Illinois Supreme Court Rule 90(c) permits the use of medical records, bills, wage loss documentation, and other relevant evidence in arbitration without requiring live testimony, so long as the documents are served on all parties at least 30 days prior to the hearing and are accompanied by proper affidavits of authenticity. This evidentiary tool is designed to streamline arbitration by allowing documentary submissions in lieu of in-person witnesses.
The following template provides a sample structure for preparing a complete Rule 90(c) submission. It outlines the types of evidence typically included, such as medical treatment records, billing summaries, wage loss verification, and property damage reports, along with the necessary affidavits to satisfy Rule 90(c) requirements. This format can be adapted for use in personal injury arbitration proceedings throughout Illinois.
PLAINTIFF’S RULE 90(c) SUBMISSION FOR ARBITRATION
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT – LAW DIVISION
JOHN DOE,
Plaintiff,
v.
JANE SMITH,
Defendant.
Case No.: 2024 L 123456
Arbitration Hearing Date: May 15, 2025
NOTICE OF SERVICE OF EVIDENCE PURSUANT TO SUPREME COURT RULE 90(c)
TO: Counsel for Defendant
PLEASE TAKE NOTICE that pursuant to Illinois Supreme Court Rule 90(c), Plaintiff hereby serves the following documentary evidence intended for use at the arbitration hearing scheduled for May 15, 2025. All records are accompanied by affidavits from the appropriate custodians attesting to authenticity and compliance with the Rule. This notice and all attached materials are being served more than 30 days prior to the arbitration hearing.
- MEDICAL RECORDS AND BILLS
- ABC Hospital Emergency Department Records
- XYZ Orthopedic Clinic Progress Notes (Dr. Ali Rezaei)
- Physical Therapy Progress Notes – MoveWell PT
- Medical Bills from ABC Hospital ($3,200)
- Bills from XYZ Orthopedic ($1,500)
- MoveWell PT Billing Summary ($2,300)
Attached as Exhibits A–E, with affidavits of records custodians
II. WAGE LOSS DOCUMENTATION
- Letter from Employer (ACME Corporation) verifying missed work: 4 weeks
- Paystubs showing pre-injury wages: $1,000/week
- Total wage loss: $4,000
Attached as Exhibit F
III. PROPERTY DAMAGE
- Auto repair estimate from BigFix Collision Center: $6,800
- Photos of the vehicle pre- and post-impact
- Insurance appraisal and declaration page
Attached as Exhibits G–I
IV. AFFIDAVITS OF AUTHENTICITY (per Rule 90(c))
- Each of the above records includes an affidavit from the record custodian swearing:
- The attached records are true and correct copies kept in the regular course of business;
- The attached bills reflect usual and customary charges for services rendered.
Respectfully Submitted,
[Your Name]
Attorney for Plaintiff
[Your Law Firm]
[Address, Email, Phone]
CONCLUSION
Properly preparing and serving a Rule 90(c) evidentiary package can significantly reduce delays and simplify the arbitration process in personal injury cases. By organizing your records, securing timely affidavits, and meeting service deadlines, you protect your claim and make your evidence admissible without unnecessary complications.
At Gosuits, we help our clients navigate every step of arbitration and litigation with confidence. Using a combination of legal experience and proprietary technology, we streamline document preparation, meet critical deadlines, and keep you informed throughout the process. When you’re facing the stress of a personal injury claim, our goal is to make the legal side feel less overwhelming—and to help you move forward with clarity and peace of mind.
