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2013 Foia Tif Response to Mtd 13 Mr 190

2013 Foia Tif Response to Mtd 13 Mr 190

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Published by Matt Hawkins

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Published by: Matt Hawkins on Oct 03, 2013
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10/03/2013

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In The Circuit CourtTwentieth Judicial CircuitSt. Clair County, Illinois
Matthias Hawkins,
Plaintiff 
,vs.
East St. Louis City Clerk,
Dorene Hoosman
City of East St. Louis City Council, et al.,
Mayor Alvin ParksCouncilman Roy MosleyCouncilwoman Emeka JacksonCouncilwoman Latoya GreenwoodCouncilman Robert Eastern III
City Manager,
Deletra Hudson
Defendant(s)
)))))))))))))))))))))))))))))Case No.:
13
 –
MR-0190
 
RESPONSE TO MOTION TO DISMISS
Now come, Matthias Hawkins, PRO SE, herein known as Plaintiff, on behalf of himself,who now resides in the City of East St. Louis, the County of St. Clair and the State of Illinois. TheDefendants et al named herein are paid elected city officials or staff in the employ of the City of East St. Louis. Plaintiff is a duly registered voter in the City of East St. Louis who currentlyresides at 1705-B Exchange Avenue, East St. Louis, IL 62205. Defendants et al are representedby Mr. Michael Wagner of the Clayborne, Sabo, & Wagner, LLP, 525 West Main Street, Suite105, Belleville, IL 62220.
 
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CASE BACKGROUND:13-MR-0190
1.
 
On July 2, 2013, an attorney from the Defendant’s law firm showed
up in Court in a
“limited appearance” claiming to not know if her firm was counsel of record or
corporate legal counsel.2.
 
By virtue of their own correspondence dated June 26, 2013, Clayborne, Wagner &
Sabo stipulates to being “corporate counsel” for the Defendants et al
;3.
 
Plaintiff prays the Court’s mercy in finding the Defendant’s et al and their legal
counsel, Michael Wagner to have perjured themselves pursuant to the Code of CivilProcedure for making statements known to be untrue and misleading to the Courtregarding who was corporate counsel for the City of East St. Louis on the morning of July 2, 2013;4.
 
On Monday, August 5 plaintiff received a registered letter dated June 26, 2013
containing the Defendant’s belated written response to Plaintiff’s Freedom of 
Information Request dated March 27, 2013, five months (approximately 150 days)beyond the time limits set forth in Section 3 of the Freedom of Information Act (5ILCS 140) of five (5) business days.5.
 
On that same day, Plaintiff received a package via regular mail which contained aMotion to Dismiss Case #13-MR-190 amongst other documents;6.
 
At no point has Attorney Wagner or his agent(s) served this Motion to Dismiss to thePlaintiff or on my
normal place of abode
followed up by a mailed copy as required
 
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in
Section 2-203: Service on Individuals
of the Illinois Code of Civil Procedure (735
ILCS 5), Defendants’ have not
perfected service. Section 2-203 reads as follows:a.
 
“Sec. 2
-203. Service on individuals.(a) Except as otherwise expressly provided, service ofsummons upon an individual defendant shall be made (1) byleaving a copy of the summons with the defendant personally,(2) by leaving a copy at the defendant's usual place of abode,with some person of the family or a person residing there, ofthe age of 13 years or upwards, and informing that person ofthe contents of the summons, provided the officer or otherperson making service shall also send a copy of the summons ina sealed envelope with postage fully prepaid, addressed to thedefendant at his or her usual place of abode, or (3) asprovided in Section 1-2-9.2 of the Illinois Municipal Codewith respect to violation of an ordinance governing parking orstanding of vehicles in cities with a population over 500,000.The certificate of the officer or affidavit of the person thathe or she has sent the copy in pursuance of this Section isevidence that he or she has done so. No employee of a facilitylicensed under the Nursing Home Care Act, the SpecializedMental Health Rehabilitation Act, or the ID/DD Community CareAct shall obstruct an officer or other person making servicein compliance with this Section.(b) The officer, in his or her certificate or in a recordfiled and maintained in the Sheriff's office, or other personmaking service, in his or her affidavit or in a record filedand maintained in his or her employer's office, shall (1)identify as to sex, race, and approximate age the defendant orother person with whom the summons was left and (2) state the

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