Family Law - Illinois State Bar Association

June 2013 Vol. 56, No. 12
Illinois State Bar Association
Family Law
The newsletter of the Illinois State Bar Association’s Section on Family Law
Chair’s column
Inside
By William J. Scott, Jr.
W
ell. The Illinois House and Senate have
failed at almost every important task
they were sent to Springfield to accomplish. The current session adjourned without any
solution to pension reform, to gambling issues,
to the budget crisis and no approval of same sex
marriage. They did resolve the gun issue. In the
meantime, they banned cell phones in cars and
approved a puppy lemon law. Important issues,
I suppose, but they could have waited for the
more difficult ones.
I believe my year as chair of the Family Law
Section Council has been more successful. We
spent a large amount of time dealing with the
issues presented by the Legislative Family Law
Committee’s proposed rewrite of the Illinois
Chair’s column . . . . . . . . . . . . 1
Marriage and Dissolution of Marriage Act. I predict that the Council will have a comprehensive
analysis of that proposed act in the near future
and that a reasoned, well thought out discussion
can occur between the interested parties and the
legislature. We also dealt with numerous other
legislative issues, provided our input into proposed legislation and, I think, improved the good
proposals or helped defeat the bad ones. More
importantly, this has been a resoundingly successful year for our continuing legal education
seminars. We have presented a top level child
custody seminar and traveled to New Orleans for
a two day event.
Relatives by choice:
The Illinois Supreme
Court’s decision
recognizing equitable
adoption. . . . . . . . . . . . . . . . . . 1
The difficulty in
understanding and
applying Section
5/513(a)(1) of the
IMDMA . . . . . . . . . . . . . . . . . . . 4
Upcoming CLE
programs . . . . . . . . . . . . . . . . . 6
Continued on page 2
Relatives by choice: The Illinois Supreme Court’s
decision recognizing equitable adoption
By Ayla N. Ellison
“Like a bud that has been cut from its
natural stem and grafted into a foreign
tree, she grew into the family and became
a part of its very life.”
—Lynn v. Hockaday, 61 S.W. 885, 889
(Mo. 1901)
I
f an adoption has not been formally judicially
completed there are several legal processes
that can be used for an adoption to still be legally recognized.
One legal process that can be used is the
contract to adopt theory. Illinois courts typically
uphold contracts to adopt. The contracts are
usually deemed valid and enforceable, and such
a contract confers on the adopted child the right
to obtain the share of the property to which he
or she would be entitled to have had the adoption been judicially completed. Dixon National
Bank of Dixon v. Neal, 5 Ill.2d 328, 125 N.E.2d 463
(1955).
If a contract to adopt is oral there is a higher
standard of proof than if the contract is in writing and simply was not judicially completed. The
courts will enforce oral contracts to adopt only
Continued on page 2
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Family Law |
June 2013, Vol. 56, No. 12
Chair’s column
Family Law
Continued from page 1
As I leave the chair position and take
possession of the coveted rubber chicken, I
would like to thank those who helped and
brought energy and countless hours of their
donated time. Pam Kuzniar is the incoming
chair and the CLE coordinator. She is responsible for the top level outstanding CLE presentations and no one works harder. Rory
Weiler was the legislative liaison and worked
countless hours with the council and with
the legislative staff at the ISBA including Jim
Covington. Kelli Gordon was secretary and
did the thankless job of providing detailed
minutes of meetings in a professional and
well-structured manner. She becomes the
vice chair and will chair the council after Pam.
Lastly, the retiring newsletter editor is Matt
Kirsh who becomes the incoming secre-
tary. Matt has helped us issue a newsletter a
month and has nagged and cajoled me into
writing twelve columns. He has been our
newsletter editor for some time and richly
deserves to move up.
The council itself deserves kudos and my
gratitude for providing energy and a willingness to work on a wide range of issues. It has
been a pleasure to work with a group of accomplished, smart and enthusiastic lawyers.
The council is composed of individuals who
bring credit to the legal profession and who
make our profession the foundation of the
justice system. People who work tirelessly to
improve things for their clients while fighting for their clients daily. Thank you all for
the pleasure of your opinions and your intellect. ■
Published at least four times per year.
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or call 217-525-1760
Office
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Phones: 217-525-1760 OR 800-252-8908
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Co-Editors
Matthew A. Kirsh
Rebecca Berlin
Rory T. Weiler
Managing Editor/Production
Katie Underwood
[email protected]
Family Law Section Council
Relatives by choice: The Illinois Supreme Court’s decision
recognizing equitable adoption
Continued from page 1
if the proof relating to the contract’s terms
is clear and conclusive, leaving no room for
reasonable doubt. Monahan v. Monahan, 14
Ill.2d 449, 153 N.E.2d 1, 3 (1958); Weiss v. Beck,
1 Ill.2d 420, 115 N.E.2d 768, 772-773 (1953).
Besides a contract to adopt, equitable
adoption is another legal process that is used
in some jurisdictions. When the statutory
guidelines have not been followed and the
adoption has not been judicially completed
equitable adoption is often times used to
establish inheritance rights for a child when
there was an oral communication by the prospective adoptive parents expressing their
intention to adopt and the child has been
placed in the physical custody of the parent
but no formal adoption process was completed.
The standards of proof concerning equitable adoption differ among jurisdictions. In
some jurisdictions estoppel or quasi-contract
considerations are applied “where there has
been clear proof of a contract, expressed or
implied, reliance upon the parent-child relationship, and performance of obligations under the de facto relationship.” See In re Estate
of Edwards, 106 Ill.App.3d 635, 637 (1982).
Other jurisdictions hold that “if a claimant
can, by clear, cogent and convincing evidence, prove sufficient facts to convince the
trier of fact that his status is identical to that
of a formally adopted child, except only for
the absence of a formal order of adoption,
a finding of an equitable adoption is proper
without proof of an adoption contract.” See,
e.g., Estate of Ford v. Ford, 82 P.3d 747, 754 (Cal.
2004); Wheeling Dollar Savings & Trust Co. v.
Stinger, 250 S.E.2d 369, 373-74 (W.Va. 1978).
Elements that support the recognition of
an equitable adoption are as follows: (1) the
benefits of love and affection accruing to the
adopting party; (2) the performances of services by the child; (3) the surrender of ties by
the natural parent; (4) the society, companionship and filial obedience of the child; (5)
an invalid or ineffectual adoption proceeding; (6) reliance by the adopted person upon
the existence of his adopted status; (7) the
representation to all the world that the child
is a natural or adopted child; and (8) the rearing of the child from an age of tender years
by the adopting parents. Ford, 82 P.3rd 754;
Wheeling, 250 S.E.2d 373.
Historically, Illinois has not recognized
2
William J. Scott, Chair
Pamela J. Kuzniar, Vice Chair
Kelli E. Gordon, Secretary
KImberly J. Anderson, Ex-Officio
Hon. Robert J. Anderson
Margaret A. Benett
Jacalyn Birnbaum
Hon. Arnold F. Blockman
Chris W. Bohlen
Edward J. Burt
Dion U. Davi
Heather M. Fritsch
Cecilia H. Griffin
David H. Hopkins
Heather M. Hurst
Matthew A. Kirsh
Sally K. Kolb
Hon. Patrick J. Leston
David H. Levy
Rebecca M. Leynaud
Marilyn F. Longwell
Hon. Mark J. Lopez
Hon. Pamela E. Loza
Laura L. Malinowski
Anne M. Martinkus
Hon. Timothy J. McJoynt
Treva H. O’Neill
Prof. Jeffrey A. Parness
Alan Pearlman
Angela E. Peters
Arlette G. Porter
Julia A. Pucci
Jon J. Racklin
Hon. Jeanne M. Reynolds
Curtis B. Ross
Jennifer A. Shaw
Letitia Spunar-Sheats
Elizabeth A. Teague
Tamika R. Walker
Richard A. Wilson
Richard W. Zuckerman
Mary M. Grant, Staff Liaison
Lisa M. Nyuli, Board Liaison
Paul A. Osborn, CLE Committee Liaison
Pamela J. Kuzniar, CLE Coordinator
Disclaimer: This newsletter is for subscribers’ personal use only; redistribution is prohibited. Copyright
Illinois State Bar Association. Statements or expressions
of opinion appearing herein are those of the authors
and not necessarily those of the Association or Editors,
and likewise the publication of any advertisement is not
to be construed as an endorsement of the product or
service offered unless it is specifically stated in the ad
that there is such approval or endorsement.
Articles are prepared as an educational service to
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The articles in this newsletter are not intended to be
used and may not be relied on for penalty avoidance.
Postmaster: Please send address changes to the
Illinois State Bar Association, 424 S. 2nd St., Springfield,
IL 62701-1779.
June 2013, Vol. 56, No. 12 |
the theory of equitable adoption. See In Re
Estate of Staehli, 86 Ill.App. 3d 1, 407, N.E.2d
741, 41 Ill.Dec. 243 (1st Dist. 1980). Recently,
in DeHart v. DeHart 2013 IL 114317, the Illinois Supreme Court officially recognized the
theory of equitable adoption. In DeHart, the
Court held that in Illinois an equitable adoption theory should be recognized under the
right circumstances even in the absence of
a statutory adoption or a contract for adoption. DeHart at 16.
In DeHart v. DeHart, Donald M. DeHart
passed away, and his son James Thomas DeHart filed a six count complaint against Blanca DeHart in her individual capacity and as
executor of the estate of Donald M. DeHart.
Plaintiff brought his suit because Blanca DeHart refused to recognize Plaintiff as Donald
DeHart’s son once she found out that Donald DeHart was not the Plaintiff’s natural
born father. Blanca DeHart denied Plaintiff
as an heir at law. The complaint contained a
count of contract for adoption and equitable
adoption. In Count V of the complaint, Plaintiff alleged that Donald Dehart entered into
a contract to adopt Plaintiff. In Count VI of
the complaint, Plaintiff alleged that Donald
Dehart equitably adopted Plaintiff and that
Donald DeHart’s estate was therefore barred
from denying Plaintiff as an heir at law.
The circuit court of Will County dismissed
with prejudice all of Plaintiff, James Thomas
DeHart’s, counts. Plaintiff appealed and the
appellate court reversed the dismissal of all
six counts. The Supreme Court of Illinois held
that Plaintiff’s complaint alleged sufficient
facts to state a cause of action for lack of testamentary capacity, undue influence, contract for adoption and equitable adoption.
DeHart at 19.
During Donald DeHart’s, the deceased’s,
lifetime, he held the Plaintiff, James DeHart
out as his son to the public. Donald DeHart
recognized the Plaintifff as his son for over
sixty years, which is the approximate age
of the Plaintiff, and even listed the Plaintiff
as his son when he made funeral arrangements. Donald DeHart always recognized
Plaintiff’s children as his grandchildren, and
provided Plaintiff, at a young age, a birth
certificate that listed Donald DeHart as the
Plaintiff’s natural father. When Donald DeHart informed the Plaintiff that he was not
actually his natural born father, he indicated
to Plaintiff that an adoption had taken place
but Donald DeHart and the Plaintiff’s mother
had chosen to keep the adoption a secret.
The Court addressed the contract to
adopt claim before the equitable adoption
claim. In analyzing the contract to adopt
claim, the Illinois Supreme Court heavily relied on the case of Monahan v. Monahan. In
Monahan, a mother left her child with the
Monahans when the child was two years old.
When the child was three, the natural born father fully abandoned the child, and after the
child turned four years old, the mother left
the child with the Monahans and consented
to the Monahans adopting her child. The Monahans raised the child as if it were their own,
but a formal adoption never took place.
The Court in Monahan found that a contract to adopt did exist because the evidence
of a contract as well as the intention to adopt
the child was “clear and convincing” based
on the following: (1) the family relationship
of parent and child clearly existed; (2) neighbors and relatives believed the child had
been adopted; (3) the child conducted himself as a dutiful child to the Monahans; and
(4) the Monahans indicated to others that
the child’s natural mother “gave” the child to
them. Monahan, 153 N.E.2d 3. The Monahans
indication that the child’s natural mother
gave the child to them “was confirmed by
written notations, along with their abortive
attempts at legal adoption.” Monahan at 3.
The Supreme Court of Illinois in DeHart
compared the facts to Monahan, and stated
that “implicit in the agreement ‘to keep the
adoption a secret’ is an agreement” between
the Plaintiff’s mother and Donald DeHart
that Donald DeHart adopt Plaintiff. DeHart
at 12. The Court further held that the allegations made in the Plaintiff’s complaint that
Plaintiff’s mother allowed Donald DeHart to
adopt Plaintiff “conferred the full benefits of
fatherhood” on Donald DeHart. DeHart at 12.
As to the contract for adoption claim, the
Supreme Court of Illinois held that the appellate court correctly determined that the circuit court erred in dismissing Plaintiff’s claim.
DeHart at 13.
The Court next moved on to the Plaintiff’s
equitable adoption claim. In this Count, the
Plaintiff alleged “that even in the absence of
an expressed or implied contract to adopt,
a finding of an equitable adoption would
nonetheless be proper in a cause where
there is clear and convincing evidence of a
foster parent’s intent to adopt and treat the
child as one’s adopted or natural child.” DeHart at 13
The Court held that Illinois should recognize equitable adoption in certain cases. The
Illinois Supreme Court held that in order to
3
Family Law
have a successful equitable adoption claim in
Illinois there must be an intent to adopt, and
the claimant must show that the decedent
acted “consistently with that intent” by forming with the claimant a “close and enduring
familial relationship.” DeHart at 16. The standard of proof to be used in equitable adoption cases, as stated by the Illinois Supreme
Court, is clear and convincing evidence. DeHart at 17. The Court stated that to not recognize equitable adoption when the two
elements have been met would “work a deception and a fraud and would be contrary
to the decedent’s intent to treat and continuously hold out the plaintiff as his or her natural child.” DeHart at 16.
Given the facts, statutory and case law,
the Supreme Court of Illinois held that Plaintiff’s complaint alleged sufficient facts to
state a cause of action for lack of testamentary capacity, undue influence, contract for
adoption and equitable adoption. DeHart at
19. ■
__________
Ayla N. Ellison is an attorney with the Law Office of Robert C. Wison. [email protected]
Support the
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Family Law |
June 2013, Vol. 56, No. 12
The difficulty in understanding and applying Section 5/513(a)(1)
of the IMDMA
By Marc K. Schwartz and Staci Balbirer
When attempting to calculate support for a
disabled child, looking for guidance under the
statute will leave you asking questions. This article will simplify how to calculate support and
the options available to your client.
S
ection 750 ILCS 5/513 of the Illinois
Marriage and Dissolution of Marriage
Act is entitled, “Support for non-minor
children and educational expenses.” Although
the title of Section 5/513 may seem clear,
the needs of the children who are the recipients of continuing 513 support could not be
more different. When representing a client
with children, section 513(a)(2) is often referenced as it sets forth guidelines to determine
each parent’s respective contribution to a
child’s educational expenses. The recipient of
continuing support under 513(a)(2) is a child
who has the aptitude to attend a higher level
education institution with the ultimate goal
of becoming independent from his/her parents.
Alternatively, Section 513(a)(1) references
an individual who upon reaching the age of
majority is mentally or physically disabled
and not otherwise emancipated. In most
cases this is an individual, who unlike their
513(a)(2) counterpart, requires continuing
support as they will never become entirely
independent.
The clear focus of Section 5/513 is educational expenses. Section 513(a)(2) is detailed as to what “educational expenses” may
include and also sets forth relevant factors
in determining how the Court may allocate
educational expenses between parties. Although the statute may be straightforward,
explaining to your client why he or she may
be responsible for educational expenses can
pose a challenge.
Although Section 513(a)(2) is clear, Section 513(a)(1) is not.
Section 750 ILCS 5/513(a)(1) states in relevant part that…
(a) The court may award sums of
money out of the property and income of either or both parties… for
the support of the child or children of
the parties who have attained majority in the following instances: (1) When
the child is mentally or physically
disabled and not otherwise emancipated, an application for support may
be made before or after the child has
attained majority.
Section 5/513(a)(1) does not explain how
support should be calculated, what support
should be used for or how long support
should continue. The ambiguity of 513(a)(1)
leaves attorneys and their clients with many
unanswered questions: How is support for
an adult disabled child calculated? What expenses should be paid with the continuing
support received? Is Supplemental Security
Income (SSI) taken into consideration when
determining an adult disabled child’s expenses? What if expenses increase-is support
modifiable? How does the Judge usually rule
in these types of cases? With so many unanswered questions, it is best to start at the
beginning when explaining 5/513(a)(1) to a
client.
If a child is disabled prior to reaching the
age of majority and a parent is seeking continuing support, a disability finding must be
made by a Domestic Relations Court. Even if
an individual has been adjudicated disabled
in Probate Court, this is insufficient as an individual could be disabled within the meaning
of the Probate Act and not be disabled within the meaning of section 513. In construing
section 513, the courts have used dictionary
definitions of disabled that, in contrast to the
Probate Act’s definition, concern the inability to manage one’s affairs. In Re Marriage Of
Lerner, 316 Ill.App.3d 1072, 1077, 738 N.E.2d
183, 187 (1st Dist. 2000). Webster’s Third New
International Dictionary defines, “disabled”
as incapacitated by or as if by illness, injury
or wounds. In ReMarriage Of Thurmond, 306,
Ill.App.3d 828, 832, 715 N.E. 2d 814, 816 (2nd
Dist. 1999). The Probate Act defines “disabled
person” as “a person 18 years or older who
(a) because of mental deterioration or physical incapacity is not fully able to manage his
person or estate, or (b) is a person with mental illness or a person with a developmental
disability and who because of his mental illness or developmental disability is not fully
able to manage his person or estate, or (c)
because of gambling, idleness, debauchery
4
or excessive use of intoxicants or drugs, so
spends or wastes his estate as to expose himself or his family to want or suffering.” In Re
Marriage Of Lerner, 316 Ill.App.3d 1077.
A Petition for Disability Finding can be
brought before the Court in both pre-decree
and post-decree matters. If your case concerns an individual who has already reached
the age of majority, it is both cost-effective
and time efficient to include an application
for continuing support in your initial Petition. It is important to note that support can
be awarded retroactive to the filing of your
Petition so time is of the essence! In postdecree litigation, the parties’ Judgment for
Dissolution of Marriage may contain language regarding an individual’s disability
and a Petition for Disability Finding may not
be necessary. However, the failure of such
a finding in the underlying judgment does
not preclude a post decree petition seeking
a finding.
When the Court finds an individual to
be disabled, the Court has discretion to order continuing support pursuant to section
513(a)(1). Although there is a plethora of
case law regarding a parent’s obligation to
provide continuing support for a disabled individual after they reach the age of majority,
there is no case law that dictates when child
support shall be calculated using the Illinois
statutory guidelines as set forth in section
5/505(a)(1), or calculated based on the child’s
needs.
A “needs based approach” can be calculated utilizing the following factors as set
forth in section 5/505(a)(2): a) the financial resources of the child; b) the financial resources and needs of the custodial parent; c) the
standard of living the child would have enjoyed had the marriage not been dissolved;
d) the physical and emotional condition of
the child, and his education needs; and e)
the financial resources and needs of the noncustodial parent. As disabled individuals may
have specialized needs, calculating support
using the Illinois statutory guidelines may
not be in the best interest of the child. Utilizing a “needs based” approach, the Court
will be able to review the individual’s specific
monthly needs and calculate a more accu-
June 2013, Vol. 56, No. 12 |
rate support amount.
When representing the custodial parent
and non-custodial parent of an adult disabled
child, the arguments as to what expenses are
to be included in determining each parties’
contribution will vary significantly. For a custodial parent, in addition to the cost of the individual’s specific needs there are expenses
such as mortgage payments, groceries, electricity, etc. Should the individual’s portion of
these additional expenses be included in a
needs based support calculation? The noncustodial parent will certainly argue against
supplementing the custodial parent’s mortgage payments and electricity bills as arguably those are expenses that the custodial
parent would incur regardless of the individual residing with them. But, as needs based
support is discretionary, being prepared to
argue the inclusion of include additional expenses may prove successful in some cases
and before some Judges.
Although you will be hard pressed to find
two Judges who calculate 513 support in an
identical manner, the Court should always
consider the financial resources of the individual-specifically, whether a disabled child
receives Supplemental Security Income or
SSI. SSI provides funds for basic needs such
as food, clothing and shelter and SSI received
should be subtracted from the total monthly
expenses of the individual. A simple example: if it is determined that an adult disabled
child’s needs based expenses are $2,000 a
month and said individual receives $694
in SSI, the total monthly expenses to be allocated between the parties is $1,306. If the
individual receives any additional benefits,
depending on the party you represent, you
should be prepared to argue whether or not
those benefits are to be included in calculating the child’s expenses and each parent’s
respective support contribution.
It is also important to note that Illinois
Courts have held that 513 expenses are a
form of child support to be read in conjunction with 5/505 and 5/510 and thus are modifiable. In Re Marriage Of Petersen, 955 N.E.2d
1131, 1134 (2011). Therefore, each parent’s
contribution to a disabled individual’s expenses can be modified upon a substantial
change in circumstance. This also means that
the Court may interpret 513(a)(1) pursuant to
statutory guidelines as set forth in 5/505(a)
and not a needs based analysis as discussed
above. If the Court utilizes a statutory approach, the non custodial parent may be ordered to pay twenty (20%) percent of his or
her monthly net income for a child with special needs. If said family has more than one
child with special needs, the percentage of
the supporting party’s net income to be paid
will increase based on the number of special
needs children. However, similar to child support under section 5/505, practitioners will
be hard pressed to find case law that states
when a needs based analysis should be utilized versus statutory guidelines. This results
in the Court having ultimate discretion.
Regardless of whether statutory guidelines or a needs based analysis is utilized, the
contribution of each parent to the individual’s monthly expenses will be determined
by the Court or by Agreement. Again, in applying a needs based analysis, the Court will
review the financial resources of both parties, the financial resources of the child, the
standard of living the child would have enjoyed had the marriage not been dissolved
and the physical and emotional condition of
the child, and his educational needs. As each
case is fact specific, each outcome will differ.
Alternatively, in applying statutory guidelines, a non-custodial parent shall pay a set
percentage of his or her monthly net income
based on the number of disabled children he
or she was ordered to support. This approach
is less fact specific and more in accordance
Family Law
with the idea of continuing child support.
In rare instances, you may represent a client with an adult disabled child who can be
classified under section 513(a)(1) and 513(a)
(2). Issues arise when the non-custodial parent, who has been ordered to contribute to
college, has also been making payments for
the individual pursuant to section 513(a)(1).
Should the payments made pursuant to section 513(a)(1) be included when calculating
the total amount of college expenses paid
by the non-custodial parent? Should a disabled child be entitled to receive benefits
under both 513(a)(1) and 513(a)(2)? These
questions remain unanswered as case law
and section 513 are silent as to a disabled
individual who attends a higher level educational institution.
Although case law is very clear that adult
disabled children are entitled to continuing
support, section 513(a)(1) does not provide
answers to important questions. When you
represent a client with an adult disabled
child, it is important to recognize the day to
day challenges in caring and providing for
an adult disabled child. It is also important
to understand and correctly apply section
513(a)(1) as the outcome of a 513 support
hearing should ultimately result in a ruling
that is in the best interest of the child. ■
You’ve got
one shot.
Make it count.
Call Nancy to find out how
an ad in an ISBA
newsletter can make
the difference in
your business.
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5
Family Law |
June 2013, Vol. 56, No. 12
Upcoming CLE programs
To register, go to www.isba.org/cle or call the ISBA registrar at 800-252-8908 or 217-525-1760.
July
Tuesday, 7/2/13- Teleseminar—Portability of the Estate Tax Exemption: Planning
Compliance and Drafting Issues. Presented
by the Illinois State Bar Association. 12-1.
Tuesday, 7/9/13- Teleseminar—Real Estate Management Agreements. Presented by
the Illinois State Bar Association. 12-1.
Tuesday, 7/9/13 – Webinar—Intro to Legal Research on Fastcase. Presented by the Illinois State Bar Association – Complimentary
to ISBA Members Only. 3:00 – 4:00 p.m. CST.
Thursday, 7/11/13 – Webinar—Advanced Tips for Enhanced Legal Research on
Fastcase. Presented by the Illinois State Bar
Association – Complimentary to ISBA Members Only. 3:00 – 4:00 p.m. CST.
Thursday, 7/11/13- Teleseminar—Corporate Governance for Nonprofits. Presented
by the Illinois State Bar Association. 12-1.
Tuesday, 7/16/13- Teleseminar—Health
Care Issues in Estate Planning. Presented by
the Illinois State Bar Association. 12-1.
Wednesday, 7/17/13- Webinar (MCLE
Credit Uncertain)—Business Building Strategies for Lawyers: Using Technology, Finding
Clients, Getting Referrals. Presented by the
Illinois State Bar Association and The Rainmaker Institute. 12-1.
Thursday, 7/18/13- Teleseminar—Managing Employee Leave. Presented by the Illinois State Bar Association. 12-1.
Tuesday, 7/23/13- Teleseminar—Private Placements for Closely Held Businesses,
Part 1. Presented by the Illinois State Bar Association. 12-1.
Wednesday, 7/24/13 – Webinar—Introduction to Boolean (Keyword) Search. Presented by the Illinois State Bar Association –
Complimentary to ISBA Members Only. 3:00
– 4:00 p.m. CST.
Wednesday, 7/24/13- Teleseminar—
Private Placements for Closely Held Business-
es, Part 2. Presented by the Illinois State Bar
Association. 12-1.
Tuesday, 7/30/13- Teleseminar—Attorney Ethics in Real Estate Practice. Presented
by the Illinois State Bar Association. 12-1.
August
Tuesday, 8/27/13- Teleseminar—Buying/ Selling LLC and Partnership Interests.
Presented by the Illinois State Bar Association. 12-1.
Thursday, 8/29/13- Teleseminar—
Mixed Use Developments in Real Estate:
Planning and Drafting Issues. Presented by
the Illinois State Bar Association. 12-1.
Tuesday, 8/6/13 – Webinar—Intro to Legal Research on Fastcase. Presented by the Illinois State Bar Association – Complimentary
to ISBA Members Only. 1:30 – 2:30 p.m. CST.
September
Tuesday, 8/6/13- Teleseminar—UCC Article 9 Update. Presented by the Illinois State
Bar Association. 12-1.
Thursday, 9/5/13- Teleseminar—Generation Skipping Transfer Tax Planning. Presented by the Illinois State Bar Association.
12-1.
Thursday, 8/8/13 – Webinar—Advanced
Tips for Enhanced Legal Research on Fastcase. Presented by the Illinois State Bar Association – Complimentary to ISBA Members
Only. 1:30 – 2:30 p.m. CST.
Monday, 9/9/13- Chicago, ISBA Chicago Regional Office—ISBA Basic Skills Live
for Newly Admitted Attorneys. Complimentary program presented by the Illinois State
Bar Association. 8:55-5:00.
Tuesday, 8/13/13- Teleseminar—Asset
Protection in Estate Planning. Presented by
the Illinois State Bar Association. 12-1.
Tuesday,
9/10/13- Teleseminar—
Choice of entity for Real Estate. Presented by
the Illinois State Bar Association. 12-1.
Thursday, 8/15/13- Teleseminar—Ethics, Virtual Law Offices and Multi-Jurisdictional Practice. Presented by the Illinois State Bar
Association. 12-1.
Tuesday, 9/10/13 – Webinar—Intro to
Legal Research on Fastcase. Presented by the
Illinois State Bar Association – Complimentary to ISBA Members Only. 10:00 – 11:00 a.m.
CST.
Tuesday, 8/20/13- Teleseminar—Understanding the Law of Debt Collection for
Businesses, Part 1. Presented by the Illinois
State Bar Association. 12-1.
Wednesday, 8/21/13- Teleseminar—
Understanding the Law of Debt Collection
for Businesses, Part 2. Presented by the Illinois State Bar Association. 12-1.
Wednesday, 8/21/13 – Webinar—Introduction to Boolean (Keyword) Search. Presented by the Illinois State Bar Association –
Complimentary to ISBA Members Only. 1:30
– 2:30 p.m. CST.
Thursday, 8/22/13- Teleseminar—Outsourcing Agreements: Structuring and Drafting Issues. Presented by the Illinois State Bar
Association. 12-1.
6
Thursday, 9/12/13 – Webinar—Advanced Tips for Enhanced Legal Research on
Fastcase. Presented by the Illinois State Bar
Association – Complimentary to ISBA Members Only. 10:00 – 11:00 a.m. CST.
Thursday, 9/12/13- Teleseminar—UCC
9: Fixtures, Liens, Foreclosures and Remedies.
Presented by the Illinois State Bar Association. 12-1.
Thursday, 9/12/13- Chicago, ISBA Regional Office—Trial Practice Series: The Trial
of a Retaliation Case. Presented by the ISBA
Labor and Employment Section. 8:55-4:15.
Monday, 9/16-Friday, 9/20/13 - Chicago, ISBA Regional Office—40 Hour Mediation/Arbitration Training. Presented by the Illinois State Bar Association. 8:30-5:45 daily. ■
June 2013, Vol. 56, No. 12 |
Family Law
Strength | Commitment | Dedication
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4/17/13 2:42 PM
Family Law
Non-Profit Org.
U.S. POSTAGE
PAID
Springfield, Ill.
Permit No. 820
Illinois Bar Center
Springfield, Illinois 62701-1779
June 2013
Vol. 56 No. 12
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