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Edwin J Belz, criminal attorney. Amended Motion to Vacate paying back Mr. Ziarnik fees for time he wasted.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 - PROBATE DIVISION
ESTATE OF
JOSEPH L. ZIARNIK, No. 08 P 8140
A Disabled Person,
Advocacy Guardianship Services, NFP, as Limited Guardian of the Person of Joseph L. Ziarnik and individually, Josh Mitzen as Director, Advocacy Guardianship Services NFP and individually; Devon Bank as agent for Joseph Ludwig Ziarnik under Power of Attorney, dated April 1, 2008, as Trustee of Joseph Ziarnik Trust, dated April 1, 2008, and individually and Janna Dutton, as attorney for the Estate of Joseph Ziarnik and individually.
Tammy Goldmann, Google, Inc. Defendants.
MOTION TO AMEND PREVIOUSLY FILED MOTION TO VACATE
Now comes Movant, Edwin J. Belz, and moves this Honorable Court for leave to
amend and file previously-filed Motion to Vacate and for reasons states:
1) On July 14, 2014 a Motion to Vacate was filed regarding the above-captioned
2) Said motion contained a scrivener's error in paragraph 4 wherein Movant
inadvertently omitted two words. Movant desires to amend said paragraph to
read "Movant was not given notice of said motion that was brought before
this Court; nor was movant given notice of hearing date". Said amended
Plaintiffs, v.
cause;
motion is attached hereto.
Wherefore Movant prays this Honorable Court grant Movant leave to amend
previously-filed Motion to Vacate.
Edwin J. Belz 4407 N. Elston Ave. Chicago, Illinois 60630 773-282-9129 Attorney No. 25663
Edwin J. Belz
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT - PROBATE DIVISION
ESTATE OF
JOSEPH L. ZIARNIK, No. 08 P 8140
A Disabled Person,
Advocacy Guardianship Services, NFP, as Limited Guardian of the Person of Joseph L. Ziarnik and individually, Josh Mitzen as Director, Advocacy Guardianship Services NFP and individually; Devon Bank as agent for Joseph Ludwig Ziarnik under Power of Attorney, dated April 1, 2008, as Trustee of Joseph Ziarnik Trust, dated April 1, 2008, and individually and Janna Dutton, as attorney for the Estate of Joseph Ziarnik and individually.
AMENDED MOTION TO VACATE WITHIN 30 DAYS
Now comes Movant, Edwin J. Belz, attorney, and moves this Honorable Court to
vacate the Order of June 19, 2014, and for reasons states as follows:
1) On June 19, 2014, a motion of Defendant to Vacate Default was heard before
this Honorable Court and a Memorandum Opinion and Order were entered;
2) Said Order contains issues which directly effect movant;
3) Movant never received aforesaid Motion to Vacate Default; thus was not
given an opportunity to respond;
4) Movant was not given notice of said motion that was brought before this
Court; nor was movant given notice of hearing date.
Plaintiffs, v.
Tammy Goldmann, Google Inc. Defendants.
Wherefore Movant, Edwin J. Belz, prays the Order of June 19, 2014 be vacated
and held for naught.
Edwin J. Belz 4407 N. Elston Ave. Chicago, Illinois 60630 773-282-9129 Attorney No. 25663
Edwin J. Belz
