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 more than 2,000 citations, more than 125 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
Illinois Pretrial Practice
