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List of Forms by Chapter - 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
- Attorney-Client Privilege
- [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 Through 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
- Rule 206 — Method of Taking Depositions Upon Oral Examination
- [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
- Rule 212 — Use of 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 — Quasi-Discovery
- I. Bills of Particulars
- [2.1] Purpose and Nature
- Effect of Bill
- [2.2] Amplification of Pleadings
- [2.3] Limitation of Recovery or Causes of Action
- [2.4] Limitation of Proofs at Trial
- [2.5] Action in Which Demand for Bill May Be Made
- Comparison to Other Procedures: Discovery and Motions Attacking the Pleadings
- [2.6] Motion for More Particular Statement
- [2.7] Motion To Strike Pleadings
- [2.8] Discovery
- Procedure for Making Demand
- [2.9] Who May Make Demand for Bill
- [2.10] When and How Demand Is Made
- Response to Demand
- [2.11] Objections
- [2.12] Time for Response
- [2.13] Content of Bill
- [2.14] Amendments to Bill
- [2.15] Filing and Service
- Failure To Provide Satisfactory or Timely Bill
- [2.16] Motion To Strike Bill or for More Complete Bill
- [2.17] Demand for Further Bill
- [2.18] Sanctions Pursuant to Supreme Court Rule 219(c)
- [2.19] Federal Rules of Civil Procedure
- Forms
- [2.20] Notice and Demand for Bill of Particulars
- [2.21] Response to Bill of Particulars
- [2.22] Motion To Deny Demand for Bill of Particulars
- [2.23] Motion for Additional or More Specific Particulars
- II. Compelling Production at Trial
- Supreme Court Rule 237
- [2.24] The Basics of Supreme Court Rule 237
- [2.25] Supreme Court Rule 237(a) — Witnesses
- [2.26] Supreme Court Rule 237(b) — Documents or Tangible Things
- [2.27] Not a Vehicle for Discovery
- [2.28] Persons and Matter Subject to Production
- [2.29] Scope of Production
- Procedures of Party Seeking Production
- [2.30] When Notice May Be Served
- [2.31] Contents of Notice — Description of Persons or Items To Be Produced
- Procedures of Responding Party
- [2.32] Compliance
- [2.33] Objections
- [2.34] Motion To Quash Supreme Court Rule 237 Request
- [2.35] Failure or Refusal To Respond
- [2.36] Appellate Review
- [2.37] Federal Procedure
- Forms
- [2.38] Notice To Produce
- [2.39] Objection to Supreme Court Rule 237 Notice
- III. Requests for Admissions of Facts and Genuineness of Documents
- Purpose and Effect
- [2.40] Supreme Court Rule 216; Related Federal Procedure
- [2.41] Nature and Purpose
- [2.42] Effect of Admission
- [2.43] Procedure for Submitting Requests for Admissions
- [2.44] When Requests May Be Served
- [2.45] Number of Requests Allowed
- Content of Requests To Admit
- [2.46] Admissions of Fact
- [2.47] Genuineness of Documents
- [2.48] Federal Practice
- [2.49] Responses to Requests for Admissions
- [2.50] Denials
- [2.51] Good Faith/Good Reasons Requirement for Denials
- [2.52] Objections to Requests
- [2.53] Failure To Timely Respond
- [2.54] Res Judicata
- [2.55] Public Records
- Forms
- [2.56] Request for Admission of Facts or Genuineness of Documents
- [2.57] Answer to Request for Admission
- [2.58] Objection to Request for Admission
- Chapter 3 — Limitations on Discovery
- I. [3.1] Introduction
- II. [3.2] Scope of Discovery
- III. Constitutional Limitations
- IV. [3.8] Statutory Limitations
- [3.9] Marriage Privilege
- [3.10] Physician-Patient Privilege
- [3.11] Statutory Exceptions to the Physician-Patient Privilege
- [3.12] Judicially Created Exceptions to the Physician-Patient Privilege
- [3.13] Ex Parte Communications with Medical Providers
- [3.14] Psychotherapist-Patient Privilege
- [3.15] Clergy’s Privilege
- [3.16] Reporter’s Privilege
- [3.17] Accountant’s Privilege
- [3.18] Social Worker’s Privilege
- [3.19] Medical Studies Privilege
- [3.20] Other Statutory Limitations
- [3.21] Informant’s Privilege
- [3.22] Union Agent and Union Member Privilege
- [3.23] Confidentiality of Statements Made to Counselors of Victims of Certain Crimes
- V. [3.24] Court Rule Limitations
- [3.25] Attorney-Client Privilege
- [3.26] Scope of the Attorney-Client Privilege
- [3.27] Necessity of Confidence
- [3.28] Exceptions to the Attorney-Client Privilege
- [3.29] Waiver of the Attorney-Client Privilege
- [3.30] Communications Between an Insured and an Insurance Carrier
- [3.31] Corporate Clients
- [3.32] Work-Product Doctrine
- [3.33] Protective Orders
- [3.34] Disclosure of Confidential Information
- [3.35] Destruction of Evidence
- VI. [3.36] Common-Law Limitations
- VII. [3.37] Conclusion
- Chapter 4 — Interrogatories
- I. [4.1] Nature and Purpose
- II. Preparing and Serving Interrogatories
- [4.4] Preliminary Considerations
- [4.5] Permissible Scope
- [4.6] Attorney-Client and Work-Product Privileges
- [4.7] Discovery Documents and Other Items
- Identity of Witnesses
- [4.8] Lay witnesses
- Expert witnesses
- [4.9] In general
- [4.10] “Expert witness” defined
- [4.11] Duty to supplement
- [4.12] Scope of expert witness’s testimony
- [4.13] Factual Basis for Pleading
- [4.14] Deciding Whether To Serve Interrogatories
- [4.15] Cost to Propounding Party
- [4.16] Effect on Responding Party
- [4.17] Anticipated Usefulness of Answers
- [4.18] Effect of Prior Discovery
- Drafting
- [4.19] Basic Principles
- [4.20] Definitions of Terms Used in Interrogatories
- [4.21] Contesting Interrogatories and Requests To Admit
- [4.22] Commencement of Discovery/Case Management
- III. Responding to Interrogatories
- [4.23] Duty To Respond
- Time To Respond
- [4.24] Statutory Requirements
- [4.25] Effect of Failure To Make Timely Response
- Objecting to Interrogatories
- [4.26] Grounds for Objection
- [4.27] Irrelevant to the Subject Matter
- [4.28] Disproportionate to the Needs of the Case
- [4.29] Annoyance, Expense, Embarrassment, or Oppression
- [4.30] Information equally available to both parties
- [4.31] “Boilerplate” and “shotgun” interrogatories
- [4.32] Privilege and Work Product
- [4.33] Uncertain, Ambiguous, and Unintelligible Interrogatories
- [4.34] Objections That Have Been Held Invalid
- [4.35] Objections That Have Been Held Valid
- [4.36] Drafting Objections — Basic Principles
- Answering Interrogatories
- [4.37] Who May Answer for Party
- Effect of Incorrect Answers
- [4.38] Made in Good Faith
- [4.39] Made in Bad Faith
- Duty To Investigate Before Answering
- [4.40] Basic Rule
- [4.41] Impropriety of “I Don’t Know” Answer
- [4.42] Fifth Amendment Privilege
- [4.43] Answer by Reference to Business Records
- Preparing and Drafting Answers
- [4.44] Basic Considerations
- [4.45] Form and Verification of Answers
- [4.46] Answers by Reference to Other Answers or Other Documents
- [4.47] Reservation Concerning Subsequently Discovered Facts
- Modification of Answers
- [4.48] Supplementation
- Amendment
- [4.49] Criteria for Amendment
- [4.50] Procedures
- IV. [4.51] Compelling Answers and Further Answers to Interrogatories
- V. [4.52] Using Interrogatories in Court
- VI. Appendix — Forms
- Chapter 5 — Production of Documents and Tangible Things
- I. Preliminary Considerations
- [5.1] Authority
- Supreme Court Rule 201
- [5.2] Scope
- [5.3] Methods and Duplication of Discovery
- [5.4] Electronically Stored Information
- [5.5] Timing, Sequence, and Cutoff
- [5.6] Protective Orders and Preservation Letters
- [5.7] Supreme Court Rule 201(k)
- [5.8] Withholding Matters Claimed To Be Privileged
- [5.9] Costs of Production
- [5.10] Obtaining Leave of Court and Court Filing
- [5.11] Supreme Court Interrogatories
- [5.12] Supreme Court Rule 213(e) — Attaching Documents to Answers to Interrogatories
- [5.13] Supreme Court Rule 213(f)(3) — Reports of Controlled Expert Witnesses
- [5.14] Supreme Court Rule 214
- [5.15] Objections
- [5.16] Affidavit of Compliance
- [5.17] Duty To Organize Materials Produced
- [5.18] Electronically Stored Information
- [5.19] Duty To Supplement
- [5.20] Audit Trail Production
- [6.21] Social Media and Production
- [5.22] Supreme Court Rule 219
- [5.23] Supreme Court Rule 222 — Cases of $50,000 or Less
- Coordination with Other Discovery
- [5.24] Depositions and Interrogatories
- [5.25] Request To Produce at Trial
- [5.26] Subpoena
- II. Procedures of Party Seeking Production
- Supreme Court Rule 214
- [5.27] Basic Provisions
- [5.28] Scope of Request
- [5.29] Product in a Products Liability Case
- [5.30] Creating or Locating Objects
- [5.31] Corporate Memory
- [5.32] Mental Health and Alcohol Abuse Records
- [5.33] Lists of Law Clients
- [5.34] Identity of Medical Patients
- [5.35] Lists of Witnesses
- [5.36] Statements of Employees
- [5.37] Statement of Nonparty Taken by Insurance Company
- [5.38] Identity of Consulting Expert
- [5.39] Basic Request
- Requests Relating to Specific Causes of Action
- [5.40] Motor Vehicles
- [5.41] Products Liability
- [5.42] Medical Negligence
- [5.43] Railroad Crossings
- [5.44] Premises Liability
- [5.45] Construction Negligence
- [5.46] Obtaining Court Order for Failure To Respond to Request for Production
- Sanctions for Failure To Comply with Discovery Orders
- [5.47] Sanctions for Withholding Available Evidence
- [5.48] Sanctions for Disposing of Available Evidence
- Obtaining Production from Nonparty
- [5.49] In General
- [5.50] Records Depositions
- III. Procedures of Party Responding
- Chapter 6 — Oral Deposition Preparation
- I. [6.1] Scope of Chapter
- II. [6.2] Authority Governing Oral Depositions
- [6.3] Discovery Depositions vs. Evidence Depositions
- [6.4] Scheduling Depositions: Notices vs. Subpoenas
- [6.5] Potential Deponents
- [6.6] Court Imposed Limitations on Depositions
- [6.7] Length of Depositions
- [6.8] Deposition Location
- [6.9] Timing of Depositions
- [6.10] Deposition Procedures
- [6.11] Video and Remote Depositions
- [6.12] Consequences for Failing To Proceed with a Deposition
- [6.13] Stipulations Regarding Depositions
- [6.14] Interstate or International Depositions
- [6.15] Costs
- III. [6.16] Oral Deposition Preparation
- Chapter 7 — Deposition Taking
- I. Introduction
- II. Taking a Deposition
- Persons Who May Be Present
- [7.4] Parties and Consulting Experts
- [7.5] Second Interpreter and Second Court Reporter
- [7.6] Excluding Nonparty Witnesses and the Public
- Stipulations and Statements for the Record
- [7.7] Usual Procedure Regarding Stipulations
- [7.8] Initial Statements for the Record — Discovery or Evidence Deposition
- Role of Counsel Taking a Deposition
- [7.9] Keys to Successful Deposition Taking
- [7.10] Inquisitiveness
- [7.11] Thoroughness — Time Limit for Discovery Depositions
- [7.12] Sample deposition checklist for plaintiff in automobile accident case
- [7.13] Use of deposition checklist
- [7.14] Preliminary Statement to the Deponent
- [7.15] Responding to a Request for Prior Statements of the Deponent
- Questioning the Deponent
- [7.16] Setting the Tone of the Deposition and Sequence of Questioning
- [7.17] The Reasons for a Deposition Determine the Form of Questions
- [7.18] To discover information
- [7.19] To commit the deponent to specific facts
- [7.20] To obtain admissions
- [7.21] To secure impeaching testimony
- [7.22] To gain an impression of the deponent
- [7.23] Changing the manner of formulating questions
- Using Documents and Photographs at a Deposition
- [7.24] Securing Documents and Photographs Before a Deposition
- [7.25] Securing Documents Used To Refresh the Deponent’s Recollection
- [7.26] Marking Documents and Photographs as Exhibits
- [7.27] Drawing on a Photograph at a Deposition
- Common Situations Encountered at a Deposition
- [7.28] Response of “I Don’t Recall”
- [7.29] Response of “I Don’t Know”
- [7.30] Nonresponsive Answer — Certifying the Question
- [7.31] Defects in the Form of an Answer
- [7.32] Refusal To Answer
- Procedures at Depositions of Various Individuals
- [7.33] Supreme Court Rule 213(f) Witnesses
- [7.34] Physicians; Sample Deposition Checklist
- [7.35] Experts; Sample Deposition Checklist
- [7.36] Deponents Who Speak a Foreign Language
- [7.37] Minors
- [7.38] Written Questions at a Deposition
- [7.39] Concluding a Deposition — Deponent’s Reading and Signature
- Role of Deponent’s Counsel
- [7.40] Listening in Silence
- [7.41] Objecting to Improper Questions
- [7.42] Reining in Obstreperous Opposing Counsel
- [7.43] Instructing the Deponent Not To Answer
- [7.44] Terminating the Deposition
- [7.45] Examining the Deponent
- Video Depositions
- [7.46] General Requirements
- [7.47] Detailed Procedures
- [7.48] Depositions by Videoconference
- III. Post-Deposition Proceedings
- IV. [7.53] Conclusion
- Chapter 8 — Interjurisdictional Depositions
- I. [8.1] Scope of Chapter
- II. Taking Depositions Out of State for Use in Illinois
- Preliminary Considerations
- [8.2] Statutory Authority
- [8.3] Strategy and Tactics
- [8.4] Conflict of Laws Problems
- [8.5] Associating Local Counsel
- [8.6] Selecting Deposition Officer
- Procedure
- [8.7] Party
- Nonparty
- [8.8] Initiating Deposition: Need for a Commission
- New York Depositions
- [8.9] Notice (if held applicable)
- [8.10] Compelling attendance and production
- [8.11] Before whom depositions may be taken
- [8.12] Objections and protective orders
- [8.13] Post-deposition procedure
- Michigan Depositions
- [8.14] Notice (if held applicable)
- [8.15] Compelling attendance and production
- [8.16] Before whom depositions may be taken
- [8.17] Objections and protective orders
- [8.18] Post-deposition procedure
- California Depositions
- [8.19] Notice (if held applicable)
- [8.20] Compelling attendance and production
- [8.21] Before whom depositions may be taken
- [8.22] Objections and protective orders
- [8.23] Post-deposition procedure
- [8.24] 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 9 — Motions for Physical and Mental Examinations
- I. Scope of Chapter
- II. Preliminary Considerations
- [9.3] Authority for Examinations
- Prerequisites to Issuance of Order
- [9.4] “Good Cause” Requirement
- [9.5] Be a Party
- [9.6] In Controversy
- [9.7] Court Has Broad Discretion
- [9.8] Restrictions on Examination
- [9.9] Who May Examine
- [9.10] Who May Be Examined
- [9.11] Time and Place of Examination
- [9.12] Cost of Examination
- [9.13] Who May Be Present
- III. Procedures
- [9.14] When Request Must Be Made
- [9.15] Examination by Agreement of Parties
- Motion for Examination and Documents in Opposition
- [9.16] Contents of Motion
- [9.17] Documents in Opposition
- [9.18] Affidavit in Opposition
- [9.19] Protective Order
- [9.20] Sanctions for Failure To Comply with Order
- Written Reports
- [9.21] Persons Entitled to Report
- [9.22] Consequences of Failure To Provide Report
- [9.23] Use of Report at Trial
- [9.24] Status of Examiner
- [9.25] Impartial Medical Examination
- [9.26] Evidence
- [9.27] Reports
- IV. Tactical Considerations
- V. [9.35] Conclusion
- VI. Appendix — Forms for Use in Connection with Examination
- 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
- Procedure
- [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
- Sanctions Common to All Discovery
- [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] Sanctions Against Nonparties
- [10.34] Sanctions Against Attorneys
- Sanctions Relating to Particular Discovery
- [10.35] Depositions
- [10.36] Interrogatories
- [10.37] Requests To Produce
- [10.38] Motions for Physical Examination
- Procedures for Obtaining Sanctions
- [10.39] Prerequisites
- Motion
- [10.40] Moving Party
- [10.41] Opposing Party
- [10.42] Order
- [10.43] Sanctions Under Supreme Court Rule 137
- IV. [10.44] Conclusion
- V. Appendix
- [10.45] Motion for Protective Order
- [10.46] Motion To Compel Party To Appear for Deposition
- [10.47] Petition for Rule To Show Cause — Nonparty — Failure To Appear for Deposition
- [10.48] Rule To Show Cause — Nonparty — Compel Appearance for Deposition
- [10.49] Motion To Compel Deponent To Answer Deposition Questions
- [10.50] Motion To Compel Production of Certain Documents at Time of Oral Examination
- Mitchell W. Bild
Mitchell W. Bild
Mitchell W. Bild is an associate at Corboy & Demetrio in Chicago. He concentrates his practice in personal injury and wrongful-death law. From November 2020 to September 2022, he served as a judicial law clerk to Hon. James N. O’Hara and Hon. Kathy M. Flanagan of the Circuit Court of Cook County, Law Division. Bild received his BA from Michigan State University and his JD from the Chicago-Kent College of Law.
- 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.
- 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.
- 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.
- 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.
- Carissa Schmidt Munier
Carissa Schmidt Munier
Carissa Schmidt Munier is Associate Corporate Counsel at Nidec Americas Holding Corporation, in St. Louis, Missouri, where she provides legal representation, advice, counsel, and opinions in all areas of law for Nidec Motor Corporation and other Nidec entities in the Americas. Schmidt is licensed in both Illinois and Missouri. She graduated magna cum laude from the University of Missouri and received her Juris Doctorate from St. Louis University School of Law.
- Conrad C. Nowak
Conrad C. Nowak
Conrad C. Nowak is a Partner at Corboy & Demetrio in Chicago, where he concentrates his practice in personal injury, products liability, toxic tort, construction, aviation, trucking, and commercial litigation. He has been recognized in the area of personal injury litigation — plaintiffs by The Best Lawyers in America (2026) and Super Lawyers (2026). Since 2024, he had been recognized by Lawdragon 500 Leading Lawyers in America. Nowak received his BA with honors from DePaul University and his JD from the Loyola University Chicago School of Law, where he served as Features Editor of The Loyola University Forum of International Law and as Assistant Features Editor of The Public Interest Law Reporter.
- Joseph C. Orlet
Joseph C. Orlet
Joseph C. Orlet is Partner at Husch Blackwell, LLP, in St. Louis, Missouri, where he concentrates his practice in toxic torts, mass torts, products liability, and class actions cases. He has been recognized by Benchmark Litigation as a “Local Litigation Star” since 2011 and by The Best Lawyers in America in the practice areas of Mass Tort Litigation/Class Actions — Defendants since 2013 and Product Liability Litigation — Defendants in 2021. Orlet received his B.S. from Southern Illinois University and his J.D. from Saint Louis University School of Law.
- 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.
- Terrence J. Sheahan
Terrence J. Sheahan
Terrence J. Sheahan is a Partner at Smith Gambrell & Russell, LLP, in Chicago, where he focuses his practice on commercial litigation. For over 15 years he has been an adjunct professor at Northwestern University School of Law. Sheahan was named one of “40 Illinois Attorneys Under Forty To Watch” by the Law Bulletin Publishing Company and has been recognized for several years as an Illinois Super Lawyer in Business Litigation and an Illinois Leading Lawyer in Commercial Litigation. He received his B.A. from Indiana University and his J.D. from DePaul University College of Law.
- Martin D. Syvertsen
Martin D. Syvertsen
Martin D. Syvertsen is an attorney at Ryan, Ryan & Viglione in Waukegan, where he concentrates in personal injury and commercial litigation. He is a member of the Chicago Bar Association and the Chicago Inn of Court. Mr. Syvertsen received his BA from the College of the Holy Cross and his JD cum laude from the Loyola University Chicago School of Law.
- Edward G. Willer
Edward G. Willer
Edward G. Willer is a Partner at Corboy & Demetrio, P.C., in Chicago, where he concentrates his practice in civil litigation. He is a member of the American Association for Justice and the Illinois Trial Lawyers Association. He is also a Board Member for the Illinois MCLE. Willer received both his B.A., with honors, and his J.D. from DePaul University.
- Laura Young
Laura Young
Laura Young is a Partner at Nielsen, Zehe & Antas, P.C., in Chicago, where she focuses her practice on medical malpractice defense. She is a Member of the Illinois Bar Association and the Society of Trial Lawyers. Young received her B.A. from George Washington University and her J.D. from Michigan State Law School.
Civil Discovery Practice 2025 Edition
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