Winning Summary Judgment: Strategies, Discovery, and Drafting (IL & Federal) (OnDemand Streaming and Recorded Packages)

What You Will Learn

Agenda
1:00 p.m. – 4:45 p.m. Central Time
(includes breaks)

Faculty: Mona Naser, Samera S. Ludwig and Kevin T. Turkan

1:00 p.m. – 2:00 p.m.
Federal Court vs. State Court

• Standards
  • FRCP 56 and section 2-1005
  • Two theories for winning SJ: “Traditional” motions vs. Celotex motions
  • Two theories for opposing SJ: Disputes of fact vs. Differing inferences from undisputed facts (the “reasonable jury” standard)
• The Big Difference: Local Rule 56.1
• Practical Differences
  • Federal court
  • State court

2:00 p.m. – 2:10 p.m.
BREAK

2:10 p.m. – 3:00 p.m.
Discovery for Summary Judgment

• Creating Undisputed Facts
  • Requests to admit
  • Depositions
  • Interrogatories
  • Admissibility issues
• Creating Disputes of Fact
  • Responding to written discovery
  • Depositions
  • Affidavits
• Exercises – Identifying Disputed vs. Undisputed Facts

3:00 p.m. – 3:10 p.m.
BREAK

3:10 p.m. – 4:00 p.m.
Drafting the Motion and Statement of Undisputed Facts

• Choosing your Arguments
  • Purpose and goals of SJ
  • Organizing and analyzing discovery
  • Selectivity vs. “Kitchen sink” approach
• Drafting the Motion
  • Why this comes first
  • Avoiding the “paper trial”
• Drafting the Undisputed Facts
  • Examples of proper vs. improper undisputed facts
  • Using exhibits effectively

4:00 p.m. – 4:45 p.m.
Drafting the Response and Statement of Additional Facts

• Disputing Facts
  • Parsing the statement of undisputed facts
  • Checklist: (1) material, (2) supported in the record, (3) admissible, (4) actually undisputed
• Drafting the Response Brief
  • Framing using the SJ standard
  • Arguing inferences
• Drafting the Additional Facts

Testimonials

This is a new program. Once this seminar is held, we will update this tab with the evaluations from the program.

However, all of our speakers at this program have taught at least twice in the past at our litigation boot camps to rave reviews. Just a few of past comments on their presentations are below:

Samera Ludwig, Esq.:

• Great job! She seemed very engaged with the subject matter.
• Very helpful and thoughtful.
• Great Introduction. Very good engagement and balanced discussion.
• Valuable tips on when and why to make depositions and strategy behind whether to object or not.
• Very good. Easy to follow and informative.
• Great – kept it short and to the point.

Kevin Turkcan, Esq.:

• Nice to hear from a clerk (very important people) about what a judge is looking for during this process.
•  He was very knowledgeable, and I appreciate the perspective of an experienced fellow practitioner.
• I appreciated the information – a very polished speaker who offered valuable information.
• Very insightful!

Mona Naser, Esq.:

• I appreciate hearing about real-life scenarios and receiving practice tips.
• AMAZING and very engaging – I learned a lot of helpful tips and dos/don’ts.
• Thorough and although a topic that was very familiar, she made it interesting.
• I really like Mona, she gave practical tips in an effective manner.
• She was personable in her presentation and provided the right amount of detail.

Faculty

Mona Naser, Esq.
Member & Director of Personnel
Carlson Dash

Mona has worked with corporate and individual clients to advise, counsel, and assist them in areas of commercial litigation, commercial real estate, general corporate work, and residential real estate.

On the litigation side of her practice, Mona represents individuals and entities as well as major creditors in a multitude of litigation matters in the areas of complex commercial cases and employment law.

In her capacity as a legal business counselor, Mona has advised individual and corporate owners of multi-unit dwellings, commercial strip malls, gas stations, mixed-use property, and small businesses in matters of dispositions, acquisitions, leasing, employee policies, and financing.

She works with clients to initially determine the appropriate business formation for their respective business needs and continues the relationship by helping business clients with corporate formalities, shareholder disputes, and dissolution. She drafts Shareholder Agreements, Bylaws, Operating Agreements, Resolutions, Employment Contracts, and other documents necessary for corporate governance.

Mona’s practice goes beyond working with businesses. She also represents buyers and sellers in all matters of dispositions and acquisitions.

Samera S. Ludwig, Esq.
Partner
Kilpatrick Townsend & Stockton LLP

Samera Syeda Ludwig focuses her practice on labor and employment and business immigration. For more than 20 years, she has represented employers in both state and federal courts and in administrative proceedings throughout the country. As an experienced litigator, Samera counsels and represents businesses on matters involving employee discipline, employee claims of discrimination, and harassment and retaliation and conducts internal investigations. Samera also advises employers on immigration policies and employment related issues including obtaining non-immigrant and immigrant visas, providing immigration related guidance during corporate mergers and acquisitions, and assisting employers with I-9 employment eligibility and verification compliance.

Kevin T. Turkcan, Esq.
Law Clerk to the Hon. Rena Marie Van Tine
Appellate Court of Illinois, First District

Kevin T. Turkcan is a law clerk to Justice Rena Marie Van Tine of the Illinois Appellate Court, First District, in Chicago. He has worked for the court since 2020 and was previously a law clerk to the Honorable Eileen O’Neill Burke, the incoming Cook County State’s Attorney. From 2013 to 2020, Kevin was in private practice, primarily representing plaintiffs in police misconduct, whistleblower, and employment discrimination cases, and also practiced criminal defense. He has tried civil and criminal cases in both state and federal court.

Kevin obtained a J.D. from Loyola University Chicago School of Law in 2013 and hisundergraduate degree from the University of Notre Dame in 2009.

Fees

Pre-order now and save $25 on your purchase with the Early Bird Rate!* Early Bird Expires August 1st!
(discount will be applied automatically at check out)

Fees & Format Options

💻 OnDemand Streaming

Watch the recorded seminar on your own schedule, as often as you’d like, from any device. Access lasts one year from purchase.

• Standard Rate: $299
• Early Bird Rate: $274*
• Includes: Seminar recording + written materials
• For individual use only

Group rates available for 3–4 attorneys watching together. Licenses available for 5+ attorneys—contact us for details. info@pincusproed.com or (877) 858-3848.

📦 Recorded Packages (Download, DVD, or CD)

These packages are for a single viewer and include seminar materials.

▶️ Video Recording (Download or DVD)

• Standard Rate: $299
• Early Bird Rate: $274*
• For individual use only

🎧 Audio Only Recording (Download or CD)

Great for listening in your car or on the go.

• Standard Rate: $299
• Early Bird Rate: $274*
• For individual use only

🎥 + 🎧 Video + Audio Combo (Download, DVD, or CD)

• Standard Rate: $349
• Early Bird Rate: $324*
• For individual use only

Shipping & Tax: $12 shipping added to DVD/CD orders (plus sales tax in CA)

🗓️ Availability

This program will be recorded live on September 22, 2026.
OnDemand Streaming and Recorded Packages will be available approximately 2–3 weeks after the seminar. If you need access sooner, direct Zoom links will be provided.

⚠️ Important Notes

• OnDemand Streaming can be viewed on any device.
• Recorded Downloads must be downloaded to a computer first before transferring to another device. Files are delivered as a zipped folder containing the recording and written materials.

💼 Group Access & Licensing

Discounted rates are available for 3–4 attorneys watching together (Live or OnDemand).
Licenses are also available for firms or agencies with 5+ attorneys.

To inquire or purchase group access:
📧 info@pincusproed.com | ☎ (877) 858-3848

CLE Credit

🎓 CLE Credit Information

IL General:
This program is pending approval for 3.25 units of general CLE credit in Illinois.

California:
Approved for 3.25 General CLE credits.

New York:
This program is eligible for 3.25 General CLE credits under New York’s Approved Jurisdiction policy.
Pincus Professional Education is a California Accredited Provider, and California is an approved jurisdiction under Section 6 of the New York State CLE Board Regulations and Guidelines.

🌎 Other States

CLE credit is officially approved in the states listed above.
If you practice in a different state, we’re happy to help—upon request, we will provide the materials and information you need to apply for CLE credit on your own. Many of our past attendees have successfully obtained credit in other jurisdictions.

To request assistance:
📧 info@pincusproed.com | ☎ (877) 858-3848