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PRESIDING JUSTICE COOK delivered the opinion of thecourt:

In February 1998, plaintiffs, Marilyn Williams (Williams) and Herman Williams, filed a medical malpractice complaintagainst Covenant Medical Center (Covenant), alleging that Covenant was negligent in allowing Williams to leave her bed and fallwhile she was a patient at Covenant. In November 1999, the trialcourt granted Covenant's September 1999 motion for summaryjudgment. Plaintiffs appeal, arguing that the trial court erred(1) in granting summary judgment on a basis not sufficientlyraised in Covenant's motion for summary judgment, (2) in denyingtheir motion to strike Covenant's motion for summary judgment andprematurely granting Covenant's motion for summary judgment, and (3) in denying their oral motion for a continuance to obtain anaffidavit from their expert. We reverse and remand.

In February 1996, Williams was admitted to Covenantwith chronic obstructive pulmonary disease. During the eveningof February 23 or the early morning hours of February 24, sheapparently fell after leaving her bed to use the bathroom. Shesuffered a compression fracture of her L1 lumbar vertebra.

In February 1998, plaintiffs filed a complaint againstCovenant, alleging that Covenant was negligent in allowingWilliams to leave her bed and fall, causing her pain and suffering, medical expenses, and disability.

In January 1999, Covenant deposed Williams. She couldnot recall the fall or even remember being hospitalized, possiblybecause she was heavily medicated during her hospital stay. Covenant also took discovery depositions of Williams' husband andher three daughters. On February 26, 1999, plaintiffs wrote aletter to Covenant's attorney, requesting the depositions of fivenurses, two nurse's aides, and Vicky Garretson, Covenant's risk-management coordinator. In March 1999, Covenant filed a motionfor summary judgment based on Williams' inability to rememberthat she fell, to describe how she fell, or to identify anywitnesses of her fall. Covenant did not attach any affidavitsfrom experts regarding the standard of care, breach of thestandard of care, or proximate causation. Plaintiffs then fileda motion to compel Covenant to produce eight potential occurrencewitnesses for deposition, alleging that Covenant refused toproduce its employees until after a hearing on its motion forsummary judgment. In April 1999, Covenant allowed plaintiffs todepose Garretson and four of its nurses.

Plaintiffs moved to revise the discovery schedule onApril 1, 1999, the initial deadline for plaintiffs to discloseexpert witnesses. In May 1999, the trial court extended thedeadline "until a date 30 days after the depositions of Covenantpersonnel requested by plaintiff[s] in a letter to defenseattorney dated February 26, 1999[,] are taken," and it allowedplaintiffs until June 15, 1999, to respond to Covenant's motionfor summary judgment. On June 14, 1999, plaintiffs moved tocontinue the deadline for their response to summary judgmentbecause Covenant failed to produce three of the eight employeesfor deposition. The trial court again granted the motion andstated in a docket entry, "The parties should notify the courtwhen discovery relating to the motion for summary judgment iscompleted and said motion is ready for consideration." A September 17, 1999, docket entry states, "Counsel have agreed to abriefing schedule which concludes [October 14, 1999]." Also onthat day, Covenant filed a motion for summary judgment that wassubstantially identical to the one that Covenant filed in March1999.

On October 8, 1999, plaintiffs filed a response toCovenant's summary judgment motion. They attached depositions ofJane Brais, Williams' daughter; Garretson; Leslie Windler, R.N.;Twyla Ingram, R.N.; and Dr. Maury Topolosky, Williams' treatingphysician. They also appended an excerpt from Covenant's policyand procedure manual regarding its "fall prevention program" aswell as a consultation report dated February 26, 1999, preparedby Dr. Ruth Craddock.

Brais stated that Garretson admitted to her thatWilliams fell. Windler's "falls assessment" report first indicated a history of falls on February 24. Ingram was on duty thenight that Williams fell, and she made the following late chartentries on February 28 based upon her observations from the earlymorning of February 24:

"[00:15 a.m.] [patient] denies questions [or]concerns. *** [02:35 a.m.] [patient] hassustained no injury. [4:00 a.m.] Tylenol #3[orally] given for back pain. *** [approximately 5:00 a.m.] I was informed [that patient disconnected] foley [catheter]. Foundfoley [catheter at] bed side with [balloon]inflated. [Patient] was in [b]athroom sitting on stool. *** [Patient] escorted to bed***. *** States she needed to go to thebathroom."

Ingram explained in her deposition that the check marks for"rails" on Williams' chart indicate that the upper two bed railswere up. Those two rails are almost always raised for allpatients to remind them that they can call a nurse for assistance. According to Ingram, only patients who are disoriented,psychotic, or have multiple tubes and intravenous needles wouldneed to have all four bed rails up to prevent them from gettingout of bed.

Dr. Topolosky stated in his deposition that Williamsinformed him that she had fallen. On the morning of February 24,Williams fit six criteria on Covenant's "falls assessment" formthat put her at a risk of falling: she was over 60 years old;had an unsteady gait; had multiple diagnoses; and had medicationswith sedative, hypotensive, and diuretic effects. According tothe form, a patient whose condition fits at least three criteriashould be considered for safety intervention under Covenant's"fall prevention program." According to that program, keepingall four bed rails raised is one of the recommended safetyprecautions.

Dr. Craddock's consultation report stated, in pertinentpart:

"Two to three evenings ago, [Williams]was trying to get out of bed to use the bathroom and she fell out of bed, noting that heroxygen cord was wrapped around her leg andmaking it difficult for her to maneuver easily. She landed on her right side. She didnot note immediate pain and called for thenurse. The nurse helped her up and did gether [onto] the commode, which she used. Shewas then put back in bed and noted progressive pain in the low back and right side ofthe lower back region as the night wore on."

In October 1999, Covenant filed a rebuttal to plaintiffs' response to its summary judgment motion. For the firsttime, Covenant explicitly asserted that plaintiffs had no experttestimony to establish the standard of care and breach of thestandard of care. In November 1999, plaintiffs filed a motion tostrike Covenant's September 1999 motion for summary judgment asuntimely because it attempted to circumvent expert discovery.

At a hearing in November 1999, the trial court deniedplaintiffs' motion to strike because it found that the September1999 motion for summary judgment was timely. Then, plaintiffsorally moved for a continuance to obtain an affidavit of anexpert to respond to Covenant's summary judgment motion. Plaintiffs also disclosed to the court that Dr. George Schoedinger wastheir retained expert and that Dr. Schoedinger had prepared thehealth professional's report that plaintiffs attached to theircomplaint. The trial court denied the motion for a continuanceand proceeded to a hearing on Covenant's motion for summaryjudgment.

The trial court granted Covenant's motion for summaryjudgment because plaintiffs failed to demonstrate that thestandard of care required Covenant's nurses to keep all fourrails raised on Williams' bed. Thus, the court found that nogenuine issue of material fact existed regarding whether anynegligence by Covenant, its agents, or its employees proximatelycaused Williams' injuries.

In December 1999, plaintiffs filed motions to reconsider, attaching an affidavit from Dr. Schoedinger. His expertopinion, based upon a reasonable degree of medical certainty, wasthat the nursing standard of care required that all four rails beraised on Williams' bed because she had conditions causing her tobe at an increased risk to fall and that Covenant's nursing staffdeviated from that standard of care by failing to raise all fourrails on Williams' bed, resulting in Williams being able to leaveher bed and fall to the floor and causing a compression fractureof her L1 lumbar vertebra. The trial court refused to considerDr. Schoedinger's affidavit because plaintiffs had or should havehad it available prior to the grant of summary judgment. Thus,the trial court denied plaintiffs' motions for reconsideration,and plaintiffs appealed.

Summary judgment is appropriate when the pleadings,depositions, and admissions, together with any affidavits, showthat there is no genuine issue of material fact and that themovant is entitled to judgment as a matter of law. 735 ILCS5/2-1005(c) (West 1998). When ruling on a motion for summaryjudgment, a trial court must view all evidence in a light mostfavorable to the nonmovant. Rotzoll v. Overhead Door Corp., 289Ill. App. 3d 410, 413, 681 N.E.2d 156, 158 (1997). We review denovo grants of summary judgment. Rotzoll, 289 Ill. App. 3d at413, 681 N.E.2d at 158.

Plaintiffs contend that the trial court erred ingranting Covenant summary judgment on the issues of the standardof care and breach of the standard of care because Covenant didnot raise those issues in its motion for summary judgment. Plaintiffs assert that defendants who move for summary judgmenthave a burden similar to those moving to dismiss the pleadings tospecifically identify deficiencies in the plaintiffs' case.

Section 2-615(a) of the Code of Civil Procedure (Code)(735 ILCS 5/2-615(a) (West 1998)) provides that a motion withrespect to pleadings "shall point out specifically the defectscomplained of." Also, section 2-615(b) of the Code (735 ILCS5/2-615(b) (West 1998)) provides that a motion to dismiss apleading that is substantially insufficient in law "must specifywherein the pleading or division thereof is insufficient." However, section 2-1005(b) of the Code (735 ILCS 5/2-1005(b)(West 1998)) enables a defendant to "move with or without supporting affidavits for a summary judgment in his or her favor asto all or any part of the relief sought against him or her." Nolanguage in section 2-1005(b) requires the same level of specificity needed in a motion to dismiss under section 2-615(b).

We reject plaintiffs' suggestion that Covenant's motionfor summary judgment was too vague for them to adequately respondto it. Covenant's motion for summary judgment was not restrictedin scope to the issue of whether Williams fell. However, we findthat it insufficiently raised the issues of plaintiffs' failureto establish with expert opinion Covenant's breach of the standard of care and the proximate cause of Williams' injuries. Covenant did not carry its initial burden of production on thoseissues.

A defendant who moves for summary judgment may meet itsinitial burden of production in at least two ways: (1) byaffirmatively disproving the plaintiff's case by introducingevidence that, if uncontroverted, would entitle the movant tojudgment as a matter of law (traditional test) (see Purtill v.Hess, 111 Ill. 2d 229, 240-41, 489 N.E.2d 867, 871 (1986)), or(2) by establishing that the nonmovant lacks sufficient evidenceto prove an essential element of the cause of action (Celotextest) (see Rice v. AAA Aerostar, Inc., 294 Ill. App. 3d 801, 805,690 N.E.2d 1067, 1070 (1998), citing Celotex Corp. v. Catrett,477 U.S. 317, 323, 91 L. Ed. 2d 265, 273, 106 S. Ct. 2548, 2552(1986); see also Fooden v. Board of Governors of State Colleges &Universities, 48 Ill. 2d 580, 587, 272 N.E.2d 497, 500 (1971)(summary judgment is appropriate if what is contained in thepleadings and affidavits would have constituted all of theevidence before the court and the trial court would have directeda verdict on that evidence)).

As the movant, Covenant bears the burden of persuasionand the initial burden of production. Only if a defendantsatisfies its initial burden of production does the burden shiftto the plaintiffs to present some factual basis that wouldarguably entitle them to a judgment under the applicable law. Rice, 294 Ill. App. 3d at 805, 690 N.E.2d at 1070. A partyopposing summary judgment may rely solely upon the pleadings tocreate a question of material fact until the movant suppliesfacts that would clearly entitle it to judgment as a matter oflaw. Malone v. American Cyanamid Co., 271 Ill. App. 3d 843, 846,649 N.E.2d 493, 495 (1995).

Covenant maintains that it is entitled to summaryjudgment because Williams cannot recall what caused her to fall. In Kimbrough v. Jewel Cos., 92 Ill. App. 3d 813, 817, 416 N.E.2d328, 331 (1981), the defendant met its burden of production byproducing a deposition of the plaintiff in which plaintiff statedshe did not know why she fell and answers to interrogatories inwhich plaintiff stated that there were no other known eyewitnesses. However, Kimbrough is distinguishable because that caseinvolved simple negligence and the plaintiff there had the burdenof proving that a condition of the defendant's premises causedher to fall. Kimbrough, 92 Ill. App. 3d at 818, 416 N.E.2d at332. Thus, the plaintiff could not prove her case when she couldnot specify what caused her to fall. Kimbrough, 92 Ill. App. 3dat 818, 416 N.E.2d at 332.

Plaintiffs' complaint alleges that Covenant was negligent in providing medical care. In this medical malpracticecase, plaintiffs must prove with expert opinion (1) the properstandard of care by which to measure the conduct of Covenant'snurses, (2) a negligent breach of the standard of care, and (3)resulting injury proximately caused by the breach. See Seef v.Ingalls Memorial Hospital, 311 Ill. App. 3d 7, 15, 724 N.E.2d115, 122 (1999), citing Higgens v. House, 288 Ill. App. 3d 543,546, 680 N.E.2d 1089, 1092 (1997). One of plaintiffs' allegations was that Covenant was negligent because its nurses allowedWilliams to get out of bed by failing to raise all four rails onher bed. Thus, the condition of Covenant's premises was not atissue, and how Williams fell after she got out of bed is irrelevant to the issue of Covenant's negligence. In any event,Williams described how she fell to Dr. Craddock, who memorializedthe account in her consultation report.

Covenant's motion for summary judgment was insufficientto place the burden on plaintiffs to come forward with expertopinion because Covenant's motion contained no affidavits andonly a bare assertion that plaintiffs had no expert testimony toestablish that Covenant's negligence was the proximate cause ofWilliams' injuries. Covenant failed to establish that plaintiffscould not produce an admissible expert opinion on the issues ofCovenant's breach of the standard of care and proximate cause ofWilliams' injuries, and Covenant made no showing that it wasclearly entitled to judgment as a matter of law on those issues. Thus, plaintiffs could have relied on their complaint to createan issue of material fact on those issues, and summary judgmentin favor of Covenant on that basis was improper.

Even if Covenant's motion was sufficient to carry itsburden of production on the issues of the breach of the standardof care and proximate cause, it was premature. The trial courterred in denying plaintiffs' motion to strike that portion ofCovenant's motion for summary judgment and in prematurely granting Covenant's motion for summary judgment based on plaintiffs'failure to show an issue of material fact on those issues.

Plaintiffs filed their complaint in February 1998. InMarch 1999, only 13 months later and prior to allowing plaintiffsto depose its nurses, Covenant filed a Celotex-type motion forsummary judgment. The motion was still premature in September1999 when Covenant filed a substantially identical motion forsummary judgment. Plaintiffs still had not completed deposingall occurrence witnesses, and expert discovery had not yetcommenced and was not even scheduled to begin. Plaintiffsproceeded diligently in gathering evidence and did not violateany discovery deadlines.

Covenant contends that its motion for summary judgmentwas timely because the parties had over six months to agree on abriefing schedule. During that time, plaintiffs obtained twocontinuances of their discovery deadlines because Covenant failedto make all occurrence witnesses available for deposition. InApril 1999, plaintiffs informed the court that they needed thosedepositions so that they could disclose expert witnesses. Covenant agreed to produce all eight occurrence witnesses fordeposition but allowed plaintiffs to depose only five of thosewitnesses. Covenant should have objected to those continuancesif it believed that it could not produce two former nurse's aidesfor deposition and that those depositions would not be neededbecause they worked after the shift during which Williams fell. Instead, Covenant failed to object and simply reiterated itsmotion for summary judgment.

Covenant points out that section 2-1005(b) of the Codestates that "[a] defendant may, at any time, move with or withoutsupporting affidavits for a summary judgment in his or her favoras to all or any part of the relief sought against him or her." (Emphasis added.) 735 ILCS 5/2-1005(b) (West 1998). However, aplaintiff should be given adequate time to gather evidence when adefendant makes a Celotex-type motion. See Hansbrough v. Kosyak,141 Ill. App. 3d 538, 549, 490 N.E.2d 181, 188 (1986) ("a medicalmalpractice plaintiff should be afforded every reasonable opportunity to establish his case"); see also 4 R. Michael, IllinoisPractice