¶ 27 ¶ 28 ¶ 29 ¶ 30 ¶ 31 ¶ 32 ¶ 33 is legally and factually sufficient and should be answered. Id. at 715. See also Stone, 2011 IL App (1st) 093386, ¶¶ 18-21 (rejecting summary judgment standard). We find the reasoning espoused by these courts persuasive and agree this is the proper standard to apply. Thus, we hold that to ascertain whether a petitioner has satisfied Rule 224’s necessity requirement, the court must evaluate a defamation complaint to determine whether it will withstand a section 2-615 motion to dismiss. Rule 224 and Hadley’s Defamation Claim We now turn to whether the circuit court properly concluded that Rule 224’s necessity requirement was met. A section 2-615 motion to dismiss tests the legal sufficiency of a complaint. Green v. Rogers, 234 Ill. 2d 478, 491 (2009). The question to be answered is whether the allegations of the complaint, when construed in the light most favorable to the plaintiff, state sufficient facts to establish a cause of action upon which relief may be granted. Id. All facts apparent from the face of the complaint, including any attached exhibits, must be considered. A circuit court should not dismiss a complaint under section 2-615 unless it is clearly apparent no set of facts can be proved that would entitle the plaintiff to recovery. Id. The standard of review is de novo. Id. To state a cause of action for defamation, a plaintiff must present facts showing the defendant made a false statement about the plaintiff, the defendant made an unprivileged publication of that statement to a third party, and the publication caused damages. Id. A defamatory statement is one that harms a person’s reputation because it lowers the person in the eyes of others or deters others from associating with her or him. Tuite v. Corbitt, 224 Ill. 2d 490, 501 (2006). A statement is defamatory per se if its harm is obvious and apparent on its face. Id. In Illinois, there are five categories of statements that are considered defamatory per se, only one of which is relevant here: words imputing the commission of a crime. Id. Even if an alleged statement falls into one of the categories of statements that are defamatory per se, it will not be actionable if it is reasonably capable of an innocent construction. Under the innocent construction rule: “ ‘courts must give the allegedly defamatory words their natural and obvious meaning. [Citations.] Courts must therefore interpret the allegedly defamatory words as they appeared to have been used and according to the idea they were intended to convey to the reasonable reader. [Citation.] When a defamatory meaning was clearly intended and conveyed, this court will not strain to interpret allegedly defamatory words in their mildest and most inoffensive sense in order to hold them nonlibellous under the innocent construction rule.’ [Citation.]” Id. at 504. The innocent construction rule “does not require courts ‘to espouse a naїveté unwarranted under the circumstances.’ [Citation.]” Id. at 505. “[I]f the likely intended meaning of a statement is defamatory, a court should not dismiss the plaintiff’s claim under the innocent construction rule. In those circumstances, an innocent construction of the statement would necessarily be strained and unreasonable because the likely intended meaning is defamatory.” Id. at 512. In addition, if a statement is defamatory per se, but not subject to an innocent construction, it may still enjoy constitutional protection as an expression of opinion. As we stated in Solaia Technology, LLC v. Specialty Publishing Co., 221 Ill. 2d 558 (2006): -7-