{ "id": 4260787, "name": "JOSE LOPEZ, Indiv. and as Special Adm'r of the Estate of Elizabeth Lopez, Deceased, Plaintiff-Appellant, v. CLIFFORD LAW OFFICES, P.C., et al., Defendants-Appellees (Joe Loran et al., Respondents-in-Discovery)", "name_abbreviation": "Lopez v. Clifford Law Offices, P.C.", "decision_date": "2005-12-12", "docket_number": "Nos. 1\u201404\u20141805, 1\u201404\u20143220 cons.", "first_page": "969", "last_page": "983", "citations": [ { "type": "official", "cite": "362 Ill. App. 3d 969" } ], "court": { "name_abbreviation": "Ill. App. Ct.", "id": 8837, "name": "Illinois Appellate Court" }, "jurisdiction": { "id": 29, "name_long": "Illinois", "name": "Ill." }, "cites_to": [ { "cite": "823 N.E.2d 1088", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 2005, "pin_cites": [ { "page": "1101", "parenthetical": "\"[ojrdinarily, it is the jury's responsibility to consider whether plaintiffs actions amounted to contributory negligence\"" } ], "opinion_index": 0 }, { "cite": "355 Ill. App. 3d 957", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 3600654 ], "year": 2005, "pin_cites": [ { "page": "972", "parenthetical": "\"[ojrdinarily, it is the jury's responsibility to consider whether plaintiffs actions amounted to contributory negligence\"" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/355/0957-01" ] }, { "cite": "653 N.E.2d 48", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1995, "pin_cites": [ { "page": "51", "parenthetical": "the original attorney is not liable for not filing the action before the expiration of the statute of limitations where \"defendants' and plaintiffs' attorney/client relationship ended sometime before April 1, 1991. The claim was not time barred until August 17, 1991\"" } ], "opinion_index": 0 }, { "cite": "273 Ill. App. 3d 545", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 258750 ], "year": 1995, "pin_cites": [ { "page": "550" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/273/0545-01" ] }, { "cite": "112 Ill. 2d 273", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 5539451 ], "year": 1986, "opinion_index": 0, "case_paths": [ "/ill-2d/112/0273-01" ] }, { "cite": "497 N.E.2d 410", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1986, "pin_cites": [ { "page": "413" } ], "opinion_index": 0 }, { "cite": "146 Ill. App. 3d 779", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 3572456 ], "year": 1986, "pin_cites": [ { "page": "784" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/146/0779-01" ] }, { "cite": "606 N.E.2d 531", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1992, "pin_cites": [ { "page": "537", "parenthetical": "the plaintiffs uncontradicted affidavit filed in response to a section 2 - 619 motion to dismiss - stating that she relied to her detriment on the defendant's representations - created a genuine issue of fact, defeating the motion to dismiss" } ], "opinion_index": 0 }, { "cite": "238 Ill. App. 3d 702", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 5155040 ], "year": 1992, "pin_cites": [ { "page": "710", "parenthetical": "the plaintiffs uncontradicted affidavit filed in response to a section 2 - 619 motion to dismiss - stating that she relied to her detriment on the defendant's representations - created a genuine issue of fact, defeating the motion to dismiss" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/238/0702-01" ] }, { "cite": "357 N.E.2d 1232", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1976, "pin_cites": [ { "page": "1236" } ], "opinion_index": 0 }, { "cite": "44 Ill. App. 3d 452", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 2814091 ], "year": 1976, "pin_cites": [ { "page": "456" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/44/0452-01" ] }, { "cite": "811 N.E.2d 670", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 2004, "pin_cites": [ { "page": "674", "parenthetical": "the treatment of proximate cause as a question of law is an exception to the general rule that proximate cause is a fact-laden issue and should be decided by a trier of fact" } ], "opinion_index": 0 }, { "cite": "211 Ill. 2d 251", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 8451324 ], "year": 2004, "pin_cites": [ { "page": "257", "parenthetical": "the treatment of proximate cause as a question of law is an exception to the general rule that proximate cause is a fact-laden issue and should be decided by a trier of fact" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/211/0251-01" ] }, { "cite": "135 Cal. Rptr. 838", "category": "reporters:state", "reporter": "Cal. Rptr.", "weight": 4, "year": 1977, "pin_cites": [ { "page": "841" }, { "page": "841" }, { "page": "841-42" } ], "opinion_index": 0 }, { "cite": "66 Cal. App. 3d 174", "category": "reporters:state", "reporter": "Cal. App. 3d", "case_ids": [ 8662050 ], "weight": 4, "year": 1977, "pin_cites": [ { "page": "179" }, { "page": "179" }, { "page": "180" } ], "opinion_index": 0, "case_paths": [ "/cal-app-3d/66/0174-01" ] }, { "cite": "720 N.E.2d 1068", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1999, "pin_cites": [ { "page": "1072" } ], "opinion_index": 0 }, { "cite": "188 Ill. 2d 252", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 536099 ], "weight": 2, "year": 1999, "pin_cites": [ { "page": "258-59" }, { "page": "258-59" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/188/0252-01" ] }, { "cite": "440 N.E.2d 1022", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1982, "pin_cites": [ { "page": "1026" } ], "opinion_index": 0 }, { "cite": "109 Ill. App. 3d 582", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 5449739 ], "weight": 3, "year": 1982, "pin_cites": [ { "page": "587" }, { "page": "587" }, { "page": "587" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/109/0582-01" ] }, { "cite": "633 N.E.2d 234", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1994, "pin_cites": [ { "page": "237" } ], "opinion_index": 0 }, { "cite": "261 Ill. App. 3d 232", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 5370452 ], "weight": 3, "year": 1994, "pin_cites": [ { "page": "237" }, { "page": "233" }, { "page": "237" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/261/0232-01" ] }, { "cite": "478 N.E.2d 1203", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1985, "opinion_index": 0 }, { "cite": "133 Ill. App. 3d 537", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 3529413 ], "weight": 5, "year": 1985, "pin_cites": [ { "page": "538-40" }, { "page": "540" }, { "page": "540" }, { "page": "540" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/133/0537-01" ] }, { "cite": "263 La. 774", "category": "reporters:state", "reporter": "La.", "case_ids": [ 9739122, 3261711 ], "weight": 2, "year": 1972, "opinion_index": 0, "case_paths": [ "/so2d/269/0239-01", "/la/263/0774-01" ] }, { "cite": "145 N.J. 395", "category": "reporters:state", "reporter": "N.J.", "case_ids": [ 819584 ], "weight": 6, "year": 1996, "pin_cites": [ { "page": "412" }, { "page": "1068" }, { "page": "413" }, { "page": "1069" }, { "page": "420" }, { "page": "1072" } ], "opinion_index": 0, "case_paths": [ "/nj/145/0395-01" ] }, { "cite": "440 N.E.2d 96", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1982, "pin_cites": [ { "parenthetical": "applying traditional negligence principles in a legal malpractice action" } ], "opinion_index": 0 }, { "cite": "92 Ill. 2d 13", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 3096980 ], "year": 1982, "pin_cites": [ { "parenthetical": "applying traditional negligence principles in a legal malpractice action" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/92/0013-01" ] }, { "cite": "628 N.E.2d 738", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1993, "pin_cites": [ { "page": "739-40" } ], "opinion_index": 0 }, { "cite": "256 Ill. App. 3d 288", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 5384895 ], "year": 1993, "pin_cites": [ { "page": "290" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/256/0288-01" ] }, { "cite": "653 N.E.2d 915", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1995, "pin_cites": [ { "page": "918" } ], "opinion_index": 0 }, { "cite": "274 Ill. App. 3d 267", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 291702 ], "year": 1995, "pin_cites": [ { "page": "270" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/274/0267-01" ] }, { "cite": "659 N.E.2d 56", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1995, "pin_cites": [ { "page": "58" } ], "opinion_index": 0 }, { "cite": "276 Ill. App. 3d 590", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 927619 ], "year": 1995, "pin_cites": [ { "page": "593" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/276/0590-01" ] }, { "cite": "773 N.E.2d 1192", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 2002, "pin_cites": [ { "page": "1193-94" } ], "opinion_index": 0 }, { "cite": "332 Ill. App. 3d 618", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 1034029 ], "weight": 4, "year": 2002, "pin_cites": [ { "page": "620" }, { "page": "619-22" }, { "page": "622" }, { "page": "620" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/332/0618-01" ] }, { "cite": "806 N.E.2d 1188", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 2004, "pin_cites": [ { "page": "1192" } ], "opinion_index": 0 }, { "cite": "347 Ill. App. 3d 169", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 3950710 ], "weight": 4, "year": 2004, "pin_cites": [ { "page": "174" }, { "page": "170-71" }, { "page": "176" }, { "page": "176" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/347/0169-01" ] }, { "cite": "826 N.E.2d 526", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 2005, "pin_cites": [ { "page": "530" } ], "opinion_index": 0 }, { "cite": "356 Ill. App. 3d 354", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 3749150 ], "year": 2005, "pin_cites": [ { "page": "358" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/356/0354-01" ] }, { "cite": "747 N.E.2d 992", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 2001, "pin_cites": [ { "page": "997" } ], "opinion_index": 0 }, { "cite": "321 Ill. App. 3d 571", "category": "reporters:state", "reporter": "Ill. App. 3d", "case_ids": [ 132476 ], "year": 2001, "pin_cites": [ { "page": "576" } ], "opinion_index": 0, "case_paths": [ "/ill-app-3d/321/0571-01" ] }, { "cite": "650 N.E.2d 1000", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1995, "pin_cites": [ { "page": "1002" } ], "opinion_index": 0 }, { "cite": "165 Ill. 2d 181", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 483559 ], "weight": 2, "year": 1995, "pin_cites": [ { "page": "185" }, { "page": "185-86" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/165/0181-01" ] }, { "cite": "619 N.E.2d 732", "category": "reporters:state_regional", "reporter": "N.E.2d", "year": 1993, "pin_cites": [ { "page": "735" } ], "opinion_index": 0 }, { "cite": "156 Ill. 2d 112", "category": "reporters:state", "reporter": "Ill. 2d", "case_ids": [ 777542 ], "weight": 2, "year": 1993, "pin_cites": [ { "page": "116" }, { "page": "116-17" } ], "opinion_index": 0, "case_paths": [ "/ill-2d/156/0112-01" ] } ], "analysis": { "cardinality": 1344, "char_count": 38340, "ocr_confidence": 0.774, "pagerank": { "raw": 1.7647625594279444e-07, "percentile": 0.7105514645834564 }, "sha256": "24894af50f355f104e0cfbe55fcd25daab6e0fbc5d6b59e1e057bc4075a340fd", "simhash": "1:4d765dc78968407d", "word_count": 6223 }, "last_updated": "2023-07-14T16:28:25.526171+00:00", "provenance": { "date_added": "2019-08-29", "source": "Harvard", "batch": "2018" }, "casebody": { "judges": [], "parties": [ "JOSE LOPEZ, Indiv. and as Special Adm\u2019r of the Estate of Elizabeth Lopez, Deceased, Plaintiff-Appellant, v. CLIFFORD LAW OFFICES, P.C., et al., Defendants-Appellees (Joe Loran et al., Respondents-in-Discovery)." ], "opinions": [ { "text": "JUSTICE GORDON\ndelivered the opinion of the court:\nThis is an appeal from a dismissal of a legal malpractice action. After Elizabeth Lopez, the daughter of plaintiff Jose Lopez, drowned in a pool that was allegedly maintained by the Rockford School District, Lopez retained defendant Clifford Law Offices (the Clifford firm) to represent him and Elizabeth\u2019s estate in a wrongful death action. Several months later, defendant Thomas K. Prindable, an attorney with the Clifford firm, wrote to Lopez, informing him that the firm was unable to continue representing him and the estate. Prindable\u2019s letter incorrectly advised Lopez that the applicable statute of limitations was two years, when, in fact, it was only one year from the date of Elizabeth\u2019s death. Ultimately, another attorney \u2014 whom Lopez retained after the expiration of the one-year statute of limitations applicable to municipalities, but before the second anniversary of Elizabeth\u2019s death \u2014 filed the wrongful death action. However, because the wrongful death action was filed after the expiration of the applicable statute of limitations, it was dismissed.\nThe Clifford firm and Prindable (collectively, the Clifford defendants), as well as defendant William King, an attorney who referred Lopez to the Clifford firm, separately moved to dismiss the malpractice action pursuant to section 2 \u2014 619(a)(9) of the Code of Civil Procedure (735 ILCS 5/2 \u2014 619(a)(9) (West 2002)) on the grounds that the wrongful death action was still viable when the Clifford firm ceased to represent the estate. The circuit court granted the motions to dismiss. For the reasons that follow, we reverse and remand.\nBACKGROUND\nLopez initially filed his malpractice action against the Clifford defendants alone. In his August 19, 2003, complaint, Lopez alleged the following. Elizabeth died on February 20, 2001. Shortly thereafter, Lopez retained the Clifford firm \u201cfor the purpose of advising [him] of his legal rights.\u201d At all pertinent times, Prindable was an employee, servant and/or agent of the Clifford firm and acting within the scope of his agency. On August 20, 2001, Prindable wrote to Lopez a letter which stated, in pertinent part:\n\u201cI am writing *** to confirm our telephone conversation in August 14, 2001, wherein I informed you that Clifford Law Offices is unable to continue to assume professional responsibility on behalf of the Estate of your daughter, Elizabeth, as a result of her tragic death on February 20, 2001. This decision does not represent an opinion as to the merit of any cause of action the Estate may have.\nPlease be advised that the statute of limitations in Illinois provides that a civil action to recover compensation for your daughter\u2019s injuries must be filed within two years after the cause of action occurred. Therefore, should you decide to pursue this matter further, we respectfully suggest that you contact an attorney of your choice immediately so that the Estate\u2019s legal rights may be fully protected. Do not delay.\u201d\nThe letter was attached as an exhibit to the malpractice complaint. Lopez alleged that Prindable\u2019s advice as to the statute of limitations, upon which he reasonably relied, was incorrect because the Rockford School District was a \u201clocal public entity\u201d within the meaning of the Local Governmental and Governmental Employees Tort Immunity Act (hereinafter, the Tort Immunity Act) (see 745 ILCS 10/1 \u2014 206 (West 2000)) and no civil action may be commenced against a \u201clocal public entity\u201d after one year from the date of the injury (see 745 ILCS 10/8\u2014 101 (West 2000)). Lopez claimed that as a result of the Clifford defendants\u2019 negligence, he and the estate irrevocably lost their rights of action, and had the wrongful death action not been aborted because of the statute of limitations defense, it would have succeeded on the merits. Although Lopez subsequently amended his complaint several times, these allegations remained unchanged throughout.\nThe record shows that in September of 2001, shortly after the Clifford defendants terminated their attorney-client relationship with Lopez but before the one-year statute of limitations would have expired, Lopez consulted with another attorney, Joseph Loran, about representing him and the estate in the wrongful death action. By a letter dated October 5, 2001, Loran declined to take the case. On March 22, 2002, a month after the one-year period of limitations expired, but almost a full year before a two-year period of limitations would have run, Lopez consulted yet another attorney regarding the wrongful death matter. That attorney informed Lopez that his previous attorney may have committed malpractice in letting the statute of limitations expire. The record indicates that Lopez did not consult any attorneys in the period between October 5, 2001, and March 22, 2002.\nIn their section 2 \u2014 619(a)(9) motion to dismiss, the Clifford defendants urged that the malpractice action against them could not stand because they terminated their attorney-client relationship with Lopez within the one-year limitations period when the wrongful death action was still viable and, furthermore, Loran\u2019s \u201cintervention\u201d within that one-year period extinguished any duty the Clifford defendants owed to Lopez. In support, among other things, the Clifford defendants attached Loran\u2019s October 5, 2001, letter to Lopez, wherein Loran stated, in pertinent part:\n\u201cI have come to the conclusion that I do not believe I can accept representation of your daughter\u2019s claim. Other attorney\u2019s [sic] may feel differently and I encourage you to contact other lawyers.\nPlease be advised that all lawsuits are limited by a period prescribed by statute. You need to have your daughter\u2019s case filed within the applicable limitations period. If you do not do so, you may lose whatever rights you have to recovery.\u201d\nOn February 17, 2004, Lopez filed an amended complaint, adding King as a respondent in discovery, and on March 10, 2004, Lopez filed a second amended complaint, adding Loran and Loran\u2019s firm as respondents in discovery.\nTo assist in formulating his response, Lopez moved to take a discovery deposition of Loran to determine whether an attorney-client relationship was ever undertaken by him. In the deposition, the transcript of which was attached as an exhibit to Lopez\u2019s response to the motion to dismiss, Loran testified that he had met with Lopez on one occasion in September of 2001. During that meeting, Loran was trying to obtain an understanding of the facts surrounding Elizabeth\u2019s death and did not discuss legal issues. At the end of the meeting, Loran told Lopez that he would contact Prindable in order to determine whether to undertake the representation of the Lopez family. After discussing the matter with Prindable, Loran decided not to take the Lopez case. According to Loran, he never entered into a retainer agreement with Lopez and did not ask for or obtain Elizabeth\u2019s medical records or a coroner\u2019s report. Nor did Loran open a file or assign a case number to the Lopez matter. After sending the October 5, 2001, letter, Loran had no further contact with Lopez.\nLoran\u2019s account was corroborated by Lopez\u2019s affidavit, which was also attached as an exhibit to the response to the motion to dismiss. In his affidavit, Lopez stated that Loran never said he would accept the matter and did not discuss the statute of limitations. Lopez additionally stated that had he known that the statute of limitations was one year, rather than two, he would have sought another attorney immediately after being turned down by Loran.\nConsequently, in his response to the Clifford defendants\u2019 motion to dismiss, Lopez argued that the motion should be denied because Loran was never retained as an attorney in the wrongful death matter and, therefore, had no duty to correct the Clifford defendants\u2019 incorrect advice. Lopez additionally asserted that Loran did not voluntarily undertake a duty to provide him legal advice and did not offer advice regarding the statute of limitations. Lopez therefore argued that Loran\u2019s actions did not break the causal chain between the Clifford defendants\u2019 negligence and the ultimate barring of the cause of action by the expiration of the statute of limitations. In the alternative, even if Loran could be regarded as a tortfeasor, Lopez argued that the Clifford defendants and Loran would be joint tortfeasors, which would preclude dismissal.\nThe circuit court, however, agreed with the Clifford defendants that the legal malpractice claim against them could not stand because the wrongful death action was still viable when the attorney-client relationship between them and Lopez came to an end. On April 12, 2004, the court granted the Clifford defendants\u2019 motion to dismiss.\nShortly thereafter, on April 20, 2004, Lopez moved for leave to amend his second amended complaint. Lopez sought to convert King from a respondent-in-discovery to a defendant. The circuit court granted that motion, and on May 4, 2004, Lopez filed his third amended complaint, which added a count against King, wherein Lopez alleged that King was the attorney who initially referred him to the Clifford firm and that King had \u201cagreed to assume the same legal responsibility for the performance of the legal services as the [Clifford firm].\u201d It appears from the record that although the circuit court allowed Lopez to file the third amended complaint, the court reaffirmed its earlier dismissal of the count against the Clifford defendants.\nOn April 27, 2004, while the motion to amend was pending, Lopez filed a motion to reconsider and vacate the circuit court\u2019s ruling granting the Clifford defendants\u2019 motion to dismiss. Lopez urged that the circuit court\u2019s ruling was problematic because it placed the burden of uncovering and remedying bad legal advice onto the client untrained in the practice of law.\nOn June 2, 2004, the circuit court denied Lopez\u2019s motion to reconsider and made a Supreme Court Rule 304(a) (134 Ill. 2d R. 304(a)) finding that there was no just reason for delay of enforcement or appeal of its decision dismissing the Clifford defendants with prejudice. On June 23, 2004, Lopez timely filed a notice of appeal as to the Clifford defendants.\nOn July 29, 2004, King moved, pursuant to section 2 \u2014 619(a)(9), to dismiss the count against him, asserting the same grounds as the Clifford defendants. On October 6, 2004, the circuit court granted King\u2019s motion, with prejudice. On October 19, 2004, Lopez timely filed a notice of appeal as to King. We granted Lopez\u2019s motion to consolidate the two appeals.\nANALYSIS\nOn appeal, Lopez admits that his relationship with the Clifford firm was terminated when there were still six months left on the limitations period and that he subsequently consulted with Loran, who declined to take his case on October 5, 2001. Lopez, however, contends that none of these facts are proper grounds for dismissal since he reasonably relied on the advice in Prindable\u2019s letter that the applicable statute of limitations was two years, and therefore Prindable\u2019s advice was the proximate cause of his and the estate\u2019s legal injuries. In response, the Clifford defendants argue that dismissal was proper for the following alternative reasons: (1) they withdrew when the action was still viable; (2) they should be absolved of liability because of Lopez\u2019s intervening consultation with Loran; and (3) Lopez did not reasonably rely on Prindable\u2019s statute of limitations advice.\nBecause this matter comes to us on a section 2 \u2014 619 dismissal, our review is de novo. Kedzie & 103rd Currency Exchange, Inc. v. Hodge, 156 Ill. 2d 112, 116, 619 N.E.2d 732, 735 (1993). A claim may be dismissed pursuant to section 2 \u2014 619(a)(9) if it \u201cis barred by other affirmative matter avoiding the legal effect of or defeating fitj.\u201d 735 ILCS 5/2 \u2014 619(a)(9) (West 2002). In ruling on a section 2 \u2014 619 motion to dismiss, the circuit court may consider external submissions of the parties, including depositions and affidavits. Zedella v. Gibson, 165 Ill. 2d 181, 185, 650 N.E.2d 1000, 1002 (1995). If a claim was thus dismissed,\n\u201c[tjhe question on appeal is \u2018whether the existence of a genuine issue of material fact should have precluded the dismissal or, absent such an issue of fact, whether dismissal is proper as a matter of law.\u2019 \u201d Zedella, 165 Ill. 2d at 185-86, quoting Hodge, 156 Ill. 2d at 116-17.\nUpon review, all well-pleaded facts, as well as reasonable inferences to be drawn from those facts, are taken as true. Keef v. Widuch, 321 Ill. App. 3d 571, 576, 747 N.E.2d 992, 997 (2001).\nIt is well established that the elements of a legal malpractice action in Illinois are: (1) the existence of an attorney-client relationship that establishes a duty on the part of the attorney; (2) a negligent act or omission constituting a breach of that duty; (3) proximate cause; and (4) damages. Paulsen v. Cochran, 356 Ill. App. 3d 354, 358, 826 N.E.2d 526, 530 (2005); Cedeno v. Gumbiner, 347 Ill. App. 3d 169, 174, 806 N.E.2d 1188, 1192 (2004); Mitchell v. Schain, Fursel & Burney, Ltd., 332 Ill. App. 3d 618, 620, 773 N.E.2d 1192, 1193-94 (2002); Goran v. Glieberman, 276 Ill. App. 3d 590, 593, 659 N.E.2d 56, 58 (1995); Majumdar v. Lurie, 274 Ill. App. 3d 267, 270, 653 N.E.2d 915, 918 (1995); Skorek v. Przybylo, 256 Ill. App. 3d 288, 290, 628 N.E.2d 738, 739-40 (1993). In a legal malpractice action, ordinary negligence principles apply. See Pelham v. Griesheimer, 92 Ill. 2d 13, 440 N.E.2d 96 (1982) (applying traditional negligence principles in a legal malpractice action); 7A C.J.S. Attorney & Client \u00a7 301, at 334 (2004) (a legal malpractice action is similar to any other negligence claim, and the standard of care inquiry is whether the lawyer failed to exercise reasonable care and skill in handling the client\u2019s matter \u2014 a classical tort negligence standard).\nIt is axiomatic, as one court aptly put it, that the duty of an attorney encompasses protecting a client \u201cfrom self-inflicted harm.\u201d Conklin v. Hannoch Weisman, 145 N.J. 395, 412, 678 A.2d 1060, 1068 (1996). The court in Conklin recognized that \u201c[mjalpractice in furnishing legal advice is a function of the specific situation and the known predilections of the client,\u201d and the standard of care \u201cmust be *** tailored to the needs and sophistication of the client.\u201d Conklin, 145 N.J. at 413, 678 A.2d at 1069. The jurisdictions which considered attorney liability for incorrect legal advice, albeit not in the context of withdrawal, generally look to whether the attorney was negligent in giving legal advice (elements of duty and breach) and whether the plaintiff relied to his detriment on the advice (elements of causation and damages). See Conklin, 145 N.J. at 420, 678 A.2d at 1072; Ramp v. St. Paul Fire & Marine Insurance Co., 263 La. 774, 269 So.2d 239 (1972); 7A C.J.S. Attorney & Client \u00a7 309, at 343 (2004).\nIn the instant case, the Clifford defendants gave Lopez incorrect legal advice with respect to how much time he had left to file the wrongful death action. It is prima facie negligent conduct for an attorney to misadvise a client on such a settled point of law that can be looked up by the means of ordinary research techniques. See 7A C.J.S. Attorney & Client \u00a7 308, at 342 (2004). In this context, we observe that such incorrect advice would undermine the client\u2019s sense of urgency to seek replacement counsel and is likely to have much more dire consequences than no advice at all. It seems to be a matter of common sense that a person who was not lulled into a false sense that he had another year and a half to file his action would aggressively seek replacement counsel soon after being discharged as a client.\nThe Clifford defendants, however, maintain, as they did below, that their alleged negligence would be of no consequence because Lopez\u2019s wrongful death action was still viable at the time of the withdrawal. In support of this \u201cviability\u201d theory, they rely on a number of cases, all of which upheld summary disposition of a legal malpractice action.\nThe Clifford defendants principally rely on Land v. Greenwood, 133 Ill. App. 3d 537, 478 N.E.2d 1203 (1985). In Land, the original attorney was discharged by the plaintiff some six months after filing the underlying action. At the time of the discharge, the original attorney had not yet served process on most of the defendants. By the time the successor attorney accomplished the service of process on all defendants, it had been a year since the action was filed. Upon the motions of the defendants, the circuit court dismissed the underlying action with prejudice, pursuant to Supreme Court Rule 103(b) (87 Ill. R. 103(b)), for lack of diligence in effecting the service of process. The circuit court\u2019s order, however, did not reference the original attorney\u2019s conduct. The plaintiff then brought a malpractice action against the original attorney. Land, 133 Ill. App. 3d at 538-40. In upholding the dismissal of the malpractice action, this court \u2014 while leaving the question of the original attorney\u2019s negligence (in putting the case at risk for dismissal) open-ended \u2014 nevertheless held that the original attorney could not be held liable. Land, 133 Ill. App. 3d at 540. This court focused on the fact that the successor attorney became involved in the case when it was still viable, i.e., when it was still possible to avert involuntary dismissal pursuant to a Rule 103(b) motion by taking a voluntary nonsuit and refiling the action within a year. Under such circumstances, this court continued, regardless of the possible negligence of the original attorney \u201c[the] successor counsel had the duty to preserve his client\u2019s cause of action. It was viable when he received it; it was not when he got through with it.\u201d Land, 133 Ill. App. 3d at 540.\nThe Clifford defendants additionally rely on two cases that followed Land and reached the same result \u2014 Mitchell and Cedeno. In Mitchell, the plaintiff\u2019s original attorney failed to prosecute the underlying action, resulting in a dismissal for want of prosecution (DWP). Some five months later, the plaintiff \u2014 who was unaware of the DWP \u2014 discharged the original attorney and retained another attorney to prosecute the matter. At that point, the action was still viable\u2014 pursuant to the Code of Civil Procedure (the Code), the successor attorney had almost two years within which to reinstate the action. The successor attorney, however, failed to do so within the period provided by the Code. The plaintiff eventually filed a malpractice action against both attorneys. Mitchell, 332 Ill. App. 3d at 619-22. This court affirmed the grant of summary judgment in favor of the original attorney, explaining:\n\u201cThere is no question that plaintiffs cause of action was viable, as a matter of law, well after defendants were discharged and successor counsel was retained. It therefore follows that defendants\u2019 alleged negligence did not cause plaintiffs damages, the loss of a viable cause of action.\u201d Mitchell, 332 Ill. App. 3d at 622.\nThis line of reasoning was also utilized in Cedeno. There, the plaintiff sought to commence a personal injury action against the Chicago Transit Authority (the CTA). The plaintiffs original attorney timely served the CTA with a statutorily required notice of a claim for personal injuries. The notice, however, incorrectly listed the date on which the plaintiffs injury occurred (it was off by one day). Some four months later, the plaintiff discharged the original attorney and retained a successor attorney to prosecute her personal injury action. Ultimately, the circuit court granted summary judgment in the personal injury action in favor of the CTA because the notice was defective. The plaintiff then sued the original attorney for malpractice. Cedeno, 347 Ill. App. 3d at 170-71. Upon review, this court found that, as a matter of law, the plaintiff\u2019s personal injury action remained actionable despite the defective initial notice and, therefore, the circuit court erred in granting summary judgment in favor of the CTA. Cedeno, 347 Ill. App. 3d at 176. Consequently, this court held that the original attorney\u2019s negligence was not the proximate cause of the plaintiffs legal injury:\n\u201c[D]efendants cannot be held accountable for the court\u2019s acceptance of a legally unsound basis for granting summary judgment against plaintiff. Where her claim remained actionable after defendants\u2019 discharge, and the circuit court\u2019s misapplication of the law served as an intervening cause, it cannot be said that plaintiffs damages proximately resulted from defendants\u2019 [negligent conduct].\u201d Cedeno, 347 Ill. App. 3d at 176, citing Mitchell, 332 Ill. App. 3d at 620, and Land, 133 Ill. App. 3d at 540.\nIn further support of their position, the Clifford defendants cite to McGee v. Danz, 261 Ill. App. 3d 232, 237, 633 N.E.2d 234, 237 (1994), and Harvey v. Mackay, 109 Ill. App. 3d 582, 587, 440 N.E.2d 1022, 1026 (1982). In McGee, the original attorney was discharged, and in Harvey the original attorney withdrew \u2014 when the underlying actions were still viable, i.e., before the running of the statute of limitations. The plaintiff in each case, however, alleged that the original attorney was negligent in failing to file the action before his withdrawal. McGee, 261 Ill. App. 3d at 233; Harvey, 109 Ill. App. 3d at 587. In McGee, this court affirmed summary adjudication of the matter in favor of the original attorney, stating:\n\u201cBecause no genuine issue of fact exists that plaintiff discharged defendant prior to the running of the four-year statute of limitations ***, as a matter of law defendant cannot be liable for legal malpractice for failing to file a claim *** prior to December 23, 1989, the date the statute of limitations expired in this case.\u201d McGee, 261 Ill. App. 3d at 237.\nThe same result was reached in Harvey:\n\u201c[C]ount I alleges defendant failed to file the lawsuit against Harris Bank within the appropriate statute of limitations. *** It is apparent that plaintiff had over one year to pursue any potential actions against Harris Bank after defendant withdrew as her attorney. We find that count I was properly dismissed.\u201d Harvey, 109 Ill. App. 3d at 587.\nWe observe that the cases relied upon by the Clifford defendants are not predicated upon a \u201cviability\u201d doctrine that would operate independently of the general negligence principles, but, in fact, are consistent with those principles. These cases fall into two categories. In the first category, Land, Mitchell and Cedeno involved situations where the original attorney presumably breached his duty to the plaintiff by either performing an act with respect to the case incorrectly or by not performing it at all under the circumstances where the law imposed an affirmative duty to perform it. However, the original attorney avoided liability because it was held that his negligence did not proximately cause the plaintiffs loss, as a matter of law. More specifically, Land and Mitchell postulated that the involvement of a successor attorney at the point where harm to the client\u2019s cause of action could still be averted extinguished a malpractice action against the original negligent attorney.\nIn the second category, McGee and Harvey, while distinguishable from the instant case, also applied ordinary negligence principles, but involved considerations different from those in Land, Mitchell and Ce-deno. In McGee and Harvey it was held that the original attorney did not breach his duty of care in failing to file the plaintiff\u2019s action because reasonable time remained to allow the plaintiff to find a replacement attorney who would file the case. In other words, the law did not impose a duty on the original attorney to file the plaintiffs action under such circumstances. More importantly, it was never alleged in McGee and Harvey that the original attorney gave incorrect advice to the client, especially of the kind that would underplay the urgency of promptly obtaining replacement counsel. Here, on the other hand, although the Clifford defendants were not remiss in failing to file Lopez\u2019s wrongful death action, they did impart incorrect legal advice to their client which may very well have contributed to his failure to timely retain successor counsel. Under the established negligence principles discussed earlier in this opinion, it is of no import that the breach of duty occurred in communicating with the client rather than with respect to the case itself. However, the line of reasoning employed in Land, Mitchell and Cedeno invokes the concept of superceding cause which breaks the chain of causation, so that a negligent actor is excused from liability. Accordingly, we must examine whether a superceding cause operated here, so as to cut off the liability of the Clifford defendants.\nSuperceding cause and proximate cause are interrelated concepts. With regard to proximate cause, we ordinarily ask:\n\u201cWas the defendant\u2019s negligence a material and substantial element in bringing about the injury, and, if so, was the injury of the type that a reasonable person would see as a likely result of his or her conduct?\u201d First Springfield Bank & Trust v. Galman, 188 Ill. 2d 252, 258-59, 720 N.E.2d 1068, 1072 (1999).\nWhere there are successive negligent actors, however, the negligence of the second actor, under certain circumstances, may be deemed a superceding cause \u2014 relieving the original negligent actor of liability, as a matter of law. It would seem that the rule adhered to in Land and Mitchell is consistent with subsection (2) of section 452 of the Restatement (Second) of Torts (hereinafter the Restatement), which provides, under certain circumstances, for the shifting of a duty of care from one negligent actor to another, with the corresponding shifting of liability, rather than holding both negligent actors jointly liable. Section 452, in its entirety, states:\n\u201c(1) Except as stated in Subsection (2), the failure of a third person to act to prevent harm to another threatened by the actor\u2019s negligent conduct is not a superseding cause of such harm.\n(2) Where, because of lapse of time or otherwise, the duty to prevent harm to another threatened by the actor\u2019s negligent conduct is found to have shifted from the actor to a third person, the failure of the third person to prevent such harm is a superseding cause.\u201d Restatement (Second) of Torts \u00a7 452 (1965).\nComment d to section 452 explains:\n\u201cSubsection (2) covers the exceptional cases in which, because the duty, and hence the entire responsibility for the situation, has been shifted to a third person, the original actor is relieved of liability for the result which follows from the operation of his own negligence. The shifted responsibility means in effect that the duty, or obligation, of the original actor in the matter has terminated, and has been replaced by that of the third person.\u201d Restatement (Second) of Torts \u00a7 452, Comment d (1965).\nComment a to section 452 further clarifies:\n\u201cThe situation covered *** is that in which, after the original actor has been negligent and so has created an unreasonable risk of harm to another, a third person has the opportunity, by taking affirmative action, to avert the threatened harm. This implies that if such action were taken, it would prevent the negligence of the original actor from causing the harm which has in fact resulted.\u201d Restatement (Second) of Torts \u00a7 452, Comment a (1965).\nIn this regard, it is important to note that section 452(2) presupposes that its operation is not precluded by policy considerations or other rules of law. See Restatement (Second) of Torts \u00a7 452, Comment e (1965) (the liability-shifting rule rests on an underlying assumption that there is no other rule of law and no reason of policy to prevent its applicability).\nAs discussed, our Illinois cases, Land and Mitchell, appear to have taken the position consistent with section 452(2) of the Restatement that when the duty of care shifts from the original attorney to the successor, so does the liability, provided that the successor had the opportunity to undo or avert the harm precipitated by the actions or omissions of the original attorney. We note that such liability-shifting approach has been challenged by the majority opinion in the California case of Cline v. Watkins, 66 Cal. App. 3d 174, 135 Cal. Rptr. 838 (1977). The court in Cline framed its inquiry as follows:\n\u201cIs the substitution of another lawyer for one whose prior representation of the client in the matter has been negligent such an exceptional circumstance that all duty and responsibility for the prevention of harm normally flowing from the negligence passes to substituted counsel?\u201d Cline, 66 Cal. App. 3d at 179, 135 Cal. Rptr. at 841.\nIn reliance on Comments a through e to section 452, the court concluded that the applicability of the liability-shifting provision of section 452 to the area of attorney malpractice turned on the issue of public policy. See Cline, 66 Cal. App. 3d at 179, 135 Cal. Rptr. at 841. The court determined that the public policy in California favored joint liability, expressing that attorneys should not be entitled to special relief from liability that is not afforded to other professions, such as physicians:\n\u201cAs a negligent physician is not relieved of the consequences of his lack of care because a subsequently treating physician could have avoided the injury had he not also been negligent [citation], so also should a negligent lawyer not be relieved because he is replaced by another. True enough, the new lawyer assumes full responsibility for the matter and has exclusive control over it; but so also does the new physician assume full responsibility and have full control.\u201d Cline, 66 Cal. App. 3d at 180, 135 Cal. Rptr. at 841-42.\nHowever, we need not reexamine the rationale underlying the holdings in Land and Mitchell in light of Cline so as to redetermine whether the retention of a successor counsel should constitute a superceding cause, absolving the original counsel of liability, since in this case no successor counsel was retained before the statute of limitations actually ran. While the Clifford defendants look to Lopez\u2019s interim consultation with another attorney, Loran, that fact is of no avail because Loran did not undertake any representation in the Lopez wrongful death matter. The cases relied upon by the Clifford defendants do not suggest that an attorney who declines to accept a case after a preliminary exploratory meeting with a prospective client assumes responsibility and corresponding liability for the preceding attorney\u2019s mistakes. The Clifford defendants assert that \u201c[a]t minimum, Loran, by declining the case after consultation, was responsible for advising Lopez as to the exact amount of time remaining on the limitations period.\u201d We disagree with this proposition. We do not find any Illinois authority which would impose that burden upon an attorney on the strength of an exploratory meeting which did not result in an acceptance of the case. Nor can such cursory involvement suffice to be characterized as a superceding cause so as to relieve the original attorney of liability for his mistakes and shift it to the shoulders of the second attorney. Finally, we note that Loran\u2019s generic advice to Lopez that \u201call lawsuits are limited by a period prescribed by statute\u201d was not inconsistent with Prindable\u2019s and could not have put Lopez on notice that a shorter period of limitations governed the wrongful death action \u2014 thereby breaking the chain of causation.\nIn sum, unlike the plaintiffs in Land, Mitchell and Cline, Lopez did not retain a successor counsel until after the expiration of the statute of limitations, i.e., when the successor counsel could not have cured the problem created by the incorrect advice. This outcome, as discussed below, may well be attributable to Lopez\u2019s reliance on Prindable\u2019s very advice.\nFor the foregoing reasons, since no superceding cause operated so as to defeat the Clifford defendants\u2019 liability as a matter of law, proximate cause in the instant case should be decided, not as a matter of law, but by a trier of fact. See Abrams v. City of Chicago, 211 Ill. 2d 251, 257, 811 N.E.2d 670, 674 (2004) (the treatment of proximate cause as a question of law is an exception to the general rule that proximate cause is a fact-laden issue and should be decided by a trier of fact); accord Public Taxi Service, Inc. v. Barrett, 44 Ill. App. 3d 452, 456, 357 N.E.2d 1232, 1236 (1976). The pertinent inquiry, as discussed, is whether the Clifford defendants\u2019 negligence was a material and substantial element in bringing about Lopez\u2019s and the estate\u2019s legal injuries (\u201ccause in fact\u201d component), and, if so, whether the injuries were of the type that a reasonable attorney would see as a likely result of his or her conduct (\u201clegal cause\u201d component). See Galman, 188 Ill. 2d at 258-59.\nThe Clifford defendants argue that, intervening superceding cause aside, the complaint and external submissions fail to allege cause in fact because they \u201cindisputably\u201d establish that Lopez in no way relied on Prindable\u2019s advice. Additionally, the Clifford defendants argue that Prindable\u2019s contemporaneous advice to Lopez to \u201ccontact an attorney of your choice immediately ***. Do not delay\u201d was an antidote to the incorrect statute of limitations advice. It would seem that this latter argument goes to the reliance not being reasonable, as a matter of law. We disagree with both arguments. In his complaint, Lopez, as noted, alleged that he reasonably relied on the Clifford defendants\u2019 advice. In addition, in his affidavit, Lopez stated:\n\u201cIf I had known the statute of limitations in my daughter\u2019s case was one year, I would have obtained an attorney immediately after seeing Loran.\u201d\nAs discussed, Lopez\u2019s reliance on Prindable\u2019s parting advice was not unreasonable, as a matter of law. Whether Prindable\u2019s advice, in its totality, gave Lopez an impression that he had 18 months, as opposed to 6, to retain another attorney and file the wrongful death action is for the trier of fact. It would certainly not be unreasonable to conclude that although Lopez consulted with Loran within weeks of being dropped as a client by the Clifford firm, Prindable\u2019s advice caused Lopez to delay making an appointment with another counsel after being turned down by Loran. Moreover, it is not unreasonable to conclude that this outcome was foreseeable to the Clifford defendants\u2014 thus satisfying the legal cause component of proximate cause. The complaint, together with the affidavit supporting its allegations, is sufficient to create questions of fact as to these issues. See Pothier v. Chicago Transit Authority, 238 Ill. App. 3d 702, 710, 606 N.E.2d 531, 537 (1992) (the plaintiffs uncontradicted affidavit filed in response to a section 2 \u2014 619 motion to dismiss \u2014 stating that she relied to her detriment on the defendant\u2019s representations \u2014 created a genuine issue of fact, defeating the motion to dismiss); Searcy v. Chicago Transit Authority, 146 Ill. App. 3d 779, 784, 497 N.E.2d 410, 413 (1986) (In light of the statements in the plaintiffs affidavit, \u201cit is at least arguable that the conduct and representations [of the defendant\u2019s agent] in this case lulled plaintiff into a false sense of security ***. *** Plaintiff reasonably may have relied upon [the agent\u2019s] conduct and representations to her detriment. Under these circumstances, it was improper for the court to dispose of the issue *** as a matter of law\u201d).\nAccordingly, because questions of fact exist as to causation, the dismissal of the Clifford defendants was improper. Consequently, the dismissal of King was improper as well since Lopez alleged that King had \u201cagreed to assume the same legal responsibility for the performance of the legal services as the [Clifford firm].\u201d On appeal, King does not dispute having assumed that responsibility and, instead, argues that he may not be held liable if the Clifford defendants are not liable. Our disposition of this matter with regard to the Clifford defendants precludes upholding King\u2019s dismissal.\nFor the reasons set forth above, we reverse the judgment of the circuit court and remand for further proceedings consistent with this opinion.\nReversed and remanded.\nCAHILL, P.J., and BURKE, J., concur.\nThe record shows that Lopez signed a representation agreement with the Clifford firm on March 8, 2001. The agreement was attached as an exhibit to Lopez\u2019s response to the Clifford defendants\u2019 motion to dismiss.\nFiled on November 13, 2003.\nKing raises substantially the same contentions on appeal as the Clifford defendants.\nUnder the prevailing law at the time, prior to the supreme court\u2019s decision in O\u2019Connell v. St. Francis Hospital, 112 Ill. 2d 273 (1986), it was possible to rescue an action by such means.\nThe plaintiff failed to follow through on her appeal in the underlying personal injury action.\nAccord Garrett v. Lawyers Inc., 273 Ill. App. 3d 545, 550, 653 N.E.2d 48, 51 (1995) (the original attorney is not liable for not filing the action before the expiration of the statute of limitations where \u201cdefendants\u2019 and plaintiffs\u2019 attorney/client relationship ended sometime before April 1, 1991. The claim was not time barred until August 17, 1991\u201d).\nIn the event the Clifford defendants meant that Lopez was contributorily negligent, the question of Lopez\u2019s contributory negligence is still for the trier of fact. See McCarthy v. Kunicki, 355 Ill. App. 3d 957, 972, 823 N.E.2d 1088, 1101 (2005) (\u201c[ojrdinarily, it is the jury\u2019s responsibility to consider whether plaintiffs actions amounted to contributory negligence\u201d).", "type": "majority", "author": "JUSTICE GORDON" } ], "attorneys": [ "Costello, McMahon & Burke, Ltd., of Chicago (James P. Costello and James L. Wideikis, of counsel), for appellant.", "Konicek & Dillon, P.C., of Geneva (Daniel F. Konicek, of counsel), for appellee William King.", "Johnson & Bell, Ltd., of Chicago (Joseph R. Marconi, David M. Macksey, and Garrett Boehm, Jr., of counsel), for other appellees." ], "corrections": "", "head_matter": "JOSE LOPEZ, Indiv. and as Special Adm\u2019r of the Estate of Elizabeth Lopez, Deceased, Plaintiff-Appellant, v. CLIFFORD LAW OFFICES, P.C., et al., Defendants-Appellees (Joe Loran et al., Respondents-in-Discovery).\nFirst District (1st Division)\nNos. 1\u201404\u20141805, 1\u201404\u20143220 cons.\nOpinion filed December 12, 2005.\nCostello, McMahon & Burke, Ltd., of Chicago (James P. Costello and James L. Wideikis, of counsel), for appellant.\nKonicek & Dillon, P.C., of Geneva (Daniel F. Konicek, of counsel), for appellee William King.\nJohnson & Bell, Ltd., of Chicago (Joseph R. Marconi, David M. Macksey, and Garrett Boehm, Jr., of counsel), for other appellees." }, "file_name": "0969-01", "first_page_order": 987, "last_page_order": 1001 }