Illinois Pretrial Practice

by Judge Jennifer Duncan-Brice, James P. Flannery, Jr., Timothy W. Kelly, & Kevin G. Owens

Answers, Tips and Forms for Illinois Litigators

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:

bluearrow.gif (273 bytes) Federal Trial Evidence
bluearrow.gif (273 bytes) Preparing a Case for Trial in Federal Court
bluearrow.gif (273 bytes) Trial Evidence Foundations
bluearrow.gif (273 bytes) Trial Objections

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Updated 12/12/07 
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