Compel Discovery For Child Support

My emotion is about. getting the court. to request the respondents girlfriends bank records I she is hiding his money.

That's what I'm asking you read that. text and tell me if everything is correct or not.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 TO COMPEL DISCOVERY AND SUBPOENA OF RESPONDENT’S GIRLFRIEND’S BANK RECORDS NOW COMES the Petitioner, Lula Korotkov, pro se, and moves this Honorable Court to compel the Respondent, Naser Beganovic, to produce the bank records of the Respondent’s girlfriend, Lisa Calderon, and to issue a subpoena for these records from Huntington Bank, pursuant to Illinois Supreme Court Rule * and the Illinois Uniform Fraudulent Transfer Act (* ILCS */). In support of this motion, the Petitioner states as follows: *. Relevance and Necessity: I have evidence showing significant payments being sent from Naser to Lisa Calderon via Zelle since *. These payments are relevant to this case as they have affected and continue to affect Naser’s financial ability to support his three biological children’s well-being and needs. *. Attempts to Resolve: I sent an email to Naser and his attorney asking if Naser was willing to provide his girlfriend’s banking records to the judge. In response to my email request, I received an extremely abusive and threatening reply, The tone of the email was highly aggressive, confrontational, and disrespectful, clearly intended to intimidate and discourage me from pursuing my legal rights. This response confirms that Lisa Calderon is hiding Naser’s income. especially since they had no issue providing her credit card statements from Bank of America to the judge. *. Evidence of Fraudulent Transfers: I have Naser’s Chase bank records from * to *, which show frequent Zelle payments from both of his Chase accounts being sent to Lisa Calderon via Zelle. Some of these bank statements were also provided to the court on June *, *. All those transfers were and are being made with the intent to hide Naser’s money to avoid paying retroactive child support, the proper amount of child support, and education expenses. *. At the end of May *, all of Naser’s money disappeared from both of his Chase accounts. He then started falsely claiming that he is making $*,* less than he did in * and also started falsely claiming that Lisa Calderon is financially helping him. Coincidentally, that is also the same time Lisa Calderon quit her job and has been unemployed since *. *. In *, Naser again falsely claimed that he is making $*,* less than he did in *. *. Naser’s Chase bank statements reveal direct patterns of income concealment. The following instances serve as a few examples: On January *, *, Naser transferred $*.* via Zelle to Lisa Calderon from his second Chase account ending in *. On the same day, Lisa transferred the same amount to Naser’s first Chase account ending in *. Subsequently, Naser sent the same amount back to Lisa on the same day. On August *, *, Lisa Calderon sent $* via Zelle to Naser, which he then sent to me. June *, *: Naser deposited a check for $*,*.* from his second claim against NCR Corporation. July *, *: Naser withdrew a cashier’s check for $*,* made out to Lisa. On August *, *: Naser transferred $*,* from his first Chase account ending with * to his second Chase account ending with *. On the same day, he received $* via Zelle from Lisa Calderon and subsequently sent her back the $*, along with an additional $*. This is also meant to create the illusion that Lisa Calderon is financially helping Naser. Lisa Calderon has been unemployed since *. *. Interference in the Case: Lisa Calderon who has been and continues interfering in my children’s well-being and needs since July *, *, and in this case since January *, *, for her own benefit at my children’s expense. *. Legal Basis: Under Section *(a) of the Illinois Uniform Fraudulent Transfer Act (* ILCS */), any transfer made with the intent to defraud, hinder, or delay a creditor is prohibited. As the custodial parent, I am considered a creditor, and Naser is the debtor. *. Request for Subpoena: I request that this Honorable Court issue a subpoena to Huntington Bank to produce Lisa Calderon’s bank records of checking and savings accounts for the period of April *, *, to September *, *, to determine the extent of the fraudulent transfers and Naser’s hidden assets. I ask that this subpoena be issued only if there is a refusal to voluntarily provide these records to the Honorable Judge without a subpoena. *. In support of the motion, I’ve attached the following documents. Exhibit A: Emails written by Lisa Calderon, both as herself and impersonating Naser, along with two text messages from Naser, will help the court understand that all the emails are authored by Lisa Calderon, not Naser, clearly proving her interference. It’s truly astonishing how someone consistently displays a troubling combination of aggressive, abusive, defensive, dismissive, confrontational, accusatory, insulting, threatening, commanding, intimidating, demanding, controlling, and entitled behavior. This conduct is genuinely terrifying. Additionally, Lisa Calderon is known to use different aliases, including Lisa Lopez and Lisa Beganovic. WHEREFORE, the Petitioner, Lula Korotkov, respectfully requests that this Honorable Court grant the relief sought herein. a. Compel Lisa Calderon to produce her bank records for the specified period. b. Issue a subpoena for Lisa Calderon’s bank records from Huntington Bank. c. Grant any other relief that this Court deems just and proper. 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 */*/*

What's wrong with the date? It is September * *.

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 TO COMPEL DISCOVERY AND SUBPOENA OF RESPONDENT’S GIRLFRIEND’S BANK RECORDS NOW COMES the Petitioner, Lula Korotkov, pro se, and moves this Honorable Court to compel the Respondent, Naser Beganovic, to produce the bank records of the Respondent’s girlfriend, Lisa Calderon, and to issue a subpoena for these records from Huntington Bank, pursuant to Illinois Supreme Court Rule * and the Illinois Uniform Fraudulent Transfer Act (* ILCS */). In support of this motion, the Petitioner states as follows: *. Relevance and Necessity: I have evidence showing significant payments being sent from Naser to Lisa Calderon via Zelle since *. These payments are relevant to this case as they have affected and continue to affect Naser’s financial ability to support his three biological children’s well-being and needs. *. Attempts to Resolve: I sent an email to Naser and his attorney asking if Naser was willing to provide his girlfriend’s banking records to the judge. In response to my email request, I received an extremely abusive and threatening reply, The tone of the email was highly aggressive, confrontational, and disrespectful, clearly intended to intimidate and discourage me from pursuing my legal rights. This response confirms that Lisa Calderon is hiding Naser’s income. especially since they had no issue providing her credit card statements from Bank of America to the judge. *. Evidence of Fraudulent Transfers: I have Naser’s Chase bank records from * to *, which show frequent Zelle payments from both of his Chase accounts being sent to Lisa Calderon via Zelle. Some of these bank statements were also provided to the court on June *, *. All those transfers were and are being made with the intent to hide Naser’s money to avoid paying retroactive child support, the proper amount of child support, and education expenses. *. At the end of May *, all of Naser’s money disappeared from both of his Chase accounts. He then started falsely claiming that he is making $*,* less than he did in * and also started falsely claiming that Lisa Calderon is financially helping him. Coincidentally, that is also the same time Lisa Calderon quit her job and has been unemployed since *. *. In *, Naser again falsely claimed that he is making $*,* less than he did in *. *. Naser’s Chase bank statements reveal direct patterns of income concealment. The following instances serve as a few examples: On January *, *, Naser transferred $*.* via Zelle to Lisa Calderon from his second Chase account ending in *. On the same day, Lisa transferred the same amount to Naser’s first Chase account ending in *. Subsequently, Naser sent the same amount back to Lisa on the same day. On August *, *, Lisa Calderon sent $* via Zelle to Naser, which he then sent to me. June *, *: Naser deposited a check for $*,*.* from his second claim against NCR Corporation. July *, *: Naser withdrew a cashier’s check for $*,* made out to Lisa. On August *, *: Naser transferred $*,* from his first Chase account ending with * to his second Chase account ending with *. On the same day, he received $* via Zelle from Lisa Calderon and subsequently sent her back the $*, along with an additional $*. This is also meant to create the illusion that Lisa Calderon is financially helping Naser. Lisa Calderon has been unemployed since *. *. Interference in the Case: Lisa Calderon who has been and continues interfering in my children’s well-being and needs since July *, *, and in this case since January *, *, for her own benefit at my children’s expense. *. Legal Basis: Under Section *(a) of the Illinois Uniform Fraudulent Transfer Act (* ILCS */), any transfer made with the intent to defraud, hinder, or delay a creditor is prohibited. As the custodial parent, I am considered a creditor, and Naser is the debtor. *. Request for Subpoena: I request that this Honorable Court issue a subpoena to Huntington Bank to produce Lisa Calderon’s bank records of checking and savings accounts for the period of April *, *, to September *, *, to determine the extent of the fraudulent transfers and Naser’s hidden assets. I ask that this subpoena be issued only if there is a refusal to voluntarily provide these records to the Honorable Judge without a subpoena. *. In support of the motion, I’ve attached the following documents. Exhibit A: Emails written by Lisa Calderon, both as herself and impersonating Naser, along with two text messages from Naser, will help the court understand that all the emails are authored by Lisa Calderon, not Naser, clearly proving her interference. It’s truly astonishing how someone consistently displays a troubling combination of aggressive, abusive, defensive, dismissive, confrontational, accusatory, insulting, threatening, commanding, intimidating, demanding, controlling, and entitled behavior. This conduct is genuinely terrifying. Additionally, Lisa Calderon is known to use different aliases, including Lisa Lopez and Lisa Beganovic. WHEREFORE, the Petitioner, Lula Korotkov, respectfully requests that this Honorable Court grant the relief sought herein. a. Compel Lisa Calderon to produce her bank records for the specified period. b. Issue a subpoena for Lisa Calderon’s bank records from Huntington Bank. c. Grant any other relief that this Court deems just and proper. 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 */*/*

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