Illinois Appellate Court
Civil Court
Forum Non Conveniens
Plaintiff e-filed medical malpractice complaint in Sangamon County, although caption of complaint and jurisdiction statement, and notice of attorney's lien and Section 2-622 affidavit and report referred to St. Clair County, where decedent received medical care. Six months later, Plaintiff filed motion to transfer venue to correct an "inadvertent" error as Sangamon County was inadvertently selected during e-filing process. Court abused its discretion in granting Plaintiff's motion to transfer venue based on forum non conveniens. The time for objecting to venue had passed prior to Plaintiff filing motion for change of venue. (HARRIS and HOLDER WHITE, concurring.)