Motion Dismissal Objection Guide

Can you read my text and tell me? How to finish the ending?

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 for Substitution of Judge for Cause NOW COMES the Petitioner, Lula Korotkov, proceeding pro se, pursuant to the Illinois Civil Code of Procedure. Hereby, Petitioner files an Objection to Respondent’s Motion to Dismiss Petitioner’s Motion for Substitution of Judge for Cause. 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 May *, *, my attorney officially filed his appearance. The State’s attorney withdrew from the case. This action was influenced by my decision to hire a private attorney after I found a hidden account in the respondent’s name. I noticed a substantial amount of money being spent and transferred via Zelle and Apple Cash to Lisa Marie Calderon and her adult sons. *. On May *, *, my attorney filed a motion for a temporary child support payment of $* per month. Those payments started in June * and ended in November * However, this amount was insufficient to meet the needs of three teenage children. This was especially significant given that Lisa Calderon and her sons spent $*,* of the Respondent’s money on dining out in a single week, intentionally depriving his biological children of these resources. Exhibit A provides evidence of the substantial amount of money being spent on Ms. Calderon and her sons. *. On June *, *, both parties were required to exchange updated financial affidavits, along with the necessary supporting documents. Despite the judge’s clear instruction for the Respondent to submit all required documents, the Respondent’s girlfriend persistently emailed Mr. Renzetti, refusing to comply and impersonating the Respondent. Evidence of this can be found in Exhibit K. *. On October *, *, my initial legal counsel filed a motion to withdraw due to the persistent interference from Lisa Calderon, the Respondent’s girlfriend. Lisa Marie Calderon has been impersonating the Respondent throughout this process and has deliberately sent misleading emails to my attorney with the intent to undermine my credibility. *. On October *, *, the court granted Mr. Renzetti’s request to withdraw from this case. *. On December 19th, *, a motion was filed for the continuation of the same temporary support amount of $* per month. This is despite my explicit instruction to Mr. Hook to request an increase in the temporary child support to $* per month. As the amount of $* was insufficient for the sustenance of our three teenage children. Furthermore, it has come to my attention that the Respondent is allocating $* on pizza for Lisa Calderon’s consumption, while our three minor children experience hunger and retire to bed without adequate nourishment. This disparity in the allocation of resources is concerning and I believe it should be taken into consideration. *. On March *, *, the Respondent was served with a three-page order to produce by my second attorney, Mr. Hook. Despite this explicit instruction, the Respondent once again did not comply, demonstrating a consistent pattern of non-compliance. Moreover, the documented evidence provided clearly indicates that Lisa Calderon, the Respondent’s girlfriend, continued to impersonate the Respondent and send emails to Mr. Hook, as she had done with Mr. Renzetti, making false claims intended to undermine my credibility. This is corroborated by the evidence in Exhibit H. *. Both parties were required to revise our financial affidavits on February *, *. My financial affidavit was revised and notarized on February *, *, as the evidence will show. However, it took the Respondent until June *, *, four months later, to revise and notarize his financial affidavit, as the evidence clearly demonstrates. This is a clear example of the Respondent’s consistent failure to adhere to the court’s orders. Evidence in Exhibit H. *. On June *, *, the respondent provided some documents. These included one month’s worth of bank statements from each of his two Chase accounts, a document from the IRS indicating his outstanding debt, his financial affidavit that was due in February, and a W-* form. Evidence in Exhibit H. *. On July *, *, a rule to show cause was filed against the respondent. A rule to show cause was filed against the respondent due to his non-compliance with a discovery request that had been served on him on March *, *. Evidence can be seen in Exhibit H. *. On July *, *, Mrs. Caldoron engaged the services of an attorney/attorneys with the Respondent’s money that she is keeping from the children. This action was taken immediately after the respondent received the DNA results of his children. Mrs. Caldoron had managed to convince the Respondent that his biological children, who had been raised by him, were not actually his biological children. Consequently, she sought the assistance of attorneys with the intention of concealing the Respondent’s assets and money from his children, who are, in fact, legally entitled to them. *. 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 December *, *, I made the decision to request my attorney to step down. This decision was made because he did not have the authority to negotiate a child support agreement on behalf of three children who have been enduring hardship. *. Motions filed by me, as the ****, a. Motion to Reconsider filed on December *, *. b. Petition for Rule to Show Cause: This petition was filed on February *, *, with a hearing date set for February *, *. This motion was stricken on February *, *, due to an oversight on my part - I failed to sign it. c. Motion for Sanctions Against Respondent’s Counsel for Filing Frivolous Motions: This motion was filed on February *, *, with a hearing date set for February *, *. Delayed by four months by the judge. d. Motion for Contempt and Sanctions for Fraudulent Misrepresentation, Obstruction of Child Support Proceedings, and Third-Party Interference: This motion was filed on February *, *. with a hearing date set for. March *, *. Delayed by four months by the judge. e. Motion to Expedite Proceedings and Address Frivolous Filings Endangering Children's well-being: This Motion was also Filed on February *, *, with a hearing date set for March *, *. Delayed by four months by the judge. f. Motion for substitution of judge for cause. Filed March *, *. *. On March *, *, after the hearing for substitution of judge for cause, I took the necessary corrective measures and filed the appropriate affidavit with the corrected statute for substitution of judge for cause. In addition, I filed an amended motion for the substitution of judge for cause. It is crucial to note that these actions were accompanied by due notifications. Copies of the affidavit, the amended motion, and the notice were sent via email to both the court and the opposing parties attorney on the same day. I believe these actions demonstrate my commitment to transparency and due process. *. It’s becoming increasingly apparent that the opposing party’s attorney is intentionally misrepresenting and delaying matters. Despite the clear distinction between motions and pleadings, the opposing party’s attorney has been consistently mislabeling my motions as pleadings. This mischaracterization seems to be a strategic move, not a mere oversight. By incorrectly applying civil codes and statutory laws, such as §*-* of the Illinois Code of Civil Procedure, which are relevant to pleadings, the opposing party’s attorney is attempting to obfuscate the issues at hand. In response to this, I would like to clarify that the section that the opposing party’s attorney referenced, §*-* of the Illinois Code of Civil Procedure, is applicable to objections to pleadings. Pleadings are formal written statements that present a party’s claims or defenses against another party’s claims in a civil action, and they help frame the issues to be decided in a lawsuit. However, a motion for substitution of judge for cause in a child support case do not fall under the category of pleadings. Instead, they are motions, which are formal requests made to the court to obtain a ruling or order directing some act to be done in favor of the applicant. Since these are motions and not pleadings, they are not subject to the same rules and procedures outlined in §*-* of the Illinois Code of Civil Procedure. Therefore, the specific requirements of §*-*, such as pointing out defects in the pleadings or asking for a pleading to be made more definite, do not apply to these motions. *. I also wish to draw the court’s attention to the pattern of frivolous litigation and abuse of process by the opposing party. They have been intentionally filing motions to dismiss, which all contain intentional falsehoods and misleading statements that bear no relevance to the facts stated in any of my motions. As can be seen, the opposing party’s motion, numbered * through *, are inaccurate and irrelevant to all the facts stated in the motion for substitution of the judge for cause. The intent behind these actions is to delay the proceedings until our twin boys graduate high school this June. Moreover, it’s an attempt to distract from the perjury and intentional infliction of neglect, financial, emotional, psychological, and mental harm that has been inflicted on the children. This is not an accidental pattern, but a calculated tactic. I respectfully ask the court to consider this deliberate abuse of process when reviewing the opposing party’s motions. As this motion is identical to their motion to dismiss, the motion to reconsider. *. Under Rule * of the Illinois Supreme Court The signature of an attorney or party certifies that they have read the document, and to the best of their knowledge, it is well grounded in fact and is warranted by existing law or a good-faith argument for the extension, modification, or reversal of existing law. The document should not be interposed for any improper purpose, such as to harass or to cause unnecessary delay. If a document is signed in violation of this rule, the court may impose an appropriate sanction. “The term ‘grounded in facts’ refers to the idea that an argument, belief, or conviction is based on real, verifiable information, rather than being arbitrary or baseless. This term is often used in legal contexts, where a document or argument is considered ‘well-grounded in fact’ if it accurately reflects the circumstances and evidence at hand, meaning that its claims or assertions are supported by factual evidence.” *. In legal proceedings, pleadings and motions are two different types of documents that serve different purposes: A pleading is a formal written statement in which a party to a legal proceeding (like a lawsuit) sets out their claims or defenses. This is the initial step in a lawsuit where parties formally submit their claims and defenses. The complaint and answer are common examples of pleadings. A motion, on the other hand, is a procedural device to bring a limited, contested issue before the court for decision. It is a request made to a court or judge for the purpose of obtaining a rule or order directing some act to be done in favor of the applicant. Motions may be made at any point in the proceedings and are not confined to the beginning phases of a lawsuit. Under Rule *, these two are listed separately, which means that a motion filed in a child support case is considered a “motion,” not a “pleading.” This distinction is important because it affects how the court processes and considers each type of document. For example, the rules of civil procedure may require different timeframes for responding to pleadings versus motions. * ILCS */*-* Sec. *-*. Substitution of judge. a A substitution of judge in any civil action may be had in the following situations: * Substitution for cause. When cause exists. i Each party shall be entitled to a substitution or substitutions of judge for cause. ii Every application for substitution of judge for cause shall be made by petition, setting forth the specific cause for substitution and praying a substitution of judge. The petition shall be verified by the affidavit of the applicant. iii Upon the filing of a petition for substitution of judge for cause, a hearing to determine whether the cause exists shall be conducted as soon as possible by a judge other than the judge named in the petition. The judge named in the petition need not testify but may submit an affidavit if the judge wishes. If the petition is allowed, the case shall be assigned to a judge not named in the petition. If the petition is denied, the case shall be assigned back to the judge named in the petition. *. In Illinois, the guidelines for filing a motion for substitution of judge due to bias do not specify a particular timeline. Upon recognizing the potential bias of the presiding judge in this case, I felt that this bias has already affected the fairness of the trial. As a result, I promptly filed a motion for substitution of judge for cause. *. The actions of the judge in this case have demonstrated a bias. This bias is not about personal prejudice, but rather a pattern of decision-making that consistently favors one party over the other, which is the definition of bias in a legal context. This is evident in the judge’s decision to expedite and approve the opposing party’s motion to impound records, and all the other instances I mentioned in my motion for the substitution of the judge for cause. All of these were done without thoroughly examining the exhibits and evidence. The judge’s decisions are being made based on inaccurate information that has been deliberately included in the opposing party’s motions. Despite the evidence I’ve provided, both electronically and in person, these unfounded motions are being accepted by the judge without proper scrutiny. Consequently, the judge’s rulings are based on misleading information. If the judge had looked at the exhibits A, B, M, and N, she would have seen that the respondent’s account number was redacted on his bank statements. Bank statements do not display personal routing numbers, and cashier’s checks do not display the purchaser’s personal account or routing number. They display the bank’s account and routing number, not the respondents. These decisions are not in the best interest of the children involved and have further endangered their well-being. The judge’s actions have shown a disregard for the well-being of the children, which is a serious concern in this case. This situation calls for a fair and unbiased examination of the facts to ensure the best outcome for the children involved. *. I have attached a few pieces of documented evidence. a. Two copies of my notarized financial affidavit dated February *, *, Not as was falsely stated in #* of the opposing party’s motion, they are once again falsely claiming that my affidavit has not been updated to date. The exact same statement was falsely made in their motion to dismiss the motion to reconsider. b. Two copies of Zelle requests from the children, which they actually sent to their father; However, Lisa Marie Calderon is the one receiving these requests. As can be seen, one was declined, and the other was ignored until it expired. c. Two emails, directed to the children, demonstrate that Lisa Marie Calderon is clearly impersonating the respondent to the children. This occurred after the children had to have their DNA taken, causing even more damage to three innocent children. *. These are not my own narratives or allegations. These are facts documented by evidence.

Should I be stating some kind of legal prayer or asking for. relief or something

read it again 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 for Substitution of Judge for Cause NOW COMES the Petitioner, Lula Korotkov, proceeding pro se, pursuant to the Illinois Civil Code of Procedure. Hereby, Petitioner files an Objection to Respondent’s Motion to Dismiss Petitioner’s Motion for Substitution of Judge for Cause. 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 May *, *, my attorney officially filed his appearance. The State’s attorney withdrew from the case. This action was influenced by my decision to hire a private attorney after I found a hidden account in the respondent’s name. I noticed a substantial amount of money being spent and transferred via Zelle and Apple Cash to Lisa Marie Calderon and her adult sons. *. On May *, *, my attorney filed a motion for a temporary child support payment of $* per month. Those payments started in June * and ended in November * However, this amount was insufficient to meet the needs of three teenage children. This was especially significant given that Lisa Calderon and her sons spent $*,* of the Respondent’s money on dining out in a single week, intentionally depriving his biological children of these resources. Exhibit A provides evidence of the substantial amount of money being spent on Ms. Calderon and her sons. *. On June *, *, both parties were required to exchange updated financial affidavits, along with the necessary supporting documents. Despite the judge’s clear instruction for the Respondent to submit all required documents, the Respondent’s girlfriend persistently emailed Mr. Renzetti, refusing to comply and impersonating the Respondent. Evidence of this can be found in Exhibit K. *. On October *, *, my initial legal counsel filed a motion to withdraw due to the persistent interference from Lisa Calderon, the Respondent’s girlfriend. Lisa Marie Calderon has been impersonating the Respondent throughout this process and has deliberately sent misleading emails to my attorney with the intent to undermine my credibility. *. On October *, *, the court granted Mr. Renzetti’s request to withdraw from this case. *. On December 19th, *, a motion was filed for the continuation of the same temporary support amount of $* per month. This is despite my explicit instruction to Mr. Hook to request an increase in the temporary child support to $* per month. As the amount of $* was insufficient for the sustenance of our three teenage children. Furthermore, it has come to my attention that the Respondent is allocating $* on pizza for Lisa Calderon’s consumption, while our three minor children experience hunger and retire to bed without adequate nourishment. This disparity in the allocation of resources is concerning and I believe it should be taken into consideration. *. On March *, *, the Respondent was served with a three-page order to produce by my second attorney, Mr. Hook. Despite this explicit instruction, the Respondent once again did not comply, demonstrating a consistent pattern of non-compliance. Moreover, the documented evidence provided clearly indicates that Lisa Calderon, the Respondent’s girlfriend, continued to impersonate the Respondent and send emails to Mr. Hook, as she had done with Mr. Renzetti, making false claims intended to undermine my credibility. This is corroborated by the evidence in Exhibit H. *. Both parties were required to revise our financial affidavits on February *, *. My financial affidavit was revised and notarized on February *, *, as the evidence will show. However, it took the Respondent until June *, *, four months later, to revise and notarize his financial affidavit, as the evidence clearly demonstrates. This is a clear example of the Respondent’s consistent failure to adhere to the court’s orders. Evidence in Exhibit H. *. On June *, *, the respondent provided some documents. These included one month’s worth of bank statements from each of his two Chase accounts, a document from the IRS indicating his outstanding debt, his financial affidavit that was due in February, and a W-* form. Evidence in Exhibit H. *. On July *, *, a rule to show cause was filed against the respondent. A rule to show cause was filed against the respondent due to his non-compliance with a discovery request that had been served on him on March *, *. Evidence can be seen in Exhibit H. *. On July *, *, Mrs. Caldoron engaged the services of an attorney/attorneys with the Respondent’s money that she is keeping from the children. This action was taken immediately after the respondent received the DNA results of his children. Mrs. Caldoron had managed to convince the Respondent that his biological children, who had been raised by him, were not actually his biological children. Consequently, she sought the assistance of attorneys with the intention of concealing the Respondent’s assets and money from his children, who are, in fact, legally entitled to them. *. 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 December *, *, I made the decision to request my attorney to step down. This decision was made because he did not have the authority to negotiate a child support agreement on behalf of three children who have been enduring hardship. *. Motions filed by me, as the ****, a. Motion to Reconsider filed on December *, *. b. Petition for Rule to Show Cause: This petition was filed on February *, *, with a hearing date set for February *, *. This motion was stricken on February *, *, due to an oversight on my part - I failed to sign it. c. Motion for Sanctions Against Respondent’s Counsel for Filing Frivolous Motions: This motion was filed on February *, *, with a hearing date set for February *, *. Delayed by four months by the judge. d. Motion for Contempt and Sanctions for Fraudulent Misrepresentation, Obstruction of Child Support Proceedings, and Third-Party Interference: This motion was filed on February *, *. with a hearing date set for. March *, *. Delayed by four months by the judge. e. Motion to Expedite Proceedings and Address Frivolous Filings Endangering Children's well-being: This Motion was also Filed on February *, *, with a hearing date set for March *, *. Delayed by four months by the judge. f. Motion for substitution of judge for cause. Filed March *, *. *. On March *, *, after the hearing for substitution of judge for cause, I took the necessary corrective measures and filed the appropriate affidavit with the corrected statute for substitution of judge for cause. In addition, I filed an amended motion for the substitution of judge for cause. It is crucial to note that these actions were accompanied by due notifications. Copies of the affidavit, the amended motion, and the notice were sent via email to both the court and the opposing parties attorney on the same day. I believe these actions demonstrate my commitment to transparency and due process. *. It’s becoming increasingly apparent that the opposing party’s attorney is intentionally misrepresenting and delaying matters. Despite the clear distinction between motions and pleadings, the opposing party’s attorney has been consistently mislabeling my motions as pleadings. This mischaracterization seems to be a strategic move, not a mere oversight. By incorrectly applying civil codes and statutory laws, such as §*-* of the Illinois Code of Civil Procedure, which are relevant to pleadings, the opposing party’s attorney is attempting to obfuscate the issues at hand. In response to this, I would like to clarify that the section that the opposing party’s attorney referenced, §*-* of the Illinois Code of Civil Procedure, is applicable to objections to pleadings. Pleadings are formal written statements that present a party’s claims or defenses against another party’s claims in a civil action, and they help frame the issues to be decided in a lawsuit. However, a motion for substitution of judge for cause in a child support case do not fall under the category of pleadings. Instead, they are motions, which are formal requests made to the court to obtain a ruling or order directing some act to be done in favor of the applicant. Since these are motions and not pleadings, they are not subject to the same rules and procedures outlined in §*-* of the Illinois Code of Civil Procedure. Therefore, the specific requirements of §*-*, such as pointing out defects in the pleadings or asking for a pleading to be made more definite, do not apply to these motions. *. I also wish to draw the court’s attention to the pattern of frivolous litigation and abuse of process by the opposing party. They have been intentionally filing motions to dismiss, which all contain intentional falsehoods and misleading statements that bear no relevance to the facts stated in any of my motions. As can be seen, the opposing party’s motion, numbered * through *, are inaccurate and irrelevant to all the facts stated in the motion for substitution of the judge for cause. The intent behind these actions is to delay the proceedings until our twin boys graduate high school this June. Moreover, it’s an attempt to distract from the perjury and intentional infliction of neglect, financial, emotional, psychological, and mental harm that has been inflicted on the children. This is not an accidental pattern, but a calculated tactic. I respectfully ask the court to consider this deliberate abuse of process when reviewing the opposing party’s motions. As this motion is identical to their motion to dismiss, the motion to reconsider. *. Under Rule * of the Illinois Supreme Court The signature of an attorney or party certifies that they have read the document, and to the best of their knowledge, it is well grounded in fact and is warranted by existing law or a good-faith argument for the extension, modification, or reversal of existing law. The document should not be interposed for any improper purpose, such as to harass or to cause unnecessary delay. If a document is signed in violation of this rule, the court may impose an appropriate sanction. “The term ‘grounded in facts’ refers to the idea that an argument, belief, or conviction is based on real, verifiable information, rather than being arbitrary or baseless. This term is often used in legal contexts, where a document or argument is considered ‘well-grounded in fact’ if it accurately reflects the circumstances and evidence at hand, meaning that its claims or assertions are supported by factual evidence.” *. In legal proceedings, pleadings and motions are two different types of documents that serve different purposes: A pleading is a formal written statement in which a party to a legal proceeding (like a lawsuit) sets out their claims or defenses. This is the initial step in a lawsuit where parties formally submit their claims and defenses. The complaint and answer are common examples of pleadings. A motion, on the other hand, is a procedural device to bring a limited, contested issue before the court for decision. It is a request made to a court or judge for the purpose of obtaining a rule or order directing some act to be done in favor of the applicant. Motions may be made at any point in the proceedings and are not confined to the beginning phases of a lawsuit. Under Rule *, these two are listed separately, which means that a motion filed in a child support case is considered a “motion,” not a “pleading.” This distinction is important because it affects how the court processes and considers each type of document. For example, the rules of civil procedure may require different timeframes for responding to pleadings versus motions. * ILCS */*-* Sec. *-*. Substitution of judge. a A substitution of judge in any civil action may be had in the following situations: * Substitution for cause. When cause exists. i Each party shall be entitled to a substitution or substitutions of judge for cause. ii Every application for substitution of judge for cause shall be made by petition, setting forth the specific cause for substitution and praying a substitution of judge. The petition shall be verified by the affidavit of the applicant. iii Upon the filing of a petition for substitution of judge for cause, a hearing to determine whether the cause exists shall be conducted as soon as possible by a judge other than the judge named in the petition. The judge named in the petition need not testify but may submit an affidavit if the judge wishes. If the petition is allowed, the case shall be assigned to a judge not named in the petition. If the petition is denied, the case shall be assigned back to the judge named in the petition. *. In Illinois, the guidelines for filing a motion for substitution of judge due to bias do not specify a particular timeline. Upon recognizing the potential bias of the presiding judge in this case, I felt that this bias has already affected the fairness of the trial. As a result, I promptly filed a motion for substitution of judge for cause. *. The actions of the judge in this case have demonstrated a bias. This bias is not about personal prejudice, but rather a pattern of decision-making that consistently favors one party over the other, which is the definition of bias in a legal context. This is evident in the judge’s decision to expedite and approve the opposing party’s motion to impound records, and all the other instances I mentioned in my motion for the substitution of the judge for cause. All of these were done without thoroughly examining the exhibits and evidence. The judge’s decisions are being made based on inaccurate information that has been deliberately included in the opposing party’s motions. Despite the evidence I’ve provided, both electronically and in person, these unfounded motions are being accepted by the judge without proper scrutiny. Consequently, the judge’s rulings are based on misleading information. If the judge had looked at the exhibits A, B, M, and N, she would have seen that the respondent’s account number was redacted on his bank statements. Bank statements do not display personal routing numbers, and cashier’s checks do not display the purchaser’s personal account or routing number. They display the bank’s account and routing number, not the respondents. These decisions are not in the best interest of the children involved and have further endangered their well-being. The judge’s actions have shown a disregard for the well-being of the children, which is a serious concern in this case. This situation calls for a fair and unbiased examination of the facts to ensure the best outcome for the children involved. *. I have attached a few pieces of documented evidence. a. Two copies of my notarized financial affidavit dated February *, *, Not as was falsely stated in #* of the opposing party’s motion, they are once again falsely claiming that my affidavit has not been updated to date. The exact same statement was falsely made in their motion to dismiss the motion to reconsider. b. Two copies of Zelle requests from the children, which they actually sent to their father; However, Lisa Marie Calderon is the one receiving these requests. As can be seen, one was declined, and the other was ignored until it expired. c. Two emails, directed to the children, demonstrate that Lisa Marie Calderon is clearly impersonating the respondent to the children. This occurred after the children had to have their DNA taken, causing even more damage to three innocent children. *. These are not my own narratives or allegations. These are facts documented by evidence.

And how would I exactly do that