Illinois Appellate Court
Civil Court
Sanctions
Court entered $2 million default judgment as discovery sanction based on Defendants' failure to meet several discovery deadlines, and Plaintiff sought additional $1 million in damages for emotional suffering. Court must both weigh efficacy of less drastic alternatives, in proportion to gravity of violations, and warn of possible sanction, before entering most damaging sanction available for discovery violations.(NEVILLE and PUCINSKI, concurring.)