Memorandum for Respondent on Legal Separation by eir20531

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									3100 - Answer/Reply File
3400 - Pretrial Memorandum (This form replaces CCDR 10 A/B)                      (Rev. 4/12/01) CCDR 1000 A


                      IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
                     COUNTY DEPARTMENT, DOMESTIC RELATIONS DIVISION

IN RE THE MARRIAGE CUSTODY
SUPPORT OF :

ANNA CHILDS                                                   NO.   06 D 7243
PETITIONER

PETER CHILDS                                                  CALENDER:
RESPONDENT

                                         PRETRIAL MEMORANDUM

        A pretrial memorandum is to be prepared by each attorney of records. Failure to prepare a
pretrial memorandum shall be considered a violation of rules and result in appropriate sanctions.

Schedules A and C shall be filed with the pretrial judge seven (7) days prior to the initial pretrial
conference.

Schedule B shall be filed with the judge to whom the case is assigned before the date is set for the
mediation intake session.

The Petitioner       Respondent       Attorney for Child         Other   presents the following
information.

All items are to be filled in.

NAME:
ADDRESS:
DATE OF BIRTH:
S.S. # :

CONDITION OF HEALTH (SPECIFY CONDITIONS):




EDUCATIONAL BACKGROUND:




DATE OF MARRIAGE :


DATE OF SEPARATION:

           DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
                                                                                   (Rev. 4/12/01) CCDR 1000 B


CHILDREN :
                    NAME                        AGE                  DATE OF BIRTH




GROUNDS: (Specify party alleging grounds:)




      SUMMARY OF DISPUTED ISSUES: (CHECK DISPUTED ISSUES. ISSUES NOT CHECKED WILL BE DEEMED
UNDISPUTED.)

                  Dissolution                             Dissipation
                  Legal Separation                        Value of Property
                  Declaration of Invalidity               Amount of Income H W 
                  Custody/Custody Modification            Whether property is marital or non-marital
                  Visitation                              Division of marital property
                  Removal                                 Reimbursement
                  Child support/Support Modification      Disposition of debts
                   Maintenance                             Attorney’s Fees
                  Educations Expenses                     Division of personal property


Briefly describe other issues to be resolved:




(PLEASE PRINT)
Preparing Atty’s No.: 40668

Preparing Atty’s Name: Pasulka & White, LLC.

Atty. for:

Address: 70 West Madison Street, Suite 650

City/State/Zip: Chicago, Illinois 60602

Telephone: (312)236-9150



       DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
(This form replaces CCDR 10 A-1)                                                                (Rev. 4/12/01) CCDR 1000 C

                              IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
                             COUNTY DEPARTMENT, DOMESTIC RELATIONS DIVISION

                                                  SCHEDULE A - ASSETS

         The date of valuation(s) is                                   unless otherwise specified. Please designate value and
whether the property is marital (M) non-marital husband (NMH) or non-marital wife (NMW).

 Title In                                                                                              VALUE
 Name Of

                1.       Cash, Bank Accounts and Equivalents, i.e., Checking, Savings,            H                W
                         IRA, CD etc; Location: Account Number.




                2.Stock, Bonds and other Securities.




                3.Real Property; Address; Physical Description; How title is held; Amounts
                         of any Mortgages or liens.




                4.Motor Vehicle(s): Model/Year; Debtor; Amount; How Title is held.




      DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
(This form replaces CCDR 10 A-1)                                                             (Rev. 4/12/01) CCDR 1000 D


Present Value & Whether the Property is Marital (M) Non-Marital Husband (NMH) or Non-Marital Wife (NMW)

 Title In                                                                                         Value
 Name Of

             5.Business Interests; Name of Business, Type of Business (e/g/,             H                   W
                      corporation, partnership, sole proprietorship): Percentage
                      Interest.




             6.Insurance Policies: Type of Insurance (life, medical, etc.); Policy
                      Number; Face Amount; Beneficiary. Show surrender value
                      and loans on policies.




             7.Retirement Plans; Name and Type of Plan; Trustee of Plan; Nature of
                      Interest; Beneficiary; Vested or non-vested.




             8.Income Tax Refunds: Amount Federal; Amount State.




             9.Choses in Action: Date of Occurrence; Nature and Amount of Claim;
                      Date Lawsuit Filed; Case Number.




             10.All other property not previously listed (except for tangible personal
                       property).




      DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
(This form replaces CCDR 10 A-1)                                                                     (Rev. 4/12/01) CCDR 1000 E


                                             TANGIBLE PERSONAL PROPERTY

Set forth any disputed items of tangible personal property (including household goods and personal effects) on a separate inventory
attached to Schedule A. Provide the following information: description and location of the goods; category claimed (M, NMW or
NMH); Value; and recommendation as to award.

                                                             DEBTS

    Debtor                     Nature/                       Date              Original           Current         Who Incurred
  (H, W, JT)                   Purpose                     Incurred            Amount             Balance          (H,W,JT)




                                                 CONTINGENT LIABILITIES

   Potential                   Claimant                     Basis of            Date              Amount          Who Incurred
   Obligor(s)                                                Claim            Incurred            Claimed          (H, W, JT)




      DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
(This form replaces CCDR 10 A-1)                                                                       (Rev. 4/12/01) CCDR 1000 F


                           SETTLEMENT POSITION WITH REFERENCE TO SPECIFIC ASSETS

IN THE EVENT SETTLEMENT DOES NOT OCCUR, THIS PAGE SHALL BE DELETED FROM THE PRETRIAL
MEMORANDUM AND RETURNED TO THE RESPECTIVE PARTIES’ ATTORNEYS.

(State items to be received by each party; whether any items are to be liquidated and if so, the division of proceeds from said
liquidation; the tax consequences of said division; and the percentage of the estate each receives, together with the reasons for said
division.)




[ATTACH THE 13.3 DISCLOSURE STATEMENT FOR PAGES G THROUGH J]




       DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
(This form replaces CCDR 10 A-1)                                                                   (Rev. 4/12/01) CCDR 1000 K


                                SCHEDULE B: CUSTODY, VISITATION & CHILD SUPPORT

This Schedule was prepared by         Petitioner        Respondent         Attorney for Child      Other


 1.       Name of Child                 Sex     Date of Birth             School and Grade             Special Problems




 2. Current order in effect relating to custody, visitation and child support.




 3. Present medical policies covering children. (Specify company and how obtained.)




      DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
(This form replaces CCDR 10 A-1)                                                                     (Rev. 4/12/01) CCDR 1000 L




 4. Professional Examinations and Reports: Unless objected to by specific motion, include the following information; name and
 type of profession or agency, date, purpose of examination and findings. Reports, if not protected by confidentiality shall be
 presented to the pre-trial judge for pre-trial purposes only and shall not be a part of the court file unless otherwise ordered.




 5. Other court proceedings having a bearing on custody, visitation and support. (Name of case, type of action and last order)




      DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
(This form replaces CCDR 10 A-1)                                                                      (Rev. 4/12/01) CCDR 1000 M




 6. Recommendations of         Petitioner       Respondent

 Indicate: (A) type of custody; (B) location and time spent at child(ren)’s residence; (C) visitation schedule, including holidays
 and vacation time.




      DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
(This form replaces CCDR 10 A-1)                                                                      (Rev. 4/12/01) CCDR 1000 N



 7. Recommendations continued:

            Indicate (D) child support, specifying to whom support will be paid and the reasons supporting the amount
            recommended; (E) medical, dental and hospital expenses, specifying type of treatment, provider, and method of
            payment (including insurance); (F) each child’s school expenses, specifying the name and type of school, (e.g. ,
            preschool, religious school, elementary/high school, college, public/private, etc.) and amount of expense; and (G) any
            special problems of each child.




(Please Print)

Preparing Atty’s No.: 40668

Preparing Atty’s Name: Pasulka & White, LLC.
Atty. for: The Respondent
Address: 70 West Madison Street, Suite 650
City/State/Zip: Chicago, Illinois 60602
Telephone: (312)236-9150


       DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
(This form replaces CCDR 10 A-1)                                                                      (Rev. 4/12/01) CCDR 1000 O


                                                  SCHEDULE C : EXPERTS

This schedule is prepared by the attorney for Petitioner         Respondent         Attorney for the Child(ren)
 Other


 Name experts of whom you are aware who will testify at trial, and indicate the date of disclosure.




Submitted By:

Preparing Atty’s No.: 40668

Preparing Atty’s Name: Pasulka & White, LLC.
Atty. for: The Respondent
Address: 70 West Madison Street, Suite 650
City/State/Zip: Chicago, Illinois 60602
Telephone: (312)236-9150



      DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
(This form replaces CCDR 10 A-1)                                                                           (Rev. 4/12/01) CCDR 1000 P


                          IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
                         COUNTY DEPARTMENT, DOMESTIC RELATIONS DIVISION

IN RE THE  MARRIAGE CUSTODY
SUPPORT OF :

                                                                      NO.
PETITIONER

                                                                      CALENDER:
RESPONDENT

                                              SCHEDULE D - TRIAL INFORMATION

         This Schedule need not be completed before the pretrial conference. If the matter is not settled at the pretrial conference, the
Court will enter an order designating the date by which Schedule D must be filed.

And stipulations entered into by the parties including exhibits, are attached hereto. If none, so indicate.

All discovery is completed.

1.         The parties’ stipulations are attached hereto.
           There are no stipulations.

2.       The expected length of the trial is                          full days. Petitioner represents that Petitioner’s case in chief will
take                                  : Respondent represents that Respondent’s case in chief will take                           ;
Attorney for the Child(ren) represents that their case in chief will take                                                         .

3.        Describe all issues still in dispute, on following page (D-2).

4.        The parties reaffirm the items contained in Schedules A, B, and C, except for the following:




       DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
(This form replaces CCDR 10 A-1)                                         (Rev. 4/12/01) CCDR 1000 Q



                                      DESCRIPTION OF DISPUTED ISSUES

The following issues are in dispute


                   Issue                     Petitioner’s Position     Respondent’s Position




      DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
Any other party shall submit their position separately.




      DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
(This form replaces CCDR 10 A-1)                                                             (Rev. 4/12/01) CCDR 1000 R




Submitted By:




PARTY
Petitioner       Respondent      Other

Name:

Address:

Telephone:

Signature:




ATTORNEY FOR
Petitioner Respondent            Children         Other

Client Name(s):

Attorney Name:            Pasulka & White, LLC.

Address: 70 W. Madison, Ste. 650 Chicago, IL 60602

Telephone:        (312) 236-9150

Signature:

Attorney No: 40668




THE COURT, having received the pretrial memoranda presented by counsel, CERTIFIES this case ready for trial.




                                                              DATED:                    ,

                                                              ENTER:




                                                              JUDGE                              JUDGE’S NO.




        DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

								
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