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List of Forms by Chapter
Chapter 1 — The Trial Advocate: Purpose, Talent, and Philosophy
II. [1.2] The Trial Lawyer’s Tools, Skills, and Qualities
Chapter 2 — The Jury: The “Right” to It and the Selection of It
Chapter 3 — Opening Statement
I. Introduction
VI. Legal and Practical Aspects
IX. Motions in Limine Prior to Opening Statement
XI. Plaintiff’s Jury Opening Statement
XII. Defendant’s Jury Opening Statement
XIII. [3.50] Example Opening Statements
Chapter 4 — Presenting Testimony
II. Preparation
III. Direct Examination
IV. Cross-Examination
V. Impeachment
VI. Redirect Examination and Recross-Examination
Chapter 5 — Preserving the Record During Trial
I. Introduction
II. Making the Record
III. Preserving the Record
Chapter 6 — Presenting the Plaintiff’s Case
I. [6.1] Introduction
II. [6.7] Discovery
III. [6.21] Jury Selection
IV. Opening Statement
VI. Witnesses
VII. [6.44] Expert Witnesses
X. Mandatory Arbitration Issues
Chapter 7 — Motions During and at the Close of the Plaintiff’s Case-in-Chief
II. Motion Practice in General — When, Where, and How To Present Motions
III. [7.5] Motions in Limine
V. Motions Regarding Evidence
VII. [7.16] Motions for Mistrial
Chapter 8 — Presenting the Defendant’s Case
Chapter 9 — Motions During and at the Close of the Defendant’s Case-in-Chief
I. Introduction
VII. [9.11] Motions To Exclude and Strike Evidence
IX. [9.18] Motions for Mistrial
Chapter 10 — Motions at the Close of the Evidence
II. Motion for a Continuance
IV. [10.5] Motions To Strike Evidence
VII. [10.10] Motion for Directed Verdict in Jury Cases
IX. [10.17] Appendix — Forms
Chapter 11 — Jury Instructions, Special Interrogatories, and Verdicts
II. Jury Instructions
III. Special Interrogatories and General Verdicts
V. Special Verdicts
Chapter 12 — Closing Argument
II. The Law of Closing Arguments — Fundamental Principles
III. The Law of Closing Arguments — Legal Rules Governing Specific Situations
IV. The Argument Itself — Techniques, Strategies, and Practice Pointers
Chapter 13 — Return of the Verdict and Entry of Judgment
II. [13.2] Problems Arising During Jury Deliberations
III. Return of the Verdict
IV. [13.17] Polling the Jury
V. [13.21] Amendment or Correction of the Verdict
VI. [13.25] Entry of Judgment on the Verdict
Chapter 14 — Posttrial Motions
I. Introduction
II. Nature of Available Motions
III. Procedure
IV. [14.37] Contents of the Motion
V. Other Motions After TrialRobert L. Byman is Of Counsel with Jenner & Block LLP, in Chicago, where he concentrates his practice in commercial litigation. Mr. Byman is Editor (2020 – present) and Past President (2013 – 2014) of the Journal of the American College of Trial Lawyers. He received his B.A. from the University of Illinois and his J.D. from the University of Illinois College of Law.
John J. Byron is a Partner Steptoe & Johnson LLP in Chicago, where he focuses his practice on regulatory litigation, white-collar defense, independent and internal investigations, and commercial litigation. He is a Fellow of the Texas Bar Foundation, and he was awarded the Thomson Reuters, Texas Rising Star in Securities Litigation (2015 – 2020). He received his B.A. cum laude from Tulane University and his and his J.D. magna cum laude from Wake Forest University School of Law.
Farah A. Chalisa is an associate at Baker McKenzie in Chicago, where she focuses her practice on complex commercial litigation and government enforcement. She is a member of the Chicago Bar Association. She received her B.S. summa cum laude from the University of Illinois at Urbana-Champaign, where she was a Bronze Tablet Scholar; her J.D from the University of Pennsylvania Law School; and her Executive Certificate in Business Management from the Wharton Aresty Institute for Executive Education.
Robert Marc Chemers is a Senior Equity Partner at Pretzel & Stouffer, Chartered, in Chicago, where he concentrates his practice in insurance coverage and appellate and complex civil litigation. He is a member of the American and Illinois State Bar Associations and a Fellow of the American College of Coverage Counsel. Mr. Chemers received his BA magna cum laude from the University of Southern California and his JD cum laude from the Indiana University Robert H. McKinney School of Law.
Elizabeth C. Curtin is a Partner at Sidley Austin LLP in Chicago, where she concentrates her practice in litigation. Ms. Curtin received her B.S. from Duke University and her J.D. from the University of Virginia School of Law.
Isaac Green is an associate at Sidley Austin, LLP in Chicago, where he focuses his practice on commercial litigation. He received his B.A. from Colorado College and his J.D. from Northwestwern University School of Law.
Stacie R. Hartman is a Partner and Cochair of the Financial Services Group at Steptoe & Johnson LLP in Chicago, where she concentrates her practice in financial services. She is recognized by Chambers Global, Chambers USA (Nationwide), and she was selected as a “Notable Women in Law” by Crain’s Chicago Business (2020), and a “Trailblazers in Finance, Banking & Capital Markets” by the National Law Journal (2019). Ms. Hartman studied at St. Catherine’s College — Oxford University, received her B.A. from Northwestern University, and received her J.D. from Northwestern University Pritzker School of Law.
Laura A. Kelly is an associate at Baker McKenzie in Chicago, where she focuses her practice on complex commercial litigation and international arbitration. She is a published author in multiple legal publications and was a prior Honoree of Baker McKenzie’s Robert L. Berner Jr. Pro Bono and Public Service Award of Excellence. She is a member of the Chicago Bar Association. Ms. Kelly received her B.A. cum laude from Vanderbilt University, where she was Phi Beta Kappa, and her J.D. cum laude from Northwestern University Pritzker School of Law.
Shane B. Kelly is an associate in the Litigation & Government Enforcement Practice Group at Baker McKenzie in Chicago, where he focuses his practice on complex civil litigation and government investigations. He served as an articles editor on the Indiana Law Journal and as an associate at Indiana University’s Federal Habeas Litigation clinic. He was also an editorial fellow for the Center for Constitutional Democracy. He received his B.A. from the University of Iowa and his J.D. magna cum laude from Indiana University — Maurer School of Law, where he was Order of the Coif.
Cara A. Lawson is an associate at Steptoe & Johnson LLP in Chicago, where she focuses her practice on commercial litigation. She is a member of the Chicago Bar Foundation’s Young Professionals Board and was recognized as “One To Watch” in Commercial Litigation by Best Lawyers in America (2021 – 2022). She received her J.D. cum laude from the University of Illinois College of Law.
Michael C. McCutcheon is a Partner at Baker McKenzie in Chicago, where he focuses his practice on international commercial litigation and arbitration. Mr. McCutcheon is a member of the Trial Bar for the United States District Court for the Northern District of Illinois, the Seventh Circuit Bar Association, and the Chicago Bar Association. Mr. McCutcheon received his B.S. from the University of Illinois and his J.D. from Loyola University Chicago School of Law.
Richard L. Miller II is a Partner at Miller PC in Chicago, where he concentrates his practice in commercial litigation, labor law, and class actions. He is an Adjunct Professor at the Northwestern 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 arbitrator since 2008; FINRA since 2018; and the Cook County Mandatory Arbitration Program from 2003 to 2005. He has served on the IICLE® Board of Directors since 2023. 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. 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.
Telly C. Nakos is a Founding Partner at O’Connor & Nakos Ltd., in Chicago, where he concentrates his practice in personal injury. He is a two-time recipient of the American College of Trial Lawyers Justice Lewis F. Powell, Jr. Award for Excellence in Trial Advocacy, and he has also received the International Academy of Trial Lawyers Advocacy Award. He was also selected as one of Illinois’ 40 under Forty by Law Bulletin Media. Mr. Nakos received his undergraduate degree from Wabash College and his J.D. from Case Western Reserve University School of Law.
Kyle R. Olson is a Partner at Baker McKenzie in Chicago, where he focuses his practice on complex commercial litigation and international arbitration. He is a member of the Board of Directors for Almost Home Kids, an Affiliate of Lurie Children’s Hospital of Chicago, and he is a three-time Honoree of Baker McKenzie’s Robert L. Berner Jr. Pro Bono Public Service Award of Excellence. Mr. Olson is also a published author in many legal publications and newspapers, including Legal 500 and the Chicago Tribune. He received his B.A. magna cum laude, Phi Beta Kappa, from Wake Forest University, his M.A. with merit from King’s College London, and his J.D. cum laude from Northwestern University Pritzker School of Law.
Cynthia N. Pietrucha is Managing Attorney at Pietrucha Law Firm, LLC, in Naperville, where she focuses her practice on employment and labor law, medical leave laws, and contracts. She was recognized by The National Black Lawyers’ Top 40 Under 40 in Employment Law (2017), and she also received the Avvo Client’s Choice Award (2017) and the Avvo Top Attorney award (2022). She received her B.S. and B.A. from the University of Illinois at Urbana-Champaign, her J.D., with Pro Bono Honors, from Northern Illinois University College of Law, and her Summer Certificate in Entertainment and Media Law from Southwestern Law School, Los Angeles.
Reid J. Schar is a Partner at Jenner & Block LLP in Chicago and San Francisco, where he focuses his practice on investigations, compliance and defense, and complex commercial litigation. He is a Fellow of the American College of Trial Lawyers and is a recipient of The Attorney General’s Award for Distinguished Service. Mr. Schar is also Band One Chambers rated in Litigation: White Collar Crime and Government Investigations. He received his BA, with Departmental Honors, from Stanford University and his JD cum laude from Northwestern University School of Law, where he was Order of the Coif and Book Review and Research Editor for the Northwestern University Law Review.
Andrew P. Shelby is a Partner at Novack and Macey LLP in Chicago, where he focuses his practice on commercial litigation. Mr. Shelby received his B.A. with distinction from Kenyon College and his J.D. cum laude from Maurer School of Law at Indiana University.
Andrew W. Vail is a Partner at Jenner & Block LLP, in Chicago, where he concentrates his practice on complex commercial litigation. Mr. Vail is a member of the American College of Trial Lawyers and Chair of the Chicago Bar Association’s Strategic Planning Committee. He is also a Board Member of the Legal Aid Society and the Mikva Challenge. Mr. Vail earned his B.A. from the University of North Carolina and his J.D. cum laude from the University of Illinois College of Law, where he was on the Moot Court Bench.
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