JUSTICE GILLERAN JOHNSON delivered the opinion of the court:

The defendant, counterplaintiff, and third-party plaintiff,Mary Goldman, appeals from the September 20, 2001, October 11,2001, and January 29, 2002, orders of the circuit court of Du PageCounty dismissing her countercomplaint and third-party complaintpursuant to section 2--615 of the Code of Civil Procedure (theCode) (735 ILCS 5/2--615 (West 2000)). On appeal, Goldman arguesthat her countercomplaint stated valid causes of action for abuseof process and that her third-party complaint stated a valid causeof action for fraudulent misrepresentation. We affirm.

The relevant facts are as follows. The plaintiff andcounterdefendant Neurosurgery and Spine Surgery, S.C.(Neurosurgery), is an Illinois corporation that operates a medicalpractice in Naperville. The plaintiff and counterdefendant MichaelRabin, M.D., is a neurosurgeon and a shareholder of Neurosurgery. Goldman was a patient of Dr. Rabin's partner, Gary Skaletsky, M.D. On April 25, 1999, Goldman was hospitalized at Edward Hospital inNaperville and treated by Dr. Rabin.

On December 20, 1999, Neurosurgery and Dr. Rabin filed adefamation action against Goldman, alleging defamation per se andper quod. More specifically, the plaintiffs' complaint allegedthat on October 18, 1999, Goldman had called the administrativeoffices of Edward Hospital for the purpose of making a complaintagainst Dr. Rabin. In their complaint, the plaintiffs alleged thatGoldman falsely reported that Dr. Rabin had forced his way into herhospital room on April 25, 1999, while she was undressed, that Dr.Rabin examined her with the door open, allowing people passing byto see her, and that Dr. Rabin had been dismissed from the staffsof Copley and Delnor Hospitals for similar conduct. The plaintiffsalleged that Goldman knew her statements were false and that sheacted with the intent to defame Dr. Rabin and his corporation. Theplaintiffs also alleged that Goldman acted with malice.

On March 6, 2001, Goldman filed a third-party complaint,naming as third-party defendants: Nancy Skaletsky, the wife of Dr.Gary Skaletsky and a nurse employed by Neurosurgery; Gregg I.Minkow, the plaintiffs' attorney; and Swarek & Associates andHinshaw & Culbertson, law firms with which Minkow was associated. The third-party complaint alleged four counts. Count I of thethird-party complaint alleged a cause of action for fraudulentmisrepresentation against Nancy Skaletsky. Specifically, count Ialleged in relevant part:

"20. During the summer of 1999, Nancy Skaletsky stated toGoldman that, due to incidences similar to the April 25, 1999,incident at Edward Hospital, Rabin had been dismissed from thestaffs of two hospitals.

21. At the time that Nancy Skaletsky told Goldman that Rabinhad been dismissed from the staffs of two hospitals, NancySkaletsky knew, or should have known, this statement wasfalse.

22. Upon information and belief, Nancy Skaletsky made thefalse statement to Goldman for the purpose of Goldman relyingupon such statement and inducing her to republish such falsestatement to third parties, including Edward Hospital.

23. Due to Nancy Skaletsky's employment with Neurosurgery asa nurse, Goldman had a right to rely upon Nancy Skaletsky'sfalse statement.

24. Goldman in fact relied upon Nancy Skaletsky's falsestatement and republished such statement to Edward Hospital.

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30. Goldman incurred legal and other costs as a result of herreliance upon Nancy Skaletsky's false representations to her.

31. Goldman suffered physical and emotional distress as aresult of Nancy Skaletsky's misrepresentation."

Counts II, III, and IV of the third-party complaint alleged causesof action for abuse of process against Minkow and Swarek &Associates and Hinshaw & Culbertson.

On July 5, 2001, Goldman filed a second amendedcountercomplaint against Neurosurgery and Rabin. The secondamended countercomplaint alleged two counts of abuse of process. Specifically, count I of the second amended countercomplaintalleged:

"38. On December 22, 1999, the Chicago Tribune published anarticle relating to a lawsuit filed by [p]laintiffs.

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41. When she reviewed the Tribune [a]rticle, Goldman notedthat the name of the defendant was not disclosed.

42. After reviewing the Tribune article, Goldman concludedthat she was the defendant in the lawsuit mentioned in theTribune [a]rticle.

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45. On December 22, 1999, Minkow called Goldman at about10:00 a.m.

46. During the December 22, 1999, telephone conversation,Minkow disclosed that he represented the plaintiffs.

47. During the December 22, 1999, conversation, Minkowspecifically referred to the Tribune [a]rticle.

48. During the December 22, 1999, conversation, Minkowstated as follows to Goldman with respect to the Tribune[a]rticle: 'Notice that your name and the nature of yourillness were not revealed.'

49. When Minkow stated to Goldman 'Notice that your nameand nature of your illness was not revealed,' in the contextof the Tribune [a]rticle and the telephone conversation,Minkow created an apprehension that Minkow was threateningto reveal publicly confidential medical informationregarding Goldman's medical condition.

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51. During the December 22, 1999, conversation, Minkow statedto Goldman that if she did not have a lawyer that she shouldobtain one from the Du Page County Bar Association.

52. When Minkow suggested to Goldman that she should obtainlegal assistance from the Du Page County Bar Association, inthe context of the telephone call, Minkow created anapprehension that the [p]laintiffs had made availablefinancial records which were part of Goldman's confidentialmedical records.

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60. On December 22, 1999, during the afternoon, Goldman wasserved with the following documents: Summons, Complaint andletter from Minkow dated December 22, 1999.

61. In the Minkow [l]etter, Minkow stated to Goldman asfollows: 'If you wish to discuss an early resolution of thismatter please call me.'

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101. All of the acts committed by Minkow alleged above wereconducted within the scope of the authority granted by[p]laintiffs to Minkow, as their attorney.

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105. The above acts of the plaintiffs and Minkow, and each of them, caused Goldman severe emotional distress and anxiety as a direct, proximate and foreseeable result of such conduct." Count II of the second amended countercomplaint incorporatedthe allegations from count I. Count II of the countercomplaintfurther alleged:

"113. During the January 17, 2000 telephone conversation,Minkow repeatedly implied to Goldman that he would terminatethe lawsuit if Goldman agreed to testify to that [sic] she hadan affair with Dr. Skaletsky and that she received drugs fromDr. Skaletsky.

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118. Minkow's offer to terminate the above-captioned lawsuitin return for Goldman's false testimony that she had an affairwith Dr. Skaletsky and that Dr. Skaletsky gave her drugs inreturn for sexual favors constitutes attempted extortion ofGoldman's false testimony."

On September 20, 2001, upon motion by Nancy Skaletsky, thetrial court dismissed count I of Goldman's third-party complaintpursuant to section 2--615 of the Code. On October 11, 2001, thetrial court ordered that the dismissal was with prejudice. OnJanuary 29, 2002, upon motion by the plaintiffs, the trial courtdismissed, with prejudice, Goldman's second amendedcountercomplaint pursuant to section 2--615 of the Code. The trialcourt found that there was no reason for delaying enforcement orappeal of this order or its previous orders dated September 20,2001, and October 11, 2001. Goldman thereafter filed a timelynotice of appeal.

Goldman's first argument on appeal is that the trial courterred in dismissing her countercomplaint pursuant to section 2--615of the Code. She maintains that her countercomplaint sufficientlystated two counts of abuse of process.

The question presented by a section 2--615 motion to dismissis whether the allegations of the complaint, when viewed in a lightmost favorable to the plaintiff, are sufficient to state a cause ofaction upon which relief can be granted. Hough v. Kalousek, 279Ill. App. 3d 855, 862 (1996). Illinois is a fact-pleadingjurisdiction that requires a plaintiff to present a legally andfactually sufficient complaint. Hough, 279 Ill. App. 3d at 863. The plaintiff is not required to prove his or her case, but mustallege sufficient facts to state all the elements of the assertedcause of action. Inland Real Estate Corp. v. Tower ConstructionCo., 174 Ill. App. 3d 421, 433 (1988).

When ruling on a section 2--615 motion to dismiss, the trialcourt should admit all well-pleaded facts as true and disregardlegal and factual conclusions that are unsupported by allegationsof fact. Lake County Grading Co. of Libertyville, Inc. v. AdvanceMechanical Contractors, Inc., 275 Ill. App. 3d 452, 456-57 (1995). If, after disregarding any legal and factual conclusions, thecomplaint does not allege sufficient facts to state a cause ofaction, the trial court must grant the motion to dismiss. LakeCounty Grading Co., 275 Ill. App. 3d at 457. The standard ofreview on a section 2--615 dismissal is de novo. T&S Signs, Inc.v. Village of Wadsworth, 261 Ill. App. 3d 1080, 1084 (1994).

Abuse of process is the misuse of legal process to accomplishsome purpose outside the scope of the process itself. Bonney v.King, 201 Ill. 47, 50-51 (1903). The two distinct elements of anabuse of process claim are: (1) the existence of an ulteriorpurpose or motive and (2) some act in the use of process that isnot proper in the regular course of proceedings. Holiday Magic,Inc. v. Scott, 4 Ill. App. 3d 962, 966 (1972). Because the tort ofabuse of process is not favored under Illinois law, the elementsmust be strictly construed. See Erlich v. Lopin-Erlich, 195 Ill.App. 3d 537, 539 (1990).

In order to satisfy the first element, a plaintiff must pleadfacts that show that the defendant instituted proceedings againsthim for an improper purpose, such as extortion, intimidation, orembarrassment. Community National Bank in Monmouth v. McCrery, 156Ill. App. 3d 580, 583 (1987). However, the mere institution of asuit for an improper purpose does not itself constitute an abuse ofprocess, the second element being the gravamen of the offense. McCrery, 156 Ill. App. 3d at 583. In order to satisfy the secondelement, the plaintiff must plead facts that show a misapplicationof process, or, in other words, the plaintiff must show that theprocess was used to accomplish some result that is beyond thepurview of the process. McCrery, 156 Ill. App. 3d at 583. Whenprocess is used only for its intended purpose, there has been nomisapplication of process. Holiday Magic, Inc., 4 Ill. App. 3d at969.

In the present case, we believe that the trial court properlydismissed Goldman's second amended countercomplaint. Neither countI nor count II of the second amended countercomplaint alleged facts that show a misapplication of process. With regard to thiselement, the countercomplaint merely alleged that a summons wasissued. This was insufficient.

"Process" has been defined as any means used by the court toacquire or to exercise its jurisdiction over a person or overspecific property. McCrery, 156 Ill. App. 3d at 583. Therefore,the issuance of a summons can be categorized as process. However,the second element is not satisfied by pleading that there has beenprocess. As noted above, a party must plead that there has been amisapplication of that process. McCrery, 156 Ill. App. 3d at 583.A summons is issued in just about every case in which a lawsuit isfiled. The intended purpose of a summons is to establish a court'sin personam jurisdiction over a person. See Coyne v. OSFHealthcare System, 332 Ill. App. 3d 717, 719 (2002). It is neitherirregular nor improper to cause a summons to be issued whenproceedings are instituted against someone. Rather, it is alwaysproper to issue a summons. See 735 ILCS 5/2--201(a) (West 2000). As such, the mere issuance of a summons cannot give rise to anabuse of process. See Holiday Magic, Inc., 4 Ill. App. 3d at 969;see also Landau v. Schneider, 154 Ill. App. 3d 875, 879-880 (1987). In a proper factual context, a fraudulent and maliciousmanipulation of service of summons might constitute an abuse ofprocess; however, no such facts were alleged in this case. Nevertheless, even had such a scenario been pleaded, we note thatthe tort of abuse of process is a very narrow tort. See CommerceBank v. Plotkin, 255 Ill. App. 870, 872 (1994). In fact, theHoliday Magic court has stated that a misapplication of process hasbeen found only in cases in which a plaintiff has suffered anactual arrest or seizure of property. Holiday Magic, Inc., 4 Ill.App. 3d at 969.

Additionally, Goldman's allegations regarding the firstelement of abuse of process, an improper motive, were alsoinsufficient. Specifically, Goldman's allegations with regard toan improper motive were unclear and confusing. For example, Goldman's allegation that "[w]hen Minkow stated to Goldman 'Noticethat your name and nature of your illness was not revealed,' in thecontext of the Tribune [a]rticle and the telephone conversation,Minkow created an apprehension that Minkow was threatening toreveal publicly confidential medical information regardingGoldman's medical condition" is bemusing and devoid of anyindication of an improper motive. While pleadings are to beliberally construed with a view to doing substantial justicebetween the parties, section 2--603 of the Code requires that thepleadings shall contain a plain and concise statement of thepleader's cause of action. See 735 ILCS 5/2--603 (West 2000); seealso Buzzard v. Bolger, 117 Ill. App. 3d 887, 890 (1983). Accordingly, as neither count I nor count II of Goldman's secondamended countercomplaint alleged sufficient facts to satisfy theelements of abuse of process, the trial court did not err indismissing the countercomplaint.

Goldman's second argument on appeal is that the trial courterred in dismissing count I of her third-party complaint. Goldmanargues that count I of her third-party complaint alleged a cause ofaction for fraudulent misrepresentation. For the followingreasons, we believe that the trial court properly dismissed countI of Goldman's third-party complaint.

We begin our discussion by noting that the tort of fraudulentmisrepresentation is often surrounded by unnecessary confusion,because misrepresentations themselves often play large roles in avariety of other torts. For instance, an untrue assertion may beat the heart of an action for false imprisonment (see Whitman v.Atchinson, 85 Kan. 150, 116 P. 234 (1911)), conversion (see Hollandv. Bishop, 60 Minn. 23, 61 N.W. 681 (1895)), or trespass to land(see Donovan v. Consolidated Coal Co., 187 Ill. 28 (1900)). Amisrepresentation is the essence of torts such as defamation,interference with contractual relations, and malicious prosecution. A malicious, outrageous lie may even give rise to a cause of actionfor intentional infliction of emotional distress. See Nickerson v.Hodges, 146 La. 735, 84 So. 37 (1920). In summary, a great numberof causes of action stem from misrepresentations.

However, not every misrepresentation gives rise to a cause ofaction for fraudulent misrepresentation. The origin of fraudulentmisrepresentation lies in the common law action of deceit, whichwas a very narrow tort. See Pasley v. Freeman, 100 Eng. Rep. 450(K.B. 1789); Derry v. Peek, 14 A.C. 337 (H.L. 1888). Prior to theeighteenth century, recovery on the action of deceit was notavailable unless the misrepresentation was part of some contractualdealing between the parties. Then, in 1789, in Pasley, it was heldthat one who fraudulently induced a third party to extend credit toa person known to be untrustworthy was liable to the defraudedparty. Pasley v. Freeman, 100 Eng. Rep. at 450. Deceit, as adistinct tort, thus came into being, independent of any contractualrelationship.

In 1889, in Peek, deceit became the tort we today refer to asfraudulent misrepresentation. In Peek, the directors of a tramwaycompany issued a prospectus to induce the public to subscribe forstock; the prospectus contained the following unqualifiedstatement: "[T]he company has the right to use steam or mechanicalmotive power instead of horses ***." Peek, 14 A.C. at 337. Infact, however, the company had no such right inasmuch as thegovernment permitted the use of steam as a motive power only if thecompany first obtained governmental consent and the company hadnever obtained such consent. Peek, 14 A.C. at 337. Peek, astockholder who had purchased shares on the faith of theprospectus, brought an action for deceit. Peek, 14 A.C. at 337. The court concluded that the defendants had honestly believed thestatement to be true, although they had no reasonable grounds forany such belief. Peek, 14 A.C. at 337. It was held that theaction could not be maintained, since nothing more than negligencewas shown. Peek, 14 A.C. at 337.

Historically, the torts of deceit and fraudulentmisrepresentation have been limited to cases involving business orfinancial transactions between parties, right down to the firstrecorded cases, Pasley and Peek. See W. Prosser, Torts