Illinois Appellate Court
Civil Court
Relation Back
Plaintiff sued hospital and its doctors as to Plaintiff's treatment at ER. Plaintiff initially named one physician as Defendant who treated him in ER, based on his name in hospital's records as treating physician. That physician filed motion to dismiss, claiming that not he but another physician treated Plaintiff. Plaintiff then amended Complaint and added the other physician, Dr. Elahi. Plaintiff's omission of Dr. Elahi was a mistake for purposes of applying Section 2-616(d)'s relation-back doctrine, even though his handwritten name appears in Plaintiff's medical records. Remanded, as whether Dr. Elahi received constructive notice is not yet developed. (REYES, concurring; LAMPKIN, dissenting.)