Gordon Rees Scully Mansukhani Chicago Partner and Illinois Defense Counsel Director, Jonathan Federman, recently co-authored an article examining a critical but often overlooked aspect of appellate practice, preserving an accurate record for appeal when no transcript is available.
Published in the First Quarter 2026 issue of Illinois Defense Counsel Quarterly, the article explores the risks and procedural requirements associated with relying on bystander reports under Illinois Supreme Court Rule 323(c). Drawing on recent appellate decisions, the authors outline common pitfalls, timing requirements, and strategic considerations for litigants seeking to ensure appellate courts can fully review trial court proceedings.
The piece offers practical guidance for trial and appellate counsel, emphasizing the importance of accurate record creation and the limitations courts may impose when a proposed bystander report is disputed or deemed unreliable.
Read the full article in Illinois Defense Counsel Quarterly.