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In an effort to determine whether requiring civil litigants to respond to a series of standard discovery requests before undertaking other discovery will reduce the costs and delays often associated with litigation, the Northern District of Illinois recently implemented a three-year Mandatory Initial Discovery Pilot Project (“MIDP”).

With the exception of a limited category of cases, the MIDP will apply to all civil lawsuits filed on or after June 1, 2017.  In particular, the MIDP mandates that litigants – without the need for any request from an opposing party – provide certain information and documents including the identification of all persons with knowledge about the matter, a detailed list of all relevant electronically stored information (“ESI”), any facts relevant to a party’s legal theories, a computation of claimed damages, and the identification of any applicable insurance agreements.

To the extent disagreements arise regarding the production of documents and ESI, the MIDP requires parties to meet and confer before seeking intervention by the Court through a single joint motion or through a conference call at the Court’s discretion.