The Illinois Appellate Court held that opinion witness disclosures pursuant to Illinois Supreme Court Rule 213 are not required when the same disclosure has been made under Illinois Supreme Court Rule 222. Rule 222 provides for limited and simplified discovery in cases where the damages sought are under $50,000. The Court noted that Rule 222(d)(6) specifically provides for the disclosure of opinion witnesses. Consequently, the Court held, "[w]hether a Rule 213(g) interrogatory requesting the disclosure of opinion witnesses is answered is of no consequence in cases to which Rule 222 applies as long as Rule 222 is complied with." Kapsouris v. Rivera, 319 Ill.App.3d 844, 747 N.E.2d 427, 254 Ill.Dec. 387 (2d Dist. 2001).
