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:

Law Books for Sale

Practice Management

Bankruptcy

Business

Civil Rights

Criminal

Employment

Estates and Trusts

Family

Insurance & Settlement

Litigation

Personal Injury

Social Security

State-Specific