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Apex Jurist Skills: Supreme Court Rule 213 (f)(3)

Depositions

Seminar Topic: This material provides a jurist skill set of the Supreme

Court Rule 213(f)(3) depositions and an in-depth examination of the

process and procedure

This material is intended to be a guide in general. As always, if you have

any specific question regarding the state of the law in any particular

jurisdiction, we recommend that you seek legal guidance relating to your

particular fact situation.

The course materials will provide the attendee with the knowledge and

tools necessary to identify the current legal trends with respect to these

issues. The course materials are designed to provide the attendee with

current law, impending issues and future trends that can be applied in

practical situations.

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Copyright © 2015 Printed in the United States of America. All rights reserved. No part of this

monograph may be reproduced or transmitted in any form or by any means, electronic or mechanical, including photocopying, recording, or by any information storage and retrieval system, except for citation within legal documents filed with a tribunal, without permission in writing from the publisher.

Disclaimer: The views expressed herein are not a legal opinion. Every fact situation is different and the reader is encouraged to seek legal advice for their particular situation.

The Apex Jurist, www.ApexJurst.com is Published by ApexCLE, Inc.

www.ApexCLE.com

Ordering Information:

Copies of this monograph may be ordered direct from the publisher for $24.95 plus $4.25 shipping and handling. Please enclose your check or money order and shipping information. For educational, government or multiple copy pricing, please contact the publisher.

Library of Congress Cataloging-in-Publication Data

ApexCLE, Inc.

1. ApexCLE, Inc. 2. Law-United States – Guide-books. 3. Legal Guide 4. Legal Education.

119 South Emerson St., Suite 248 Mount Prospect, Illinois 60056 Toll Free 866-657-2004

920 South Spring Street Springfield, Illinois 62704

Toll Free 866-657-2004

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Author’s Email Address: mbaron@gfblaw.net

Author’s Website: http://gfblaw.net/

Author’s Mailing Address:

33 N. Dearborn, Suite 950

Chicago, IL 60602

Author’s Phone Number: 312-726-7772

About The Author Mr. Baron is a Senior Partner at Goldstein, Fluxgold & Baron, P.C. and has been working with Louis S. Goldstein and Cindy G. Fluxgold since 1994. For over 20 years, Mr. Baron has represented Plaintiffs in civil litigation, including medical malpractice, personal injury and civil rights, in both state and federal court. He has represented clients in major injury and death cases. Over the years, Mr. Baron has obtained millions of dollars for his clients through settlement, litigation and trial.

Mr. Baron lectures to student groups and provides instruction regarding current trial techniques. He remains actively involved in judging trial competitions, mediations and negotiation competitions. In addition to joining the adjunct faculty at the Chicago-Kent College Of Law, Mr. Baron has served as a panelist, evaluator and Judge for various trial courses, court competitions and exercises. He has been coaching Chicago-Kent Trial Advocacy Teams, including, Georgetown White Collar Crime, American Association for Justice, NBLSA and NCTC Competitions. Mr. Baron is actively involved with his alma mater, The John Marshall Law School, with mentoring current students, assisting with job placement and alumni relations.

Mr. Baron has continually contributed to Personal Injury Forms: Illinois – 4 Volumes, which was published by Lawyers Cooperative Publishing. Mr. Baron is Co-author of the Chapter entitled “Opinion Evidence” of Illinois Civil Trial Evidence, Illinois Institute of Continuing Legal Education.

Mr. Baron is a member of the Illinois Bar, US District Court for the Northern District of Illinois and the West Suburban Bar Association.

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Supreme Court Rule 213(f)(3) Expert Deposition Outline

Who are you?

• C.V. Licensure, suspended or revoked - Privileges, suspended or

revoked

• Last 7 years, testify, Plaintiff or Defendant, income tax purposes for

expert work

• Expert Consulting vs. Practice / Operate / exam, see

patients/customers

• Publications in the field - Continuing education, research

What do you look at?

If they sent everything, if not, did you ask for other materials

• Plaintiff depositions, list of depositions, records, all materials

• Plaintiff or Product or Subject matter of litigation

• Outside materials, tangible things

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What did they ask you to do?

• Who, correspondence, contact on phone, conversations, emails

• Literature, related to attorney of retaining firm, social relationships,

• 1st work, number of case for firm, individual attorney, how did they

find you?

What did you do?

• How do you work? What is your process as an expert?

• Notes, tabs, margin writing, electronic record, where is your file?

• Did you only answer specific question? Anything beyond what was

asked?

• Telephone – what did they ask?

• Literature – What was it?

• Go through Supreme Court Rule 204(a)(3) NP, timely served and responded to.

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What do you understand the facts were?

• Given facts by attorney v. Plaintiff deposition v. other source

• Was there treatment before accident, circumstances before event

• Exams of Plaintiff, review actual MRI films

What do you think about it?

• Use witnesses filed 213 SRC 213(f)(3) Opinions & Disclosures

• Are opinions all in report, Go through the report and eliminate

ambiguities

• Exhibits & Logical Colloraries

Is there anything else?

• Under SCR rules need to disclose opinions Any other opinions you

have?

• Are these all exhibits & opinions that you will be testifying to