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Table of Contents

List of Forms by Chapter

Chapter 1 — Deposition and Discovery

Chapter 2 — Protecting Litigation Rights

Chapter 3 — Tax Aspects of Litigation

Chapter 4 — Injunctions

Chapter 5 — Declaratory Relief

Chapter 6 — Voluntary and Involuntary Dismissal

Chapter 7 — Default and Default Judgment

Chapter 8 — Illinois Summary Judgment

Chapter 9 — Pretrial Conference

Chapter 10 — Final Preparations for Trial

Chapter 11 — Motions, Requests, and Notices in Preparation for Trial

Chapter 12 — Some Proof of Facts in Civil Cases

Authors

Nicholas A. Caputo
Nicholas A. Caputo
Nicholas A. Caputo is a shareholder of the Caputo Law Firm, P.C., in Chicago, practicing complex civil litigation in the areas of commercial and general litigation. He is also an adjunct professor at IIT Chicago-Kent College of Law, where he teaches Trial Advocacy I, Intensive Trial Advocacy, Evidence and Advocacy, and Litigation Technology, and serves as a coach for the IIT Chicago-Kent College of Law Trial Advocacy Program. He received his B.S./B.A. cum laude from Villanova University. He received his J.D. cum laude from IIT Chicago-Kent College of Law, where he served as teaching assistant to Professor Ralph Brill, was a member of the Trial Advocacy Team, and was awarded membership in the Bar & Gavel Society. He is admitted to practice in Illinois and Minnesota as well as before the United States District Courts in the Northern District of Illinois and the Northern District of Indiana. Mr. Caputo is a member of the Illinois State Bar Association. He was twice elected to the ISBA Assembly (2002 and 2005) and serves by appointment on the Standing Committee on Legal Education, Admission, and Competence. He has been a member of the ISBA Fellows since 2006. He is a frequent lecturer on trial advocacy as well as the use of technology in litigation. He has been recognized as the IIT Chicago-Kent College of Law Adjunct Professor of the Year (2010 – 2011), as a Rising Star by Illinois Super Lawyers (2011), and is the recipient of the IIT Chicago-Kent Young Alumni Award (2011).
Robert Marc Chemers
Robert Marc Chemers
Robert Marc Chemers is a Shareholder of Pretzel & Stouffer, Chartered, in Chicago, where he focuses on insurance coverage and appellate practice. He is a Fellow of the American College of Coverage Counsel and a member of the Illinois State and Chicago Bar Associations. Mr. Chemers received his B.A. magna cum laude from the University of Southern California and his J.D. cum laude from the Indiana University Robert H. Mckinney School of Law.
Steven A. Hart
Steven A. Hart
Steven A. Hart is an equity partner at Segal McCambridge Singer & Mahoney, Ltd., in Chicago, where he is a trial lawyer with a concentration in product liability, toxic tort, environmental, automotive, and transportation law. Mr. Hart also represents corporations in employment-related matters and currently acts as national coordinating and trial counsel for several Fortune 500 companies in asbestos and environmental litigation. He received his B.A. from the University of Wisconsin and his J.D. from The John Marshall Law School. He is a member of the Illinois and New York State Bars. Mr. Hart is a published legal author and frequent lecturer. He has been asked to speak before numerous bar associations and legal groups, including the Chicago Bar Association, the Defense Research Institute, Sterling Education Services, and the American Bar Association. Mr. Hart is a member of the Defense Research Institute, the American Trial Lawyers Association, the Chicago Bar Association, and the Risk and Insurance Management Society. Mr. Hart has continuously been nominated and selected by peers in the legal community as an Illinois Super Lawyer (representing the top five percent of all attorneys in Illinois).
Adam Jagadich
Adam Jagadich
Adam Jagadich is an associate with the firm of Segal McCambridge Singer & Mahoney, Ltd., in Chicago, where he concentrates his practice in defense of product liability, toxic tort, and commercial litigation matters. He received his B.A. from Purdue University and his J.D. from the University of Wisconsin Law School.
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.
Carson D. Maricle
Carson D. Maricle
Carson D. Maricle is an associate at Mathis, Marifian & Richter, Ltd., in Belleville, where he concentrates his practice in estate planning, probate, taxation, and general business law. He is a member of the Illinois and Missouri Bars. Mr. Maricle received a B.A. magna cum laude in both Criminal Justice Studies and Political Science from Southern Illinois University Edwardsville in 2006. He is a 2010 graduate of Southern Illinois University School of Law, where he graduated cum laude and served on the Board of Editors for the Law Journal.
Patrick B. Mathis
Patrick B. Mathis
Patrick B. Mathis is a Shareholder of Mathis Marifian & Richter, Ltd., in Belleville, where he concentrates his practice in civil tax appeals and tax litigation, criminal tax defense, tax planning, estate planning, probate, and banking and business law. He is member of the American, Illinois State, and St. Clair County Bar Associations, the American College of Trust and Estate Counsel, and the Illinois Supreme Court Mandatory Continuing Legal Education Commission. In 2010, he received the Addis E. Hull Award of Excellence from IICLE^®. He served as Chairman of the IICLE^® Board of Directors in 1996 – 1997. Mr. Mathis received his B.A. from St. Louis University and his J.D., M.B.A., and LL.M. in Taxation from Washington University in St. Louis.
Gregory M. McMahon
Gregory M. McMahon
Gregory M. McMahon is an associate with the firm of Segal McCambridge Singer & Mahoney, Ltd., in Chicago. He is a member of the American, Illinois State, and Chicago Bar Associations. He received his B.A. from the University of Southern California and his J.D. from DePaul University College of Law.
Richard L. Miller II
Richard L. Miller II
Richard L. Miller II is a Partner at Miller PC in Chicago, concentrating his practice in commercial litigation, labor law, and class actions. Mr. Miller is an Adjunct Professor at Northwestern University Pritzker School of Law, where he has served as an instructor for Trial Advocacy since 2005 and Advanced Trial Advocacy since 2013. He has been an arbitrator for the American Arbitration Association since 2008, FINRA since 2018, and the Cook County Mandatory Arbitration Program from 2003 – 2005. Mr. Miller prosecuted approximately 50 jury trials as an assistant state’s attorney, including two murder cases. He has spoken at IICLE^® events addressing “Trial Advocacy for Civil Litigations” (2019) and “Laying Foundations for Introducing Evidence” (2018). He also 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. Mr. Miller was named one of the 40 Illinois Attorneys Under Forty To Watch by the Law Bulletin Publishing Company, publishers of Chicago Lawyer and Chicago Daily Law Bulletin. He is a past President of the Law Alumni Board for the University of Illinois College of Law. Mr. Miller 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.
Christine J. Moody
Christine J. Moody
Christine J. Moody is a partner with the firm of Korein Tillery LLC in St. Louis, where she concentrates her practice on representing plaintiffs in complex civil litigation. She received her B.S. from the University of Illinois and her J.D. from St. Louis University School of Law. Ms. Moody is a member of the Illinois and Missouri State Bar Associations, the American Association for Justice, the Illinois Trial Lawyers Association, the Missouri Association of Trial Attorneys, and Public Justice.
Christopher S. Moore
Christopher S. Moore
Christopher S. Moore is the founder and principal of Chris Moore Law LLC, in Chicago, a commercial litigation firm. Prior to founding the firm, he was a Partner at Novack and Macey LLP, in Chicago, where he concentrated his practice in complex business litigation. Moore is a member of the American Bar Association and the Illinois State Bar Association. He received his B.A. from the University of Chicago and his J.D. summa cum laude from the University of Illinois College of Law.
Nicholas J. Motherway
Nicholas J. Motherway
Nicholas J. Motherway is a Founding Partner at Motherway & Napleton in Chicago, where he concentrates in representing plaintiffs in personal injury cases. He is a member of the American College of Trial Lawyers. He is the recipient of a Lifetime Achievement Award from the Illinois Trial Lawyers Association and the Jury Verdict Reporter. He is a 20-year member of National Board and past President of Chicago Chapter of the American Board of Trial Advocates. Mr. Motherway received his B.S.C. from Loyola University Chicago and his J.D. from DePaul University College of Law, where he served as chairman of the Advisory Board.
Patrick A. Salvi II
Patrick A. Salvi II
Patrick A. Salvi II, a Partner with Salvi, Schostok & Pritchard P.C. in Chicago, has been with the firm since 2007 and concentrates his practice on medical malpractice and personal injury. Mr. Salvi is a member of the American Association for Justice, from which he received the Scott Baldwin Award as most outstanding young trial lawyer in 2015. He is also a member of the Illinois Trial Lawyers Association, where he sits on the executive committee, and a board member for the Legal Assistance Foundation. In addition, he was listed in the Lawdragon 500 Leading Lawyers in America and is a member of the Illinois State, Lake County, and Chicago Bar Associations. Mr. Salvi received his B.A. with distinction from the University of Colorado and his J.D. cum laude from Notre Dame Law School.
John Seber
John Seber
John Seber is an associate at Edwards Wildman Palmer LLP in Chicago. Mr. Seber represents clients in a variety of complex commercial disputes and concentrates his practice on insurance and reinsurance matters and class action litigation. He received his B.A. from Georgetown University and his J.D. from the University of Michigan Law School.
Hon. Richard A. Siebel
Hon. Richard A. Siebel
Hon. Richard A. Siebel retired December 31, 2005, as a judge of the Circuit Court of Cook County after serving seven years in the Law Division (Commercial Calendar) and the Chancery Division. He currently is of counsel to the firm of K&L Gates LLP in Chicago. Judge Siebel received his A.B. from Brown University and his J.D. from Northwestern University.
Lisa S. Simmons
Lisa S. Simmons
Lisa S. Simmons is General Counsel at the American Society for Clinical Pathology in Chicago. She was formerly a Partner at Edwards Wildman Palmer LLP, in Chicago, where her practice was focused on complex commercial disputes, both in and out of court, with expertise in the defense of class actions. She has defended insurance, medical device, and chemical companies in putative class action lawsuits alleging consumer fraud and other claims. In addition, she has extensive appellate experience, including appeals arising from high-profile cases brought by governmental entities against firearms and lead pigment manufacturers. She has been a presenter concerning class action topics for several organizations, including the American Conference Institutes 3rd National In-House Counsel Conference on Defending and Managing Complex Litigation, and was coauthor of Class Action Fairness Act: Reflections on the First Years for the NorthStar Conferences 5th Annual Class Action Litigation Summit. Ms. Simmons received her B.A. from the University of Wisconsin and her J.D. from the University of Wisconsin Law School.
Jeffrey Singer
Jeffrey Singer
Jeffrey Singer is Of Counsel to Segal McCambridge Singer & Mahoney, Ltd., in Chicago, where he concentrates his practice in products liability and complex litigation. He is a frequent speaker at local and national attorney seminars and association meetings regarding the defense of products liability and medical negligence lawsuits, cost-effective methods of defending catastrophic injury cases, techniques to prevent products liability claims, and effective product safety warnings. He is a member of the Products Liability Advisory Council and the Defense Research Institute, has been named to the Top Ten Product Liability Defense Attorneys by Leading Lawyers, and is an adjunct professor at Northwestern Pritzker School of Law.
R. John Street
R. John Street
R. John Street is Of Counsel at Eimer Stahl LLP, in Chicago. Mr. Street has over 25 years of experience in counseling and representing insurance industry clients, including investigating and resolving regulatory issues, negotiating and litigating amounts owed loss-sensitive insurance programs, resolving underwriting and pricing issues with insureds and regulators, and defending allegations that claims were mishandled under loss-sensitive insurance programs. He also has a great deal of experience in class action litigation involving the insurance industry, both in personal lines and in commercial lines matters. In addition, he has significant experience in general commercial litigation and in counseling trade associations with respect to antitrust and other matters. Mr. Street joined Eimer Stahl in June 2013. Before joining Eimer Stahl, John was a Partner with Edwards Wildman Palmer LLP. He is a member of the American Bar Association. He received his B.S. from Ohio University and his J.D. summa cum laude, Order of the Coif, from Case Western Reserve University School of Law.
Stephen M. Tillery
Stephen M. Tillery
Stephen M. Tillery is a Senior Partner at Korein Tillery, with offices in Chicago, Illinois, and St. Louis, Missouri, where he concentrates his practice in the area of complex civil litigation. Korein Tillery has been selected seven times since 2003 by the National Law Journal as one of the nation’s top 20 plaintiffs’ law firms. Mr. Tillery was selected by Public Justice in 2003 and 2013 as a finalist for the Trial Lawyer of the Year Award. He received his B.A. magna cum laude, Phi Beta Kappa, from Illinois College and his J.D. magna cum laude, with highest honors, from St. Louis University School of Law.
Paul E. Wojcicki
Paul E. Wojcicki
Paul E. Wojcicki is a Shareholder of Segal McCambridge Singer & Mahoney, Ltd., in Chicago, where he concentrates his practice in automotive and transportation, complex commercial litigation, and products liability. He is the President of the Global Warranty and Service Contract Association. He is Martindale-Hubbell AV Preeminent Peer Review Rated and an Illinois Super Lawyer (2005 – 2018). Mr. Wojcicki received his B.A. from Columbia University in the City of New York and his J.D. from DePaul University College of Law.

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Civil Practice (Illinois): Preparing for Trial (ARCHIVED 2012 EDITION)

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Nicholas A. Caputo

Robert Marc Chemers

Steven A. Hart

Adam Jagadich

Michael C. Kominiarek

Carson D. Maricle

Patrick B. Mathis

Gregory M. McMahon

Richard L. Miller II

Christine J. Moody

Christopher S. Moore

Nicholas J. Motherway

Patrick A. Salvi II

John Seber

Hon. Richard A. Siebel

Lisa S. Simmons

Jeffrey Singer

R. John Street

Stephen M. Tillery

Paul E. Wojcicki

Civil Practice (Illinois): Preparing for Trial (ARCHIVED 2012 EDITION)