Motion Reconsideration Legal Guidance

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 v. No: 2021D051242 NASER BEGANOVIC, Respondent. MOTION FOR RECONSIDERATION OF DENIED MOTION TO COMPEL RESPONDENT TO PROVIDE UNEMPLOYED SPOUSE'S BANK RECORDS AND FOR SUBPOENA IF NECESSARY NOW COMES the petitioner, Lula Korotkov, pro se, and respectfully submits this motion for reconsideration of the court's denial of my Motion to Order Respondent to Provide Girlfriend's Bank Records and for Subpoena if Necessary. This motion outlines the procedural history, the substantial evidence provided, and the necessity of obtaining these records to ensure a fair and accurate assessment of the respondent's financial situation, which directly impacts the child support obligations for my three children as per Illinois Supreme Court Rule *(b)(*), * ILCS */*, and Illinois Supreme Court Rule *. Background *. Filing the Motion: On September *, *, I filed a motion to compel discovery and subpoena of the respondent's girlfriend's bank records due to substantial financial transactions from Naser to Lisa Calderon/Beganovic. *. Judge's Instruction: On September *, *, the judge instructed me to change the title of the motion and resubmit it, which I did on September *, *. It was retitled Motion to Order Respondent to Provide Girlfriend's Bank Records and for Subpoena if Necessary. Court Sessions *. On October *, *, when I inquired about the motion, both the judge and Naser's former attorney, Ms. Abellar, stated that the motion was not yet up for consideration. *. On November *, *, when I once again inquired about the motion, the judge stated that she had already denied that motion. I respectfully pointed out that: a. The judge had not previously denied the motion. b. That on September *, *, the judge had stated for me to retitle the motion and resubmit it. c. That on October *, *, the judge stated the motion was not up yet. d. That none of the previous court orders reflected a denial of the motion. *. Judge's Response: Despite my clarifications, the judge stated, "Well, I'm denying it now." This statement was made without any clear recorded reasoning or consideration of the substantial evidence provided. The drafted court order signed and dated November *, *, also only states, "Lula's motion to order respondent to provide girlfriend's bank records and for subpoena if necessary is hereby denied," without further explanation. Direct Evidence of Transactions, Hidden Assets, and Discrepancies in Written Explanations *. I have provided extensive documented evidence throughout this case, plus emailed them to the judge on June *, *, demonstrating significant financial transactions from Naser’s Chase bank accounts to Lisa Calderon/Beganovic. a. Naser's Chase bank statements clearly show that over $*,* has been sent to Lisa Calderon/Beganovic, who has been unemployed since *, through Apple Cash, Zelle, and cash withdrawals in a relatively short period. b. An image provided by Chase Bank shows a cashier's check for $*,* made out to Lisa Beganovic, dated July *, *. This money was part of the $*,*.* Naser received from his second false claim against his former employer, NCR Corporation, which he deposited on June *, *. On June *, *, the judge ordered that the $*,*.* be included in Naser's income as it related to the initial child support set on November *, *, based on the false information provided in a pre-trial memorandum. However, this has not yet been done. c. Monthly spending between $*,* and $*,*, including large cash withdrawals and deposits, from Naser’s Chase Bank account from March * until Naser’s money began disappearing from his Chase account in May of *. d. Under-the-table income Naser was receiving via Zelle from Edina Gredelj, whose husband is the owner of International Protective Services Inc., and frequent cash deposits from Advanced Security Solutions Inc. that have been redirected to Lisa since *. e. Purchase of a townhouse under Lisa and her son Anthony C. Calderon’s names in May *, with a $*,* down payment coming out of Naser’s pocket. f. Payments for the mortgage, groceries, bills, shopping, vacations, vehicles, school clothing supplies, college tuitions, jewelry, entertainment, eating out, and birthday parties for Lisa and her five sons, aged *, *, *, *, and *, all came out of Naser's pocket, at the expense of his three biological children. g. Discrepancies between the written explanations Naser provided to my previous attorney and those he provided to his previous attorney regarding the cash withdrawals and deposits in his Chase accounts. h. Evidence that Naser was covering college tuition and other expenses for Lisa’s adult sons, while not providing for his own twin sons' college expenses, books, or any related costs. i. Naser also received $*,*.* from his first false claim against his ex-employer, NCR Corporation, on May *, *, which would pertain to retroactive child support. Financial Deception *. On August *, *, Naser falsely claimed to have poor credit and to be financially struggling, with $*,* in debt. He did not want to cover college expenses for his biological twin sons out of his pocket. He also stated that he needed to refinance his townhouse, which would have been impossible since he did not purchase the property under his own name. These claims are further invalidated by the transaction on September *, *, where Lisa's son Anthony sold the property to Lisa using Naser's money for the down payment once again, which is also property concealment. *. Naser also falsely stated that he owes $*,* on his motorcycle when, in fact, it is paid off. *. Naser claimed to have poor credit and to be $*,* in debt, it would have been highly unlikely for him to easily obtain auto loans. Despite these claims, he previously had a * Chrysler * with a balance due of $*,*, for which his bank statements show he was making a monthly payment of $*.*. He currently has a * Chevrolet Blazer with a balance due of $*,*, which contradicts his stated financial struggles. Legal Basis *. Illinois Supreme Court Rule *(b)(*): Allows discovery of non-privileged information relevant to the case, applicable to Naser’s financial transactions. *. * ILCS */*: Statute emphasizes proper financial support for children, relevant to Naser’s concealed assets. *. Illinois Supreme Court Rule *: Provides procedures for issuing subpoenas to third parties, crucial for obtaining Lisa's bank records. Argument *. Necessity of Obtaining Spouse's Bank Records: Naser’s financial transactions with Lisa Calderon/Beganovic clearly and directly indicate financial misconduct and asset hiding. Obtaining her Huntington Bank records is crucial for a fair and accurate assessment of Naser’s financial situation. *. Impact on Child Support Obligations: Since July *, *, Naser has provided overwhelming financial support to Lisa and her five sons while completely neglecting his obligations to his three biological children. This neglect, which began when his children were * and *, has deprived and continues to deprive them of the proper support they are legally entitled to receive. *. Procedural Irregularities: The judge's denial of the motion without discussion or recorded reasoning overlooks significant evidence and raises concerns about the fairness of the judicial process. WHEREFORE, I respectfully request that this Honorable Court: *. Reconsider the denial of the motion to compel discovery and subpoena the respondent's spouse's Huntington Bank records dating from May *, *, to present. *. Issue a subpoena if necessary to obtain the bank records. *. Provide a written explanation for the denial of the initial motion. *. Ensure that Naser’s financial situation is accurately assessed to provide the proper retroactive child support, child support he should have been paying, and should be paying moving forward for the children involved. *. I urge this Honorable Court to reconsider the substantial evidence I have presented throughout this case and grant the motion to compel respondent to provide unemployed spouse's bank records and for subpoena if necessary to ensure a fair and just outcome for my children. Respectfully Submitted, Lula Korotkov Lula Korotkov */*/* Lula Korotkov * N, Central Park Ave Chicago IL, * *-*-* Alisagiana@yahoo.com

I just wanna know if every. thing I stated in my document in this child support case. is that irrelevant? or inaccurate? as the situation is stated in my documents and is a child support judge supposed to be telling me that my motion has no legal basis, has no evidence and is inaccurate and inaccurate, not I would say that this judge should not be a judge.

You're not understanding me. if the parents non custodial parents, bank statements show all The transfers to the girlfriend. and I provide those bank statements to the judge. Are not. relevant. Is it not relevant? that the judge should and could request the girlfriend's bank records since the non custodial parent's records show clear proof of all the money transfers.

Now, from my document and how I drafted it and stated in it, would you. say that I do not understand. because the judge said that I don't seem to understand the law not from my understanding. I understand law well

Now I need to file a complaint against this charge and I need to know how to do it.

Also I wanna know something on. the November 19th * The drafted court order that was signed by this judge clearly states that the respondent is granted leave to file a response to my motion to strike respondents motion to dismiss my motion for retroactive child support. Now this judge today when I brought that up that he did not respond. she falsely claimed that she already handled that and that she denied it. which does not make sense.

She clearly signed it on November 19th * and it clearly states Nasser is granted leave to file a response to partitioners motion to strike respondents motion to dismiss petitioners motion for retroactive child support. Now she's stating. that she handled the retroactive a long. time ago, None of the court orders showed that she denied it or anything All this judge has been doing is causing financial harm to my children. All her court rulings are in favor of the respondent now. what estates in the Illinois statute law of child support and educational expenses It is also the fathers obligation to provide and support the children, not himself. and this judge also stated that she has the right to overrule the IRS at S advisory of me not to provide my daughter's identification pin to the respondent and she's stated that I should bring bond money with myself. that our next in person hearing

yes