Illinois Appellate Court
Civil Court
Workers' Compensation
Claimant, who was vice-president of sales and marketing, suffered two work-related accidents. Commission erred in allowing IME physician's evidence deposition and report over Claimant's Section 12 objection to untimely disclosure. When Section 12 objection is made, the proponent of medical testimony has burden to prove compliance with Section 12, including showing of good cause for failure to meet time deadlines for disclosure and for taking of evidence deposition. (McCULLOUGH, HUDSON, and HOFFMAN, concurring; HOLDRIDGE, specially concurring.)