DOCSLIB.ORG

Illinois Civil Practice Guide

Total Page：16

File Type：pdf, Size：1020Kb

Download full-text PDF Read full-text
Illinois Civil Practice Guide Practice Series Illinois Civil Practice Guide Andrew W. Vail Tiffany M. Cartwright © 2013 Jenner & Block LLP All Rights Reserved © 2012 Jenner & Block LLP All Rights Reserved Practice Series Illinois Civil Practice Guide 2013 Mid-Year Update Andrew W. Vail Tiffany M. Cartwright © 2013 Jenner & Block LLP All Rights Reserved www.jenner.com ABOUT JENNER & BLOCK Founded in 1914, Jenner & Block is a national law firm of approximately 450 attorneys. Our firm has been widely recognized for producing outstanding results in corporate transactions and securing significant litigation victories from the trial level through the United States Supreme Court. Companies and individuals around the world trust Jenner & Block with their most sensitive and consequential matters. Our clients range from the top ranks of the Fortune 500, large privately held corporations and financial services institutions to emerging companies, family-run businesses and individuals. OFFICES 353 North Clark Street 633 West 5th Street, Suite 3600 Chicago, Illinois 60654-3456 Los Angeles, California 90071 Firm: 312 222-9350 Firm: 213 239-5100 Fax: 312 527-0484 Fax: 213 239-5199 919 Third Avenue 1099 New York Avenue, N.W., Suite 900 New York, New York 10022-3908 Washington, D.C. 20001-900 Firm: 212 891-1600 Firm: 202 639-6000 Fax: 212 891-1699 Fax: 202 639-6066 © 2013 Jenner & Block LLP. This publication is not intended to provide legal advice but to provide general information on legal matters. Transmission is not intended to create and receipt does not establish an attorney- client relationship. Readers should seek specific legal advice before taking any action with respect to matters mentioned in this publication. The attorney responsible for this publication is Andrew W. Vail. ATTORNEY ADVERTISING 1 AUTHOR INFORMATION Andrew W. Vail is a partner in Jenner & Block’s Litigation Department and a member of the firm’s Complex Commercial Litigation, Antitrust Litigation, Trade Secret and Restrictive Covenant Litigation, and Real Estate Litigation Practice Groups. Mr. Vail has extensive litigation experience in federal and state courts and a commitment to providing legal services to those in need and to the bar. Mr. Vail currently serves as an appointed member of the Illinois Supreme Court Committee on Jury Instructions in Criminal Cases and the Illinois Bar Journal’s Editorial Board. He also serves as a member of the board of directors for the Constitutional Rights Foundation Chicago (CRFC) and Public Interest Law Initiative (PILI). Mr. Vail’s complete biography can be found at http://jenner.com/people/AndrewVail. He can be contacted at [email protected] or (312) 840-8688. Tiffany M. Cartwright is an associate in Jenner & Block’s Chicago office. She is a member of the firm’s Litigation Department. Prior to joining Jenner & Block, Ms. Cartwright served as a law clerk to the Honorable Dana Fabe on the Alaska Supreme Court and the Honorable Betty Binns Fletcher on the U.S. Court of Appeals for the Ninth Circuit. Ms. Cartwright’s complete biography can be found at http://jenner.com/people/TiffanyCartwright. She can be contacted at [email protected] or (312) 840-7268. 1 The authors welcome and are grateful for comments and questions that improve the contents of the Guide. TABLE OF CONTENTS Page I. SPECIAL APPEARANCES IN ILLINOIS COURTS ..........................................................1 A. OUT-OF-STATE ATTORNEYS .................................................................................1 B. LIMITED SCOPE APPEARANCES ...........................................................................1 II. CITING ILLINOIS CASES IN ILLINOIS COURT PLEADINGS ......................................2 III. JURY DEMAND ...................................................................................................................2 IV. PLEADINGS ..........................................................................................................................3 A. FORM OF PLEADINGS ..............................................................................................3 B. THE COMPLAINT ......................................................................................................4 C. VERIFIED PLEADINGS .............................................................................................4 D. AFFIDAVIT REGARDING DAMAGES SOUGHT ...................................................5 E. EXHIBITS ....................................................................................................................5 F. SERVICE OF PROCESS .............................................................................................5 G. ANSWERING THE COMPLAINT .............................................................................6 i. Time to Appear and Answer ...............................................................................6 ii. Waiver of Service ................................................................................................7 iii. Denials ................................................................................................................7 iv. Affirmative Defenses ..........................................................................................7 H. REPLIES TO ANSWERS AND AFFIRMATIVE DEFENSES ..................................8 I. COUNTERCLAIMS AND CROSS-CLAIMS .............................................................9 J. REPLIES TO COUNTERCLAIMS .............................................................................9 K. THIRD PARTY COMPLAINTS .................................................................................9 L. INTERVENTION .........................................................................................................9 M. SANCTIONS FOR IMPROPER PLEADINGS OR OTHER FILINGS ....................10 V. MOTIONS ............................................................................................................................11 A. MOTION FOR SUBSTITUTION OF JUDGE ..........................................................11 i. As a Matter of Right ..........................................................................................11 ii. As a Matter of Cause .........................................................................................11 B. MOTION TO CHALLENGE PERSONAL JURISDICTION ...................................12 C. MOTION TO CHALLENGE VENUE ......................................................................12 D. MOTION TO DISMISS OR TRANSFER FOR FORUM NON CONVENIENS ............................................................................................................13 E. BILL OF PARTICULARS .........................................................................................14 i F. MOTION TO CONSOLIDATE OR SEVER CLAIMS .............................................14 G. MOTION FOR VOLUNTARY DISMISSAL ............................................................15 H. PRE-ANSWER MOTION TO DISMISS ...................................................................15 i. Time for Filing and Proof of Service ................................................................16 ii. 2-615 Motion to Dismiss ...................................................................................16 iii. 2-619 Motion for Involuntary Dismissal ..........................................................16 iv. Combined 2-615/2-619 Motions .......................................................................17 I. MOTION FOR CONTINUANCE ..............................................................................18 J. MOTION FOR EXTENSION OF TIME ...................................................................18 K. SUMMARY JUDGMENT MOTIONS ......................................................................18 i. Timeframe for Moving for Summary Judgment ...............................................18 ii. Procedure for Moving for Summary Judgment ................................................18 L. MOTION FOR DEFAULT ........................................................................................19 M. MOTION TO WITHDRAW ......................................................................................19 VI. DISCOVERY .......................................................................................................................20 A. COMMENCING CASE MANAGEMENT AND DISCOVERY ..............................20 B. SCOPE OF DISCOVERY ..........................................................................................21 i. Generally ...........................................................................................................21 ii. When a Motion Challenging Personal Jurisdiction is Pending .........................21 C. FILING DISCOVERY WITH THE COURT .............................................................21 D. ASSERTING PRIVILEGE FOLLOWING DISCOVERY DISCLOSURE ..............21 E. MANDATORY DISCLOSURES IN CERTAIN TYPES OF CASES ......................22 F. DOCUMENT REQUESTS ........................................................................................23 i. Serving Requests for Production .......................................................................23 ii. Responding or Objecting to Document Requests .............................................23 iii. Electronically Stored Documents ......................................................................24 G. INTERROGATORIES ...............................................................................................25 i. Serving Interrogatories
Load more

Recommended publications
  • Service of Process. What Is It?
    Superior Court of California, County of Sacramento Self-Help Services Service of Process. What is it? “Service” is the legal act of giving papers to the other party. Types of Service. Service can be done in the following ways: o Handing papers to the other party personally. This is called “personal service.” o Sending papers by mail, by express mail, or overnight delivery. This is called “service by mail.” o Fax or electronically (such as e-mail.) The person receiving the documents must agree to these methods. o Publication (with Court approval). Certain papers require personal service. Be sure to check the rules applicable to the type of papers you are serving for the requirements. Who can serve the papers? You cannot serve the papers. Any person over the age of 18, who is not involved with the case, must serve the papers. The person serving the papers must fill out a “Proof of Service” which describes the documents they gave or sent to the other party or parties, and the date the documents were served. You must file the completed “Proof of Service” with the court. The Sheriff Department’s Civil Bureau is available to personally serve papers. They charge a fee for this service. This fee may be waived if you have an active fee waiver for the case. They can only serve someone in Sacramento County. Contact the Sacramento Sheriff’s Civil Bureau, 3341 Power Inn Rd, Rm. 313, Sacramento, CA 95826. The phone number is (916) 875-2665. The public counter hours are Monday through Friday from 9:00 am – 3:00 pm Private companies will serve also personally serve papers.
    [Show full text]
  • Initial Stages of Federal Litigation: Overview
    Initial Stages of Federal Litigation: Overview MARCELLUS MCRAE AND ROXANNA IRAN, GIBSON DUNN & CRUTCHER LLP WITH HOLLY B. BIONDO AND ELIZABETH RICHARDSON-ROYER, WITH PRACTICAL LAW LITIGATION A Practice Note explaining the initial steps of a For more information on commencing a lawsuit in federal court, including initial considerations and drafting the case initiating civil lawsuit in US district courts and the major documents, see Practice Notes, Commencing a Federal Lawsuit: procedural and practical considerations counsel Initial Considerations (http://us.practicallaw.com/3-504-0061) and Commencing a Federal Lawsuit: Drafting the Complaint (http:// face during a lawsuit's early stages. Specifically, us.practicallaw.com/5-506-8600); see also Standard Document, this Note explains how to begin a lawsuit, Complaint (Federal) (http://us.practicallaw.com/9-507-9951). respond to a complaint, prepare to defend a The plaintiff must include with the complaint: lawsuit and comply with discovery obligations The $400 filing fee. early in the litigation. Two copies of a corporate disclosure statement, if required (FRCP 7.1). A civil cover sheet, if required by the court's local rules. This Note explains the initial steps of a civil lawsuit in US district For more information on filing procedures in federal court, see courts (the trial courts of the federal court system) and the major Practice Note, Commencing a Federal Lawsuit: Filing and Serving the procedural and practical considerations counsel face during a Complaint (http://us.practicallaw.com/9-506-3484). lawsuit's early stages. It covers the steps from filing a complaint through the initial disclosures litigants must make in connection with SERVICE OF PROCESS discovery.
    [Show full text]
  • Service of Civil Summons and Subpoenas Upon Members of The
    GENERAL ORDER Title Service of Subpoenas and Civil Lawsuits Upon Members of the Department Topic Series Number PCA 701 04 Effective Date November 10, 2011 Replaces: DISTRICT OF COLUMBIA General Order 701.04 (Service of Subpoenas and Civil Lawsuits Upon Members of the Department) Effective Date: June 9, 2011 I. Background Page 1 II. Policy Page 2 III Definitions Page 2 IV. Regulations Page 4 V. Procedures Page 7 V.A Civil and Criminal Subpoenas Page 7 V.B Summonses and Complaints for Civil Lawsuits Page 13 V.C Substitute Service of Subpoenas and Civil Lawsuits Page 15 V.D Obtaining Legal Counsel Page 17 VI. Cross References Page 18 VII. Attachments Page 18 I. BACKGROUND On June 3, 2011, Chapter 20 of Title 6A “Police Personnel” District of Columbia Municipal Regulations (DCMR), was amended pursuant to D.C. Official Code § 5- 105.09 (Service of Process). Under the amendments, non-government attorneys and unrepresented parties may request the Court Liaison Division (CLD) assist in transmitting via electronic mail: A. Notifications of Subpoenas generated through the Computer Assisted Notification System (CANS), B. Subpoenas for civil or criminal cases, and C. Summonses and complaints for civil lawsuits to members arising out of their official duties for the Metropolitan Police Department (MPD). Non-government attorneys and unrepresented parties may also choose to have a process server personally serve members with subpoenas or summonses and complaints. In lieu of personal service, members may designate the Bureau Head of the bureau to which they are assigned to accept service of subpoenas or summonses and complaints on their behalf.
    [Show full text]
  • Responding to a Complaint: Washington, Practical Law State Q&A W-000-4121
    Responding to a Complaint: Washington, Practical Law State Q&A w-000-4121 Responding to a Complaint: Washington by Barbara J. Duffy, Lane Powell PC, with Practical Law Litigation Law stated as of 10 Jun 2019 • United States, Washington A Q&A guide to responding to a complaint in a trial court of general jurisdiction in Washington. This Q&A addresses the time to respond, extending the time to respond, pre-answer motions, answers, replies to the answer, counterclaims, crossclaims, third-party claims (also known as impleader), and defensive interpleader. Answers to questions can be compared across a number of jurisdictions (see Responding to a Complaint: State Q&A Tool). Overview of Responding to a State Complaint 1. When must a defendant respond to the complaint? In Washington, a defendant must respond to a complaint within 20 days after being served with the summons and complaint (Wash. Super. Ct. Civ. R. 4(a)(2) and 12(a)(1)). If process is served by publication, a defendant must respond within 60 days from the date of first publication of the summons (RCW 4.28.110 and Wash. Super. Ct. Civ. R. 12(a)(2)). If a plaintiff serves a defendant outside of Washington, the defendant has 60 days to respond to the complaint (RCW 4.28.180 and Wash. Super. Ct. Civ. R. 12(a)(3)). 2. How, if at all, can one obtain an extension of time to respond (for example, by stipulation, so-ordered stipulation, ex parte motion, motion on notice)? Counsel should check the local court's website for additional information regarding extending time to respond to a complaint.
    [Show full text]
  • Federal Jurisdiction and Due Process in the Era of the Nationwide Class Action
    University of Pennsylvania Carey Law School Penn Law: Legal Scholarship Repository Faculty Scholarship at Penn Law 2008 Federal Jurisdiction and Due Process in the Era of the Nationwide Class Action Tobias Barrington Wolff University of Pennsylvania Carey Law School Follow this and additional works at: https://scholarship.law.upenn.edu/faculty_scholarship Part of the Civil Procedure Commons, Courts Commons, Jurisdiction Commons, Jurisprudence Commons, Legislation Commons, Litigation Commons, and the Public Law and Legal Theory Commons Repository Citation Wolff, Tobias Barrington, "Federal Jurisdiction and Due Process in the Era of the Nationwide Class Action" (2008). Faculty Scholarship at Penn Law. 1623. https://scholarship.law.upenn.edu/faculty_scholarship/1623 This Article is brought to you for free and open access by Penn Law: Legal Scholarship Repository. It has been accepted for inclusion in Faculty Scholarship at Penn Law by an authorized administrator of Penn Law: Legal Scholarship Repository. For more information, please contact [email protected]. FEDERALJURISDICTION AND DUE PROCESS IN THE ERA OF THE NATIONWIDE CLASS ACTION TOBIAS BARRINGTON WOLFFt INTRO DUCTIO N .................................................................................... 2035 I. INTERDICTING STATE COURT PROCEEDINGS: TARGETED GRANTS OFJURISDICTION AND THE ANTISUIT INJUNCTION ......... 2046 A. The Anti-Injunction Act in an Era of Nationwide Complex Litigation ............................................................. 2047 B. TargetedJurisdiction
    [Show full text]
  • Rule 19. Required Joinder of Parties (A) PERSONS REQUIRED to BE JOINED IF FEASIBLE
    Rule 19. Required Joinder of Parties (a) PERSONS REQUIRED TO BE JOINED IF FEASIBLE. (1) Required Party. A person who is subject to service of process and whose joinder will not deprive the court of subject matter jurisdiction must be joined as a party if: (A) in that person's absence, the court cannot accord complete relief among existing parties; or (B) that person claims an interest relating to the subject of the action and is so situated that disposing of the action in the person's absence may: (i) as a practical matter impair or impede the person's ability to protect the interest; or (ii) leave an existing party subject to a substantial risk of incurring double, multiple, or otherwise inconsistent obligations because of the interest. (2) Joinder by Court Order. If a person has not been joined as required, the court must order that the person be made a party. A person who refuses to join as a plaintiff may be made either a defendant or, in a proper case, an involuntary plaintiff. (3) Service of Process. Service of process under this rule must be accomplished in the manner and within the time limits prescribed by Rule 4. (b) WHEN JOINDER IS NOT FEASIBLE. If a person who is required to be joined if feasible cannot be joined, the court must determine whether, in equity and good conscience, the action should proceed among the existing parties or should be dismissed. The factors for the court to consider include: (1) the extent to which a judgment rendered in the person's absence might prejudice that person or the existing parties; (2) the extent to which any prejudice could be lessened or avoided by: (A) protective provisions in the judgment; (B) shaping the relief; or (C) other measures; (3) whether a judgment rendered in the person's absence would be adequate; and (4) whether the plaintiff would have an adequate remedy if the action were dismissed for nonjoinder.
    [Show full text]
  • Chapter 6 – Civil Case Procedures
    GENERAL DISTRICT COURT MANUAL CIVIL CASE PROCEDURES Page 6-1 Chapter 6 – Civil Case Procedures Introduction Civil cases are brought to enforce, redress, or protect the private rights of an individual, organization or government entity. The remedies available in a civil action include the recovery of money damages and the issuance of a court order requiring a party to the suit to complete an agreement or to refrain from some activity. The party who initiates the suit is the “plaintiff,” and the party against whom the suit is brought is the “defendant.” In civil cases, the plaintiff must prove his case by “a preponderance of the evidence.” Any person who is a plaintiff in a civil action in a court of the Commonwealth and a resident of the Commonwealth or a defendant in a civil action in a court of the Commonwealth, and who is on account of his poverty unable to pay fees or costs, may be allowed by the court to sue or defendant a suit therein without paying fees and costs. The person may file the DC-409, PETITION FOR PROCEEDING IN CIVIL CASE WITHOUT PAYMENT OF FEES OR COSTS . In determining a person’s ability to pay fees or costs on account of his/her poverty, the court shall consider whether such person is current recipient of a state and federally funded public assistance program for the indigent or is represented by legal aid society, including an attorney appearing as counsel, pro bono or assigned or referred by legal aid society. If so, such person shall be presumed unable to pay such fees and costs.
    [Show full text]
  • Rule 19 Report (Tab 1).DOCX
    THE DIFFERING STANDARDS OF REVIEW THAT HAVE BEEN APPLIED TO RULE 19 DETERMINATIONS The federal appellate courts differ regarding the standard of review to be applied to district court determinations under Rules 19(a) and (b) of the Federal Rules of Civil Procedure. Rule 19(a) governs whether an absent party is a required party who should be joined if feasible. Rule 19(b) governs whether the action should be dismissed if it is not feasible to join a required party. The First, Second, Fourth, Fifth, and Eleventh Circuits apply an abuse of discretion standard in reviewing Rule 19(a) and 19(b) determinations. The Eighth Circuit also applies an abuse of discretion standard to Rule 19(b) determinations, but we were unable to find a decision clearly indicating the standard of review applied in that circuit for Rule 19(a) determinations. The Third Circuit applies an abuse of discretion standard to Rule 19(b) determinations, but reviews Rule 19(a) determinations de novo if based on conclusions of law, and reviews any subsidiary Rule 19(a) factual findings under a clear error standard. The Sixth Circuit reviews Rule 19(a) determinations under an abuse of discretion standard and Rule 19(b) determinations de novo. Both the Ninth and Tenth Circuits apply an abuse of discretion standard to Rule 19(a) and (b) determinations, unless they are based upon a legal conclusion, in which case those determinations are reviewed de novo. The Seventh Circuit has declined to adopt a standard of review. This report discusses the split in authority and whether there is a meaningful difference in the standards being applied.
    [Show full text]
  • Circuit Court Clerks' Manual
    CIRCUIT COURT CLERKS’ MANUAL - CIVIL Pre-Trial PAGE 4-1 Chapter 4 - Pre-Trial Pretrial Conferences Rule 4:13, titled Pretrial Procedures; Formulating Issues reads as follows: The court may in its discretion direct the attorney for the parties to appear before it for a conference to consider: ● A determination of the issues; ● A plan and schedule of discovery; ● Any limitations on the scope and methods of discovery; ● The necessity or desirability of amendments to the pleadings; ● The possibility of obtaining admissions of fact and of documents which will avoid unnecessary proof; ● The limitation of the number of expert witnesses; ● The advisability of a preliminary reference of issues to a master for findings to be used as evidence when the trial is to be by jury; ● Such other matters as may aid in the disposition of the action. The court shall make an order which recites the action taken at the conference, the amendments allowed to the pleadings, the agreements made by the parties as to any of the matters considered, and which limits the issues for trial to those not disposed of by admissions or agreements of counsel; and such order when entered controls the subsequent course of the action, unless modified at the trial to prevent manifest injustice. This rule is designed to allow the court to consider such matters as will aid it in the disposition of the case in subsequent proceedings. It is not intended to substitute a new way of trying a case when an issue of fact exists. In most cases, judges will require counsel to meet with the judge in chambers prior to the trial to dispose of preliminary matters.
    [Show full text]
  • Service of Process in the Circuit Court
    TIP06 Service of Process in the Circuit Court Service of process is the way the other person, often called the defendant, receives court papers and notice about a court case. The defendant must be served before the court will hear your case. You may not serve the defendant yourself. Someone else, 18 or older, who is not involved in the case, must serve the defendant. There are three ways to serve someone: by certified mail, sheriff, and private process. Receiving the Summons . The Clerk will mail you two copies of the paperwork you filed and two copies of the summons. One copy is for serving on the defendant. The other will later be returned to the court. Certified Mail . Give the summons to another adult who is not directly involved in your case. Have that person go to any United States post office. Have that person send the summons to the defendant for you, by certified mail. They must request restricted delivery and a return receipt. If the defendant accepts service by certified mail, the post office will send the return receipt postcard back to the person who helped you with the service. Your server must then complete an affidavit of service. This is form CC‐DR‐056. Submit the return receipt, the affidavit of service, and the extra copy of the complaint and summons to the court. Sheriff Service . Request service by the sheriff when you file your case at the Clerk’s Office. You will pay an extra fee for the sheriff. The clerk will forward the summons to the sheriff’s office.
    [Show full text]
  • Circuit Court Clerks' Manual
    CIRCUIT COURT CLERKS’ MANUAL - CIVIL CASEFLOW MANAGEMENT PAGE 3-1 Chapter 3 - Caseflow Management Docket Call Civil Docket Call is a method used to call pending civil cases for the purpose of setting trial dates. Note: Not all courts may conduct a civil docket call. In some courts, cases are set by praecipe or pretrial scheduling orders. Civil Docket Call is often referred to as “term day.” Virginia Code § 17.1-517 provides that the chief judge of each circuit shall specify, through a court order, the terms of court for each court within his/her circuit. A “term of court” is the period of time during which the circuit court is in session. Terms may vary in length among courts, but no court may have less than four terms of court each year. Any change in the terms of court is to be reported by the chief judge of the circuit to the Office of the Executive Secretary by January 1 of each year. Va. Code § 17.1-517. Civil and Criminal Terms are often combined, however several courts have set terms for civil cases and separate terms for criminal cases. Some examples of civil terms throughout the Commonwealth are: • “First Monday in March, June and December and Third Monday in September”; • “Third Wednesday in each month except August”; • “Third Wednesday in February, April, June, August, October and December”; • “First Tuesday in each month” Again, “Term day” refers to the day on which a term of court commences. The times for commencement of terms for each circuit court are set out in Rule 1:15.
    [Show full text]
  • Exhibit B – Joint Proposed Case Management Order
    Case 1:17-cv-02511-RJL Document 40-2 Filed 12/15/17 Page 1 of 19 – Exhibit B – Joint Proposed Case Management Order United States v. AT&T Inc. et al., No. 17-cv-02511-RJL Case 1:17-cv-02511-RJL Document 40-2 Filed 12/15/17 Page 2 of 19 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA UNITED STATES OF AMERICA, Plaintiff, v. Case No. 1:17-cv-02511-RJL AT&T INC., DIRECTV GROUP HOLDINGS, LLC, and TIME WARNER INC., Defendants. [PROPOSED] CASE MANAGEMENT ORDER This Court, having considered the motions of the parties for entry of their Proposed Case Management Order, and having conducted a hearing on December 7, 2017, enters this Case Management Order pursuant to Rule 16 of the Federal Rules of Civil Procedure and LCvR 16.4: 1. Service of Complaint: Counsel for Defendants, acting on behalf of Defendants, have accepted service of the Complaint and have waived formal service of a summons. 2. Discovery Conference. The parties’ prior consultations and submission of this Order relieve the parties of their duty under Federal Rule of Civil Procedure 26(f). 3. Completion of Planned Transaction. Defendants agree not to consummate or otherwise complete the challenged acquisition until the entry of a final and appealable judgment and, if the Court enters such judgment in favor of Defendants, not to consummate or otherwise complete the challenged acquisition until 12:01 a.m. on the sixth calendar day following entry of such judgment. 4. Calculation of Dates. Unless otherwise specified, dates are calculated according to Rule 6(a) of the Federal Rules of Civil Procedure.
    [Show full text]