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					                                                Attorney Code # 91927
              IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
            COUNTY DEPARTMENT, DOMESTIC RELATIONS DIVISION


In re the Former Marriage of

RONALD P. ANGELL,                                NO. 05 D 13022
               Petitioner,
 and
                                                CAL C
ANNE MARIE ANGELL-RIGBY,
              Respondent.

               MOTION TO COMPEL RESPONDENT’S ASSISTANCE
                 WITH THE SALE OF THE MARITAL RESIDENCE

        Petitioner, RONALD P. ANGELL, (“RON@), by his attorneys, DOWNS LAW

OFFICES, P.C., pursuant to 750 ILCS 5/511, and in support of his Motion to Compel

Respondent’s Assistance with the Sale of the Marital Residence, states as follows:

      1.     On December 4, 2006, a Judgment for Dissolution of Marriage was entered,

dissolving the marriage of RON and ANNE MARIE ANGELL-RIGBY (“ANNE”).

      2.     On December 4, 2006, the parties entered into a Marital Settlement

Agreement, which was incorporated to the Judgment for Dissolution of Marriage.

      3.     Article III, paragraph 2 of the Marital Settlement Agreement reads, in part:

               “…if RON fails to pay the amounts owed pursuant to the agreement within
the 120 days provided for herein then the home shall be listed for sale, with a mutually
agreeable broker, and not sold for a price less then $675,000.00 or such other figure
that the parties may agree to in writing.”

      4.     RON has decided not to purchase the Martial Residence located at 316 S.

Oak Park Ave., Oak Park, Illinois 60302.

      5.     On March 6, 2007, RON’s attorney sent ANNE’s attorney a letter regarding


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issues surrounding the sale of the Marital Residence. (See Exhibit A.)

      6.     On April 25, 2007, RON’s attorney sent ANNE’s attorney a second letter

regarding using a new real estate agent, and enclosing an Exclusive Listing Agreement.

(See Exhibit B.)

      7.     On or about April 29, 2007, ANNE’s attorney discussed adding additional

language to the Exclusive Listing Agreement with RON’s attorney.

      9.     On or about May 14, 2007, RON’s attorney had a telephone conference with

ANNE’s attorney, when he was informed of ANNE’s intent to purchase RON’s interest in

the Martial Residence.

      10.    On May 17, 2007, RON’s attorney sent ANNE’s attorney, a letter where RON

requested that, “ANNE make her decision (about purchasing the Marital Residence within

21 days), so that if (ANNE) decides not to purchase the house that it can be placed on the

market this summer.” (See Exhibit C.)

      11.    On June 5, 2007, RON’s attorney sent a letter to ANNE’s attorney, requesting

that they inform RON immediately of her intention regarding purchasing the Marital

Residence and in obtaining financing. (See Exhibit D.)

      12.    As of July 2, 2007, RON has received no response regarding ANNE’s

intention of purchasing and/or obtaining financing to buy his interest in the Marital

Residence.

       WHEREFORE, PETITIONER, RONALD P. ANGELL, respectfully pray this

Honorable Court enters an Order as follows:

       A.    That ANNE MARIE ANGELL-RIGBY shall, assist in all ways necessary with


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the listing and sale of the Marital Residence, including but not limited to signing the

Exclusive Listing Agreement;

       B.     That Fred Podjasek, of Prudential Realty located in Oak Park, or another

realtor from his office, shall be the realtor used for the sale of the Marital Residence;

       C.     That in the alternative, that ANNE MARIE ANGELL-RIGBY shall, obtain

financing for the purchase of RON’s interest in the Marital Residence within seven (7) days.

       D.     Any such other relief as in equity this Honorable Court deems just.



                                                         _________________________
                                                         RONALD P. ANGELL



                                     CERTIFICATION

STATE OF ILLINOIS           )
                            ) SS.
COUNTY OF COOK              )

       RONALD P. ANGELL, being first duly sworn on oath, deposes and states that,
under penalties as provided by law pursuant to 735 ILCS 5/1-109, the undersigned certified
that the statements set forth in this instrument are true and correct, except as to matters
therein stated to on information and belief and as to such matters the undersigned certifies
as aforesaid that she verily believes the same to be true.



                                                         _________________________
                                                         RONALD P. ANGELL




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                         CERTIFICATION OF ATTORNEY

The undersigned certifies that he has read the above and foregoing Motion to Compel
Respondent’s Assistance with the Sale of the Marital Residence, and it conforms to
Supreme Court Rule 137.


                                                   _________________________
                                                   DOWNS LAW OFFICES, P.C.




________________________
DOWNS LAW OFFICES, P.C.
Attorneys for RONALD P. ANGELL
150 N. Wacker Dr., Suite 1870
Chicago, IL 60606
(312) 781-1963
AttorneyCode#91927




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