the witness and the witness’ role
in the case. For example: “George Washington is Plaintiff’s cousin. Washington witnessed the
arrest of Plaintiff where Defendants allegedly used excessive force.” Or: “John Adams is
Defendant’s Chief Operating Officer. Adams made promises concerning the timing of payments
under the contract.” Witnesses who are not on the lists are barred from testifying unless the
proponent shows good cause for the failure to disclose the witness. The names of witnesses on the
lists will be read to the jury during jury selection to ensure that potential jurors do not personally
know any witnesses.
7. EXHIBITS AND EXHIBIT CHARTS
The parties must submit an exhibit chart, one each for Plaintiff’s exhibits and Defendant’s exhibits.
The charts must state the following:
(a) the exhibit number;
(b) the date of the document or exhibit, if applicable;
(c) a concise, neutral description of the exhibit;
(d) a concise statement of the exhibit’s relevance; and
(e) whether there is an objection to the exhibit’s admission, and if so, a concise explanation
of the objection.
The chart’s format shall be substantially similar to the example below (landscape orientation is
encouraged).
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No. Date Description Relevance Objection
1 02/15/06 2005 Performance Proves record of R. 402 relevance; R.
Review satisfactory job 403 confusion.
performance Plaintiff fired 2011.
In addition to substantive exhibits and Federal Rule of Evidence 1006 summary exhibits, the chart
should also include proposed demonstrative exhibits and any exhibits that are likely to be referred
to at trial even though not allowed into evidence. For example, deposition transcripts of witnesses
likely to be impeached, or documents likely to be used to refresh memory, should be included on
the chart (and assigned an exhibit number and description).
Any substantive exhibit not objected to shall be deemed admissible into evidence by this Order
(note: for the exhibit to be actually entered into the record for the jury’s consideration, the exhibit
still must be referred to during trial testimony or otherwise published to the jury). Do not over-
designate exhibits, because we will examine exhibits one-by-one during the pretrial conference,
and plainly inadmissible exhibits will needlessly consume time. By the same token, the parties
must limit the objections to only good-faith objections. Frivolous and boilerplate objections will
waste time, because in preparation for the pretrial conference, the Court will review, as much as
possible, the exhibits and the objections. The parties shall stipulate to the authenticity of exhibits
whenever possible. If a foundation objection is asserted and the offering party proffers a foundation
that the Court believes overcomes the objection, the offering party still must lay the foundation
at trial.
As noted above, non-objected-to exhibits will be admissible into evidence by operation of this
Order, without any need for further foundation testimony (remember, however, that the exhibit
must still be referred-to during trial testimony or otherwise published to the jury in order for the
exhibit to be considered by the jury). But during the trial, for the jury’s sake and for the clarity
of the record, still move the exhibit into evidence before publishing it to the jury. The Court will
ask whether there is any “further” objection.
At least 5 business days before the pretrial conference, the parties must submit to chambers a USB
storage device, DVD, or CD with all of the proposed exhibits. The parties must use the exhibit-
naming convention for the Jury Evidence Recording System (JERS); the Court will provide the
parties with an instruction memorandum on how to use JERS and name exhibits.1 In addition to
the disc, the parties also must supply 2 sets of exhibit binders containing copies of objected-to
exhibits only. The party that is objecting to an exhibit is responsible for providing the copy of the
objected-to exhibit. (After the pretrial conference and rulings on exhibits, no later than 5 business
days before trial, the parties must submit the final trial exhibits on a disc or drive and provide one
paper copy of the exhibits, double-sided in three-ring binders.)
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Ideally, any exhibit in .pdf format will have undergone Optical Character Recognition (OCR) and be text-
searchable.
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8. DEPOSITION DESIGNATIONS
If a party proposes to introduce a witness’ testimony via a deposition rather than live testimony,
then the offering party must serve the page/line designations of the deposition transcript on the
opposing party 10 business days in advance of the pretrial order’s due date. The opposing party
must serve objections to designations (including a concise basis for the objection, like the Exhibit
Chart) and also state the opposing party’s counter-designations (including counter-designations
conditioned on an objection being overruled) 5 business days in advance of the pretrial order’s due
date. The parties shall generate a joint chart, in page order, that sets forth the designation, objection,
counter-designation if objection overruled, any counter-designations, and any objections to the
counter-designations (again, with a concise basis for the objection, like the Exhibit Chart).
9. DAMAGES ITEMIZATION
Plaintiff (and counter/cross-claimants, if any) shall itemize damages and other relief sought, and
provide a concise explanation of the evidentiary basis for each itemization.
10. MOTIONS IN LIMINE
In the Proposed Final Pretrial Order, each party must provide a list that very briefly summarizes
its motions in limine, e.g., “Motion to bar reference to Witness A’s drug use.” The motions
themselves must be filed the earlier of: (a) the due date of the Proposed Final Pretrial Order; or (b)
3 weeks before trial. The parties must confer on all motions in limine before filing them. If
there is no objection to a motion, but the movant wishes to file a motion memorializing the non-
objection, then the motion must state that there is no objection. To the extent reasonable, file
multiple motions in one filing (or a few consolidated filings) to reduce the number of filings.
Unless otherwise ordered, responses are due 5 business days after the motion’s filing, and replies
are due 3 business days after the responses; again, consolidate as much as reasonable. The goal is
to be in a position to rule on all of the motions in limine at the pretrial conference.
11. VOIR DIRE QUESTIONS
The parties should check Judge Iasparro’s website for the standard background questions that the
Court asks prospective jurors during voir dire. For additional questions, the parties must file a list
divided into: (a) agreed-upon questions; and (b) proposed questions to which there is an objection.
A short basis for any objection must accompany the list. Each side is limited to 12 proposed
disputed questions, unless a motion is filed before the pretrial conference that explains good cause
for proposing more than the limit.
12. JURY INSTRUCTIONS/ VERDICT FORMS
The parties must meet and confer in order to attempt to agree on as many jury instructions and
verdict forms as possible. Where applicable, the Court generally prefers the Seventh Circuit’s
Pattern Jury Instructions. The proposed jury instructions must state, on an instruction-by-
instruction basis, the following information:
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(a) the proponent of the instruction;
(b) the legal authority for the instruction; and
(c) whether there is an objection to the instruction.
If an instruction is disputed, the proponent of the instruction should concisely explain the basis for
the instruction, if more explanation is required beyond the identified legal authority. Moreover, if
an instruction is disputed, the objecting party must concisely state—on the page immediately
following the instruction— the grounds for the objection, as well as any proposed modification or
alternative. The same principles apply to proposed verdict forms.
13. SIGNATURE
The Proposed Final Pretrial Order must be signed (electronically) by counsel for each party.
ENTERED:
Date: May 30, 2025 /s/ Michael F. Iasparro__
United States Magistrate Judge
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