Property Ownership Misrepresentation

Can you tell me if these Are cited properly?Legal Basis *. Illinois Supreme Court Rule *(b)(*): The scope of discovery allows for obtaining non-privileged information relevant to the case. Naser’s financial transactions with Lisa Calderon/Beganovic are directly relevant to the retroactive child support. and child support obligations. *. * ILCS */*: This statute emphasizes the importance of proper financial support for children. Naser’s concealed assets and financial misconduct, including directing significant amounts of money to Lisa Calderon/Beganovic, who is concealing these assets, have impacted, and continue to impact, Naser’s ability to fulfill his child support obligations to his three biological children, as required by law. *. Illinois Supreme Court Rule *: This rule provides the procedures for issuing subpoenas to third parties. Obtaining Lisa's Huntington bank records from May * to present is essential to uncovering Naser’s concealed assets and ensuring a proper assessment of his financial situation.

Can you please remove these?*

Can you please read and look through my motion?MOTION FOR RECONSIDERATION OF DENIED MOTION TO COMPEL RESPONDENT TO PROVIDE UNEMPLOYED SPOUSE'S BANK RECORDS AND FOR SUBPOENA IF NECESSARY NOW COMES the petitioner, Lula Korotkov, pro se, and respectfully submits this motion for reconsideration of the court's denial of my Motion to Order Respondent to Provide Girlfriend's Bank Records and for Subpoena if Necessary. This motion outlines the procedural history, the substantial evidence provided, and the necessity of obtaining these records to ensure a fair and accurate assessment of the respondent's financial situation, which directly impacts the child support obligations for my three biological children as per Illinois Supreme Court Rule *(b)(*), * ILCS */*, and Illinois Supreme Court Rule *. Background *. Filing the Motion: On September *, *, I filed a motion to compel discovery and subpoena of the respondent's girlfriend's bank records due to substantial financial transactions from Naser to Lisa Calderon/Beganovic. *. Judge's Instruction: On September *, *, the judge instructed me to change the title of the motion and resubmit it, which I did on September *, *. It was retitled Motion to Order Respondent to Provide Girlfriend's Bank Records and for Subpoena if Necessary. Court Sessions *. On October *, *, when I inquired about the motion, both the judge and Naser's former attorney, Ms. Abellar, stated that the motion was not yet up for consideration. *. On November *, *, when I once again inquired about the motion, the judge stated that she had already denied that motion. I respectfully pointed out that: a. The judge had not previously denied the motion. b. That on September *, *, the judge had stated for me to retitle the motion and resubmit it. c. That on October *, *, the judge stated the motion was not up yet. d. That none of the previous court orders reflected a denial of the motion. *. Judge's Response: Despite my clarifications, the judge stated, "Well, I'm denying it now." This statement was made without any clear recorded reasoning or consideration of the substantial evidence provided. The drafted court order signed and dated November *, *, also only states, "Lula's motion to order respondent to provide girlfriend's bank records and for subpoena if necessary is hereby denied," without further explanation. Direct Evidence of Transactions, Hidden Assets, and Discrepancies in Written Explanations *. I have provided extensive documented evidence throughout this case, plus emailed them to the judge on June *, *, demonstrating significant financial transactions from Naser’s Chase bank accounts to Lisa Calderon/Beganovic. a. Naser's Chase bank statements clearly show that over $*,* has been sent to Lisa Calderon/Beganovic, who has been unemployed since *, through Apple Cash, Zelle, and cash withdrawals in a relatively short period. b. An image provided by Chase Bank shows a cashier's check for $*,* made out to Lisa Beganovic, dated July *, *. This amount was part of the $*,*.* Naser received from his second false claim against his former employer, NCR Corporation, which he deposited on June *, *. On June *, *, the judge ordered that the $*,*.* be included in Naser's income as it related to the initial child support set on November *, *, based on the false information provided in a pre-trial memorandum. However, this has not yet been done. c. Monthly spending between $*,* and $*,*, including large cash withdrawals and deposits, from Naser’s Chase Bank account from March * until Naser’s money began disappearing from his Chase account in May of *. d. Under-the-table income Naser was receiving via Zelle from Edina Gredelj, whose husband is the owner of International Protective Services Inc., and frequent cash deposits from Advanced Security Solutions Inc. that have been redirected to Lisa since *. e. Purchase of a townhouse under Lisa and her son Anthony C. Calderon’s names in May *, with a $*,* down payment coming out of Naser’s pocket. f. Payments for the mortgage, groceries, bills, shopping, vacations, vehicles, school clothing supplies, college tuitions, jewelry, entertainment, eating out, and birthday parties for Lisa and her five sons, aged *, *, *, *, and *, all came out of Naser's pocket, at the expense of his three biological children. g. Discrepancies between the written explanations Naser provided to my previous attorney and those he provided to his previous attorney regarding the cash withdrawals and deposits in his Chase accounts h. Evidence that Naser was covering college tuition and other expenses for Lisa’s adult sons, while not providing for his own twin sons' college expenses, books, or any related costs. i. Naser also received $*,*.* from his first false claim against his ex-employer, NCR Corporation, on May *, *, which would pertain to retroactive child support. Financial Deception *. On August *, *, Naser falsely claimed to have poor credit and to be financially struggling, with $*,* in debt. He did not want to cover college expenses for his biological twin sons out of his pocket. He also stated that he needed to refinance his townhouse, which would have been impossible since he did not purchase the property under his own name. These claims are further invalidated by the transaction on September *, *, where Lisa's son Anthony sold the property to Lisa using Naser's money for the down payment once again, which is also property concealment. *. Naser also falsely stated that he owes $*,* on his motorcycle when, in fact, it is paid off. *. Naser claimed to have poor credit and to be $*,* in debt, it would have been highly unlikely for him to easily obtain auto loans. Despite these claims, he previously had a * Chrysler * with a balance due of $*,*, for which his bank statements show he was making a monthly payment of $*.*. He currently has a * Chevrolet Blazer with a balance due of $*,*, which contradicts his stated financial struggles. Legal Basis *. Illinois Supreme Court Rule *(b)(*): Allows discovery of non-privileged information relevant to the case, applicable to Naser’s financial transactions. *. * ILCS */*: Statute emphasizes proper financial support for children, relevant to Naser’s concealed assets. *. Illinois Supreme Court Rule *: Provides procedures for issuing subpoenas to third parties, crucial for obtaining Lisa's bank records. Argument *. Necessity of Obtaining Spouse's Bank Records: Naser’s financial transactions with Lisa Calderon/Beganovic clearly and directly indicate financial misconduct and asset hiding. Obtaining her Huntington Bank records is crucial for a fair and accurate assessment of the respondent's financial situation. *. Impact on Child Support Obligations: Since July *, *, Naser has provided overwhelming financial support to Lisa and her five sons while completely neglecting his obligations to his three biological children. This neglect, which began when his children were * and *, has deprived and continues to deprive them of the proper support they are legally entitled to receive. *. Procedural Irregularities: The judge's denial of the motion without discussion or recorded reasoning overlooks significant evidence and raises concerns about the fairness of the judicial process. WHEREFORE, I respectfully request that this Honorable Court: *. Reconsider the denial of the motion to compel discovery and subpoena the respondent's spouse's Huntington Bank records dating from May *, *, to present. *. Issue a subpoena if necessary to obtain the bank records. *. Provide a written explanation for the denial of the initial motion. *. Ensure that Naser’s financial situation is accurately assessed to provide the proper retroactive child support, child support he should have been paying, and should be paying moving forward for the children involved. *. I urge this Honorable Court to reconsider the substantial evidence I have presented throughout this case and grant the motion to compel respondent to provide unemployed spouse's bank records and for subpoena if necessary to ensure a fair and just outcome for my children.