Rule 2.1 of the Rules of the Circuit Court of Cook County controlls this situation. It reads as follows:
Rule 2.1. Notice of Hearing of Motions
(a) Notice required -- Except in actions appearing on the
daily trial call or during the course of trial, written notice of the hearing of
all motions shall be given to all parties who have appeared and have not
theretofore been found by the court to be in default for failure to plead, and
to all parties whose time to appear has not expired on the date of notice.
Notice that additional relief has been sought shall be given in accordance with
Supreme Court Rule 105.
(b) Content of notice --
The notice of hearing shall show the title and number of the action, the name of
the judge before whom, the time and date when, and the place where the motion
will be presented. If the motion is made orally, the notice shall state the
nature of the motion. If the motion is presented in writing, a copy of the
motion or a statement that it previously has been served, shall be served with
the notice. Copies of all papers presented to the court with the motion shall be
served with the notice or the notice shall state that copies have been
(c) Manner and time of service of
(i) Notice shall be given in the manner
and to the persons described in Supreme Court Rule 11. If notice of hearing is
given by personal service, the notice shall be delivered before 4 p.m. of the
second (2nd) court day preceding the hearing of the motion. If notice is given
by mail, the notice shall be deposited in a United States Post Office or Post
Office Box on or before the fifth (5th) court day preceding the hearing of the
You stated that Plaintiff mailed the notice of the motion on the same day as the hearing. So, in your Motion to Strike/Reconsider, you simply need to cite the above stated rule requiring notice. Then cite Stewart v. Lathan, 401 Ill. App. 3d 623 (Ill. App. Ct. 1st Dist. 2010) for the proposition that you are required by fundamental principles of due process to receive adequate notice of a motion before the court and that the court must reconsider any ruling made at the inadequately noticed hearing. Accordingly, the court must strike Plaintiff's notice and reconsider any ruling made.
You would then ask the court to grant your motion and deny Plaintiff's motion.