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Judge Atkins asked the Plaintiff's attorney if they would accept a verbal motion to vacate. Mr. Marconi of (Johnson & Bell) explained they worked hard and would like a written copy. In the back of the courtroom, he explained to the Defendant that the judge is allowing her leave to file a 30-day motion even though it was beyond thirty days. The Defendant did and realized Johnson & Bell said that so they could make a little extra money for themselves pointing out the error. It didn't make a difference. It was vacated.Elder Abuse and Financial Exploitation through the use of Guardianship. Cook County Chicago. IL. Janna Dutton of Dutton & Casey Elder Law, Josh Mitzen of Advocacy Services. Richard Block of Devon Bank. Sally Griffin. Profiting off the elderly utilizing court system. How an attorney sets up a will and Trust Account to become sole heir.
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IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT, CHANCERY DIVISION
In the Estate of Joseph Ziarnik,
Plaintiff,
v.
Tami Goldmann,
Defendant.
No. 08 P 8140
DEFENDANT'S MOTION TO VACATE DEFAULT JUDGMENT
Defendant, Tami Goldmann, pro se, petitions this Court, pursuant to 735 ILCS
5/2-1301, to vacate the default judgment in this case. In support of her motion, Defendant
states as follows:
1. This motion is filed within 30 days of the default judgment of April 29, 2014.
2. On March 6, 2014, Defendant’s case was set to be heard at 10:30 a.m.
Defendant did not appear at the hearing on that date and time because:
She was unaware of the court hearing and on April 29, 2014 Judge Atkins
is allowing her leave to file a 30 day Motion to Vacate.
3. The Defendant learned of the default judgment on April 15, 2014.
4. Defendant filed this motion as soon as possible after learning of the
default.
5. This matter was not decided on the merits, and Defendant requests an
opportunity to be heard.
6. Defendant has at all times tried her best to defend her case and preserve
her rights.
7. In this case, justice will be served only by vacating the default judgment
entered against Defendant and allowing the case to proceed to trial on its merits.
WHEREFORE, Defendant asks that this court vacate the default judgment of
March 6, 2014, stay all proceedings, and grant Defendant leave to file an appearance at
this time.
The undersigned certifies and acknowledges that she is representing herself in this case,
that she has read this motion, and that to the best of her knowledge, information and
belief, formed after reasonable inquiry, this motion is true and is warranted by existing
law, or a good faith argument for the extension, modification, or reversal of existing law,
and that this motion is not made for any improper purpose such as to harass, to delay, or
to increase cost of litigation.
Respectfully submitted,
____________________________
Tami Goldmann
Pro Se Defendant
Tami Goldmann
Pro Se
3939 N Kostner Ave Chicago, Illinois 60641
Telephone: (773) 416-2965
#99500
