The current issue of the Illinois Bar Journal has a cover story by Helen Gunnarsson about judicial pet peeves. Members of the Illinois State Bar Association can view the article online. For non-members, here are some ideas from the article that come straight from the judges Gunnarsson interviewed.
- Be completely candid when arguing motions relating to discovery. Judges don’t like to be put in the middle of “he said-she said” disputes about agreements the lawyers made with each other about discovery.
- Don’t use discovery to play “hide the ball.” Discovery isn’t the beginning and end of the litigation. After the facts are developed, the case will be decided on the merits.
- Know and follow the local court rules.
- Be on time; if it’s not possible due to conflicting court appearances, call ahead.
- Don’t remind a judge that you plan to “file an immediate appeal” if you lose an argument.
- Don’t talk to judges during hearings as if you’re making a closing argument to a jury. Give the facts without the “theatrics.”
There’s much more in Gunnarsson’s article, including suggestions for dealing with lawyers who engage in unprofessional tactics.