Short v. Pye  ·  2018-07-31  ·  Appellate Court of Illinois  ·  pin 757 N.E.2d at 875

"[M]otions for sanctions under our Rule 137 are 'claims' in the cause of action with which they are connected" and "filing a Rule 137 motion is the functional equivalent of adding an additional count to a complaint, or counterclaim, depending on which party files the motion."