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Motions to compel must also include arguments supporting the relevance and proportionality of the requested discovery and a recitation of the parties' meet and confer efforts. Motions to compel may be summarily stricken for a failure to comply with these rules.
Rule 201 provides that a court ?may judicially notice a fact that is not subject to reasonable dispute because it: (1) is generally known within the trial court's territorial jurisdiction; or (2) can be accurately and readily determined from sources whose accuracy cannot reasonably be questioned.? Fed.
Sec. 220. Enforcement of a civil no contact order. (a) Nothing in this Act shall preclude any Illinois court from enforcing a valid protective order issued in another state.
The court may at any time on its own initiative, or on motion of any party or witness, make a protective order as justice requires, denying, limiting, conditioning, or regulating discovery to prevent unreasonable annoyance, expense, embarrassment, disadvantage, or oppression.
One of those rules, 201(k), requires the parties to cooperate in resolving any disputes they have regarding discovery. ?Reasonable Attempt to Resolve Differences Required. The parties shall facilitate discovery under these rules and shall make reasonable attempts to resolve differences over discovery.
The court may at any time on its own initiative, or on motion of any party or witness, make a protective order as justice requires, denying, limiting, conditioning, or regulating discovery to prevent unreasonable annoyance, expense, embarrassment, disadvantage, or oppression.
Illinois Rule of Evidence 201 also refers to "legislative facts," which do not directly relate to the parties before the court. A court may take notice of legislative facts, but the procedural requirements of Rule 201 do not apply.
Be as persuasive as possible as you write your motion in a sequential, logical format. Express your ideas clearly, and make sure you outline what steps are necessary and how they will help your case. Use facts of the case whenever you can to avoid baseless emotional appeals.