

Every case is different, but an experienced Chicago personal injury lawyer does the following things in almost every third party liability suit that goes to trial:
• Investigate the accident
• File suit and serve the defendants with suit papers
• Files responses to motions to transfer venue
• Analyzes and responds to affirmative defenses
• Prepares and answers written discovery
• Obtains photographic evidence of injuries where needed
• Files motions to compel
• Analyzes the contribution case and insurance coverage issues
• Presents the plaintiff for deposition
• Takes multiple depositions
• Meets with witnesses
• Analyzes the contribution case and insurance coverage issues
• Responds to pre-trial motions to dismiss and for summary judgment
• Obtains and analyzes medical records
• Doctor depositions
• Coordinates third party liability suit with worker’s compensation case
• Analyzes case for settlement potential
• Engages in settlement negotiations and/or mediation
• Selects and hires well-qualified liability, medical, and/or damages experts
• Identifies and discloses trial witnesses for all aspects of trial
• Presents experts for deposition
• Reviews defendant trial witness disclosures
• Takes depositions of defendant expert witnesses
• Selects and prepares trial exhibits
• Conducts pretrial focus groups
• Prepares all cooperative witnesses for testifying
• Prepares for questioning all other witnesses
• Prepares pretrial evidentiary motions and researches anticipated defense motions
• Issues notices to appear and subpoenas for trial witnesses
• Prepares jury instructions
• Prepares questions for jury selection
• Prepares opening statements and closing and rebuttal arguments
• Argues pretrial evidentiary motions
• Conducts jury selection
• Gives opening statement
• Puts on case in chief
• Responds to defense case in chief
• Offers rebuttal evidence
• Participates in a jury instruction conference
• Gives closing argument and rebuttal argument
• Prepares judgment order based on jury verdict
• Prepares and/or responds to post-trial motions
• Handles appeals to Appellate Court and/or Illinois Supreme Court, if needed
• Enforces judgment
• Disputes questionable claimed liens
• Verifies the correct amount of liens
• Disburses money to client and lienholder as required
• Provides full accounting of all money from verdict or settlement to the client
The Law Offices of
Barry G. Doyle, P.C.
100 W Monroe St.,
Ste 2100
Chicago, IL 60603
Phone: 312.263.1080
Fax: 312.263.0153
Proudly Serving Many Illinois Cities and Counties, Including:
Chicago, Aurora, Rockford, Naperville, Joliet, Waukegan, Geneva, Sycamore, Woodstock, Kankakee, Morris, Ottawa; Cook, DuPage, Will, Lake, Winnebago, DeKalb, McHenry, Kankakee, Grundy, LaSalle, Peoria, McLean, Champaign, Tazewell Counties
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The Law Offices of Barry G. Doyle, P.C.
100 W MONROE ST.
STE 2100
CHICAGO, IL 60603
Phone: 312.263.1080
Fax: 312.263.0153
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The Law Office of
Barry G. Doyle, P.C.
100 W Monroe Street
Suite 2100
Chicago, IL 60603
Phone: 312.263.1080
FAX: 312.263.0153

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