Where a party is subject to both civil litigation and criminal prosecution for a single act, a criminal conviction may serve to collaterally estop the issue of liability even if the avenues for appeal have not been exhausted prior to the trial, so long as they have been exhausted prior to the final civil order.The 1st District Appellate Court affirmed the decision of Cook County Circuit Judge Thomas J. Lipscomb.In October 2011, there was a confrontation between Charles Dahms and Terry Enadeghe that began when Enadeghe …