Mufarreh v. Google, Inc.

Illinois Appellate Court
Civil Court
Pre-Suit Discovery
Citation
Case Number: 
2026 IL App (1st) 251340
Decision Date: 
Friday, May 1, 2026
District: 
1st Dist.
Division/County: 
5th Div./Cook Co.
Holding: 
Reversed.
Justice: 
MITCHELL

Interested party John Doe appealed from a circuit court order allowing the plaintiffs’ to obtain Doe’s identify from the respondents as pre-suit discovery under Supreme Court Rule 224. At issue on appeal was whether the circuit court erred in allowing pre-suit discovery because petitioners failed to state a claim for intentional infliction of emotional distress and because petitioner’s already knew John Doe’s identity. The appellate court reversed, finding that the circuit court erred because petitioners failed to state a claim for intentional infliction of emotional distress. (ODEN JOHNSON and WILSON, concurring)