On October 11, 2007, in Crull v. Sriratana, et. al., the 4th District held that the plaintiff must disclose the name and address of the health care professional authoring a 2-622 report. This is consistent with the Cargill decision issued in 2004. After the Cargill decision, some judges were granting motions to dismiss for failure to identify the 2-622 physician and some were denying such motions. In November 2005, Judge Ward (Cook County) consolidated all such motions under the case name Dorian O'Conner v. The University of Chicago Hospital and decided that plaintiffs were not required to identify the name and address of their 2-622 consultants in Cook County. The Crull case states that all circuit courts must follow the Cargill decision until either the 4th District or Supreme Court holds otherwise.

Bottom Line: It appears plaintiffs are once again required to identify the name and address of their 2-622 consultants. This decision applies to cases that accrued (a/k/a occurred) before August 25, 2005. For cases that accrued after that date, the new tort reform provisions apply and plaintiffs are likewise required to identify the name and address of their 2-622 consultants.