IN THE CIRCUIT COURT OF THE TWELFTH JUDICIAL CIRCUIT WILL COUNTY, ILLINOIS _______________________________________ Plaintiff vs CASE NO: ______________________________ _______________________________________ Defendant INITIAL CASE MANAGEMENT/ ARBITRATION ORDER The requirement of "disclosure statements" applies to all parties in cases subject to mandatory arbitration. Each party must provide a written disclosure to every other party within the time limit as set by the court instanter. Each party must disclose the following: 1) The factual basis for each claim or defense; 2) The legal theory upon which each claim or defense is based. 3) The current name, address, and telephone numbers of each witness the disclosing party expects to call at trial, including the subject matter (meaning the topics) of the expected testimony; 4) The name, address, and telephone number of any person the party believes to have knowledge or information relating to the events, transactions, or occurrences giving rise to the action, as well as the nature of that knowledge or information; 5) The name, address, and telephone number of each person who has given a statement, whether signed or unsigned written or recited and the custodian of the statement; 6) The identity and address of each person whom the disclosing party expects to call as an expert witness at trial, plus the information called for by SCt Rule 213(f); 7) A computation and measure of damages alleged and the documents and testimony on which it is based, plus the names, addresses and telephone numbers of all damage witnesses; 8) The existence, location, custodian and general description of any tangible evidence or documents the disclosing party plans to use at trial and relevant insurance agreements; 9) A list of the documents, (or categories of documents if voluminous,) that a disclosing party knows exists whether or not in the party's possession, custody or control and that the party believes may be relevant to the action plus those that appear reasonably calculated to lead to the discovery of admissible evidence. The list should also include the dates available, for inspection and copying. Unless good cause is shown for not serving a copy, a copy of each listed document must be served with the disclosure. The name and address of the custodian must be given if such production is not made. All production must be made as the documents are kept in the usual course of business. 10) All such disclosures must be made within the time set by the court in paragraph 15. 11) A Notice of Disclosure as required by SCt Rule 222(c) or a copy of the actual disclosures must be filed promptly with the court clerk upon service of the disclosure. ANDREA LYNN CHASTEEN, CLERK OF THE CIRCUIT COURT OF WILL COUNTY Orig. ­ Court Copy ­ Plaintiff Copy­ Defendant American LegalNet, Inc. www.FormsWorkFlow.com AR 11 (Part 1 of 2) Revised (12/16) 12) Each party has a continuing duty to seasonably supplement or amend all of its disclosures as required by SCt Rule 222(c). 13) All disclosures must be in writing and accompanied by an affidavit of completeness and correctness as of the date of disclosure and that all reasonable attempts have been made to comply with Rule 222(e). 14) If not already filed the defendant(s) shall file an appearance and responsive pleading to the complaint within 28 days of the date of this order. 15) The plaintiff(s) and the defendant(s) shall make initial written disclosures (and accompany 222(e) affidavit) and file the Notice of Disclosure or a copy of the actual disclosures with the court all in compliance with the Supreme Court Rule 222(c),(d), and (e) on or before _______________________, 20_____. 16) Failure to comply with #15 above and the requirements of SCt Rule 222 will expose the offending party to the penalties and sanctions set forth in Supreme Court Rule 219 & 222(g) and to any other sanction the court may impose. 17) All disclosures shall have been supplemented or amended and the limited and simplified discovery beyond the Rule 222 disclosures, [as authorized by Supreme Court Rule 222(f)] shall be completed no later than 30 days prior to the status date. Set out in paragraph #20. The notice of intent pursuant to SCt Rule 90(c) [Exchange of 90 (c) packets] shall have been given to every other party at least 30 days prior to the arbitration hearing date. All discovery is cut off as of the status date set out in paragraph # 20 below. 18) IN ALL EVENTS THE USE OF OTHER OF DISCOVERY METHODS TO OBTAIN THE SAME INFORMATION AS DISCLOSED IN 222 DISCLOSURES SHALL BE AVOIDED (SCt Rule 201). Each party is limited to an aggregate total of 30 interrogatories including sub parts. Only the deposition of A) the parties (or in the case of a corporation or other legal entity one representative). B) Treating Physicians and experts who have been identified as testifying at trial are allowed without leave of court for good cause. Other discovery allowed by SCt Rule 222(f) shall not duplicate the automatic disclosure requirements of Supreme Court Rule 222. 19) Any dispositive motions shall be filed and set for hearing not less than 28 days prior to the arbitration hearing date. 20) This case is set for a final SCR 218 case management conference and status on ________________________, 20 ______ at 1:30 p.m. At that time the case will be set for arbitration hearing. It is expected the hearing will occur within (approximately) 30 to 60 days of the status date. 21) Other______________________________________________________________________________ __________________________________________________________________________________ Attorney or Party, if not represented by Attorney Name _____________________________________ ARDC # ___________________________________ Firm Name _________________________________ Attorney for ________________________________ Address ___________________________________ City & Zip _________________________________ Telephone _________________________________ Date:_______________________,20______ Entered:_____________________________ Judge ANDREA LYNN CHASTEEN, CLERK OF THE CIRCUIT COURT OF WILL COUNTY Orig. ­ Court Copy ­ Plaintiff Copy ­ Defendant American LegalNet, Inc. www.FormsWorkFlow.com AR 11 (Part 2 of 2) Revised (12/16)