Illinois Appellate Court
Civil Court
Sanctions
(Modified upon denial of rehearing 12/8/17.) Plaintiff law firm served a 3rd-party citation to discovery assets on Respondent LLC, to collect a debt owed by defendant. Court granted Defendant's motion for sanctions, but never awarded a specific monetary amount. Thus, appeal from order granting motion for sanctions is dismissed for want of jurisdiction. Court provided sufficient detail to discern basis for order granting Plaintiff's motion for sanctions. Court erred in denying Defendant's request to hold an evidentiary hearing as to attorney fees. Party seeking award of attorney fees has burden to present enough evidence to enable court to determine reasonableness of fees requested. (HOFFMAN and CONNORS, concurring)