Legal Citation For Illinois Motion

Can you read my text and tell me? Exactly which? Illinois Civil Code or Illinois State statute law I should be citing into this. IN THE CIRCUIT COURT OF COOK COUNTY ILLINOIS COUNTY DEPARTMENT-DOMESTIC RELATIONS DIVISION IN RE THE PARENTAGE OF: A.K, J.K, S.K., minor children, ) ) LULA KOROTKOV, ) Petitioner, Pro Se ) ) and ) No: 2021D051242 ) NASER BEGANOVIC, ) Respondent. Objection to Respondent’s Motion to Dismiss. Petitioner’s Motion to Expedite Proceedings and Address Frivolous Filings Endangering Children’s Well-being. NOW COMES the Petitioner, Lula Korotkov, proceeding pro se, pursuant to the Illinois Civil Code of Procedure. Hereby, Petitioner files an Objection to the Respondent’s Motion to Dismiss Petitioner’s Motion to Expedite Proceedings and Address Frivolous Filings Endangering Children’s Well-being. Hereof, Petitioner states as follows: *. The respondent and I were in a committed relationship for 17 years, during which time we raised three children together. In August of *, we moved into my parents’ basement. We were preparing to purchase a home for our children before we separated on July *, *. Although we were never legally married, the respondent has a legal obligation to provide for our children. *. I filed for child support through Healthcare and Family Services (HFS) on July *, *. The process was delayed due to administrative reasons, and it took nine months for HFS to send me the necessary paperwork, which I received and signed in April *. documented evidence of this is in Exhibit C. *. On October *, *, the Respondent filed his appearance following successful service by the Kane County Sheriff on September *, *. This came four months after an unsuccessful attempt by the Cook County Sheriff on May *, *, the delay was a result of the Respondent's intentional evasion of service, as evidenced by documentation showing his whereabouts as unknown. Evidence provided in Exhibit C. *. Our first court hearing took place via Zoom on January *, *. Throughout the hearing, the respondent consistently demanded DNA tests for the children, refuting his paternity. He also requested a continuance, ostensibly to hire an attorney. However, it was apparent that his intentions were to financially exploit our twin boys for personal gain by falsely claiming them on his tax returns. *. On February *, *, the State’s Attorney formally requested the submission of financial documents from both parties. In Exhibit J, there’s documented evidence of what the respondent provided to the State’s Attorney. Additionally, my email to the State’s Attorney, which included the respondent’s bank statements from his hidden account at that time. *. On March *, *, I sought a continuance with the aim of obtaining legal representation. This decision was influenced by my examination of the respondent’s bank records, where I uncovered a hidden account and observed substantial amounts of money being spent and transferred to Lisa Marie Calderon and her sons. I presented these findings to the State’s Attorney on March *, *, as supported by the provided evidence. I would like to note for the record that the State’s Attorney expressed her concerns to the judge regarding the respondent’s bank records, particularly because the respondent had only provided two bank statements from an account ending in *. This is corroborated by the evidence in Exhibit J. *. On November *, *, an agreement was struck between my previous attorney and the opposing party’s attorney in the judge’s chambers, without my knowledge, while I was sitting out in the courtroom. It’s important to note that an attorney cannot agree to a child support order without consulting with the custodial parent. The custodial parent has the right to be involved in decisions that affect their children’s financial support. The ruling was based on intentionally false information stated in a pretrial memorandum that was submitted to the court by the opposing party’s attorney on November *, *. The pretrial memorandum also had the respondent’s ex-employer, NCR Corporation, listed as his full-time employer. This has led to no child support payments coming for the children, as I have received only one since then. This is due to the fact that the respondent intentionally provided his ex-employer’s information for wage withholding. As a result, HFS had to submit a wage withholding notice to his actual employer, Cardtronics, on February *, *. The respondent’s true monthly income is $*,*, as can be seen in the overwhelming documented evidence I personally delivered to the judge’s courtroom on February *, *. *. On October *, *, my first attorney filed a motion to withdraw due to the respondent’s continuous refusal to comply. This situation was further complicated by Lisa Calderon, the respondent’s girlfriend, who persistently interfered and impersonated the respondent via email. Evidence of this can be found in Exhibit K. *. I would like to draw the court’s attention to item #* on page * of the opposing party’s motion, as it is intentionally misleading. I only requested my second attorney, Mr. Hook, to withdraw from this case because he agreed to an order without my knowledge. The state’s attorney withdrew from this case due to the fact that I hired an attorney in May *, who subsequently withdrew in October *. For the reasons I mentioned in item #* of my objection to the respondent’s motion. *. Since July *, *, the Respondent has been fully aware of the precarious living conditions he left our three children in - a basement with flooding issues at their grandparents’ house. Despite this knowledge, the Respondent has chosen to neglect his own children both financially and emotionally. This neglect is not limited to failing to provide for their basic needs, but also extends to allowing his girlfriend to inflict intentional financial, emotional, psychological, and mental distress on our children. In addition to this neglect, the Respondent has been fully supporting his girlfriend and her five sons, three of whom are well over the age of *. This disparity in financial support further underscores the Respondent’s disregard for his own children’s well-being. Despite the clear and present danger posed to our children’s well-being, the Respondent’s attorney has filed a motion to dismiss my motion to expedite the proceedings and address frivolous filings endangering the children’s well-being. This action not only prolongs the proceedings but also continues to put our children’s well-being at risk. Furthermore, the Respondent has committed perjury by providing false information and hiding money and assets under his girlfriend’s name. These actions, taken together, paint a picture of a parent who is indifferent to his children’s well-being. The Respondent’s actions, or lack thereof, speak volumes about his indifference towards our children’s well-being and call for immediate intervention by the court. He should be held legally accountable for his neglectful actions. *. It has become increasingly clear that the opposing party’s pattern of providing intentionally false information to the court serves as a distraction from the respondent’s perjury. This behavior appears to be a deliberate attempt to divert attention away from the extreme financial, emotional, psychological, and mental harm inflicted on the children since July *, *. The frivolous motions and misleading information not only disrupt the proceedings but also undermine the integrity of the legal process. I respectfully request the court to consider this pattern of behavior when reviewing the motions filed by the opposing party and the impact it has on the children involved. *. It has become increasingly clear that the opposing party’s attorney is employing a strategy of intentional misrepresentation and delay. Despite the clear distinction between motions and pleadings, the attorney has been consistently mislabeling my motions as pleadings. This mischaracterization is not a mere oversight but appears to be a calculated tactic. By incorrectly applying the rules of civil codes and statute laws, such as §*-* and §*-* of the Illinois Code of Civil Procedure, that are relevant to pleadings, the attorney is attempting to muddle the issues at hand. *. In the ongoing legal proceedings, I, as the pro se Petitioner, have provided substantial documented evidence that was both electronically uploaded and personally delivered to the judge’s courtroom. This evidence directly supports all the statements I have made in my motions, including the Motion to Reconsider, the Motion to Expedite Proceedings and Address Frivolous Filings Endangering the Children’s Well-being, the Motion for Contempt and Sanctions for Fraudulent Misrepresentation, Obstruction of Child Support Proceedings, and Third-Party Interference, and the Motion to Substitute the Judge for Cause. Despite this, the opposing party continues to make inaccurate statements, suggesting that my Motion to Expedite provides countless conclusory allegations and history of events without any sufficient factual basis to support my statements. This is not the case. Each of my motions is backed by relevant, factual evidence in exhibits A through O. I respectfully request the court to consider the extensive evidence provided when reviewing the statements and requests made in my motions. *. I would like to clarify that my motions are not merely composed of conclusions of law and conclusory factual allegations. Each statement made in my motions is substantiated by specific factual evidence, which has been both electronically uploaded and personally delivered to the judge’s courtroom. This evidence directly supports all the statements made in my motions. Therefore, the assertion that my complaint consists of only conclusions of law and conclusory factual allegations unsupported by specific factual statements is not accurate. *. My “Motion to Expedite and Address Frivolous Filings Endangering the Children’s Well-being” is not a complaint, but a motion. A motion is a request for the court to take a specific action during an ongoing case. My motion is supported by specific factual evidence, contradicting the claim that it consists only of conclusions of law and conclusory factual allegations. *. As a pro se litigant, I am expected to follow the same rules of procedure as attorneys. However, this does not change the fact that my motions are backed by substantial documented evidence. I am not seeking leniency but asking the court to consider the extensive evidence I have provided when reviewing my motions. *. Contrary to the opposing party’s claim, my “Motion to Expedite and Address Frivolous Filings Endangering the Children’s Well-being” is not merely composed of conclusory factual allegations. Each statement made in my motion is substantiated by specific factual evidence, which has been both electronically uploaded and personally delivered to the judge’s courtroom. Therefore, the assertion that my motion consists of only conclusory factual allegations unsupported by specific factual statements is not accurate. I respectfully request the court to consider the extensive evidence provided when reviewing the statements and requests made in my motions. *. In my motions, I have referred to the Illinois child support statute laws as this is a child support case. While I may not have cited a specific statute in every instance, the basis for the reliefs I requested is grounded in these laws. My reference to the Illinois Code of Civil Procedure was intended to provide a general legal framework for my motions. As for the request for expedited proceedings, it is based on the urgency of the matters at hand, particularly the well-being of the children involved. While I understand the importance of citing specific statutes, the essence of my motions lies in the substantive issues concerning the children’s welfare and not merely in procedural formalities. I believe the court has the discretion to expedite proceedings in circumstances where the best interests of the children are at stake. *. All the motions that I have filed on behalf of the children’s well-being are serious and substantial. These motions are supported by overwhelming documented evidence, all of which is aimed at substantiating my statements. These motions are not frivolous; they are grounded in fact and reflect a concern for the children’s best interests. On the other hand, all the motions filed by the opposing party are considered frivolous. They contain intentionally misleading information with the intent of prolonging the proceedings. These motions lack substantial evidence and are intended to delay the process rather than address the issues at hand. Such tactics not only waste the court’s time but also detract from the real issues concerning the children’s well-being. *. It’s important to note that the respondent’s decision to incur substantial attorney fees by filing frivolous motions is not my responsibility. These motions are a distraction from the fact that the respondent is hiding his true monthly income and assets, and attempting to cover up his perjury. The financial and emotional neglect of the children is a serious concern. These motions, which lack substantial evidence, are intended to delay proceedings until after our twin boys graduate high school. This is the respondent’s choice. The financial implications of these actions fall on the respondent. My focus remains on the well-being of the children and the substantive issues at hand. This approach emphasizes my commitment to the children’s well-being and highlights the respondent’s responsibility for his own actions. *. It is important to note that my motions are not substantially insufficient in law. They are grounded in fact and concern for the children’s best interests, and are supported by overwhelming documented evidence. The motions I have filed are serious and substantial, aimed at ensuring the welfare of the children involved in these proceedings. They are not frivolous and should not be stricken as such. *. The decision of NASER to incur attorney’s fees in the preparation of this motion and the proceedings recently brought forth by me is a choice made by NASER. The financial implications of these actions fall on NASER. My focus remains on the well-being of the children and the substantive issues at hand. The tactics employed by NASER, including filing motions that contain intentionally misleading information with the intent of prolonging the proceedings, are a distraction from the real issues at hand. WHEREFORE, I, LULA, acting pro se, respectfully request this Honorable Court to consider the following: a. Not to dismiss my Motion to Expedite Proceedings and Address Frivolous Filings. My motions are serious, substantial, and backed by overwhelming documented evidence, all aimed at protecting the children’s best interests. b. I have not made false allegations against NASER or NASER’s girlfriend. My statements are based on facts and evidence, and they are made in the interest of the children’s well-being. c. The attorney’s fees incurred by NASER for filing this Motion are a result of his own actions. The financial implications of these actions fall on NASER. d. I request any other relief this Court deems appropriate and equitable in the circumstances, keeping the children’s best interests at the forefront.

Not this one. * ILCS */*-*, * ILCS */*-* (for procedural issues) Because my emotions that I have filed are not complaints nor pleadings.

I don't think any. Part of * IL CS.Should be cited in my motion as again, it is not a complaint. Nor a pleading.