Illinois Appellate Court
Civil Court
Civil Procedure
Appeal arising from circuit court grant of a motion for SCR 137 sanctions against plaintiff’s counsel for filing a summons for discovery when there was no underlying cause of action. The appellate court affirmed, finding that the appellant violated Rule 137 by filing a section 2-402 summons with a Rule 224 petition and that the circuit court did not abuse its discretion in imposing sanctions. (PIERCE and MIKVA, concurring)