Under these circumstances, whether the owner is an individual or an LLC is essentially immaterial to Defendant ex ante. It effects neither Defendant's exposure to risk, nor the price of the policy. Pl SOF ¶¶ 48-49; compare Lighting Fixture and Electric Supply Co., Inc. v. Continental Ins. Co., 420 F.2d 1211, 1214 (5th Cir. 1969) (proper formal identity of the owner is of no particular concern to the insurer); and Court Tobacco Stores, Inc. v. Great Eastern Ins. Co., 43 A.D.2d 561, 561-62 (N.Y.App. 1973) (where the nature of ownership is innocently misdescribed, the error is mutual for purposes of reformation even if the insurer is not aware of the error; the name of the insured is not always important if the intent to cover the risk is clear); with Schwartz v. Great Cent. Ins. Co., 188 Ill.App.3d 264, 272 (5th Dist. 1989) (where the alleged mistake regarding the identity of the insured did materially impact the scope of coverage, the mutuality of the mistake was called into question). The point here is that Defendant entered into an agreement to insure the owner of a piece of property, and the agreement mistakenly did not name the proper owner.

Further, an attorney may verify a complaint if she possesses personal knowledge of the relevant facts, but is not required to do so. Gonzales v. Lawent, 2004 WL 2036409 at *2; Schwartz v. Great Central Insurance Co., 188 Ill.App.3d 264, 269 (5th Dist. 1989). The court must also pause to note the irony of Calek's certification argument.

In refusing to dismiss this claim, the court noted that under Illinois law an attorney "may verify a complaint if the attorney possesses personal knowledge of the relevant facts." Id. at *1 (citing Schwartz v. Great Cent. Ins. Co., 188 Ill. App.3d 264, 268-69, 544 N.E.2d 131, 133 (1989)). However, the attorney's alleged "personal knowledge" of the debt in Young consisted of only a review of a computer print-out allegedly showing the debt Id. The court noted that this print-out could not prove the debt at trial and, therefore, could not provide the basis for the attorney's verification based on personal knowledge.

Schwartz v. Great Central Insurance Co., 188 Ill.App.3d 264, 268 (1989).

Schwartz v. Great Central Insurance Co., 188 Ill.App.3d 264, 268 (1989).

¶ 42 II. ANALYSIS ¶ 43 A court of review is entitled to have briefs submitted that are articulate, organized, and present cohesive legal argument in conformity with our supreme court rules. Schwartz v. Great Central Insurance Co., 188 Ill.App.3d 264, 268 (1989). A reviewing court is also entitled to have issues clearly defined with pertinent authority cited and coherent arguments presented; arguments inadequately presented on appeal are forfeited.

A reviewing court is entitled to have all the issues clearly defined, and be provided with meaningful, coherent argument and citation to pertinent authority. See Schwartz v. Great Central Insurance Co., 188 Ill.App.3d 264, 268 (1989). As such, petitioner has failed to articulate any legal argument which would allow a meaningful review of this alleged error.

There is no need for this court to address the redundant objections. The remaining objections are random, vague or disconnected suppositions that either miss or pretend to miss the point of the court's sanction order, ignore governing case law on the issue, recite basic law that is irrelevant here, deliberately or carelessly misinterpret caselaw and display a fundamental lack of understanding of why the trial court entered sanctions against appellants. ¶ 87 For example, where Kim moved for fee and cost reimbursement under both the Citizen Participation Act and Rule 137, appellants challenge his sanction award because he "was not entitled to fees under the Citizen Participation Act," even though the order clearly indicated that the sole basis for the sanction award was Rule 137. ¶ 88 A court of review is entitled to have briefs submitted that are articulate, organized and present cohesive legal argument in conformity with our supreme court rules. Schwartz v. Great Central Insurance Co., 188 Ill. App. 3d 264, 268 (1989). A reviewing court is also entitled to have issues clearly defined with pertinent authority cited and coherent arguments presented; arguments inadequately presented on appeal are waived.

" Plaintiff filed pro se a notice of appeal that same day. ¶ 7 Initially, we observe that our review of this appeal is hindered by plaintiff's failure to fully comply with Supreme Court Rule 341(h) (eff. May 25, 2018). It is well established that "a court of review is entitled to have briefs submitted that are articulate, organized and present a cohesive legal argument in conformity with supreme court rules." Schwartz v. Great CentralInsurance Co., 188 Ill. App. 3d 264, 268 (1989) (citing In re Application of Anderson, 162 Ill. App. 3d 815, 819 (1987)). Plaintiff's pro se status does not excuse her from complying with the appellate procedures required by our supreme court rules.

¶ 8 Initially, we observe that our review of this appeal is hampered by plaintiff's failure to comply with Supreme Court Rule 341(h) (eff. Nov. 1, 2017). It is well established that a court of review is entitled to briefs that conform to supreme court rules. Schwartz v. Great Central Insurance Co., 188 Ill. App. 3d 264, 268 (1989). Plaintiff's pro se status does not excuse her from complying with supreme court rules governing appellate procedure (Coleman v. Akpakpan, 402 Ill. App. 3d 822, 825 (2010)), and she is expected to meet a minimum standard before this court can adequately review her appeal (Rock Island County v. Boalbey, 242 Ill. App. 3d 461, 462 (1993)).