Live webinar | Tuesday, September 22, 2026 | Illinois & Federal | $125 | Also available OnDemand

Summary judgment is usually won or lost in discovery, not in the brief. By the time you sit down to write, the record either contains the admissions and the undisputed facts you need or it does not, and no amount of drafting skill will manufacture them. Attorneys who consistently win these motions are working backward from the motion during depositions and written discovery, months before anything is filed.

This session treats the motion as the end of a process rather than a discrete writing task. It covers how to identify, early in the case, which issues are genuinely susceptible to summary disposition and which are not. It addresses how to structure deposition questioning to lock in the testimony a motion will rely on, and how to use requests to admit and interrogatories to close off the disputes that would otherwise defeat the motion.

The drafting portion covers what actually persuades: framing the undisputed facts, handling the evidence rules that govern what can support or oppose the motion, and the affidavit requirements under Illinois Supreme Court Rule 191 that regularly sink otherwise sound filings. It also addresses the differences between Illinois practice under Section 2-1005 and federal practice under Rule 56, including the local statement of material facts requirements that vary by district and are enforced strictly.

The session also covers the defensive side.

Speakers include the fabulous Mona Naser of Carlson Dash; Edward J. Samuelson, who spent nearly 12 years as a judicial law clerk at the Circuit Court of Cook County; and Kevin T. Turkcan, Law Clerk to Justice Rena Marie Van Tine of the Illinois Appellate Court, First District. Two of the three bring an inside view of how courts actually evaluate these motions.

Full details and registration: https://new.pincusproed.com/product/winning-summary-judgment-strategies-discovery-and-drafting-il-federal-webinar-watch-live-or-via-ondemand-streaming/