Illinois Appellate Court
Civil Court
Statutes of Limitations
Plaintiff filed complaint in 2014 against bank and accounting firm, alleging fraud, civil conspiracy, and breach of fiduciary duty, arising from Defendants' promotion of an illegitimate tax shelter in which Plaintiff invested in 2000. Plaintiff was not immediately aware that his $18 million loss was an injury wrongfully caused, but events occurring after the act of concealment in 2002 were sufficient to put Plaintiff on notice, in 2008, of his injury and its wrongful cause. Thus, Plaintiff's complaint was filed beyond the 5-year statute of limitation applicable to bank and the 2-year statute applicable to accounting firm. (LAVIN and PUCINSKI, concurring.)