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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
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Satisfying the
“particularity” requirement. §22:64
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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
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Responding to
missing, evasive, or incomplete answers. §25:274
-
How to correct
an inadvertent disclosure. §22:303
Privileges
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Unauthorized
disclosure by agent. §21:62
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Placing
privileged matter at issue. §21:90
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Protecting
lawyer-client communications. §21:110
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In-house
attorney challenges. §21:112
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Unprivileged
attorney-client items. §21:122
-
What is and is
not work product. §21:180
-
What constitutes
a trade secret. §21:230
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Scope and
limitations of patient-physician privilege. §21:250
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Therapist-patient communications. §21:280
Motions
-
Strategic
considerations. §14:13
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Pitfalls to
avoid. §14:20
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Practical advice
on pagination, titling, parties’ names, etc. §14:21
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Brief-drafting
tips. §14:60
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Service timing
issues. §14:112
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Grounds for
disqualifying the judge. §14:190
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Practical
hearing suggestions from the bench. §14:340
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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
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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
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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
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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:
Updated annually. ISBN
1-58012-077-6 Book price: $129
B7 |