Heerey v. Berke

Third-party plaintiff, Benitta Berke (Berke), appeals from an order of the circuit court of Cook County dismissing with prejudice counts VI and VII of her amended third-party complaint. Counts VI and VII alleged that a letter drafted and published by third-party defendants Nathaniel I. Grey (Grey), an attorney, and Foss, Schuman, Drake & Bernard (Foss), a law partnership, constituted libel per quod and libel per se. Berke argues on appeal that she sufficiently alleged causes of action for libel per quod and libel per se. Berke additionally argues that (1) it was error for the trial court to…