Illinois Pretrial Practice

Illinois Pretrial Practice delivers quick and reliable answers with its unique outline format, tight writing, superb scholarship, and extensive citations. Its practice-tested forms and pattern paragraphs speed drafting.

This book concentrates on the topics where questions and disputes arise. It devotes pages where you spend time: drafting pleadings, preparing and presenting motions, conducting discovery, resolving discovery disputes, and negotiating settlements. You will find coverage of troublesome matters like:

Written Discovery

Techniques for obtaining damaging documents. §22:60
How to obtain a log of privileged documents. §22:45
Satisfying the “particularity” requirement. §22:64
What is and isn’t discoverable. §20:20
How to expedite discovery. §20:110
Tips for crafting “objection-proof” interrogatories. §25:180
Dealing with problem interrogatories. §25:290
Responding to missing, evasive, or incomplete answers. §25:274
How to correct an inadvertent disclosure. §22:303

Privileges

Unauthorized disclosure by agent. §21:62
Placing privileged matter at issue. §21:90
Protecting lawyer-client communications. §21:110
In-house attorney challenges. §21:112
Unprivileged attorney-client items. §21:122
What is and is not work product. §21:180
What constitutes a trade secret. §21:230
Scope and limitations of patient-physician privilege. §21:250
Therapist-patient communications. §21:280

Motions

Strategic considerations. §14:13
Pitfalls to avoid. §14:20
Practical advice on pagination, titling, parties’ names, etc. §14:21
Brief-drafting tips. §14:60
Service timing issues. §14:112
Grounds for disqualifying the judge. §14:190
Practical hearing suggestions from the bench. §14:340
Motions requiring evidentiary hearings. §14:350
Grounds for emergency motions. §14:380

Illinois Pretrial Practice provides authoritative and direct responses to everyday discovery issues like these:

Paper discovery

Strategic considerations when confidential information is sought. §25:290
The limited situations when seeking a protective order is advisable. §25:370
Must I answer this interrogatory? §25:210
What are the best grounds and tactics for refusing to respond to interrogatories? §25:280
Which objections to a notice to produce are likely to stand up? §22:230
What are the best grounds and tactics for withholding documents from production? §22:240

Depositions

What are the procedures for subpoenaing a non-party witness for deposition? §23:120
When is it appropriate and not appropriate to suspend a deposition? §23:280
What should examining counsel do when a witness refuses to answer questions at deposition? §23:303
When representing a deposition witness, when should I instruct the deponent not to answer a question or produce a document? §23:392
What objections are proper during a deposition? §23:263

Other issues

Practical considerations in discovery disputes. §27:05
What can I do when intransigent opposition stonewalls my discovery? §27:30
When is supervision warranted? §27:33
How do I formally compel compliance with my discovery requests? §27:60
When can I expect to be successful if I move for sanctions? §27:44
What information can I protect under a privilege? §21:101
What is and isn’t protected as work product? §21:190

The book’s issue-oriented outline format is supported by 1,900 citations, 110 forms, advice from the bench, recent case-based illustrations, practice-proven strategies, step-by-step procedures, pattern language, and a full-text CD. Coverage runs from taking the case up to trial, and includes numerous tips on how to:

Avoid and fix mistakes
Resolve peripheral disputes
Craft better documents
Answer ethical questions
Process cases efficiently
Improve your advocacy

Updated annually. ISBN 1-58012-077-6 Book price: $129

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Related Titles:

Federal Trial Evidence

Preparing a Case for Trial in Federal Court

Trial Evidence Foundations

Trial Objections

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Updated 07/15/10