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THIS APPEAL INVOLVES A QUESTION OF CHILD CUSTODY,AFFECTING THE BEST INTERESTS OF A CHILD
 No. XXXXXX
 ______________________________________________________________________________________ 
In the
SUPREME COURT
Of The State of Illinois
 ______________________________________________________________________________________ 
) Petition for Leave to AppealIN RE MARRIAGE OF)DXXXX XXXXXX) On Appeal from Appellate Court, FirstPetitioner-Appellant-Petitioner (divorce) ) District, No. 11-XXXXRespondent-Appellant-Petitioner (OOP))) There Heard on Appeal from Circuit) Court of Cook County,v.) Domestic Relations Division)) No. 09 D XXXXXX)CXXXXXXXX XXXXXX) Honorable Judge David Haracz,Respondent-Appellee-Respondent (divorce)) Trial JudgePetitioner-Appellee-Respondent (OOP)) Order of Trial Court April 29, 2011)Revised on May 9, 2011) Order of Appellate Court)November 14, 2011) Order on Motion for Rehearing) December 19, 2011
PETITION TO APPEAL AS A MATTER OF RIGHT OR INTHE ALTERNATIVE FOR LEAVE TO APPEAL
DXXXX F. XXXXXXXXXX XXXXXX XXXXXXXXXX XX XXXXXXXX XXX-XXXX
 Petitioner-Appellant-Petitioner, Pro Se
Petitioner wishes to file supplemental brief to more fully argue the issues and respectfullyrequests a copy of any rules pertaining to preparing supplemental briefs.Oral argument respectfully requested.
 
22
 
3
PRAYER FOR PETITION TO APPEAL AS A MATTER OF RIGHT OR IN THEALTERNATIVE FOR LEAVE TO APPEAL
Pursuant to Illinois Supreme Court Rules 317, due to issues of first impression of a constitutional nature, and 315, DXXXX F. XXXXXX (“DXXXX”), Petitioner Pro Se,hereby petitions the Illinois Supreme Court to Appeal, the order of the Illinois AppellateCourt (“IAC”) of December 19, 2011, (Supreme Court Appendix [“SCA
1
”] – A), whichdenied
 
Reconsideration of 304(b)(6) Appeal affirmed November 14, 2011 (SCA – B).This petition is timely filed within 35 days of final order on motion to reconsider (rehearing)Petitioner prays this Honorable Court allows this Petition to Appeal to reverse theIAC’s affirmation of DXXXX’s appeal, (SCA B )
because this case poses the followingconstitutional issues of first impression
(
which affect thousands of potential/pending/concluded similar cases regarding orders of protection (“OOP”) and/or fordissolution of marriage (“DOM
”),
 
for which Petitioner essentially argues that the trialcourt orders are all null and void
ab initio
due to violation of statutes, violation of due process rights, fraud upon the court, as well as because this case poses questions wheretrial error cumulatively is grotesquely apparent including but not exclusively:A.
whether the IAC has plenary power to
 sue sponte
by fiat declare that the trialcourt had jurisdiction, ignoring statutory 30 day limit for interim OOP andargument that violation of this statute, 750 ILCS 60/220(2) terminates case andvoids all orders issued after case was terminated. (The Court should NOTE that theDOM custody findings were based on the orders from the OOP case.)
B.
whether the IAC has plenary power to
 sue sponte
by fiat declare that a trialfor DOM may proceed without the child representative serving the parents withstatutorily required pre-trial memorandum (discovery), 750 ILCS 5/506(a)(3)(whose legislative intent was for this memorandum to serve as discovery), or if thisdenies due process requiring a new trial.
1
SCA = Supreme Court Appendix3
of 00

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