Court File Content Overview

So now. if I initially filed through the state for child support, on July * * But for whatever reason, the state took nine months to send the documents out to me. Now, the court file copies shows my signature. dated April *. * So I attempted to ask the judge to order the respondent to pay retroactive from April *. * as it's copied in the court files The opposing party stated that retroactive should not be ordered because the case was taken off call and retroactive should only be considered dating from December *. *.

I'm asking you. would that affect the retroactive

So the issue now is as. I filed and requested retroactive transport b. paid from the date the court file shows my signature, which is April *. * the judge did. not My request for retroactive child support, and did not order the respondent to pay any retroactive child support. She made her ruling based on a six page pretrial memorandum without a. without a single documented fact presented by the other party that stated. that retroactive if it is ordered by the judge if she decides to order a retroactive it should only be set from December * * and the judge two weeks ago stated to me that my retroactive has already been handled but the respondent never paid any retroactive so this is not adding up to me

She verbally stated that to me. she denied at first. She said, that she believes if there was delays in the case that retroactive should be ordered from April * * two weeks later, she changed her mind and stated that my retroactive has already been handled. although none of the court orders reflect that. So this judge actually went by the pretrial memorandum. that was presented to her by the opposing party. stating that retroactive should only be ordered from December 19th. * because this case was taken off call. Now I don't believe that is fair to my three children for this judge. not to order the respondent to pay retroactive. as she is a child support judge and her main job as a child support judge is to make her rulings in the best interest of the children, not to respondent.

Can I file a complaint against this judge for this reason that we just spoke about? And for many other reasons, such as. judge is not looking at documented evidence. or just completely disregarding the evidence has not made one ruling in the best interest or well being or educational needs of my children.

This judge actually made. her ruling. based on a * page Pre trial memorandum. That was filled with false misleading. statements without a single documented evidence presented. That's what she made her decision based off of. even though she was presented with overwhelming documented evidence, proving that everything stated in the prechild memorandum was false and misleading. This judge continues to make all her rulings in the respondents favor. completely neglecting the needs and well being of the children involved. as each and every single court order. clearly indicates all her rulings are in the respondents favor no one of them reflect anything in the children's interest.

Also, this judge. always holds the respondent and myself at the end. of each zoom call as if she does not want anybody else to hear what she states to us verbally. which is also concerning. as there is no court review recorder in the court but the court orders reflect her decision making She does not look at evidence. she verbally stated that she does not look at evidence. which is also concerning. And for these reasons, the respondent successfully. evaded from being ordered to pay retroactive child support payments. successfully evaded from paying the actual amount of child support payments. and successfully evaded of being ordered to cover college expenses or any thing that comes along with attending college such as books, transportation, the respondent was able to evade all of that because this judge will not refuse it. She refuses to look at evidence as she was making excuses for the respondents transactions that are visible in his bank statement. which is mind boggling

I also wanna ask your opinion. and I just need a yes or no answer. Is it normal for a judge not to order? retroactive even though presented with the actual court files showing the signature of when the case was filed for child support? and shouldn't have this judge order ed the respondent to pay retroactive from April * * *

So which part are you saying no to.

OK. I asked you yes or no is. it normal for a judge not to order retroactive

Again. If I file for child support through the state July 6th * But the state takes nine months. to send the documents out to me for my signature, which I received in April of * the court copies show my signature dated April * * From which I requested child retroactive be set. From that date. Now, the judge denied that. Is that normal?

The judge me. ruling based on the opposing parties statement in a pretrial memorandum without any documented evidence. that retroactive should only be ordered if the judge decides to order any retroactive dating from December * * Is this normal? Yes or no?

This is what I filed and stated. Tell me if it's relevant or irrelevant. And does it make sense to you?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 RETROACTIVE CHILD SUPPORT NOW COMES the petitioner, Lula Korotkov, pro se, pursuant to the Illinois Civil Code of Procedure, hereby files a Motion for retroactive child support. In support of this motion, Petitioner states as follows: *. Request for Retroactive Child Support: I respectfully request that this Honorable Court order retroactive child support payments from Respondent, Naser Beganovic, dating back to April *, *. *. Initial Filing: I initially filed my complaint for child support through HFS on July *, *. It took HFS nine months to send me the forms, as evidenced by my signature on the complaint for support in the court file dated April *, *. HFS stated they are unable to provide me with the records showing my initial filing date, but they did mention that the court can subpoena those records if needed. *. Service Attempts: Copies of documents from the court file include the first summons dated May *, *, and a copy of the Cook County Sheriff’s attempt to serve Naser on May *, *, in Streamwood, IL. However, Naser had already moved, knowing that I filed for child support on July *, *. The sheriff also visited my parents’ house on the same day, asking if we knew where Naser had moved, and listed his whereabouts as unknown, as can be seen in the attached documents. *. Alias Summons: Also in the court file is the alias summons dated August *, *, which includes Naser’s new address. His mother provided me with his new address, and I passed it on to HFS. They then forwarded it to the Kane County Sheriff, who successfully served Naser on September *, *, as can be seen in the attached documents. and our first initial court hearing for this case was on January *, *. *. Misleading Statements in Pretrial Memorandum: I have also attached a copy of the pretrial memorandum submitted to the court on November *, *, which falsely stated: “On May *, *, petitioner Lula Korotkov filed her complaint for support through the Health Care and Family Services. On October *, *. Prior to being formally served, Naser filed his appearance on November *, *.” Which is false. My complaint for support was stamped by the circuit clerk on May *, *. *. False Claims of Voluntary Support: Also falsely stated in the pretrial memorandum is: “Naser voluntarily provided for the party’s children specifically from September * to June *. Naser voluntarily sent Lula at least $*,* for the support of the party’s children.” Naser voluntarily provided a total of $*,* out of his pocket: a. $* on September *, * b. $* on November *, * c. $* on December *, * d. $* on January *, * (plus $*,* of the stimulus money) e. $*,* on February *, * (part of the tax return he received on the boys) f. $*,* on March *, * (stimulus money) g. $*,* on November *, * (advanced child tax credit he received from the IRS $* in September and $* in October for the boys) h. $* on November *, * (advanced child tax credit from the IRS) i. $* on December *, * (advanced child tax credit from the IRS) j. $* on August *, * *. Government Support Misrepresented: Naser claimed that the tax return money, stimulus money, and advanced child tax credit were provided out of his pocket, but these funds were given by the government and distributed by the IRS. Therefore, they should not be considered as coming out of his pocket. *. In June *, Naser was ordered to pay temporary child support of $* per month. *. On November *, *, the court established a biweekly child support order of $*.* for three children. Based on false and inaccurate income information, as well as false misleading statements presented in the pretrial memorandum. Additionally, retroactive child support was not ordered. *. On June *, *, the court granted Naser’s motion to modify child support to $*.* biweekly, based on false and inaccurate income information. The issue of retroactive child support was still not addressed. *. In Illinois, retroactive child support is primarily governed by two laws: a. Illinois Parentage Act of * (* ILCS */): This act establishes the parent-child relationship and outlines the responsibilities of parents, including financial support. It ensures that every child has the right to physical, mental, emotional, and financial support from their parents. b. Illinois Marriage and Dissolution of Marriage Act (* ILCS */): This act governs the dissolution of marriage, including child support obligations. It aims to protect the best interests of children and ensure they receive adequate support from both parents. *. Illinois law and public policy do mandate that both parents have a financial duty to support their children. The ability of the courts to award retroactive child support is crucial in ensuring that a parent cannot evade their obligations by deliberately stalling and delaying. This provision helps to prevent any further attempts to avoid support obligations through delays and emphasizes the importance of both parents contributing to their children’s well-being regardless of any legal delays. *. In determining whether and the extent to which the payments shall be made for any prior period, the court shall consider all relevant facts, including factors for determining the amount of support and other equitable factors including but not limited to: a. The father's prior willingness or refusal to support the children. b. The extent to which the mother or the public agency bringing the action previously informed the father of the children’s needs or attempted to seek or require his help in supporting the children. c. The father’s prior knowledge of the children d. Needs of the children, including education, healthcare, and general living expenses. *. Naser has consistently refused to provide financial support for our children, neglecting their basic needs such as food, clothing, and school supplies. Whenever the children or I reached out to him, we were met with verbal abuse and threats. Numerous false police reports have been filed against me and the children. The children were told they don’t deserve anything and were even subjected to cruel remarks, such as being told to die and suffer, simply for asking for essentials like money for food, social activities, soccer cleats, school clothing, supplies, and backpacks. This behavior has persisted from July *, *, to the present. *. In *, both boys needed braces, but Naser refused to pay for them. Since public aid does not cover the cost of braces, the boys were unable to receive the necessary orthodontic treatment. *. At our first hearing on January *, *, Naser stated that he is not the father of the children and requested a continuance to hire an attorney. However, it became evident at the following hearing that his true intention was to delay the proceedings so he could claim the boys on his tax returns, as he did not hire an attorney. He continuously claimed that he is not the children’s father from January *, *, through August of *, using these assertions as a tactic to delay the proceedings until the boys turned *. *. Naser repeatedly refused to comply with the discovery. *. The children were * and * when the case was initially filed on July *, *. The initial child support was set on November *, *, based on false and inaccurate income in a pretrial memorandum. This demonstrates a significant period during which the children were deprived of financial support. *. Naser's Chase Bank statements demonstrated that he was more than capable of providing the proper amount of support for the children. This was evidenced in the documents I emailed to the honorable judge on June *, *, a week before our in-person pretrial on June *, *: a. Naser’s * and * Chase bank statements revealed his extravagant monthly spending ranging from $*,*.* to $*,*.*. Additionally, the documents showed all the cash deposits and Zelle payments received from the two known sources of his under-the-table income. b. Naser’s * and * Chase bank statements provided direct proof of income cycling, diversion, and concealment. c. The documents also reveal that Naser withdrew $*,* from his Chase account for the down payment on his townhouse on April *, *, the same day I signed the complaint for support. d. Despite the comprehensive evidence provided, these documents were either not considered or deemed insufficient. *. Naser’s * Chase Bank statements also revealed a deposit of a check for $*,*.* made on June *, *, which he received from his second false claim against his ex-employer, NCR Corporation. These documents also included an image of a cashier’s check for $*,* made out to Lisa Calderon, which was part of the $*,*.* and intended for concealment purposes. *. On June *, *, the honorable judge ordered that the $*,*.* be calculated into Naser’s income, which led to our pretrial being continued to August *, *. My motion for reconsideration of the child support order from November *, *, was entered and continued, pending the submission of a legal memorandum from Ms. Abellar, which was supposed to be submitted to the court seven days prior to August *, *. However, the continued pretrial scheduled for August *, *, did not take place for that purpose. Instead, it addressed everything that transpired after our first pretrial on June *, *. *. I respectfully request that this honorable court take notice of the following: On June *, *, after our pretrial, Naser’s mother informed me that Lisa Calderon has been unemployed since *. It was falsely claimed that she is financially assisting Naser, which is not true. Naser has been fully supporting and providing for her and her five sons, aged *, *, *, *, and *, all of whom live with him. *. On August *, *, via Zoom call with the court, Naser referred to his biological *-year-old sons as grown men who need to support themselves. Naser also claimed that he is unable to request the remaining balance for the boys’ college tuitions Through the parent PLUS loan. Because he is financially struggling and in debt. He also stated that he needs to refinance his townhouse. However, the townhouse is not under his name; he purchased it in April * in the names of his girlfriend and her *-year-old son. This indicates that his claim about refinancing the townhouse was a deliberate attempt to avoid requesting the remaining balance of the boys’ tuitions, as he cannot refinance a property that is not in his name. *. Naser’s out-of-pocket monthly expenses include: a. Mortgage payments b. Loan payments for multiple vehicles and a motorcycle c. Insurance payments for the vehicles and motorcycle d. Multiple credit card bills, including those for others e. Gas f. Electricity g. Phone bills *. And he's still able to comfortably Afford. a. Groceries b. Dining out c. Shopping sprees for clothing, shoes, and jewelry d. Entertainment e. Vacations f. College tuitions for Lisa Calderon’s sons, who are well over the age of *, plus books and supplies g. Over $*,* in attorney fees *. Naser’s Chase bank statements also showed that on March *, *, he withdrew $*,* from his 401k again, on March *, *, he paid $*,* to a Citi credit card. *. Subpoena Responses via email from Citibank: a. The first email response states that Citibank was unable to find any accounts with Naser’s information as provided in the subpoena. b. The second email clarified that if Naser is not the primary holder of the account or cardholder account, his information would not appear in their search. Therefore, if Naser were only an authorized user on his girlfriend’s credit card account at Bank of America, as claimed by both Naser and his attorney, Bank of America would not have found any information related to Naser in their search. Consequently, they would not have notified him of any subpoenaed records, as there would be no records to produce. *. Relevance of Naser’s Loan Documents: a. Creditworthiness: Loan records from Financial Performance and Capital One Auto Financing will show that Naser has secured multiple loans contradict his claims of poor credit. This proves that he has a higher income and more financial resources than he has disclosed. b. Debt Load: These records detail Naser’s monthly payments and total debt, providing evidence of his actual financial obligations versus claimed struggles. This proves that he has additional assets and income streams that were not reported. c. Lifestyle Indicators: Naser’s ability to afford multiple loans for vehicles and a motorcycle demonstrates his expensive lifestyle and financial stability, clearly indicating that he had and has the means to provide the appropriate amount of child support. d. Challenging Income Representation: Naser has misrepresented his income. His loan documents can be used to contradict his claim of having a low income, as they reveal multiple loans that indicate his true financial situation. The loan records can reveal discrepancies and inconsistencies in Naser’s reported income and financial statements, countering false claims such as poor credit and $*,* debt stated on June *, *. e. Determining True Financial Capability: The court can use his loan documents to get a clearer picture of Naser’s financial capability. This includes his ability to make loan payments, which can be factored into the calculation of child support. These records provide a comprehensive view of Naser’s financial situation, aiding the court in determining the appropriate amount of retroactive child support. *. Neglecting to order retroactive child support would effectively reward Naser for his deliberate evasion and delay tactics. *. In support of this motion, I’ve attached the following documents. Exhibit A: Copies from the court file and the 2nd page of Naser’s pretrial memorandum from November *, *. Exhibit B: Four emails I received three on August *, *, pertaining to the parent PLUS loans and mocking the children’s inability to afford new clothes for school, followed by another threatening email on August *, *, after I had submitted copies of the subpoenas to the court. The following morning, on August *, *, security footage revealed Naser pouring sugar into my gas tank in the middle of the night. This footage, along with the threatening email and other emails wishing death upon the children, was handed over to the police. The police stated that Naser and Lisa Calderon should be considered a threat to the children’s lives and recommended obtaining an order of protection for the children. Exhibit C: Two emails from Citibank. *. Exhibits that will not be filed electronically, but will be provided to the court via email: a. Naser’s bank statements showing the payment of a Citi card for $*,* on March *, *. b. Text messages and emails to the children c. A copy of Ms. Abellar’s drafted court order dated July *, *, stating Lula’s motion to reconsider the child support ordered on November *, *, is entered and continued, pending a submission of a legal memorandum from Naser’s counsel to be submitted within seven days of the next court date. This matter is set for continued pre-trial on August *, *. This was for the $*,*.* to be calculated into Naser’s income. Copies of both motions to quash subpoenas to Bank of America and Performance Finance, drafted by Ms. Abellar on July *, *, also state whether Naser’s previous settlement should be considered income as it relates to the previous child support amount ordered. WHEREFORE, Petitioner Lula Korotkov respectfully requests that this Honorable Court: *. Order retroactive child support payments from Respondent Naser Beganovic dating back to April *, *. *. Determine the proper amount of retroactive child support based on the previously provided bank statements from * and *, which clearly demonstrated Naser’s actual income and his ability to support the children. *. Ensure that the court disregards government funds (stimulus, tax credits, etc.) in the calculation of Respondent’s contributions, as these were falsely presented as voluntary support by Respondent. *. Take into account the children’s medical, educational, and living expenses, including the need for braces, and any ongoing expenses that were not met by Respondent. *. Impose appropriate sanctions or additional remedies for the respondent’s pattern of delay, including but not limited to an order for compensatory damages for the financial hardship caused by his evasion and stalling tactics, or provide financial relief due to the petitioner’s pro se representation and the respondent’s misconduct. *. Grant any other and further relief this court deems just and equitable in the interest of the children’s welfare. Respectfully Submitted, Lula Korotkov Lula Korotkov */*/* Lula Korotkov * N, Central Park Ave Chicago IL, * *-*-* Alisagiana@yahoo.com PRO SE PETITIONERS’ VERIFICATION I, Lula Korotkov, acting Pro Se, under penalties as provided by law pursuant to Illinois Supreme Court Rule * and Section *-* of the Code of Civil Procedure, certify that I have read the foregoing and within the motion. I further state that the allegations contained in the foregoing, and within the motion, are true to the best of my knowledge, information, and belief. I further state that I have provided information which, to the best of my knowledge and belief, is true and correct. This motion is being filed with my consent and as part of my required duties in representing myself. I understand that by signing this verification, I am acknowledging that I am acting with my consent and at my direction and that I have based my actions and statements on the factual information provided by me. Lula Korotkov Pro Se Petitioner * N, Central Park Ave Chicago IL, * *-*-* Alisagiana@yahoo.com Lula Korotkov Lula Korotkov */*/*

But the judge. Stated that she already denied my retroactive and that it has already been handled. although none of the court orders reflect that statement by the judge, So I wanna know. if this is normal for a child or judge to do.

When she made that statement I. believe she was referring to referring to the state man made in the pretrial memorandum presented to her by the opposing party on November * * That retroactive should only be set if the judge decides to order a retro any retroactive child support only. dating from December 19th. *. which was, I believe, reserved so the judge telling me that she has already handled the retroactive is kind of mind boggling and concerning as the responder has not been ordered to pay any retroactive. So I wanna know and legal theory legal terms Is this normal for a judge to do? based on false statement by the opposing party that was written in a Pretrial memorandum.

I am considering filing a complaint against this judge for these reasons and many other reasons that are. extremely concerning

I also wanna know. for example on November * * both myself the petitioner and the respondent had attorneys both attorneys were in the judges chamber With the judge. While the respondent was not. present. I was present in the courtroom. Now what was going on in the judges chamber between the judge and the two attorneys? I have no clue. All I know is when they reappeared in the courtroom from the chambers that there was a deal stricken. that I was not aware of. My attorney had no permission or right to make. any deal or accept any deal on behalf of my children without consulting with me now. once the judge heard that my attorney did that What was she supposed to do? Shouldn't have that told the judge. Hey, wait a minute. She did not consult with the attorney. The attorney made a decision. on behalf of her children without her consult consent. or approval. or should have the judge. continued with her ruling. She made based on false information and attorneys checking deals without my consent on behalf of my children that are involved. This is where I'm confused and I need to understand. because if she wasn't supposed to do that. And started over again knowing. why I fired my attorney after that.

The judge also falsely stated recently. that she was not. in the chambers with the two attorneys. at the time that they struck the deal all on their own. which is also concerning. when the judge was actually in the chambers with the two attorneys.

I believe this is warrants for a complaint to be filed against this judge.

Now, the judge's decision ruling on that date was based off a six page pretrial memorandum. Drafted by the opposing party's attorney. without a single documented evidence. the only evidence that the opposing party presented with their pretrial memorandum were a single court paper that showed the date of my first attorney withdrawing. and they used my father's bank state ment, who is not involved in this case, to falsely clay. that my father is paying for my mortgage when in fact the house was purchased by my father under my name in * even though I provided documented evidence proving that that's what the judge made her ruling based on that pretrial memorandum. And there are three children involved in this case. Not a single court order shows that the judges decisions were based in the best interest of the children or the children's needs or educational needs. Not a single *. All the court orders do show all her decisions being in favor of the respondent. which is odd.

I wanna know your opinion is this. normal is this typical of a child support judge? that behavior the ruling's I'm just trying to understand if it's normal.

Now. I also wanna know your opinions on. if I'm representing myself after. firing my attorney for those reasons. and I provide overwhelming actual document evidence. Now somebody's Main statements are not hearsay state. bank statements of the respondent are actual. documented evidence Now, if those bank statements show. clearly show the amount of transfers from his account to his girlfriend's account. Why would this judge overlook them or just trade out disregard them? in a child support case,

To be honest, the judge. was clearly making excuses for the respondents transactions and transfers to the girlfriend stating that people do that. which kind of shocked me. hearing the judge say that now the respondent's girlfriend has been unemployed, said * The respondents bank statements clearly show that over $*,* has been transferred to the group to the girlfriends account. The respondents Chase Bank also provided an image of a cashier's check that the respondent made out to the girlfriend for the amount of $*,*. leaving his account balance with $*. the judge overlooked it and did not even take it. Take any concern to that. She clearly stated that people do that. People don't do that. That is not normal. That's a clear indication that he is hiding his income.

The judge also multiple times ordering. me to provide the response. with my daughters identity protection pin so that he can claim her on his. tax returns although the judge knows that the respondent has not seen my daughter or his two sons for over four years the judge is also aware that the non custodial parent respondent has not been in the children's lives for 4 years. but multiple times ordered me to provide the pin number to the respondent so that he can claim my daughter on his taxes. Wouldn't that be giving the respondent permission? to benefit off My daughter, who he has not been supporting and. successfully evaded. from being ordered to pay retroactive child support. successfully succeed. ed in hiding his actual monthly income. successfully evaded being ordered to cover any college expenses or anything else that comes along with college. for his twin sons, What did that only allow the respondent to further benefit of of children and how does that what does that have to do with my daughters well being? for this judge to order me to provide the pin number to him so he can claim her on his taxes, knowing that the children do not live with the parent is this? supposed to be done by a child support judge?

So I asked you that question. for your opinion, and is this proper of a child support judge? because she actually helped the respondent evade all responsibilities. and ordering me to provide him the pin so that he may further benefit on a child. He cheated out of retroactive child support payments and the proper child support payments. and educational expenses. because my understanding is a child support judge is supposed to be prioritizing the children. not the respondent

So everything I've stated that the judge either stated or has done. Can you tell me how many of those. could be or are considered as misconduct by the judge or improper?

Is it also? odd and considered as misconduct? or improper? if this judge verbally states that she has already denied a motion when she has not

I'm asking this question because I file. a motion from the judge to order the respondent to provide his girlfriend's bank records to. the court not to me to the court because the respondents bank statements clearly show clearly show over $*,* being transferred to the girlfriend plus an image of a cashier's check made out to made out to the girlfriend for $*,*. Now, the cashiers check alone should have been red flags to disjudge to. approve that motion. Wouldn't you say?

So when I filed that first motion for the girlfriend's records, and then two weeks later, asked about it the judge stated that it is not up yet. A month after that, as I. asked about the motion again the judge straight out states ohh. I've already denied that motion. As I explained to her that she did not. She then stated, ohh well, I'm denying it now. Is this considered as misconduct by discharge?