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Archive for Month: July 2018


The Requirements of Section 2-622 Should Be Liberally Construed

The First District Appellate Court in Lee v. Birkshire Nursing & Rehab Center, LLC, et. al., reversed the trial court’s decision to dismiss certain parties with prejudice due to Plaintiff’s failure to file the requisite attorney affidavit and physician’s report pursuant to 735 ILCS 5/2-622(a)(2) within 90 days of the commencement […]


Do I have a Workers’ Compensation Claim or a Civil Claim? The Appellate Court Weighs In

In Peng v. Nardi, 2018 IL App (1st) 170155, the first district appellate court addressed the question whether an employee who is injured when commuting to and/or from work has a civil claim or a workers’ compensation claim. The answer depends on the facts.  This decision provides an excellent summary […]