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HARRIS v. ONE HOPE UNITED, INC.

No. 1-13-1152.

2 N.E.3d 1132 (2013)

2013 IL App (1st) 131152

377 Ill. Dec. 851

Robert F. HARRIS, Public Guardian of Cook County, as Independent Administrator of the Estate of Marshana Philpot, Deceased, Plaintiff-Appellee, v. ONE HOPE UNITED, INC., Lashana Philpot, and Pixie Davis, Individually and as Agent of One Hope United, Inc., Defendants (Stellato and Schwartz, Ltd., Contemnor-Appellant).

Appellate Court of Illinois, First District, First Division.

December 16, 2013.

Attorney(s) appearing for the Case

Stellato & Schwartz, Ltd., Chicago ( Esther Joy Schwartz , Richard W. Schumacher , of counsel), for appellant.

Law Office of Daniel E. Goodman, LLC, Rosemont ( Gary W. Klages , of counsel), for appellee.

OPINION

Justice DELORT delivered the judgment of the court, with opinion.

¶ 1 The self-critical analysis privilege protects certain documents from disclosure in litigation. Some federal courts have recognized the privilege, but Illinois state courts have not. In the court below, the defendant relied on the privilege to justify its refusal to turn over certain documents to the plaintiff. The defendant was held in "friendly contempt" to facilitate an...

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