Winning Summary Judgment: Strategies, Discovery, and Drafting (IL & Federal) [Webinar] (Watch Live or via OnDemand Streaming)

Agenda

Agenda
September 22, 2026
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

Date/Time/Location

📅 Live Webinar

Dates:

• Tuesday, September 22, 2026

Time:
🕐 1:00 p.m. – 4:45 p.m. Central Time

You’ll receive your login instructions and program materials approximately one week before the seminar. Be sure to check your inbox (and spam folder), and add info@pincusproed.com to your contacts to ensure delivery.

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 – Live Two-Part Webinar

🎓 Registration Fees (Per Person)

💼 Standard Individual Registration

• Early Bird Rate: $274
• Standard Rate: $299

👥 Group Rate (2+ from same firm/agency)

• Early Bird Rate: $264 per person
• Standard Group Rate: $289 per person
  All attendees must pre-register together.

🏛️ Government / Legal Aid Attorneys**

• Early Bird Rate: $254
• Standard Rate: $279

📚 Law Students / Paralegals*

• Early Bird Rate: $174
• Standard Rate: $199

📦 Pre-Order the Recording (Attendee-Only Special)

When registering for the live webinar, you can pre-order the Recorded Package (Download or OnDemand) for just $99.

This special rate is only available to registered attendees for their own use.

📩 Program Materials & Access

• A PDF copy of the seminar handbook will be emailed to you a few days before the program.
• We’ll also send your login instructions and any exercises approximately one week prior.
• Please check your spam folder and add info@pincusproed.com to your contacts.

💼 Group Access & Licensing (Live or OnDemand)

Discounted rates are available for 3–4 attorneys from the same organization.

Licenses are also available for firms or agencies with 5+ attorneys who wish to attend live or access the OnDemand recording.

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

⚠️ *Important Notes

• Registration fees are per person, unless a group license is purchased.
• Law Student Rate is for currently enrolled law students only. Please be prepared to provide student ID after registering via email.
• Legal Aid Rate applies only to attorneys employed full-time by legal aid or nonprofit organizations.
  

  It does not apply to private firm attorneys volunteering time, taking pro bono cases, or serving on nonprofit boards.

🎓 Scholarships for Legal Aid Attorneys

Full or partial scholarships may be available for a limited number of legal aid attorneys.

Please contact us to inquire:
📧 info@pincusproed.com | ☎ (877) 858-3848

CLE Credits