Huber v. American Accounting Association

Plaintiff's Notice of Appeal was received by clerk of circuit court after 30-day deadline. As Plaintiff did not provide attorney certificate or nonattorney affidavit, he failed to provide proof of mailing required by Supreme Court Rules. Proof of mailing cannot be shown by postage label from self-service kiosk, as label is not a postmark. Label shows date of sale but does not necessarily indicate date Plaintiff placed envelope in the mail and post office took custody of it. (GARMAN, FREEMAN, THOMAS, KILBRIDE, KARMEIER, and BURKE, concurring.)