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law-books-291676_1920-300x225Depositions are an enormously useful and important resource and typically the most effective way for parties to obtain information necessary for trial. Illinois rules provide for two types of depositions: discovery depositions and evidence depositions. See Ill. So. Ct. R. 202. Illinois is unique in that it is the only state that recognizes two different types of depositions. Understanding the distinction between the two is important in litigating a case and preserving the ability to introduce certain evidence at trial. While both are designed to elicit relevant evidence, the scope of what is relevant, and ultimately what is proper to ask, differs between the two types of depositions.

Discovery depositions are used for the purpose of exploring the facts that are not only relevant to the case, but also will lead to the discovery of additional evidence. In this regard, the scope and manner of questioning in discovery depositions is given great latitude. Conversely, evidence depositions are used for the purpose of preserving evidence for trial. The questioning in an evidence deposition is limited by the rules of evidence. As a result, the scope of inquiry in a discovery deposition is broader than the questioning allowed in an evidence deposition. In practical terms, the initial deposition of a witness normally will be a discovery deposition given the wider scope of inquiry afforded. Discovery depositions are usually less formal than their counterpart. Counsel participating in an evidence deposition should treat it as if he or she were at trial.

A party electing to conduct a deposition must specify in the notice or subpoena served on the witness whether the deposition will be a discovery deposition or evidence deposition. Absent a specification, the deposition will proceed for discovery purposes only. Because the type of deposition dictates the scope of questioning and what will ultimately be admissible at trial, it is important that parties understand the significance in specifying the type of deposition he or she intends to take.

snow-3916172_1920-300x200Winter is a time many people look forward to every year. It can be beautiful outside and cozy inside, with warm nights spent by the fire with good food and better company. However, getting to those warm nights can be a slippery slope. Snow, ice, and sleet can make for a disastrous day when it comes to driving.

Seventy percent of the roads and the population in the United States are in snowy regions and 17% of all crashes occur during winter weather. Research done by AAA’s Foundation for Traffic Safety shows that almost half a million crashes and 2,000 road deaths are caused every year by poor road conditions or bad weather conditions in the United States. With scary statistics like that, it is important to take as many precautions as possible to keep yourself safe during these bad weather months. So, we’ve compiled a list of do’s and don’ts to help you avoid a serious winter car accident.

Do:

It started with a letter to Congress.

Seven past EPA chiefs, appointed by both Democratic and Republican presidents, wrote to Congress in April. They were concerned aboutUS-EPA-1-300x300 the direction of the current EPA and offered to help Congress use its oversight to put a halt to Trump’s misguided deregulatory push and the dismissal of science in favor of politics at the agency.

The seven EPA leaders signing the letter had served under Obama, Reagan, and both Bushes, so the current administration could not blame the letter on partisan politics.

Going to the hospital can save your life. If you arecare-928653_1920-300x200 a patient at a hospital with a poor safety ranking, however, it could cost you your life.

That’s the conclusion of a recent report by the nonprofit group Leapfrog, which also gives 2600 hospitals a Hospital Safety Grade twice a year based on 28 measures of safety.

The report, prepared for the Johns Hopkins Armstrong Institute for Patient Safety and Quality, found that an estimated 160,000 lives are lost annually from avoidable medical errors, and hospitals with a poor safety grade have twice the mortality rate of hospitals with a good grade.

The Collins Law Firm is pleased to announce that Super Lawyers has once again named five attorneys at the firm to the Super Lawyers list.  Attorneys Shawn Collins, Edward Manzke, and John Sopuch have been named as 2019 Super Lawyers, and attorneys Jeffrey Cisowski and John Risvold have been named as 2019 Rising Stars.

 We would like to congratulate these attorneys for being included in the 2019 Super Lawyers list for Illinois. This honor is only granted to the top five percent of lawyers in the state based on performance and peer recognition. Attorneys are selected from over 70 practice areas after a rigorous selection process conducted through peer nomination, independent investigation, and evaluation.

Shawn Collins is an accomplished trial lawyer and the founding partner of The Collins Law Firm. He represents environmental, personal injury, and business clients in complex litigation. Shawn graduated summa cum laude with majors in business and accounting from the University of Notre Dame and earned a J.D. from the University of Chicago Law School. His environmental cases have set precedents around the country and have helped build the reputation of The Collins Law Firm as a nationally recognized environmental litigation firm. Every year since 2008, Shawn has been named as one of the “Top 100 Trial Attorneys” by The American Trial Lawyers Association. He has also been recognized by his peers as a “Leading Lawyer” in Illinois since 2017, an honor only offered to five percent of the lawyers in the state. In addition, Shawn has been included on the Super Lawyers list eleven times, and received a Lifetime Achievement Award from America’s Top 100 Attorneys for Illinois. His cases have been featured in the top news outlets around the country.

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