Reviewing Important Illinois Healthcare Court Rulings: One Year Limitation to Provide a 2-622 Written Report

In Horlacher v. Cohen, 2017 IL App (1st) 162712, the Court held that Plaintiff's Third Amended Complaint was properly dismissed when she failed to include a Section 2-622 written report concluding that a "reasonable and meritorious cause" for her action existed. Plaintiff, appearing pro se, had previously filed three other versions of the Complaint without attaching the required Section 2-622 written report.

Plaintiff argued that her failure to provide the 2-622 written report was due to receiving incomplete dental records from Defendant. Plaintiff argued that she should have 90 days from the time she received complete dental records to submit a written report. The Appellate Court noted that the purpose of Section 2-622 was to reduce the number of frivolous malpractice suits, and therefore, Plaintiff's argument that she had unlimited time to provide a reviewing dentist's written report was incorrect.

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