Illinois Appellate Court
Criminal Court
Discovery
Court erred in sanctioning Plaintiff in arbitration case via self-executing order barring her from testifying or presenting evidence at arbitration hearing, where Plaintiff's sole discovery violation was being one week late in providing discovery answers, without first obtaining leave of court. Rule 219(c) does not provide trial court with statutory authority to bar a party from presenting testimony other than the plaintiff's. When Plaintiff was later barred from rejecting arbitration award, the Rule 219(c) order was tantamount to a dismissal of plaintiff's case. (LAMPKIN, concurring; GARCIA, specially concurring.)