Meet and Confer Statement
(IL)

Summary

This template is a clause to include in a discovery motion (like a motion to compel) to demonstrate that you have satisfied your "meet and confer" obligations under Illinois Supreme Court Rule (Supreme Court Rule) 201(k). The template includes practical guidance, drafting notes, and alternate clauses. While some courts have held that "strict technical compliance with [Supreme Court] Rule 201(k) is not required "so long as the record reflects that the movant attempted to resolve his difficulties with his opponent prior to seeking judicial intervention in discovery matters," avoid uncertainty and include this statement in any discovery-related motion. Ill. State Bar Ass'n Mut. Ins. Co. v. Cavenagh, 2012 IL App (1st) 111810, ¶ 48. Though this template begins with numbered paragraphs, you should still insert it into your motion where appropriate. Since a Supreme Court Rule 201(k) consultation is a prerequisite to bringing a discovery-related motion, consider recounting these efforts before reciting the relevant facts and legal arguments. For a related template, see Discovery Deficiency Letter (IL). For related practice notes, see Motion Practice: Making a Motion (IL), Discovery Planning and Strategy (IL). For related checklists, see Motion Practice: Making a Regular Motion Checklist (Cook County) (IL) and Motion Practice: Making a Contested Motion Checklist (Cook County) (IL).