The Circuit Court of Cook County entered an order extinguishing the workers’ compensation lien rights of an employer and the employer’s carrier pursuant to Borrowman v. Praestein. 356 Ill. App. 3d 546 (4th Dist 2005). Gary Jansen filed a motion requesting the trial court reconsider the order based upon Gallagher v. Lenart, 226 Ill. 208 (Ill. 2007). The trial court denied the motion to reconsider. The First District Appellate Court reversed the trial court’s order. The Appellate Court held that the trial court erred in extinguishing the workers’ compensation lien rights of the employer and its carrier. Raul Sanchez v. Rental Service Corporation, 02 L 5613.