Repeated False Statements Identified

Can you read the text? And tell me. If you see. The identical. Misleading. Statements. By the opposing party which is meant. To confuse the court.

MOTION TO DISMISS PETITIONER’S MOTION FOR SANCTIONS AGAINST RESPONDENT’S COUNSEL FOR FILING FRIVOLOUS MOTIONS AND OTHER RELIEF NOW COMES Respondent, NASER BEGANOVIC (hereinafter “NASER”) by and through his attorney, Alyana Abellar of Blacha Law Office, LLC, and pursuant to the Illinois Civil Code of Procedure, and relevant case law, hereby files his Motion to Dismiss Petitioner’s Motion for Contempt and Sanctions for Fraudulent Misrepresentation, Obstruction of Child Support Proceedings, and Third Party Interference (hereinafter “Motion”), and in support hereof, NASER states as follows: *. That Petitioner, LULA KOROTKOV (hereinafter “LULA”), and NASER were never married, but shared three (*) children together, namely: A.K., and J.K., both born in September *, and S.K., born in October *. *. That the parties were living together from their children’s birth until their separation in *. *. On May *, *, Petitioner, LULA KOROTKOV (hereinafter referred to as “LULA”) filed her Complaint for Support through the Healthcare and Family Services (“HFS”). *. On October *, *, NASER filed his Appearance. *. On November *, *, HFS filed a Motion for an Order of Support. *. On February *, *, HFS through the Cook County State’s Attorney’s Office (“State”) was granted additional time to “review financials and make recommendation for child support/medical/retroactive support.” See February *, * Order incorporated herein by reference only. *. On March *, *, this matter was set for hearing on HFS’ Complaint for Support, and LULA requested a continuance to obtain her own counsel. See March *, * Order incorporated herein by reference only. *. Between March *, * and the date of filing of this Motion, LULA has asked her two previous attorneys to withdraw. Specifically, counting the Assistant State Attorney, LULA has had three attorneys helping her in the instant matter, with her last counsel withdrawing on December *, *, shortly after this Court conducted a Pretrial.

MOTION TO DISMISS PETITIONER’S MOTION FOR SUBSTITUTION OF JUDGE FOR CAUSE NOW COMES Respondent, NASER BEGANOVIC (hereinafter “NASER”) by and through his attorney, Alyana Abellar of Blacha Law Office, LLC, and pursuant to the Illinois Civil Code of Procedure, hereby files his Motion to Dismiss Petitioner’s Motion Substitute Judge for Cause (hereinafter “Motion”), and in support hereof, NASER states as follows: *. That Petitioner, LULA KOROTKOV (hereinafter “LULA”), and NASER were never married, but shared three (*) children together, namely: A.K., and J.K., both born in September *, and S.K., born in October *. *. That the parties were living together from their children’s birth until their separation in *. *. On May *, *, Petitioner, LULA KOROTKOV (hereinafter referred to as “LULA”) filed her Complaint for Support through the Healthcare and Family Services (“HFS”). *. On October *, *, NASER filed his Appearance. *. On November *, *, HFS filed a Motion for an Order of Support. *. On February *, *, HFS through the Cook County State’s Attorney’s Office (“State”) was granted additional time to “review financials and make recommendation for child support/medical/retroactive support.” See February *, *, Order incorporated herein by reference only. *. On March *, *, this matter was set for hearing on HFS’ Complaint for Support, and LULA requested a continuance to obtain her own counsel. See March *, *, Order incorporated herein by reference only. *. On May *, *, LULA’s first counsel filed his appearance on LULA’s behalf after being granted leave to do so. On the same day, the HFS’ Complaint for Support was withdrawn and this matter is taken off call as to State issues. See May *, *, Order incorporated herein by reference only. *. During the May *, *, court date, it appears that the parties agreed to set temporary support at $*.* per month. NASER has been making said payments since then. *. On June *, *, LULA through her first counsel filed a Motion for Temporary Support. Parties were then required to exchange updated financial affidavits with supporting documentation. *. LULA’s first counsel filed his Motion to Withdraw on October *, *. *. On October *, *, the Motion to Withdraw was granted and LULA was ordered to file an appearance within 21 days. LULA did not file an appearance within 21 days and on November *, *, this matter was again taken off call and the pleading is stricken with leave to reinstate. *. On December *, *, LULA’s second counsel filed a Motion for Temporary Support. *. On March *, *, LULA’s counsel served NASER his request to produce documents. *. On April *, *, both parties were ordered to exchange financial affidavits and NASER was ordered to produce the documents LULA’s counsel requested. To date, LULA has not updated her financial affidavit. *. On June *, *, NASER sent LULA’s counsel his updated financial affidavit, bank statements, * W2, and documents from IRS. *. On July *, *, LULA filed her Petition for Issuance of Rule to Show Cause alleging that NASER failed to comply with LULA’s discovery request. *. On July *, *, undersigned counsel filed an Appearance on behalf of NASER. *. On November *, *, this Court conducted a pretrial conference whereby per the parties’ agreement, an Order for Support was entered setting permanent child support for the parties’ three minor children at the rate of $*,*.* per month to be paid bi-weekly consistent with NASER’s pay schedule, beginning December *, *. During said pretrial, LULA was present in the courtroom, and should have had sufficient time to confer with her then counsel. *. On December *, *, LULA’s previous second counsel, Gene Hook, Jr., filed his Motion to Withdraw which was granted on December *, *. Since the withdrawal of Mr. Hook as LULA’s counsel, LULA has filed several pro se Motions which are as follows: a) Motion for Reconsideration; b) Motion to

No. In one motion. To opposing party is listing. False and accurate information. * to * That is irrelevant. Two statements in my motion. End the opposing parties second motion. It's a listing. The exact same false, inaccurate, irreverent. Statements * to *

I want to know if you were able. To catch that. The two motions. Are almost identical. And one they're listing false statements one through *. And the other delisting false information * Through *.

MOTION TO DISMISS PETITIONER’S MOTION FOR SANCTIONS AGAINST RESPONDENT’S COUNSEL FOR FILING FRIVOLOUS MOTIONS AND OTHER RELIEF NOW COMES Respondent, NASER BEGANOVIC (hereinafter “NASER”) by and through his attorney, Alyana Abellar of Blacha Law Office, LLC, and pursuant to the Illinois Civil Code of Procedure, and relevant case law, hereby files his Motion to Dismiss Petitioner’s Motion for Contempt and Sanctions for Fraudulent Misrepresentation, Obstruction of Child Support Proceedings, and Third Party Interference (hereinafter “Motion”), and in support hereof, NASER states as follows: *. That Petitioner, LULA KOROTKOV (hereinafter “LULA”), and NASER were never married, but shared three (*) children together, namely: A.K., and J.K., both born in September *, and S.K., born in October *. *. That the parties were living together from their children’s birth until their separation in *. *. On May *, *, Petitioner, LULA KOROTKOV (hereinafter referred to as “LULA”) filed her Complaint for Support through the Healthcare and Family Services (“HFS”). *. On October *, *, NASER filed his Appearance. *. On November *, *, HFS filed a Motion for an Order of Support. *. On February *, *, HFS through the Cook County State’s Attorney’s Office (“State”) was granted additional time to “review financials and make recommendation for child support/medical/retroactive support.” See February *, * Order incorporated herein by reference only. *. On March *, *, this matter was set for hearing on HFS’ Complaint for Support, and LULA requested a continuance to obtain her own counsel. See March *, * Order incorporated herein by reference only. *. Between March *, * and the date of filing of this Motion, LULA has asked her two previous attorneys to withdraw. Specifically, counting the Assistant State Attorney, LULA has had three attorneys helping her in the instant matter, with her last counsel withdrawing on December *, *, shortly after this Court conducted a Pretrial.

MOTION TO DISMISS PETITIONER’S MOTION FOR SUBSTITUTION OF JUDGE FOR CAUSE NOW COMES Respondent, NASER BEGANOVIC (hereinafter “NASER”) by and through his attorney, Alyana Abellar of Blacha Law Office, LLC, and pursuant to the Illinois Civil Code of Procedure, hereby files his Motion to Dismiss Petitioner’s Motion Substitute Judge for Cause (hereinafter “Motion”), and in support hereof, NASER states as follows: *. That Petitioner, LULA KOROTKOV (hereinafter “LULA”), and NASER were never married, but shared three (*) children together, namely: A.K., and J.K., both born in September *, and S.K., born in October *. *. That the parties were living together from their children’s birth until their separation in *. *. On May *, *, Petitioner, LULA KOROTKOV (hereinafter referred to as “LULA”) filed her Complaint for Support through the Healthcare and Family Services (“HFS”). *. On October *, *, NASER filed his Appearance. *. On November *, *, HFS filed a Motion for an Order of Support. *. On February *, *, HFS through the Cook County State’s Attorney’s Office (“State”) was granted additional time to “review financials and make recommendation for child support/medical/retroactive support.” See February *, *, Order incorporated herein by reference only. *. On March *, *, this matter was set for hearing on HFS’ Complaint for Support, and LULA requested a continuance to obtain her own counsel. See March *, *, Order incorporated herein by reference only. *. On May *, *, LULA’s first counsel filed his appearance on LULA’s behalf after being granted leave to do so. On the same day, the HFS’ Complaint for Support was withdrawn and this matter is taken off call as to State issues. See May *, *, Order incorporated herein by reference only. *. During the May *, *, court date, it appears that the parties agreed to set temporary support at $*.* per month. NASER has been making said payments since then. *. On June *, *, LULA through her first counsel filed a Motion for Temporary Support. Parties were then required to exchange updated financial affidavits with supporting documentation. *. LULA’s first counsel filed his Motion to Withdraw on October *, *. *. On October *, *, the Motion to Withdraw was granted and LULA was ordered to file an appearance within 21 days. LULA did not file an appearance within 21 days and on November *, *, this matter was again taken off call and the pleading is stricken with leave to reinstate. *. On December *, *, LULA’s second counsel filed a Motion for Temporary Support. *. On March *, *, LULA’s counsel served NASER his request to produce documents. *. On April *, *, both parties were ordered to exchange financial affidavits and NASER was ordered to produce the documents LULA’s counsel requested. To date, LULA has not updated her financial affidavit. *. On June *, *, NASER sent LULA’s counsel his updated financial affidavit, bank statements, * W2, and documents from IRS. *. On July *, *, LULA filed her Petition for Issuance of Rule to Show Cause alleging that NASER failed to comply with LULA’s discovery request. *. On July *, *, undersigned counsel filed an Appearance on behalf of NASER. *. On November *, *, this Court conducted a pretrial conference whereby per the parties’ agreement, an Order for Support was entered setting permanent child support for the parties’ three minor children at the rate of $*,*.* per month to be paid bi-weekly consistent with NASER’s pay schedule, beginning December *, *. During said pretrial, LULA was present in the courtroom, and should have had sufficient time to confer with her then counsel. *. On December *, *, LULA’s previous second counsel, Gene Hook, Jr., filed his Motion to Withdraw which was granted on December *, *. Since the withdrawal of Mr. Hook as LULA’s counsel, LULA has filed several pro se Motions which are as follows: a) Motion for Reconsideration; b) Motion to

I'm trying to explain. That the opposing party has been. Filing frivolous motions. To dismiss. Stating. The exact same. Untrue. Statements. For example, in one motion they will list. False statements one through *. And another motion they'll list false. The same statements numbered one through *. Despite knowing that I have documented evidence. Refuting their claims. They continue that pattern.

For example. In this motion. Read their text. In .* through .*.MOTION TO DISMISS PETITIONER’S MOTION FOR SANCTIONS AGAINST RESPONDENT’S COUNSEL FOR FILING FRIVOLOUS MOTIONS AND OTHER RELIEF NOW COMES Respondent, NASER BEGANOVIC (hereinafter “NASER”) by and through his attorney, Alyana Abellar of Blacha Law Office, LLC, and pursuant to the Illinois Civil Code of Procedure, and relevant case law, hereby files his Motion to Dismiss Petitioner’s Motion for Contempt and Sanctions for Fraudulent Misrepresentation, Obstruction of Child Support Proceedings, and Third Party Interference (hereinafter “Motion”), and in support hereof, NASER states as follows: *. That Petitioner, LULA KOROTKOV (hereinafter “LULA”), and NASER were never married, but shared three (*) children together, namely: A.K., and J.K., both born in September *, and S.K., born in October *. *. That the parties were living together from their children’s birth until their separation in *. *. On May *, *, Petitioner, LULA KOROTKOV (hereinafter referred to as “LULA”) filed her Complaint for Support through the Healthcare and Family Services (“HFS”). *. On October *, *, NASER filed his Appearance. *. On November *, *, HFS filed a Motion for an Order of Support. *. On February *, *, HFS through the Cook County State’s Attorney’s Office (“State”) was granted additional time to “review financials and make recommendation for child support/medical/retroactive support.” See February *, * Order incorporated herein by reference only. *. On March *, *, this matter was set for hearing on HFS’ Complaint for Support, and LULA requested a continuance to obtain her own counsel. See March *, * Order incorporated herein by reference only. *. Between March *, * and the date of filing of this Motion, LULA has asked her two previous attorneys to withdraw. Specifically, counting the Assistant State Attorney, LULA has had three attorneys helping her in the instant matter, with her last counsel withdrawing on December *, *, shortly after this Court conducted a Pretrial.

Now read text. And their other emotion from point * Through point. * MOTION TO DISMISS PETITIONER’S MOTION FOR SUBSTITUTION OF JUDGE FOR CAUSE NOW COMES Respondent, NASER BEGANOVIC (hereinafter “NASER”) by and through his attorney, Alyana Abellar of Blacha Law Office, LLC, and pursuant to the Illinois Civil Code of Procedure, hereby files his Motion to Dismiss Petitioner’s Motion Substitute Judge for Cause (hereinafter “Motion”), and in support hereof, NASER states as follows: *. That Petitioner, LULA KOROTKOV (hereinafter “LULA”), and NASER were never married, but shared three (*) children together, namely: A.K., and J.K., both born in September *, and S.K., born in October *. *. That the parties were living together from their children’s birth until their separation in *. *. On May *, *, Petitioner, LULA KOROTKOV (hereinafter referred to as “LULA”) filed her Complaint for Support through the Healthcare and Family Services (“HFS”). *. On October *, *, NASER filed his Appearance. *. On November *, *, HFS filed a Motion for an Order of Support. *. On February *, *, HFS through the Cook County State’s Attorney’s Office (“State”) was granted additional time to “review financials and make recommendation for child support/medical/retroactive support.” See February *, *, Order incorporated herein by reference only. *. On March *, *, this matter was set for hearing on HFS’ Complaint for Support, and LULA requested a continuance to obtain her own counsel. See March *, *, Order incorporated herein by reference only. *. On May *, *, LULA’s first counsel filed his appearance on LULA’s behalf after being granted leave to do so. On the same day, the HFS’ Complaint for Support was withdrawn and this matter is taken off call as to State issues. See May *, *, Order incorporated herein by reference only. *. During the May *, *, court date, it appears that the parties agreed to set temporary support at $*.* per month. NASER has been making said payments since then. *. On June *, *, LULA through her first counsel filed a Motion for Temporary Support. Parties were then required to exchange updated financial affidavits with supporting documentation. *. LULA’s first counsel filed his Motion to Withdraw on October *, *. *. On October *, *, the Motion to Withdraw was granted and LULA was ordered to file an appearance within 21 days. LULA did not file an appearance within 21 days and on November *, *, this matter was again taken off call and the pleading is stricken with leave to reinstate. *. On December *, *, LULA’s second counsel filed a Motion for Temporary Support. *. On March *, *, LULA’s counsel served NASER his request to produce documents. *. On April *, *, both parties were ordered to exchange financial affidavits and NASER was ordered to produce the documents LULA’s counsel requested. To date, LULA has not updated her financial affidavit. *. On June *, *, NASER sent LULA’s counsel his updated financial affidavit, bank statements, * W2, and documents from IRS. *. On July *, *, LULA filed her Petition for Issuance of Rule to Show Cause alleging that NASER failed to comply with LULA’s discovery request. *. On July *, *, undersigned counsel filed an Appearance on behalf of NASER. *. On November *, *, this Court conducted a pretrial conference whereby per the parties’ agreement, an Order for Support was entered setting permanent child support for the parties’ three minor children at the rate of $*,*.* per month to be paid bi-weekly consistent with NASER’s pay schedule, beginning December *, *. During said pretrial, LULA was present in the courtroom, and should have had sufficient time to confer with her then counsel. *. On December *, *, LULA’s previous second counsel, Gene Hook, Jr., filed his Motion to Withdraw which was granted on December *, *. Since the withdrawal of Mr. Hook as LULA’s counsel, LULA has filed several pro se Motions which are as follows: a) Motion for Reconsideration; b) Motion to

In other words. The opposing party. Continues. Listing. In accurate? Statements. Trying to blame shift? Knowing. That I have actual document that evidence. That proves. They are lying But they continue. Using the same pattern.

So I want to know. How would I exactly describe that? Or? Explain it.

To clarify the situation. I filed a motion to reconsider. The opposing party. File.d A frivolous motion to dismiss. Stating. A revelant. Statement. That have nothing to do. With anything stated in my motions. They continue stating the same False statements. For which I actually have evidence. Refuting them. Which is intentional. These are intentional, frivolous motions. With the intent to prolong. The proceeding. And confuseThe court. As I have noticed. That they will list. False and accurate. Statements numbered one through *. In one motion. And then we'll list. False Inaccurate statements. In another motion. One through *.

all

I just want to know. How do I describe that situation? How do I it?