In In Re Estate of Good, 2013 IL App (2d) 120875-U, the Second District strictly construed the business records hearsay exception and held that a single-page spreadsheet (the “Spreadsheet”), prepared specifically for litigation by one of the parties from various print and electronic sources, didn’t satisfy the business records admissibility rules. Facts: The plaintiff real estate auction company sued …
Tag Archives: Illinois
Illinois Business Records: Getting Them In at Trial
I’ve learned from painful experience to always have evidentiary foundation and authenticity considerations at the forefront of my trial preparation plan. I’ve also found that having a working knowledge of Illinois Supreme Court Rule 236 (SCR 236), as well as Federal and Illinois Evidence Rules 803(6) and 902(11) (hearsay exception and self-authentication rules for business records, respectively) is essential to preparing for and …
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Illinois Mechanics Lien Basics
The Statute: The Illinois Mechanics’ Lien Act, 770 ILCS 60/1 et seq. Purpose: to provide a remedy to a contractor who provides valuable improvements to real estate by allowing him to lien the property (place a hold on the property to secure payment). Once the lien is in place (or perfected), the lien clouds the property’s title and …