Motion To Strike Guidance

I want to know if this is enough to persuade the judge.Sure, I can help you draft this motion with persuasive language. Here's a revised version: --- **MOTION TO STRIKE RESPONDENT'S MOTION TO DISMISS PETITIONER'S MOTION FOR RETROACTIVE CHILD SUPPORT** NOW COMES the Petitioner, Lula Korotkov, pro se, pursuant to the Illinois Civil Code of Procedure, hereby files this Motion to Strike Respondent's Motion to Dismiss Petitioner’s Motion for Retroactive Child Support. In support of this motion, Petitioner states as follows: *. **Missed Deadlines**: a. On September *, *, Respondent Naser was given 21 days to respond to Petitioner’s motion for retroactive child support and provide an updated financial affidavit, with a deadline of October *, *. Respondent missed this deadline. b. On October *, *, Respondent’s attorney claimed the delay was due to Respondent being out of state. However, Petitioner received a text message from Respondent through the Talking Parents app on October 15th, indicating he was not out of state. c. Respondent was given additional days to provide his updated financial affidavit and 14 days to respond, starting from October *, *, when the judge signed the court order. Respondent filed a motion to dismiss Petitioner’s motion for retroactive child support on November *, *, which is well past both deadlines. *. **Questionable Justifications**: a. Respondent’s attorney stated that the initial deadline was missed due to Respondent being out of state. However, an email from the attorney indicates that she would be back in her office on October *, *. This conflicting information raises concerns about the credibility of the excuse provided. b. Respondent has consistently claimed financial hardship, making it questionable how he could afford extended out-of-state travel. This inconsistency further raises concerns about the credibility of Respondent's financial statements and their commitment to timely legal compliance. *. **Inconsistencies in Financial Affidavit**: - Respondent's updated financial affidavit, received after the deadline, contains several discrepancies: - Respondent previously stated that he owed $*,* on his motorcycle loan, yet the updated affidavit indicates it is now paid off. - Respondent claims to have bad credit and to be $*,* in debt, yet he has acquired a new vehicle. - Respondent also stated that he needed to refinance his townhouse, which would be impossible as the townhouse was not purchased under his own name. - Additionally, Respondent claimed the need to refinance the townhouse, despite it being under the names of his girlfriend and her *-year-old son. On September *, *, the son sold his share of the property to his mother, making her the sole owner. Given that the girlfriend has been unemployed since *, Respondent would have needed to put another down payment, further questioning his financial claims. - Respondent's Chase bank statements show that he sent over $*,* via Zell and Apple Cash to his girlfriend, raising further concerns about undisclosed income. The girlfriend has Respondent listed as an authorized user, making it difficult to trace his hidden income. - An exhibit provided by Respondent's own attorney demonstrates that Respondent was capable of paying the retail hourly rate and hearing amounts, totaling $*,* just for a hearing. This indicates Respondent has financial resources contrary to his claims of financial hardship. *. **False Statements in Respondent's Motion to Dismiss**: - Respondent's motion to dismiss falsely states that Petitioner filed for child support through FFS on May *, *. In fact, Petitioner filed for child support through HFS on July *, *. Although it took HFS nine months to send the documents, the court copies show Petitioner's signature dated April *, *, which is the date from which Petitioner is requesting retroactive child support. *. **Prejudice to Petitioner**: - The repeated failure to meet court-ordered deadlines and the inconsistencies and false statements in Respondent's financial statements are prejudicial to Petitioner and cause undue delay in the proceedings. **WHEREFORE, Petitioner respectfully requests that this Court strike Respondent's Motion to Dismiss Petitioner’s Motion for Retroactive Child Support and grant such other and further relief as the Court deems just and proper.** --- I hope this helps! Let me know if you need any further adjustments.

yes

Would this be correct?To ensure your motion is accurate and persuasive, you should reference the correct statutes. Based on the nature of your motion, here are the relevant statutes: *. *** ILCS */*-***: This statute is appropriate for your motion to strike and dismiss for insufficiency of the pleadings. It addresses the grounds for striking a motion based on the inadequacy of the respondent's arguments or evidence. *. *** ILCS */***: This statute pertains to child support guidelines and retroactive child support. It is relevant to your motion for retroactive child support and can be cited to support your arguments regarding the respondent's financial obligations. Here’s how you can incorporate these references into your motion: --- **MOTION TO STRIKE RESPONDENT'S MOTION TO DISMISS PETITIONER'S MOTION FOR RETROACTIVE CHILD SUPPORT** NOW COMES the Petitioner, Lula Korotkov, pro se, pursuant to *** ILCS */*-*** and *** ILCS */***, hereby files this Motion to Strike Respondent's Motion to Dismiss Petitioner’s Motion for Retroactive Child Support. In support of this motion, Petitioner states as follows: *. **Missed Deadlines**: a. On September *, *, Respondent Naser was given 21 days to respond to Petitioner’s motion for retroactive child support and provide an updated financial affidavit, with a deadline of October *, *. Respondent missed this deadline. b. On October *, *, Respondent’s attorney claimed the delay was due to Respondent being out of state. However, Petitioner received a text message from Respondent through the Talking Parents app on October 15th, indicating he was not out of state. c. Respondent was given additional days to provide his updated financial affidavit and 14 days to respond, starting from October *, *, when the judge signed the court order. Respondent filed a motion to dismiss Petitioner’s motion for retroactive child support on November *, *, which is well past both deadlines. *. **Questionable Justifications**: a. Respondent’s attorney stated that the initial deadline was missed due to Respondent being out of state. However, an email from the attorney indicates that she would be back in her office on October *, *. This conflicting information raises concerns about the credibility of the excuse provided. b. Respondent has consistently claimed financial hardship, making it questionable how he could afford extended out-of-state travel. This inconsistency further raises concerns about the credibility of Respondent's financial statements and their commitment to timely legal compliance. *. **Inconsistencies in Financial Affidavit**: - Respondent's updated financial affidavit, received after the deadline, contains several discrepancies: - Respondent previously stated that he owed $*,* on his motorcycle loan, yet the updated affidavit indicates it is now paid off. - Respondent claims to have bad credit and to be $*,* in debt, yet he has acquired a new vehicle. - Respondent also stated that he needed to refinance his townhouse, which would be impossible as the townhouse was not purchased under his own name. - Additionally, Respondent claimed the need to refinance the townhouse, despite it being under the names of his girlfriend and her *-year-old son. On September *, *, the son sold his share of the property to his mother, making her the sole owner. Given that the girlfriend has been unemployed since *, Respondent would have needed to put another down payment, further questioning his financial claims. - Respondent's Chase bank statements show that he sent over $*,* via Zell and Apple Cash to his girlfriend, raising further concerns about undisclosed income. The girlfriend has Respondent listed as an authorized user, making it difficult to trace his hidden income. - An exhibit provided by Respondent's own attorney demonstrates that Respondent was capable of paying the retail hourly rate and hearing amounts, totaling $*,* just for a hearing. This indicates Respondent has financial resources contrary to his claims of financial hardship. *. **False Statements in Respondent's Motion to Dismiss**: - Respondent's motion to dismiss falsely states that Petitioner filed for child support through FFS on May *, *. In fact, Petitioner filed for child support through HFS on July *, *. Although it took HFS nine months to send the documents, the court copies show Petitioner's signature dated April *, *, which is the date from which Petitioner is requesting retroactive child support. *. **Prejudice to Petitioner**: - The repeated failure to meet court-ordered deadlines and the inconsistencies and false statements in Respondent's financial statements are prejudicial to Petitioner and cause undue delay in the proceedings. **WHEREFORE, Petitioner respectfully requests that this Court strike Respondent's Motion to Dismiss Petitioner’s Motion for Retroactive Child Support and grant such other and further relief as the Court deems just and proper.** --- I hope this helps! Let me know if you need any further adjustments.

How would you better draft the entire thing?

How do I phrase this with persuading? language?Missed Deadlines: a. On September *, *, Naser was given 21 days to respond to my motion for retroactive child support, EDGE provide an updated financial affidavit.with a deadline of October *, *. Naser missed this deadline.