Articles From Mary Dalenberg | Illinois State Bar Association

Anticipatory Discovery: Predicting Issues in Litigation By Devin J. Piper & Mary Dalenberg Young Lawyers Division, April 2026 Anticipatory discovery is not about expanding the scope of litigation, it is about ensuring your access to relevant evidence, and making sure you have what you need to best advocate for your client. By framing targeted early discovery, and sequencing strategically, counsel can optimize their position and set their case up for fair resolution.

Audit Trails and the Scope of Medical Record Discovery in Illinois By Courtney A. Berlin & Mary Dalenberg Tort Law, February 2026 As electronic medical records have become standard practice, discovery disputes focus on not only what appears in the patient chart, but how the chart was created, accessed, and modified. One of the most contested sources of that data is the audit trail, a system-generated log showing when records were accessed, altered, or reviewed.

Venue Battles: Understanding and Defending Against Motions To Transfer Under Forum Non Conveniens By Courtney A. Berlin & Mary Dalenberg Tort Law, October 2025 Both plaintiff and defense attorneys need to be cognizant of venue and the doctrine of forum non conveniens. This article details strategies to consider when arguing against a forum non conveniens motion.

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