Brookbank v. Olson

I respectfully dissent.

In Vision Point of Sale, Inc. v. Haas, 226 Ill. 2d 334 (2007), our supreme court overruled an interpretation of Rule 216 that imposed a signature requirement not created by the rule’s plain language and held that denials certified in accordance with section 1 — 109 of the Code of Civil Procedure are sufficient to satisfy the rule’s requirement of service of a sworn statement. I do not believe that the majority’s opinion sufficiently adheres to the course set by the Vision Point court.

As the majority notes, Rule 216 provides that facts that are the subject of admission…