White v. GARLOCK SEALING TECHNOLOGIES, LLC

This case presents the question of whether Supreme Court Rule 237(b) (210 Ill. 2d R. 237(b)), dealing with persons whom a party may be required to produce at trial, includes not only persons who are “officer[s], director[s], or employee[s,]” but also those persons who are under a party’s control. We hold that it does not.

I. PROLOGUE

During an October 2008 wrongful-death jury trial based upon asbestos exposure (which was the second jury trial in this case), the trial court sanctioned defendant, Garlock Sealing Technologies, LLC, pursuant to Rule 237(b) (210 Ill. 2d R. 237(b)) for failing to…