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Chapter 1 — The Practical Application of Illinois Discovery Rules -
I. Introduction - II. Supreme Court Rule 201 — General Discovery Provisions
- [1.3] Discovery Methods
- [1.4] Full Disclosure
- [1.5] Privileges and Work Product
- [1.6] Individuals
- [1.7] Corporations
- [1.8] Work-Product Doctrine
- [1.9] Petrillo Doctrine
- [1.10] Consultants
- [1.11] Protective Orders
- [1.12] Timing of Discovery
- [1.13] Sequence of Discovery
- [1.14] Effect of Discovered Matter
- [1.15] Discovery Disputes
- [1.16] Filing Materials
- [1.17] Claims of Privilege
- III. Supreme Court Rules 202 – 212 — Depositions
- [1.18] Rule 202 — Purposes for Which Depositions May Be Used
- [1.19] Rule 203 — Where Depositions May Be Taken
- [1.20] Rule 204 — Compelling Appearance of Deponent
- [1.21] Deposition Subpoenas
- [1.22] Deposition Notices
- [1.23] Production of Documents in Lieu of Appearance of Deponent
- [1.24] Actions Pending in Other States
- [1.25] Depositions of Physicians
- [1.26] Rule 205 — Persons Before Whom Depositions May Be Taken
- [1.27] Notice of Deposition
- [1.28] Representative Deponent
- [1.29] Audiovisual Depositions
- [1.30] Remote Electronic Means Depositions
- [1.31] Method of Examination: Discovery vs. Evidence Depositions
- [1.32] Objections
- [1.33] Length of Depositions
- [1.34] Terminating Depositions
- [1.35] Rule 207 — Signing and Filing Depositions
- [1.36] Rule 208 — Fees and Costs
- [1.37] Rule 209 — Failure To Attend or Serve Subpoenas
- [1.38] Rule 210 — Depositions on Written Questions
- [1.39] Rule 211 — Errors, Irregularities, and Objections at Depositions
- [1.40] Discovery Depositions
- [1.41] Evidence Depositions
- [1.42] Partial Use of Depositions
- [1.43] Substitution of Parties, Dismissal, and Remand
- IV. [1.44] Supreme Court Rule 213 — Written Interrogatories
- [1.45] Number of Interrogatories
- [1.46] Answers and Objections
- [1.47] Option To Produce Documents
- [1.48] Identity and Testimony of Witnesses
- [1.49] Limitation on Testimony and Freedom To Cross-Examine
- [1.50] Use of Interrogatory Answers
- [1.51] Duty To Supplement
- [1.52] Supreme Court-Approved Interrogatories
- V. [1.53] Supreme Court Rule 214 — Discovery Production of Documents, Objects, and Tangible Things and Inspection of Real Estate
- VI. [1.54] Supreme Court Rule 215 — Physical and Mental Examination of Parties and Other Persons
- VII. [1.59] Supreme Court Rule 216 — Admission of Fact or Genuineness of Documents
- VIII. [1.62] Supreme Court Rule 217 — Depositions for the Purpose of Perpetuating Testimony
- IX. [1.63] Supreme Court Rule 218 — Initial Case Management
- X. Supreme Court Rule 219 — Sanctions for Failure To Comply with Discovery and Pretrial Procedures
- XI. [1.66] Supreme Court Rule 222 — Limited and Simplified Discovery in Certain Cases
- XII. [1.73] Supreme Court Rule 224 — Discovery Before Suit To Identify Responsible Persons and Entities
- Chapter 2 — Limitations on Discovery
- I. [2.1] Introduction
- II. [2.2] Scope of Discovery
- III. Constitutional Limitations
- IV. [2.8] Statutory Limitations
- [2.9] Marriage Privilege
- [2.10] Physician-Patient Privilege
- [2.11] Statutory Exceptions to the Physician-Patient Privilege
- [2.12] Judicially Created Exceptions to the Physician-Patient Privilege
- [2.13] Ex Parte Communications with Medical Providers
- [2.14] Psychotherapist-Patient Privilege
- [2.15] Clergy’s Privilege
- [2.16] Reporter’s Privilege
- [2.17] Accountant’s Privilege
- [2.18] Social Worker’s Privilege
- [2.19] Medical Studies Privilege
- [2.20] Other Statutory Limitations
- [2.21] The Informant’s Privilege
- [2.22] Union Agent and Union Member Privilege
- [2.23] Confidentiality of Statements Made to Counselors of Victims of Certain Crimes
- V. [2.24] Court Rule Limitations
- [2.25] Attorney-Client Privilege
- [2.26] Scope of the Attorney-Client Privilege
- [2.27] Necessity of Confidence
- [2.28] Exceptions to the Attorney-Client Privilege
- [2.29] Waiver of the Attorney-Client Privilege
- [2.30] Communications Between an Insured and an Insurance Carrier
- [2.31] Corporate Clients
- [2.32] Work-Product Doctrine
- [2.33] Protective Orders
- [2.34] Disclosure of Confidential Information
- [2.35] Destruction of Evidence
- VI. [2.36] Common-Law Limitations
- VII. [2.37] Conclusion
- Chapter 3 — Interrogatories
- I. [3.1] Nature and Purpose
- II. Preparing and Serving Interrogatories
- [3.4] Preliminary Considerations
- [3.5] Permissible Scope
- [3.6] Attorney-Client and Work-Product Privileges
- [3.7] Discovery Documents and Other Items
- [3.8] Lay witnesses
- [3.9] In general
- [3.10] “Expert witness” defined
- [3.11] Duty to supplement
- [3.12] Scope of expert witness’ testimony
- [3.13] Factual Basis for Pleading
- [3.14] Deciding Whether To Serve Interrogatories
- [3.15] Cost to Propounding Party
- [3.16] Effect on Responding Party
- [3.17] Anticipated Usefulness of Answers
- [3.18] Effect of Prior Discovery
- [3.19] Basic Principles
- [3.20] Definitions of Terms Used in Interrogatories
- [3.21] Contesting Interrogatories and Requests To Admit
- [3.22] Commencement of Discovery/Case Management
- III. Responding to Interrogatories
- [3.23] Duty To Respond
- [3.24] Statutory Requirements
- [3.25] Effect of Failure To Make Timely Response
- [3.26] Grounds for Objection
- [3.27] Irrelevant to the Subject Matter
- [3.28] Annoyance, Expense, Embarrassment, or Oppression
- [3.29] Information equally available to both parties
- [3.30] “Boilerplate” and “shotgun” interrogatories
- [3.31] Privilege and Work Product
- [3.32] Uncertain, Ambiguous, and Unintelligible Interrogatories
- [3.33] Objections That Have Been Held Invalid
- [3.34] Objections That Have Been Held Valid
- [3.35] Drafting Objections — Basic Principles
- [3.36] Who May Answer for Party
- [3.37] Made in Good Faith
- [3.38] Made in Bad Faith
- [3.39] Basic Rule
- [3.40] Impropriety of “I Don’t Know” Answer
- [3.41] Fifth Amendment Privilege
- [3.42] Answer by Reference to Business Records
- [3.43] Basic Considerations
- [3.44] Form and Verification of Answers
- [3.45] Answers by Reference to Other Answers or Other Documents
- [3.46] Reservation Concerning Subsequently Discovered Facts
- [3.47] Supplementation
- [3.48] Criteria for Amendment
- [3.49] Procedures
- IV. [3.50] Compelling Answers and Further Answers to Interrogatories
- V. [3.51] Using Interrogatories in Court
- VI. Appendix — Forms
- Chapter 4 — Production of Documents and Tangible Things
- I. Preliminary Considerations
- [4.1] Authority
- [4.2] Scope
- [4.3] Methods and Duplication of Discovery
- [4.4] Computer-Stored Information
- [4.5] Timing, Sequence, and Cutoff
- [4.6] Protective Orders
- [4.7] Supreme Court Rule 201(k)
- [4.8] Withholding Matters Claimed To Be Privileged
- [4.9] Costs of Production
- [4.10] Obtaining Leave of Court
- [4.11] Supreme Court Rule 213(e) — Attaching Documents to Answers to Interrogatories
- [4.12] Supreme Court Rule 213(f)(3) — Reports of Controlled Expert Witnesses
- [4.13] Supreme Court Rule 214
- [4.14] Objections
- [4.15] Affidavit of Compliance
- [4.16] Duty To Organize Materials Produced
- [4.17] Computer-Stored Information
- [4.18] Duty To Supplement
- [4.19] Supreme Court Rule 219
- [4.20] Supreme Court Rule 222 — Cases of $50,000 or Less
- [4.21] Depositions and Interrogatories
- [4.22] Request To Produce at Trial
- [4.23] Subpoena
- II. Procedures of Party Seeking Production
- [4.24] Basic Provisions
- [4.25] Scope of Request
- [4.26] Product in a Products Liability Case
- [4.27] Creating or Locating Objects
- [4.28] Corporate Memory
- [4.29] Mental Health and Alcohol Abuse Records
- [4.30] Lists of Law Clients
- [4.31] Identity of Medical Patients
- [4.32] Lists of Witnesses
- [4.33] Statements of Employees
- [4.34] Statement of Nonparty Taken by Insurance Company
- [4.35] Identity of Consulting Expert
- [4.36] Basic Request
- [4.37] Products Liability
- [4.38] Medical Negligence
- [4.39] Railroad Crossings
- [4.40] Premises Liability
- [4.41] Construction Negligence
- [4.42] Obtaining Court Order for Failure To Respond to Request for Production
- [4.43] Sanctions for Withholding Available Evidence
- [4.44] Sanctions for Disposing of Available Evidence
- [4.45] In General
- [4.46] Records Depositions
- III. Procedures of Party Responding
- Chapter 5 — Oral Deposition Preparation
- I. [5.1] Scope of Chapter
- II. [5.2] Statutory Foundations for Taking Oral Depositions
- [5.3] Who Can Be Deposed?
- [5.4] Proceedings in Which Depositions May Be Taken
- [5.5] Potential Deponents
- [5.6] Parties
- [5.7] Witnesses
- [5.8] Limits on Who Can Be Deposed
- [5.9] Respondents in Discovery
- [5.10] What Type of Oral Deposition?
- [5.11] Where Should the Deposition Proceed?
- [5.12] When Should the Deposition Be Taken?
- [5.13] How Should the Deposition Proceed?
- [5.14] Notices for Depositions
- [5.15] Subpoena Depositions
- [5.16] Video Depositions
- [5.17] Stipulations
- [5.18] Compelling Production of Deponents’ Documents
- [5.19] Interstate or International Depositions
- [5.20] Special Considerations for International Depositions
- [5.21] Petition To Perpetuate Testimony
- [5.22] Costs
- III. [5.23] Oral Deposition Preparation
- [5.24] Determining Which Witnesses To Depose Using Supreme Court Rule 213(f) Requiring Disclosure of Witnesses for Trial
- [5.25] Lay Witnesses
- [5.26] Independent Expert Witnesses
- [5.27] Controlled Expert Witnesses
- [5.28] Preparing To Take or To Attend Discovery Deposition
- [5.29] Preparing To Present Deponent
- [5.30] Privileges
- [5.31] Preparing for Evidence Deposition
- IV. Appendix
- Chapter 6 — Deposition Taking
- I. Introduction
- II. Taking a Deposition
- [6.4] Parties and Consulting Experts
- [6.5] Second Interpreter and Second Court Reporter
- [6.6] Excluding Nonparty Witnesses and the Public
- [6.7] Usual Procedure Regarding Stipulations
- [6.8] Initial Statements for the Record — Discovery or Evidence Deposition
- [6.9] Keys to Successful Deposition Taking
- [6.10] Inquisitiveness
- [6.11] Thoroughness — Time Limit for Discovery Depositions
- [6.12] Sample deposition outline-checklist
- [6.13] Use of deposition outline-checklist
- [6.14] Preliminary Statement to the Deponent
- [6.15] Responding to a Request for Prior Statements of the Deponent
- [6.16] Setting the Tone of the Deposition and Sequence of Questioning
- [6.17] The Reasons for a Deposition Determine the Form of Questions
- [6.18] To discover information
- [6.19] To commit the deponent to specific facts
- [6.20] To obtain admissions
- [6.21] To secure impeaching testimony
- [6.22] To gain an impression of the deponent
- [6.23] Changing the manner of formulating questions
- [6.24] Securing Documents and Photographs Before a Deposition
- [6.25] Securing Documents Used To Refresh the Deponent’s Recollection
- [6.26] Marking Documents and Photographs as Exhibits
- [6.27] Drawing on a Photograph at a Deposition
- [6.28] Response of “I Don’t Recall”
- [6.29] Response of “I Don’t Know”
- [6.30] Nonresponsive Answer — Certifying the Question
- [6.31] Defects in the Form of an Answer
- [6.32] Refusal To Answer
- [6.33] Supreme Court Rule 213(f) Witnesses
- [6.34] Physicians
- [6.35] Experts
- [6.36] Deponents Who Speak a Foreign Language
- [6.37] Minors
- [6.38] Written Questions at a Deposition
- [6.39] Concluding a Deposition — Deponent’s Reading and Signature
- [6.40] Listening in Silence
- [6.41] Objecting to Improper Questions
- [6.42] Reining in Obstreperous Opposing Counsel
- [6.43] Instructing the Deponent Not To Answer
- [6.44] Terminating the Deposition
- [6.45] Examining the Deponent
- [6.46] General Requirements
- [6.47] Detailed Procedures
- [6.48] Depositions by Videoconference
- III. Post-Deposition Proceedings
- IV. [6.53] Conclusion
- Chapter 7 — Interjurisdictional Depositions
- I. [7.1] Scope of Chapter
- II. Taking Depositions Out of State for Use in Illinois
- [7.2] Statutory Authority
- [7.3] Strategy and Tactics
- [7.4] Conflict of Laws Problems
- [7.5] Associating Local Counsel
- [7.6] Selecting Deposition Officer
- [7.7] Party
- [7.8] Initiating Deposition: Need for a Commission
- [7.9] Notice (if held applicable
- [7.10] Compelling attendance and production
- [7.11] Before whom depositions may be taken
- [7.12] Objections and protective orders
- [7.13] Post-deposition procedure
- [7.14] Notice (if held applicable)
- [7.15] Compelling attendance and production
- [7.16] Before whom depositions may be taken
- [7.17] Objections and protective orders
- [7.18] Post-deposition procedure
- [7.19] Notice (if held applicable)
- [7.20] Compelling attendance and production
- [7.21] Before whom depositions may be taken
- [7.22] Objections and protective orders
- [7.23] Post-deposition procedure
- [7.24] Use at Trial
- III. Taking Depositions in Foreign Countries for Use in Illinois
- IV. Taking Depositions in Illinois for Use Out of State
- V. Appendix
- Chapter 8 — Motions for Physical and Mental Examinations
- I. Scope of Chapter
- II. Preliminary Considerations
- III. Procedures
- [8.13] When Request Must Be Made
- [8.14] Examination by Agreement of Parties
- [8.15] Contents of Motion
- [8.16] Documents in Opposition
- [8.17] Affidavit in Opposition
- [8.18] Protective Order
- [8.19] Sanctions for Failure To Comply with Order
- [8.20] Persons Entitled to Report
- [8.21] Consequences of Failure To Provide Report
- [8.22] Use of Report at Trial
- [8.23] Status of Examiner
- [8.24] Impartial Medical Examination
- [8.25] Evidence
- [8.26] Reports
- IV. Tactical Considerations
- V. [8.34] Conclusion
- VI. Appendix — Forms for Use in Connection with Examination
- Chapter 9 — Quasi-Discovery
- I. Bills of Particulars
- [9.1] Purpose and Nature
- [9.2] Amplification of Pleadings
- [9.3] Limitation of Recovery or Causes of Action
- [9.4] Limitation of Proofs at Trial
- [9.5] Action in Which Demand for Bill May Be Made
- [9.6] Motion for More Particular Statement
- [9.7] Motion To Strike Pleadings
- [9.8] Discovery
- [9.9] Who May Make Demand for Bill
- [9.10] When and How Demand Is Made
- [9.11] Objections
- [9.12] Time for Response
- [9.13] Content of Bill
- [9.14] Amendments to Bill
- [9.15] Filing and Service
- [9.16] Motion To Strike Bill or for More Complete Bill
- [9.17] Demand for Further Bill
- [9.18] Sanctions Pursuant to Supreme Court Rule 219(c)
- [9.19] Federal Rules of Civil Procedure
- [9.20] Notice and Demand for Bill of Particulars
- [9.21] Response to Bill of Particulars
- [9.22] Motion To Deny Demand for Bill of Particulars
- [9.23] Motion for Additional or More Specific Particulars
- II. Compelling Production at Trial
- [9.24] The Basics of Supreme Court Rule 237
- [9.25] Supreme Court Rule 237(a) — Witnesses
- [9.26] Supreme Court Rule 237(b) — Documents or Tangible Things
- [9.27] Not a Vehicle for Discovery
- [9.28] Persons and Matter Subject to Production
- [9.29] Scope of Production
- [9.30] When Notice May Be Served
- [9.31] Contents of the Notice — Description of Persons or Items To Be Produced
- [9.32] Compliance
- [9.33] Objections
- [9.34] Motion To Quash Supreme Court Rule 237 Request
- [9.35] Failure or Refusal To Respond
- [9.36] Appellate Review
- [9.37] Federal Procedure
- [9.38] Notice To Produce
- [9.39] Objection to Supreme Court Rule 237 Notice
- III. Requests for Admissions of Facts and Genuineness of Documents
- [9.40] Supreme Court Rule 216; Related Federal Procedure
- [9.41] Nature and Purpose
- [9.42] Effect of Admission
- [9.43] Procedure for Submitting Requests for Admissions
- [9.44] When Requests May Be Served
- [9.45] Number of Requests Allowed
- [9.46] Admissions of Fact
- [9.47] Genuineness of Documents
- [9.48] Federal Practice
- [9.49] Responses to Requests for Admissions
- [9.50] Denials
- [9.51] Good Faith/Good Reasons Requirement for Denials
- [9.52] Objections to Requests
- [9.53] Failure To Timely Respond
- [9.54] Res Judicata
- [9.55] Public Records
- [9.56] Request for Admission of Facts or Genuineness of Documents
- [9.57] Answer to Request for Admission
- [9.58] Objection to Request for Admission
- Chapter 10 — Remedies for Noncompliance
- I. Introduction
- II. Compelling Discovery
- [10.3] Scope of Trial Court’s Authority
- [10.4] Various Types of Discovery
- [10.5] Depositions
- [10.6] Compelling Attendance
- [10.7] Compelling Answers to Specific Questions
- [10.8] Compelling Witness To Produce Documents
- [10.9] Interrogatories
- [10.10] Requests To Produce
- [10.11] Motions for Physical Examination
- [10.12] Methods
- [10.13] Moving Party
- [10.14] Opposing Party
- [10.15] Grounds
- [10.16] Order
- [10.17] Appellate Review
- [10.18] Generally Interlocutory and Not Immediately Appealable
- [10.19] Contempt
- [10.20] Supreme Court Rule 224
- [10.21] Mandamus
- III. Sanctions
- [10.22] Scope of Trial Court’s Authority
- [10.23] Sanctions Against Parties
- [10.24] Motion for Sanctions
- [10.25] Unreasonable Failure To Comply with Discovery Rules
- [10.26] Failure To Comply with Order
- [10.27] Need for a Just Order
- [10.28] Imposition of Sanctions
- [10.29] Stay of further proceedings
- [10.30] Barring testimony
- [10.31] Extreme sanctions
- [10.32] Burden on sanctioned party
- [10.33] Cautionary Note
- [10.34] Sanctions Against Nonparties
- [10.35] Sanctions Against Attorneys
- [10.36] Depositions
- [10.37] Interrogatories
- [10.38] Requests To Produce
- [10.39] Motions for Physical Examination
- [10.40] Prerequisites
- [10.41] Moving Party
- [10.42] Opposing Party
- [10.43] Order
- [10.44] Sanctions Under Supreme Court Rule 137
- IV. [10.45] Conclusion
- V. Appendix
- [10.46] Motion for Protective Order
- [10.47] Motion To Compel Party To Appear for Deposition
- [10.48] Petition for Rule To Show Cause — Nonparty — Failure To Appear for Deposition
- [10.49] Rule To Show Cause — Nonparty — Compel Appearance for Deposition
- [10.50] Motion To Compel Deponent To Answer Deposition Questions
- [10.51] Motion To Compel Production of Certain Documents at Time of Oral Examination
- Chapter 11 — Special Considerations in an Automobile Accident Case
- I. [11.1] Introduction
- II. [11.2] Pre-Suit Investigation by the Plaintiff
- III. [11.5] Written Discovery
- [11.6] Standard Interrogatories
- [11.7] Numerical Limits
- [11.8] Duty To Supplement Answers to Interrogatories
- [11.9] Trial Witnesses
- [11.10] Lay Witnesses
- [11.11] Independent Expert Witnesses
- [11.12] Controlled Expert Witnesses
- [11.13] Preparing Answers to Written Interrogatories
- [11.14] Requests To Produce
- [11.15] Obtaining Records
- [11.16] Request for Medical Examination
- [11.17] Preparation Is the Key
- [11.18] Deposition Procedures
- [11.19] Use of Depositions
- [11.20] Rear-End Collision
- [11.21] Sideswipe
- [11.22] Left Turn
- [11.23] Red Light-Green Light
- [11.24] Auto-Pedestrian
- [11.25] Auto-Bicycle
- [11.26] Stop Sign-Through Street
- [11.27] Types of Depositions
- [11.28] Witness Depositions
- [11.29] Depositions of Parties
- [11.30] Preparing your own client for deposition
- [11.31] Preparing for an adverse party deposition
- [11.32] Taking the defendant driver’s deposition
- IV. Additional Discovery Considerations
- V. [11.36] Standard Interrogatories and Request To Produce in Automobile Cases
- Chapter 12 — Special Considerations in a Construction Injury Case
- Chapter 13 — Special Considerations in a Medical Negligence Case
- Chapter 14 — Special Considerations in a Federal Employers’ Liability Act Plaintiff’s Case
- I. [14.1] Introduction
- II. [14.2] Initial Interview with Federal Employers’ Liability Act Client
- III. [14.3] Statements of Witnesses
- IV. [14.4] Ex Parte Interviews and Statements of Witnesses
- V. [14.5] Railroad Records
- VI. [14.6] Union Officials
- VII. [14.7] Rule Books
- VIII. [14.8] Governmental Regulations and Publications
- IX. [14.9] Other Publications
- X. [14.10] Association of American Railroads Documents/Craft Job Descriptions
- XI. [14.11] Contract Between Union and Railroad
- XII. [14.12] Transcript of Investigation
- XIII. [14.13] Experts
- XIV. [14.14] Rehabilitation
- XV. [14.15] Prediscovery Tool — Preserve Evidence Letter; Sample Letter
- XVI. Discovery Tools
- XVII. [14.20] Retaliatory Discharge
- XVIII. [14.21] Conclusion
- Chapter 15 — Special Considerations in a Federal Employers’ Liability Act Defendant’s Case
- Chapter 16 — Special Considerations in a Class Action
- I. What Is Unique About Discovery in Class Action Cases
- [16.1] Discovery Regarding Class Issues Should Be Done as Soon as Practicable
- [16.2] Federal Legislation Impacting Timing of Discovery
- [16.3] Federal Court Stays of State Court Discovery
- [16.4] Private Securities Litigation Reform Act Stays and Derivative Actions
- [16.5] Pre-Certification Communications with Putative Class Members
- [16.6] Discovery of Absent Class Members
- II. [16.7] Areas for Discovery in Class Action Cases
- Chapter 17 — Special Considerations in a Wrongful-Death Case
- I. [17.1] Introduction
- II. Plaintiff’s Case
- [17.2] First Client Contact
- [17.3] Next of Kin
- [17.4] Medical Providers
- [17.5] Inquest Testimony
- [17.6] Supreme Court Rule 213 Interrogatories
- [17.7] Prefiling Statements
- [17.8] The Complaint
- [17.9] Document Production
- [17.10] Witnesses
- [17.11] Expert Witnesses
- [17.12] Supreme Court Rule 216 Requests To Admit Facts
- [17.13] Expert Discovery
- III. Defendant’s Investigation and Trial Preparation
- IV. [17.17] Summary
- Chapter 18 — Special Considerations in a Products Liability Case
- Chapter 19 — Special Considerations in a Premises Liability Case
- Index
- List of Forms
- Lew R.C. Bricker
Lew R.C. Bricker
Lew R.C. Bricker is a Partner at Amundsen Davis, LLC, in Chicago, where he concentrates his practice in commercial transportation and products liability. He is a BTI Client Service All Star and a Thomson Reuters Stand Out Lawyer, and he is rated AV Preeminent by Martindale-Hubbell. Bricker received his B.A. cum laude from the University of Illinois, where he was also Phi Beta Kappa, and his J.D. cum laude from the University of Illinois College of Law.
- Erin Lynch Cordier
Erin Lynch Cordier
No bio available.
- Christopher G. Dean
Christopher G. Dean
No bio available.
- Thomas A. Demetrio
Thomas A. Demetrio
Thomas A. Demetrio is a Cofounding Partner at Corboy & Demetrio, P.C., in Chicago, where he focuses on the areas of personal injury and wrongful death. He is a member of the International Academy of Trial Lawyers and the American College of Trial Lawyers, as well as a 30-year member of the Inner Circle of Advocates. Demetrio received his B.A. from the University of Notre Dame and his J.D. from IIT Chicago-Kent College of Law, where he was a Past Chair of the Board of Advisers.
- Joseph G. Feehan
Joseph G. Feehan
No bio available.
- Kevin M. Forde
Kevin M. Forde
Kevin M. Forde is a Partner in Forde Law Offices LLP, in Chicago, where he focuses his practice in commercial litigation, including trials and appeals. He has served as the President of the Federal Defender Program, Northern District of Illinois; a member of Senator Richard Illinois Durbin’s Judicial Screening Committee (2009 – present); and a member of Justice Anne Burke’s Judicial Screening Committee. Among his recognitions are the 2014 Certificate of Appreciation, presented by the Federal Judges Association; the 2014 John Paul Stevens Award, conferred by the Chicago Bar Association; and the 2002 Amicus Curiae Award, presented by the Illinois Judges Association. Mr. Forde is a member of the American College of Trial Lawyers, the International Academy of Trial Lawyers, and the American Academy of Appellate Lawyers. He received his B.S. from Marquette University and his J.D. from Loyola University School of Law, Medal of Excellence.
- M. John Hefner, Jr.
M. John Hefner, Jr.
M. John Hefner, Jr., is a Sole Practitioner in Mattoon, where he focuses on professional negligence, products liability, and wrongful death. He has been Martindale-Hubbell AV Preeminent Rated for over 20 years. He is the author of New Power of the Chapter IX Bankruptcy Court to Authorize the Issuance of Certificates of Indebtedness: Congressional Relief or Congressional Overreaching?, 51 A.Bankr.L.J. 1 – 18 (1977). Mr. Hefner received his B.A. from Southern Illinois University Edwardsville and his J.D. from St. Louis University School of Law.
- Richard Fred Johnson
Richard Fred Johnson
Richard Fred Johnson is the owner of the Law Office of Richard Fred Johnson, in Chicago, where he concentrates his practice in general, transportation, and personal injury law. He is a member of the Illinois State Bar Association, the National Association of Railroad Trial Lawyers, and the National Immigrant Justice Center. Johnson received his B.S. from Miami University and his J.D. cum laude from Northwestern University School of Law.
- David R. Jones
David R. Jones
David R. Jones is a Principal with the Law Office of Beatty, Motil & Jones in Glen Carbon. He is licensed in Illinois, Missouri, all three Illinois federal districts, the Southern District of Indiana, and the Western District of Kentucky. He has tried cases in eight states in both federal and state courts. Mr. Jones earned his A.B. from Washington University, his M.A. from St. Louis University, and his J.D. from St. Louis University School of Law.
- Michael C. Kominiarek
Michael C. Kominiarek
Michael C. Kominiarek, a member of the Chicago firm of Kominiarek Bresler Harvick & Gudmundson, LLC, concentrates his practice in civil litigation with a focus on defense of medical malpractice cases for physicians and hospitals. A graduate of Marquette University, he received his J.D. from The John Marshall Law School. Mr. Kominiarek is licensed in Illinois and Indiana. Mr. Kominiarek is a member of the Illinois State, Indiana State, and Southwest Bar Associations and the Society of Trial Lawyers. He is also a past president of the Southwest Bar Association.
- Daniel M. Kotin
Daniel M. Kotin
Daniel M. Kotin is a Partner at Tomasik Kotin Kasserman, LLC, in Chicago, where he focuses on trial law. He is a member of the Chicago Bar Association, the Illinois Trial Lawyers Association, and the Society of Trial Lawyers. Kotin earned his B.A. cum laude from Boston College and his J.D. cum laude from Loyola University of Chicago School of Law.
- Jeffrey J. Kroll
Jeffrey J. Kroll
Jeffrey J. Krollis a Partner at Kaveny + Kroll in Chicago, where he concentrates his practice in personal injury and wrongful death. He has been named to the Illinois Super Lawyers list since 2005 and has been named one of the Top 100 Trial Lawyers in Illinois by the American Association for Justice (formerly ATLA) for ten consecutive years. Mr. Kroll received his B.A. from DePaul University and his J.D. from the DePaul University College of Law.
- John J. Lynch
John J. Lynch
No bio available.
- Kevin R. Malloy
Kevin R. Malloy
Kevin R. Malloy is an associate at Forde & O’Meara LLP in Chicago, where he concentrates his practice in commercial litigation and appeals. He is a member of the Appellate Lawyers Association, the Chicago Bar Association (where he served as an investigator with the Judicial Evaluation Committee), and the Illinois State Bar Association. He was rated as a Super Lawyer in business litigation in 2024. Mr. Malloy received his B.A. from the University of Notre Dame and his J.D. cum laude from the American University Washington College of Law.
- Craig W. Mandell
Craig W. Mandell
Craig W. Mandell is an associate at Hinkhouse Williams Walsh LLP, in Chicago, where he focuses his practice on products liability, trademark infringement/dilution, and copyright infringement. He is a member of the Chicago Bar Association and the International Trademark Association, and he has also been recognized as an Illinois Super Lawyer. Mandell received his B.A. from the University of Wisconsin and his J.D. from DePaul University College of Law, where he was a member of the DePaul Law Review and Cofounder of the DePaul University Arts, Technology, and Intellectual Property Law Journal.
- Richard L. Miller II
Richard L. Miller II
Richard L. Miller II is a Partner at Miller PC, in Chicago, where he concentrates his practice in commercial litigation, class actions, and labor law. He has litigated disputes involving business contracts, employment law, insurance coverage, trademarks, partnership agreements, and corporate veil-piercing claims, among others. Miller is an Adjunct Professor at Northwestern Pritzker School of Law, where he has served as an instructor for Trial Advocacy since 2005 and for Advanced Trial Advocacy since 2013. He has been an arbitrator for the American Arbitration Association since 2008, for FINRA since 2018, and for the Cook County Mandatory Arbitration Program from 2003 to 2005. As an assistant state’s attorney, he prosecuted approximately 50 jury trials, including two murder cases. Miller has served on the IICLE® Board of Directors since 2023. He has also spoken for IICLE® programs, including Trial Advocacy for Civil Litigators (2019) and Laying Foundations for Introducing Evidence (2018), and he served on the faculty for IICLE®’s Trial Advocacy series, speaking on motions, negotiating settlements, and cross-examinations. He has been repeatedly recognized as a Leading Lawyer, Super Lawyer, and Rising Star. In 2008, he was named one of the 40 Illinois Attorneys Under 40 To Watch by the Law Bulletin Publishing Company, which publishes the Chicago Lawyer and Chicago Daily Law Bulletin. Miller is a Past President of the Law Alumni Board for the University of Illinois College of Law. He attended the University of Illinois College of Law on a full, merit scholarship and graduated cum laude in 1997. He graduated magna cum laude from the University of Illinois College of Business in 1992.
- Thomas J. Nathan
Thomas J. Nathan
No bio available.
- Mai Lin P. Noffke
Mai Lin P. Noffke
No bio available.
- David V. O'Connor
David V. O'Connor
No bio available.
- Justin A. Relihan
Justin A. Relihan
Justin A. Relihan is Vice President of Legal Services for Nidec Americas Holding Corporation, in St. Louis, Missouri, where he is responsible for all legal functions for the corporation in the Western Hemisphere, including management of all claims, products liability litigation, business litigation, warranty claims, and all other litigation matters. He is a member of the DRI and the Association of Corporate Counsel. Relihan received his B.A. from the College of the Holy Cross and his J.D. from The John Marshall Law School.
- Michelle J. Rozovics
Michelle J. Rozovics
No bio available.
- Jeffrey A. Schulkin
Jeffrey A. Schulkin
Jeffrey A. Schulkin is a Partner at Ankin Law Office in Chicago, where he concentrates his practice on medical malpractice. He is Chair for the Illinois State Bar Association’s Section Council (2026 – 2027). Schulkin received his BA from the University of Illinois Urbana-Champaign and his JD from the Chicago-Kent College of Law.
- Susan J. Schwartz
Susan J. Schwartz
Susan J. Schwartz is a Partner at Corboy & Demetrio, P.C., in Chicago, where she is a trial lawyer focusing on medical negligence cases on behalf of patients and their families. She serves on the Advisory Board for Coordinated Advice and Referral Program for Legal Services and previously served as an officer and on the Board of Directors for the Women’s Bar Foundation and the Board of Governors for Loyola University Chicago School of Law. She is a member of the American Board of Trial Advocates and has served on the Board of Managers for the Illinois Trial Lawyers Association. Ms. Schwartz received her B.S.F.S. from Georgetown University and her J.D. from Loyola University Chicago School of Law.
- Meghan M. Sciortino
Meghan M. Sciortino
Meghan M. Sciortino is a Shareholder of Johnson & Bell, Ltd., in Chicago, where she concentrates her practice in products liability, premises liability, and construction negligence. She is a member of the DRI and was named an Emerging Lawyer by Leading Lawyers in 2015 and an Illinois Super Lawyer Rising Star in 2013 – 2017. Ms. Sciortino received her B.A. from Purdue University and her J.D. from IIT Chicago-Kent College of Law.
- Miles J. Zaremski
Miles J. Zaremski
Miles J. Zaremski is the Founding Partner of the Zaremski Law Group in Highland Park, where he concentrates his practice in healthcare, professional medical liability, alternative dispute resolution, and appeals. He is a member of the Illinois State Bar Association and Who’s Who in American Law and has been named an Illinois Leading Lawyer and an Illinois Super Lawyer in healthcare. Mr. Zaremski received his B.S. from the University of Illinois and his J.D. from Case Western Reserve University School of Law.
Civil Discovery Practice (Illinois) (ARCHIVED 2014 EDITION)
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