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List of Forms by Chapter - Chapter 1 — Automobile Accident Cases
- I. [1.1] Introduction
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II. [1.2] Pre-Suit Investigation by the Plaintiff - III. [1.5] Written Discovery
- Written Interrogatories
- [1.6] Standard Interrogatories
- [1.7] Numerical Limits
- [1.8] Duty To Supplement Answers to Interrogatories
- [1.9] Trial Witnesses
- [1.10] Lay Witnesses
- [1.11] Independent Expert Witnesses
- [1.12] Controlled Expert Witnesses
- [1.13] Preparing Answers to Written Interrogatories
- [1.14] Requests To Produce
- [1.15] Obtaining Records
- [1.16] Request for Medical Examination
- Depositions
- [1.17] Preparation Is the Key
- [1.18] Deposition Procedures
- [1.19] Use of Depositions
- Relevant Deposition Issues in Specific Auto Accident Settings
- [1.20] Rear-End Collision
- [1.21] Sideswipe
- [1.22] Left Turn
- [1.23] Red Light-Green Light
- [1.24] Auto-Pedestrian
- [1.25] Auto-Bicycle
- [1.26] Stop Sign-Through Street
- [1.27] Types of Depositions
- [1.28] Witness Depositions
- [1.29] Depositions of Parties
- [1.30] Preparing your own client for deposition
- [1.31] Preparing for an adverse party deposition
- [1.32] Taking the defendant driver’s deposition
- IV. Additional Discovery Considerations
- V. [1.36] Standard Interrogatories and Request To Produce in Automobile Cases
- Chapter 2 — Construction Injury Cases
- Chapter 3 — Medical Negligence Cases
- Chapter 4 — Federal Employers’ Liability Act Plaintiffs’ Cases
- I. [4.1] Introduction
- II. [4.2] Initial Interview with Federal Employers’ Liability Act Client
- III. [4.3] Statements of Witnesses
- IV. [4.4] Ex Parte Interviews and Statements of Witnesses
- V. [4.5] Railroad Records
- VI. [4.6] Union Officials
- VII. [4.7] Rule Books
- VIII. [4.8] Governmental Regulations and Publications
- IX. [4.9] Other Publications
- X. [4.10] Association of American Railroads Documents/Craft Job Descriptions
- XI. [4.11] Contract Between Union and Railroad
- XII. [4.12] Transcript of Investigation
- XIII. [4.13] Experts
- XIV. [4.14] Rehabilitation
- XV. [4.15] Prediscovery Tool — Preserve Evidence Letter; Sample Letter
- XVI. Discovery Tools
- XVII. [4.20] Retaliatory Discharge
- XVIII. [4.21] Conclusion
- Chapter 5 — Federal Employers’ Liability Act Defendants’ Cases
- Chapter 6 — Class Actions
- I. What Is Unique About Discovery in Class Action Cases
- [6.1] Discovery Regarding Class Issues Should Be Done as Soon as Practicable
- [6.2] Federal Legislation Impacting Timing of Discovery
- [6.3] Federal Court Stays of State Court Discovery
- [6.4] Private Securities Litigation Reform Act Stays and Derivative Actions
- [6.5] Pre-Certification Communications with Putative Class Members
- [6.6] Discovery of Absent Class Members
- II. [6.7] Areas for Discovery in Class Action Cases
- Chapter 7 — Wrongful Death Cases
- I. [7.1] Introduction
- II. Plaintiff’s Case
- [7.2] First Client Contact
- [7.3] Next of Kin
- [7.4] Medical Providers
- [7.5] Inquest Testimony
- [7.6] Supreme Court Rule 213 Interrogatories
- [7.7] Prefiling Statements
- [7.8] The Complaint
- [7.9] Document Production
- [7.10] Witnesses
- [7.11] Expert Witnesses
- [7.12] Supreme Court Rule 216 Requests To Admit Facts
- [7.13] Expert Discovery
- III. Defendant’s Investigation and Trial Preparation
- IV. [7.17] Summary
- Chapter 8 — Products Liability Cases
- I. [8.1] What Is Unique About Discovery in the Area of Products Liability?
- II. Areas for Investigation
- Information Gathering
- [8.7] The Incident
- [8.8] The Product in Question
- Litigation Preparation
- [8.9] Generally
- [8.10] Deposing an Adverse Witness
- [8.11] Deposing the Plaintiff
- Examples
- [8.12] Sample Interrogatories (Excluding Standard Interrogatories)
- [8.13] Sample Requests To Produce — Supreme Court Rule 214
- Chapter 9 — Premises Liability Cases
- 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.
- Sandra J. Cukierski
Sandra J. Cukierski
Sandra J. Cukierski is a Partner at SmithAmundsen LLC in Chicago, where she focuses her practice on commercial transportation, products liability, and premises liability. She is a member of the Defense Research Institute. She was selected as an Illinois Super Lawyer Rising Star in 2013 – 2017 and selected by the Leading Lawyers Network as an Emerging Lawyer in personal injury defense and transportation defense law. Ms. Cukierski received her B.S. from the University of Illinois and her J.D. from Loyola University Chicago School of Law.
- Thomas A. Demetrio
Thomas A. Demetrio
Thomas A. Demetrio is a Founding Partner at Corboy & Demetrio, P.C., in Chicago, where he focuses on the areas of personal injury and wrongful death. He is Past President of the Chicago Bar Association and the Illinois Trial Lawyers Association, and he is a member of the International Academy of Trial Lawyers and the Inner Circle of Advocates. Mr. 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.
- 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.
- Jeffrey S. Jordan
Jeffrey S. Jordan
Jeffrey S. Jordan is a Partner with the law firm of O’Connor & Nakos Ltd., in Chicago, where he focuses his practice on personal injury. He is a member of the Illinois Trial Lawyers Association and Illinois State Bar Association. Jordan earned his B.A. from Loyola University in Chicago and his J.D. cum laude, in addition to a certificate in Trial Advocacy, from Loyola University Chicago School of Law.
- Daniel M. Kotin
Daniel M. Kotin
Daniel M. Kotin is a Partner at Tomasik Kotin Kasserman, LLC, in Chicago. His practice focuses on trial law. He is a Past President of the Chicago Bar Association (2016 – 2017), a member of the House of Delegates of the American Bar Association, and a Fellow of the International Society of Barristers. He received his B.A. cum laude from Boston College and his J.D. cum laude from the Loyola University 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.
- 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.
- Robert P. Marcus
Robert P. Marcus
Robert P. Marcus is a Partner at Kujawski Marcus, LLC, in O’Fallon, where he focuses on the Federal Employers’ Liability Act and personal injury law. He currently serves as Special Counsel to the Attorney Registration and Disciplinary Commission. He is Martindale-Hubbell AV Preeminent Rated. He was named an Illinois Super Lawyers Rising Star in 2016 and 2017. Mr. Marcus received his B.S. from James Madison University and his J.D. from Southern Illinois University School of Law, where he participated in moot court and was a published member of the Law Journal.
- Daniel V. O’Connor
Daniel V. O’Connor
Daniel V. O’Connoris a Partner at O’Connor & Nakos, Ltd., in Chicago, where he focuses on plaintiffs’ personal injury law. He is a member of the Illinois Trial Lawyers Association, the American Association for Justice, and the American and Chicago Bar Associations. He has been a lecturer for the Illinois Trial Lawyers Association in areas of pretrial litigation and the selection and presentation of experts in products liability cases. Mr. O’Connor received his B.S. from Loyola University Chicago and his J.D. from Loyola University Chicago School 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.
- Charles J. Swartwout
Charles J. Swartwout
Charles J. Swartwout is a Founding Partner at Boyle Brasher LLC in Belleville, where he concentrates his practice primarily in the defense of physicians, hospitals, nurses, railroads, and transportation companies. He is a member of the Illinois State, Missouri, and St. Clair County Bar Associations, the National Association of Railroad Trial Counsel, the Counsel on Litigation Management, the American Health Lawyers Association, the Illinois Association of Healthcare Attorneys, the Illinois Association of Defense Trial Counsel, and the Missouri Organization of Defense Lawyers. Mr. Swartwout received his B.S. from Purdue University and his J.D. from Southern Illinois University School of Law.
Discovery Considerations in Specific Civil Cases (ARCHIVED 2017 EDITION)
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