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List of Forms by Chapter
Chapter 1 — Sources and Preparation
II. General Principles of Investigation
III. Collecting, Preparing, and Preserving Evidence
IV. [1.44] Relevancy and Materiality
V. Competency of Witnesses
VI. Appendix — Sample Forms
Chapter 2 — Methods and Sufficiency of Proof
I. Introduction
II. Mechanics of Trial
III. Mechanics of Proof
Chapter 3 — Questions and Objections: Relationship of the Witness to the Form of the Question
II. Types and Timeliness of Objections
III. Direct and Cross-Examination
IV. Examination of Particular Types of Witnesses
V. Common Objections to Form
VI. Use of Documents To Refresh Memory
VII. Form of Questions to Experts
VIII. Wilson v. Clark; Federal Rules of Evidence 703 and 705
Chapter 4 — Hearsay: The Rule and the Exceptions
II. Hearsay
IV. [4.5] Non-Hearsay
V. [4.11] Hearsay Exceptions
Chapter 5 — Opinion Evidence
I. Introduction
II. Lay Opinions
III. Expert Opinions
Chapter 6 — Writings at Trial
II. Writings and the Best Evidence Rule
III. Writings and the Hearsay Rule
IV. Business Records as Exceptions to the Hearsay Rule
V. Authentication of Writings
Chapter 7 — Privileges
IV. Waiver of Privileged Communications
V. Attorney-Client Privilege
VII. Marital Communications Privilege
VIII. Medical and Psychiatric Privileges
XVII. Miscellaneous Privileges
Chapter 8 — Physical Objects and Demonstrative Evidence
II. [8.2] Real Evidence
III. Demonstrative Evidence
IV. Documentary Evidence (Real and Demonstrative)
Chapter 9 — Evidentiary Motions at Trial
I. Evidentiary Motions at Trial — General Considerations
II. [9.8] The When, Where, and How of Motions at Trial
III. [9.16] Housekeeping Motions Before Trial
IV. [9.21] Substantive Motions That Should Be Raised Before the Trial Begins
V. The First Motions After Trial Begins
VI. [9.33] Keeping the Record Neat and Tidy
VII. [9.42] Motions Made for Purposes of Enforcement
VIII. Motions Made for Purposes of Admitting, Barring, or Limiting Witness Testimony— Including Experts
IX. Motions Made for Purposes of Admitting, Barring, or Limiting the Use of Exhibits
X. [9.60] Motions When Things Go Awry
XI. [9.68] Motions To End Trial
Chapter 10 — Judicial, Attorney, and Juror Misconduct
II. Voir Dire
III. Opening Statement
IV. Conduct of Counsel During Trial
V. Closing Argument
VI. Contempt
VII. Judicial Misconduct
VIII. Juror MisconductMichael J. Baron is a Partner with Goldstein, Fluxgold & Baron, P.C., in Chicago, where he concentrates his practice in medical malpractice and personal injury. Baron has served on the adjunct faculty at the Chicago-Kent College of Law and has coached Chicago-Kent Trial Advocacy Teams, including for Georgetown White Collar Crime, NCTC, and BLSA competitions. Baron has continually contributed to PERSONAL INJURY FORMS: ILLINOIS. He is also a member of the Advocates Society and the West Suburban Bar Association. He received his B.A. from the University of Illinois and his J.D. from The John Marshall Law School in Chicago.
Jeremy N. Boeder is a Partner with Tribler Orpett & Meyer, P.C., in Chicago. His practice focuses on professional liability defense. Mr. Boeder was named as a Rising Star by Super Lawyers (2013 – 2017) for his work in the area of professional malpractice defense and as a Leading Lawyer in the areas of professional malpractice defense, commercial litigation, and personal injury defense. Mr. Boeder received his B.A. from the University of Wisconsin-Madison and his J.D. from Loyola University Chicago School of Law, where he served as the Lead Articles Staff Editor for the Loyola Law Review.
Peter G. Bora is a Partner with Foran Glennon Palandech Ponzi & Rudloff PC., in Chicago, where he concentrates his practice in complex commercial litigation and insurance coverage matters. Prior to joining the firm, he worked at his own independent firm developing an individualized client management approach to provide confident and compassionate advocacy in litigation matters. Bora is a member of the American and Chicago Bar Associations and regularly serves as a featured speaker at events hosted by both associations. He has also served as a judicial clerk in the Circuit Court of Cook County’s Chancery Division. Bora received his B.S. from Illinois State University and his J.D. with distinction from The John Marshall Law School, where he was a member of and is published in The Software Law Journal.
Brian E. Devilling is a Partner at Foran Glennon Palandech Ponzi & Rudloff PC, in Chicago, where he focuses on civil defense litigation. He has served as adjunct professor of Advocacy at Loyola University Chicago School of Law. He received his B.A. from the University of Michigan and his J.D. from Loyola University Chicago School of Law.
John C. Ellis is the Owner of Ellis Legal P.C., in Chicago, and focuses his practice on commercial litigation. He is a member of the Board of Managers with the Chicago Bar Association. Ellis received his B.A. from the University of Illinois at Urbana-Champaign with distinction and his J.D. from Loyola University School of Law, where he was a Philip H. Corboy Fellow.
Cindy G. Fluxgold is a Partner with Goldstein, Fluxgold & Baron, P.C., in Chicago, where she concentrates her practice in medical malpractice and personal injury law. Fluxgold is coeditor of PERSONAL INJURY FORMS: ILLINOIS. She has lectured to bar associations and student groups, including appearances on both radio and television. She is a member of the Illinois State Bar, the Decalogue Society of Lawyers, the U.S. District Court for the Northern District of Illinois, the Illinois Trial Lawyers Association, and the Women’s Bar Association of Illinois. Fluxgold received her B.A. from the University of Illinois and her J.D. from IIT/Chicago-Kent College of Law.
Nathan P. Karlsgodtis Partner at McKnight & Kitzinger, LLC, in Chicago, where he concentrates his practice on civil litigation and appellate practice. Mr. Karlsgodt received his B.A. from the University of Southern California and his J.D. from the University of San Diego School of Law.
Corry P. Keilin is an attorney with Tribler Orpett & Meyer, P.C. in Chicago. He focuses his practice on civil litigation and general tort defense. In September 2014, Mr. Keilin presented Discovering the Discoverable to the Chicagoland Health, Safety, and Environmental Conference at Northern Illinois University-Naperville. He was selected for inclusion in “Super Lawyers — Rising Stars Edition” in 2012 and 2013 for his work in the area of general personal injury defense. Mr. Keilin is a member of the Chicago and Illinois State Bar Associations. He received his B.A. from the University of Iowa and his J.D. from The John Marshall Law School.
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. Miller has been an arbitrator for the American Arbitration Association since 2008, FINRA since 2018, and the Cook County Mandatory Arbitration Program from 2003 – 2005. He has served on the IICLE® Board of Directors from 2023 – present, and 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. 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, and he graduated magna cum laude from the University of Illinois College of Business.
Melissa N. Schoenbein is an attorney with the firm of Heyl, Royster, Voelker & Allen, P.C., in Peoria. She concentrates her practice in commercial litigation. Ms. Schoenbein served as the Assistant Managing Editor of LEGAL MEDICINE PERSPECTIVES (2012 – 2013) and as a Young Lawyers Committee member, Peoria County Bar Association (2010 – present). She received the Best Brief Award, Southern Illinois University Health Law Intramural Moot Court Competition and the CALI Award in Advanced Appellate Advocacy. She is a member of the Peoria County Bar Association and the Abraham Lincoln Inn of Court in Peoria. Ms. Schoenbein received her B.A. from Bradley University summa cum laude and her J.D. from Southern Illinois University School Law cum laude.
Patrick J. Sprague is an attorney at Bruce Farrel Dorn & Associates in Chicago. He concentrates his practice in civil litigation defense. He has taken multiple civil cases to verdicr before juries in the Law and Municipal Divisions of Cook County. He has also successfully drafted and argued summary judgment motions on a range of topics including: premise liability, landlord/tenant, employee/independent contractor, contract disputes, etc. Mr. Sprague serves as an Auxiliary Board Ambassador for the Big Shoulders Fund. He is a member of the Chicago Bar Association where he is a volunteer for the Wills for Heroes program. He received hi J.D. from Valparaiso Law School magna cum laude.
Craig L. Unrath is a Partner at Heyl, Royster, Voelker & Allen, P.C., in Peoria, and is Chair of the firm’s Appellate Practice Group and Vice Chair of the Professional Regulation/Licensure Practice Group. Mr. Unrath is Chair of the Amicus Committee for the Illinois Association of Defense Trial Counsel and has been named to the Illinois Super Lawyers list (2008 – 2018). He earned his J.D. from the University of Illinois and his B.A. from Shimer College.
Lorenzo Valladolid is a Partner with Goldstein, Fluxgold & Baron, P.C., in Chicago, where his practice is concentrated in medical malpractice and personal injury law. Valladolid has served as an evaluator for various trial completions and has coached mock trial competition teams at the IIT/Chicago-Kent College of Law. He is a member of the Illinois State Bar Association and active in Hispanic and minority legal community and advocacy, and he is a member of the Hispanic Lawyers Association of Illinois. Valladolid received his B.S. from the University of Notre Dame and his J.D. from IIT/Chicago-Kent College of Law.
Michael J. Waters is an attorney with the law firm Vedder Price P.C. in Chicago where he is a member of the firm’s Litigation Practice Group and focuses his practice in commercial litigation. He is a Certified Information Privacy Professional (CIPP/US) through the International Association of Privacy Professionals (IAPP) and also has served as Assistant Editor of the American Bar Association’s Antitrust Law Journal. He was recognized as an “Illinois Rising Star” by Super Lawyers Magazine (2009 – 2014). Mr. Waters is an active member of the American and Chicago Bar Associations as well as being a member of the Trial Bar of the Northern District of Illinois. He received his B.S. from the University of Michigan and his J.D. from Northwestern University Law School.
M. Derek Zolner is an attorney with Vedder Price P.C. in Chicago, where he focuses his practice on all areas of civil business litigation, including commercial disputes, intellectual property litigation, and business torts. Mr. Zolner received his B.A. and J.D. from the University of Oklahoma.
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