About The Legal Filings

All legal filings available to you are reproductions of those filed with the courts.

I have made some changes which I believe you will accept as non-essential.

For example, rather than scan some filed papers, I have converted them from their original formats into PDFs. This results in smaller files that are easier to download. That is why you will see some documents without official court time stamps (papers are time stamped showing the date and hour when they were filed with the court), notarization or signatures.

More files will be added as the case progresses. Some of the already filed papers are not included at this time. These are generally of two types. The first are Motions to Join. Basically, these are notices to the court that another defendant desires to "piggyback" on the motion filed by another defendant. Heretofore, most of the Motions to Dismiss have been initiated by the attorneys representing Rush (except RNSMC), Dr. Layfer and Dr. Ibrahim. The second type comprises the court orders. They will be added as time permits.

It is possible that I may not, through innocent oversight, fail to upload a publicly available document. Please be assured this is unintentional. If you are aware of such a document, let me know and I will correct the mistake as soon as practical.

Remember, this is a novel. Only the un-annotated medical records and legal filings can be considered as accurate representations of what is claimed to be true.

Some of these files are large. A fast internet connection helps.

It is possible that you will have to "play" with the settings on your PDF reader to see the complete pages. In general, you will have to decrease the zoom (e.g., going from 100% zoom to 33% zoom).

Complaint at Law

• Original filed Complaint
• First Amended Complaint
• Second Amended Complaint

Motions to Dismiss

• 2-622 Motion to Dismiss
• Unlicensed Practice of Law Motion to Dismiss 

Filings With the Court of Appeals

• Brief and Arguments of Appellants
• Brief and Argument of Appellee
• Reply Brief and Argument of Appellants
• Appellate Court Decision of 28 September 2007
• Motion For Extension Of Time To File Petition For Rehearing 03 October 2007
• Petition for Rehearing of 20 November 2007

Filings With the Illinois Supreme Court

• Plaintiff's Petition For Leave To Appeal
• Appellees' (Defendants') Answer To Petition For Leave To Appeal
• Appellant's (Plaintiff's) Supreme Court Brief and Argument
• Appellees' (Defendants') Brief and Argument
• Appellant's (Plaintiff's) Reply Brief
• Amicus Brief of the Illinois Trial Lawyers Association
• Video and Audio of Oral Argument, September 11, 2008
• Audio of Oral Argument, September 11, 2008