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
ANNE MARIE ANGELL-RIGBY,
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
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
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
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
STATE OF ILLINOIS )
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
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