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Illinois Compiled Statutes

735 ILCS 5/2-606 (2026)

Exhibits

✓ current as of May 2026
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(735 ILCS 5/2-606) (from Ch. 110, par. 2-606)
    Sec. 2-606. Exhibits. If a claim or defense is founded upon a written instrument, a copy thereof, or of so much of the same as is relevant, must be attached to the pleading as an exhibit or recited therein, unless the pleader attaches to his or her pleading an affidavit stating facts showing that the instrument is not accessible to him or her. In pleading any written instrument a copy thereof may be attached to the pleading as an exhibit. In either case the exhibit constitutes a part of the pleading for all purposes.
(Source: P.A. 82-280.)

    
Notes of Decisions
Cited in 94 cases (24 in the last 5 years), 1996–2026 · leading case: Law Offices of Colleen M. McLaughlin v. First Star Fin. Corp., 2011 IL App (1st) 101849 (Ill. App. Ct. 2011).
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Law Offices of Colleen M. McLaughlin v. First Star Fin. Corp., 2011 IL App (1st) 101849 (Ill. App. Ct. 2011). · cites it 5× “of the plain language of the settlement agreement attached to the complaint reveals the plaintiff was a party to the settlement agreement and, therefore, had standing to maintain the action; (2) admission of the copy of the settlement agreement into evidence was proper under our…”
Law Offices of Colleen M. v. First Star, 963 N.E.2d 968 (Ill. App. Ct. 2011). · cites it 5× “of the plain language of the settlement agreement attached to the complaint reveals the plaintiff was a party to the settlement agreement and, therefore, had standing to maintain the action; (2) admission of the copy of the settlement agreement into evidence was proper under our…”
Razor Capital v. Antaal, 2012 IL App (2d) 110904 (Ill. App. Ct. 2012). · cites it 2× “1 (West 2010)), defendant filed a combined motion to dismiss the complaint, based on standing and plaintiff’s failure to attach to the complaint a written agreement as required by section 2-606 of the Code (735 ILCS 5/2-606 (West 2010)).1 At a March 8, 2011, hearing on…”
Godfrey Healthcare & Rehab. Ctr., LLC v. Toigo, 2019 IL App (5th) 170473 (Ill. App. Ct. 2019). · cites it 2× “Without such documentation, as required by section 2-606 of the Code (735 ILCS 5/2-606 (West 2014)), defendant claimed that plaintiff had no standing to bring the litigation.”
Asset Acceptance, LLC v. Tyler, 966 N.E.2d 1039 (Ill. App. Ct. 2012). · cites it 2× “Asset alleged the "Defendant incurred charges by the use of the credit card," but failed to state the date of the last charge on the credit card. While Asset alleged that "[o]n or about January 15, 2007, the plaintiff (Asset) filed a Demand for arbitration with the National…”
Empire Indem. Ins. Co. v. The Chicago Province of the Soc'y of Jesus, 2013 IL App (1st) 112346 (Ill. App. Ct. 2013). · cites it 2× “In response, Pennsylvania General argued: (i) section 2-606 of the Illinois Code of Civil Procedure (735 ILCS 5/2-606 (West 2010)) only required it to attach the relevant portions of the policies and not complete copies of them; and (ii) it was up to the Jesuits to either…”
Wesly v. Nat'l Hemophilia Found., 2020 IL App (3d) 170569 (Ill. App. Ct. 2020). “Although the two e-mails at issue are incorporated into the complaint and form a part of plaintiff’s allegations of fact (see 735 ILCS 5/2-606 (West 2016) (“the exhibit constitutes a part of the pleading for all purposes”)), although their plain language appears to flatly…”
Ferris, Thompson & Zweig, Ltd. v. Esposito, 2017 IL 121297 (Ill. 2017). “1 Attached to the complaint were copies of each of the retainer agreements signed by the various clients along with letters drafted by defendant and initialed by a representative of the plaintiff law firm confirming the terms of their respective obligations under each of the…”
Weatherman v. Gary-Wheaton Bank of Fox Valley, N.A., 713 N.E.2d 543 (Ill. 1999). “Only those facts apparent from the face of the pleadings, including exhibits attached to the pleadings (735 ILCS 5/2-606 (West 1992)), and matters of which the court can take judicial notice, and judicial admissions in the record, may be considered.”
Pepper Constr. Co. v. Palmolive Tower Condos., LLC, 2021 IL App (1st) 200753 (Ill. App. Ct. 2021). “See 735 ILCS 5/2-606 (West 2018); Capital One Bank, N.”
Armagan v. Pesha, 2014 IL App (1st) 121840 (Ill. App. Ct. 2014). · cites it 2× “First, that plaintiff’s claims were based on a written instrument not attached to the complaint, which required its dismissal pursuant to section 2-606 of the Code (735 ILCS 5/2-606 (West 2010)). Second, that the nature of plaintiff’s alleged agreement with defendants was not…”
Arnold v. Janssen Pharmaceutica, Inc., 215 F. Supp. 2d 951 (N.D. Ill. 2002). “9 (outlining special pleading rules, none of which requires quoting contractual language or attaching documentation), with 735 ILCS 5/2-606 (requiring attachment or recitation of written instrument if that document, is the foundation of a claim).”
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