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* Illinois Litigation Bundle *
Audio program! (check our CLE Programs page for live versions)
Save $825 by purchasing the bundle! The normal cost of these programs is $2125.
Our Illinois Litigation Bundle includes the following programs:
We cover everything from complaints to discovery to case management conferences, motion writing and issues, oral argument, trial prep, and trial techniques. Faculty will teach both specific skills, tasks, rules and timelines related to Circuit Court as well as providing general litigation skills tips and advice. We have multiple judges as well as experienced attorneys teaching, from both sides of the isle, so you get a variety of perspectives.
Perspectives from the bench include: Hon. Sanjay Taylor, Hon. William Sullivan and Hon. Patricia Spratt
This seminar is geared towards the litigator that wants to delve into evidence – gathering and deploying it before and during trial (as well as using it for settlement). Faculty cover the top seven things you need to know to get what you need, when you need it and to use it well once you have it.
Perspectives from the bench include: Hon. Thomas Durkin.
Our Federal Court Boot Camp has taught thousands of attorneys about the ins-and-outs of Federal Court, as well as general litigation strategies and skills, all over the country. The program is both a litigation primer and a primer for litigating in Federal Court*.
Perspectives from the bench include: Hon. Sidney I. Schenkier
(*you may substitute a download of our 2019 Federal Court Boot Camp if you prefer. Please put a note in the comments of your order.)
During this program, experienced trial attorneys and a sitting judge will teach you how to get it right, how to improve your skills at selecting a jury and how to avoid classic mistakes. They will walk you through the mechanics and rules, provide advice and strategies, update you on governing case law, and help you navigate the latest issues related to jury selection.
Perspectives from the bench include: Hon. Thomas Lyons, Hon. Rena Marie Van Tine and Hon. Edward Washington (Retired and now in private practice with Nixon Peabody).
A very practical program, our expert litigators will guide attendees through the nuanced art of the depo, from the strategic differences between trial and discovery depos to witness prep, expert witnesses, dealing with hostile witnesses and difficult opposing counsel and more.
Please note: Our Mastering the Deposition is being recorded live; the audio package will be available the first week of April.
The Illinois Litigation Bundle is available in download or CD format.
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What You Will Learn
Summaries for each program are below. Each program title is in red. For more details about each program, including the faculty list and CLE credits, please click on the links in each title.
The Early Stuff: Case Theories, Complaints, Answers, Motions to Dismiss, Motions to Strike and CMCs
- Case Theories
- Complaints and Answers
- MTDs/Motions to Strike
- MTDs v. Answers
- Case Management Conference / Scheduling Your Case
Non-Oral Discovery & E-Discovery
- Regular Discovery
- Key Rules and Timeline
- Overlooked Deadlines
- Procedural Issues that are often missed or common
- Strategies and choices
- Circuit Court v. Federal Court
- Key Rules and timeline
- Cost Saving Measures
- Mistakes not to make
- Important state cases
- State v. Federal rule differences
- Deciding whom to depose
- Taking good depositions / Mistakes not to make
- Making effective use of depositions at trial
Motions for Summary Judgment
- Motions to Compel / Motions for Protective Order
- Motion to Exclude Expert Testimony
Heading to Trial
- Final Status Conference
- Trial Outline
- Motions in Limine
Your Pre-Trial Tasks, Selecting and Dealing with Your Jury
- Jury Selection in State Court / Procedure, Strategies and Questionnaires
- Jury Instructions, Jury Verdict Forms
- Evidence Issues
- Opening Statements
- Direct and Cross-Examinations of Lay
- Direct and Cross-Examination of Expert witnesses
- Evidentiary Objections
- Closing Arguments
Post-Trial Motions and Judgments
- Post-Trial Motions
Procuring and Producing Electronically Stored Information
- Avoiding Spoliation Side-Shows with Proper Litigation Holds
- Proportionality, cost-management, and efficiency in gathering ESI
◦ Includes recent changes to FRCP
- Coping with party disparity as it relates to ESI
- ESI protocols and cooperation as safe-harbors
- Technology-assisted review
Investigating and Gathering Evidence from Challenging Sources
- Archived records or old information
- Non-cooperative witnesses
- International discovery
- Overcoming admissibility barriers
Effectively Using Pretrial Discovery to Settle Your Case
- Informing the Court (in non-dispositive motion practice)
◦ Case Management/Status Conferences
- Mediations and other settlement negotiations
◦ Non-Binding Arbitration
◦ Informal Settlement Meetings (Meet for Lunch)
- Motion practice (e.g., summary judgment, Daubert, and other pretrial motions)
◦ Motions for Partial Summary Judgment
◦ Motions in Limine
- Using technology to show the evidence
◦ Powerpoints and Videos
◦ Video Reenactments
◦ Putting the jury there
Opening Statements, with demo
- What the evidence will be in the trial and what you are likely to see and hear in the testimony
- Visual aids
- Problems with your case
- The other side’s case
- Strategic Planning
◦ Developing the theme of the client’s case
◦ Organization, presentation and order of witnesses
◦ Preparing the witness
◦ Ethical considerations
- Persuasive Testimony
◦ Subcategories of the story
◦ Transitions that build on the testimony
◦ Eliciting facts and emphasizing strengths
◦ Holding the judge and jury’s attention
◦ Enhancing the credibility of the story
- The Form of the Questions – tips and techniques
- Anticipate & handle objections
Cross Examination (with demo)
- Using the depo against a witness
- Cross-examination, an art exhibiting the pinnacle of trial advocacy
- Who is subject to cross-examination
- When should I cross-examine
- Cross examination of lay v expert witnesses
- Techniques of cross-examination and key points to consider
- Word choice/ Connecting with Jurors
- Whether to address witness by title
- Dealing with non-responsive witness
- How to not ask one question too many
Closing Arguments, with demo
- Format the closing around the jury charge – addressing the elements of the claims and defenses
- Use documents to resolve credibility questions
- Use demonstratives to summarize voluminous records
- Showing how the evidence supports the themes introduced in opening statement
Intro to program and Federal Court
- We’re not in Kansas Anymore: Overview of Practical Differences Between State Court and Federal Court Practice
- Material Differences Among Illinois’ Federal Districts
- Highlights from the Local Rules and Local Practice (key practical rules, CM/ECF, forms, 28 USC § 636 Magistrate Judges, and more!)
- Rule 1
Complaint and Answer Rules, Differences, Advice and Strategies
- Plausibility Standard: Rule 8’s Short and Plain Statement
- Forms of Complaints and Answers/Defenses
- Defenses vs. Affirmative Defenses
- Practice Pointers and Pitfalls
Case Scheduling and the Case Management Conference in Federal Court
- Rule 16.1
- Case Management Reports
Rule 12 and Other Motions
- Top ten tips for drafting Rule 12(b)(6) motions, responses, and replies.
- How to enhance the effectiveness of memoranda addressing motions to dismiss.
- How to address procedural issues that frequently arise when briefing motions to dismiss.
- Additional Rule 12 motions
- Ex Parte Motions
- TRO or preliminary injunctions
Discovery & eDiscovery
- CM/ECF brief overview/advice
- Pilot program on mandatory initial disclosures
- 26(a)(1) initial disclosures
- Interrogatories, request to produce – differences between state and federal
- 2015 Amendments to the Rules of Civil Procedure
- Scope of discovery / proportionality
- Requests for production and responses
- Failure to preserve / sanctions
- How courts have interpreted them
- Overview and considerations
- Sources and preservation
- Federal Rule of Evidence 502
- Federal Rules related to Depos
- Federal v. State differences
- Subpoenas & affidavits
- Deadlines and rules
- Strategy and Deciding whom to depose
- Taking good depositions
- Making effective use of depositions at trial or for settlement
Drafting and Replying to Motions for Summary Judgment
Oral Argument Tips
Heading to Trial
- Trial Briefs
- Pretrial Statement
- Pretrial Conference and Order (FRCP 16)
- Your Jury:
- What is unique about Jury Selection in Federal Court?
- Questionnaire and Voir Dire Tips
- Jury Instructions – pitfalls & best practices
- Jury Verdict Forms – pitfalls & best practices
- Motions in Limine – How do they differ from state court?
- Introduction of Exhibits
- Evidentiary Objections
- Direct and Cross-Examinations
- Purpose, audience and format requirements
- Basic direct examination skills
- Basic cross examination skills
- Preserving the Record for Appeal
Post-Trial Motions & Judgments
Overview of Jury Selection
- Goal(s) of jury selection
- Is it jury selection or jury de-selection?
The Law of Jury Selection (include ethics)
- The rules pertaining to challenging jurors for cause
- Batson/Wheeler motions in jury selection
- The rules about monitoring jurors’ social media
The Mechanics – Critical Skills
- The basic mechanics of jury selection (12-packs, 18-packs, etc.)
- Rating and tracking methods
- Planting seeds and introducing themes and issues
- The danger of demographics in jury selection
- Challenges – Strike strategies
- Juror Questionnaires:
- Civil v. Criminal differences
Finding out about Jurors: Voir Dire
- How Lawyers can ask good questions
- Do’s and Don’ts of Voir Dire
- Questions from the bench vs. questions from lawyers
- How judicial voir dire can sometimes help
- Efficient approaches to questioning the panel
- Focus on identifying “bad” leaders
- Voir Dire Time limits in state and federal court
Potential Impact of 21st Century Potential Juror Nuances on Selection
How Lawyers Should Deal with Juries During the Trial
- Rules about contact with jurors
- Tips on how to be polite without engaging
- What to do if you observe improper juror behavior
- Continuing relationship with Jurors without contact
A Few Comments about Jury Selection for Personal Injury v. Jury Selection for Commercial Disputes
Demonstration and Analysis of Jury Selection
Mastering the Deposition
The following testimonials are from our Circuit Court Boot Camps:
“Great overview…great practical, real-life experience, especially for new attorneys.” – Aaron Curry, Esq.
“Good, well-rounded introduction to basic civil litigation practice.” – Nemura Pencyla, Esq.
“Good explanation of limited attorney-client privilege for client corporations in Illinois. Judge Tailor is a quintessential jurist…[Jack Snyder was] Excellent.” – Thorn McClellan Smith, Esq.
“I recently made the transition from criminal to civil litigation. This was a great refresher course in smoothing that transition.” – Stephanie Pauly, Esq.
“Very detailed [and] covered a wide variety of topics.” – Brad Eben, Esq.
“The example deposition with objections was one of the most helpful and practical examples I have ever seen; Most presenters tell you what to do or not to do without showing you; this was great!”
“Best part of the seminar was the mock deposition conducted by Leonard and White.”
“Good substantive content, legal updates, and case law.” – David Swiss, Esq.
“I very much liked the opportunity for spontaneous questions and resulting discussion.” – Mel Newman, Esq.
“It covered a lot of beneficial [information]. Speakers’ experiences were very helpful.” – Gabriel Borges, Esq.
“I really liked the example of the deposition being acted out.”
”Excellent program and extremely beneficial!” – Peter Benke Esq.
“This was one of the best CLE’s I have attended this year.” – John A. Doerrer, Esq.
“Great investment to my future in trial practice.” – Kevin Borozan, Esq.
“I really enjoyed how the speakers talked about mistakes they’d seen or done. It made it less dry and easier to follow. I really liked the list of objections.”
“Nice to have a judge’s perspective. [Judge Tailor was a] good speaker. [Megan Thibert-Ind] was my favorite speaker…very engaging and great advice.”
“The speakers were informative and animated, keeping me engaged. Many wonderful tips I will carry over into my own practice.” – Shanna N. Crafts, Esq.
“This program should be mandatory for all new attorneys.” – Anthony McMahon, Esq.
“This was extremely helpful for my practice.” – Lhea Keller, Esq.
”Very happy with the practical tips and experience that came out of the seminar.” – Jessica Rimkus, Esq.
”Panel/Speakers were very pleasant. Significant amount of information packed in sessions. The seminar was enjoyable and informative.” – Greg Sandifer Esq.
“Good info in each section. Thank you.” – Eric Chisholm, Esq.
“Extremely well organized, informative, interesting and helpful.” – Nancy Pacher, Esq.
“All the speakers were great!” – Amit Patel, Esq.
”Very informative, especially practical pointers.”
”I liked having both plaintiff and defense counsel on the same panel. I like the diversity of the forms represented and appreciated the practical tips.” – Natasha Adler, Esq.
”Speakers were very knowledgeable and informative.”
”Everything was covered – jury instructions were very helpful.”
”Very good course especially when they gave specific stories and/or examples.”
”Very good trial advocacy overview.” – Amanda Wendorff, Esq.
”The mechanical aspect of litigation improved my knowledge as a new attorney. Understanding the process from beginning to end.”
“Really informative and great to hear a judge’s perspective, especially one from the law division.” – Julie Sieracki, Esq.
“Helpful info presented.” – David Mellem, Esq.
“Excellent and hugely helpful. Animated but extememly relevant info…” – Mario P. Carlasare, Esq.
“Great aids. Excellent panel – very informative.” – Anthony O’Neill, Esq.
“Good explanation of discovery requirements.” – Amy Rapoport, Esq.
“Very good. Would recommend to others.” – Bruce Theobald, Esq.
“Very experienced speakers with practical real-world examples.” – Lisa Clay, Esq.
“Good content!” – Michael Lightfoot, Esq.
“The enumerated lessons (i.e. 10 things to do on direct examination for expert witness) were very valuable!” – Valerie Magnuson, Esq.
“Great discussion of direct and cross.”
“Gave a lot of insight on the inner mechanics of the Circuit Court system at trial. A++!”
“[Morning speakers] were great and worked well together.”
“The course was very comprehensive…the speakers were all knowledgeable and engaging.”
“Morning panel on pre-trial issues was…strong, particularly on discovery and depositions.”
“[Mike Leonard] was my favorite…I enjoyed the afternoon panel.”
“Very satisfied. [Wanted] an overview and this was what I was looking for.”
“Engaging, thought-provoking relevant information.”
“Great overview of a lot of topics!”
“Great tips on drafting discovery requests.”
“Excellent examples and analogies.”
“Great suggestions! Good to have a judge’s perspective.”
The following testimonials are from our Evidence program in 2017:
“Great panel. Thank you!” Elizabeth J. Fragale, Esq.
“It was a great day, thank you! Much of the content was very helpful.”
“Great presentation of a cross-examination.”
“Great personal experiences in the cases he presented, as well as relevant case law to later refer to.”
“Very valuable training. Thank you.”
“Great presentation and practical tips for conducting statements and strategies which were applicable across the board.”
” Fantastic! Professional with a mastery of the content.”
The following testimonials are from our Federal Court Boot Camps:
“Excellent presentations. The discovery pilot program discussion was very good.” – Colin O’Brien, Esq.
“They addressed great topics.” – Zartosht Khodavandi, Esq.
“The program is fantastic! I was so impressed by the depth and content of each speaker’s oral presentations and course materials. The program was great. I am so glad I came.” – Laura Lee Robinson, Esq.
“I thought the deposition, MSJ, and trial tips were very helpful and informative. Ms. McNally was a great instructor. She had a lot of very useful tips, strategies, and practice pointers. I learned a lot from her presentations.” – Mikayla Hamilton, Esq.
“Laura McNally was great! Loved the PowerPoints and MSJ advice she gave.” – Maria Magginas, Esq.
“This gave me a good overview of federal court practice, and pointed me towards other helpful resources. Thanks for giving a few spots to legal aid. We really appreciate it!” – Kathryn Socha, Esq.
“Good information on depositions, especially pertaining to entities and Mr. Bolton gave excellent advice and presentation.” – Nathan A. Frisch, Esq.
“Excellent overview of complaint and answer strategies.” – Jenna Milaeger, Esq.
“Excellent.” – Julia Funke, Esq.
“Good program with useful info.” – Jeff Hamera, Esq.
“The seminar was excellent – very helpful in my development for practicing in federal court. It provided a lot of practical advice in one day. The judges were very helpful in providing the perspective from the bench.” – Rob Harrer, Esq.
“Our firm is beginning to take on more federal cases. This covered everything I wanted. The program was fantastic.” – Peter Beake, Esq.
“I’m very happy with the topics that were covered. Excellent seminar! I will recommend this to other attorneys!” – Sarah Hertz, Esq.
“Very satisfied. It was an efficient use of time. The seminar had well-prepared presenters, good written materials and the staff/facilitators were well-organized.” – Michael P. Coghlan, Esq.
“I am agency counsel, so I don’t practice in Federal Court, but rather assist the AUSAs with the case against staff. This training was very helpful to me to get a better understanding of why the AUSAs request or need certain information. It was also helpful for me to know how I can assist them better.” – Amy Standefer Mallott
“This program allows attorneys to ask ‘dumb questions’ they can’t ask the firm, and gives the background for a lot of topics they haven’t been exposed to yet. This eliminates the need to do preliminary research on only background guidance.” – Kerri Feczko, Esq.
“Best CLE program I’ve been to, because it was comprehensive.” – Ronald Boggs, Esq.
“The Federal Rules Course in Chicago was outstanding. Rick Levin, Brad Nahrstadt and their group of outstanding attorneys worked hard and delivered a most thoughtful scholarly presentation.” – B.F. Natarus, Esq.
”Good straight forward presentation. Clear and concise.” – Randy Wolf, Esq.
“Insightful discussion as to what clerks and judges are looking for.” – Richard Lehman, Esq.
“Very informative and insightful commentary.” – Tim Lessman, Esq.
“insightful and educational on a wide variety of federal court subjects.” – Jonathan Wassell, Esq.
”I learned a lot about depositions regardless of fed vs. state.” – Lucas Sun, Esq.
“Very relevant.” – Jeffrey A. Goodloe, Esq.
“Excellent – very thorough!” – Steve McMullen, Esq.
“Good overview from start to finish.” – Kevin Halverson, Esq.
“This was an excellent seminar!” – Charles P. Romaker, Esq.
“I liked comparisons between state and federal court.” – Lisa Clay, Esq.
“Great pointers and good checklist materials.” – Amy Wilson
The following testimonials are from our Jury Selection programs:
“Great seminar – particularly compared to something I listened to on CD from another MCLE provider.” – Ardith Juan, Esq.
“I was very satisfied. I picked up a lot of very useful insights from a panel with obviously experienced and talented attorneys.” – Luke Ryan, Esq.
“Very professional and informative presentation. Panelists worked so well together – very impressive.” – Ardith Juan, Esq.
“Excellent program full of practical examples; loved the demonstrations at the end.” – Kimberly Smith, Esq.
“Appreciated insights from perspective of both judge and attorney.”
“I’ve practiced and picked juries for 44 years – but it’s always good to get more ideas.”
“Very good seminar!” – Scott T. Kamin, Esq.
“Very good course! Thank you!” – Aileen Flanagan, Esq.
“Excellent program.” – Paul Blatz, Esq.
“The live demonstration was incredibly helpful in illustrating the lessons discussed during this seminar.” – Fitzgerald A. Javellana, Esq.
“As a defense attorney, I am regularly staring down the barrel of jury selection with little or no time to prepare. This program helped point out the major points I should focus on during jury selection.” – Anthony Burchell, Esq.
“Gave great nuts and bolds on Jury Selection, not just topical but in-depth.” – Michael Lynott, Esq.
“I’m brand new to jury trials, so the fundamentals and discussion were very helpful.”
“Great! Very helpful mock jury demonstration to see how it all goes down!”
“I found it very helpful and worthwhile.”
“This was very interesting and helpful.”
“The lectures were very important and covered some really good subjects.” – George Ford, Esq.
“The materials are great.”
“Informative and practical.” – Barbara Paige, Esq.
“Very helpful.” – Raul Aspuru, Esq.
“Very helpful and well organized. It was good to hear both sides of various issues.”
“Very informative, a lot of great insight from trainers.”
“Very good information; learned a lot.”
“I liked it, very useful.”
The following testimonials are from our Mastering the Deposition seminars:
“Speakers used a real life examples, which was incredibly helpful. Very engaging presentations!” Grace K. Nae, Esq.
“I learned a lot about expert witnesses, which would be useful in one of my current cases.” Jay Kumar, Esq.
“Everyone was great – very knowledgeable about the subject matter and all speakers imparted great advice and insight.” Neil McLaughlin, Esq.
“Lots of good material and examples.” Maureen Faller, Esq.
“Everything was great. Each speaker was so informative and provided great examples and tactics. I learned a lot of useful information.” Krista Sifuentez, Esq.
“This was a very informative. Better than reading books about the topic.” James Lin, Esq.
“I thoroughly enjoyed the seminar. I feel that I now have the knowledge necessary to better choose witnesses to depose and how to properly and completely prepare for taking and defending such depositions.”
“Very satisfied – I appreciate the program was at the appropriate level for the audience, I learned tidbits that will increase my confidence and taking depositions as I return to the action practice of law.”
“Presenters were all excellent and really knew their stuff.”
“Very thorough and very informative.”
“Speakers were all excellent and presenting practical tips.”
“Very well done by all speakers involved. Deposition taking seems much less daunting.”
“The demonstrations were a highlight, particularly Leonard and Warner.”
“I found the demonstrations helpful.”
Please click on the program name to see the full list of faculty for each program.
Save $825 by ordering the bundle! If you ordered each program individually, the cost would be $2125.
Audio Recording & Materials Package – CD or Download: $1299
For CDs please add $7.50 shipping and, in CA, sales tax.
IL General: The full bundle is approved for 38.5 units of general CLE in Illinois. Please check the individual seminars to see when each program expires.
Professional Responsibility: 5.0 units
Please check the individual seminars to see when each program expires.
CA General: This program is approved for 38.5 units of general CLE in California.
This program is approved for CLE in the states listed above. Upon request, Pincus Pro Ed will provide any information an attorney needs to support their application for CLE approval in other states other than what is listed above.
Terms and Policies
Recording policy: No audio or video recording of any program is permitted.
Seminar Cancellations: Should you be unable to attend for any reason, please inform us in writing no later than 14 days prior to the event and a credit voucher will be issued. If you prefer, a refund, less a $50 non-refundable deposit, will be issued. No refunds or credits will be given for cancellations received within 14 days of an event. However, if you notify us within 14 days of an event, and wish to convert your in-person attendance registration to an Audio CD package (with handout), we can do so. A small additional shipping charge, and sales tax in CA, will be incurred. No shipping charge is incurred for downloads. We will also issue a voucher for the amount paid if you notify us within 14 days and prefer not to have the audio recording.
Substitutions may be made at any time.
Webinars, Tele-seminars and Webcast Cancellations: Once log-in codes and passwords are issued for a webinar, tele-seminars or webcasts, a refund is not possible. If for any reason you cannot attend the event after you have received the codes, we will automatically convert your registration to an instant streaming/instant download or CD format and provide you with the information you need to access the recording after the program concludes and the recording is available. Conversions to CD require a $7.50 shipping fee, and in CA, 9% sales tax.
Downloads/CDs/DVDs – Refund policy:
Downloads are non-returnable/non-refundable once purchased and received. Tapes, CDs and DVDs are returnable for a full refund or replacement if defective, within 90 days of purchase.
Reminder: The room temperature at hotels and other seminar locations are notoriously hard to control. Please bring a sweater or jacket in case it gets cold and/or layer as if you are going to the movies so you are comfortable.