IPJ^^W^WJ^^M^W^^

r
5 ♦
n People ex rel
IN THE CIRCUIT COURT OF LAKE COUNTY
V
on behalf of
self and/or on behalf of

Case No.
.v a
Petitioner
D Independent Proceeding
C4a&c -vs- O Other Civil Proceeding
(Specify)
J, ^plttiGA \ IZ Criminal Prpccedii
Respondent i'Z Juvenile Pfojftedi!

PETITION FOR ORDER OF PROTECTION

[Fill in lines and check boxes as applicable.

Now comes the Petitioner

behalf of C r t t U S I T ' f ' f t dM
J a minor child, or on behalf of
r own behalf or on

, an sdull prevented by disability or advanced age from seeking protection on

his/her own behalf, pursuant to the Illinois Domestic Violence Act of 1986 as amended (IDVA). and moves this honorable Coun
to issue an Order of Protection in this cause and in sujppon thereof states as follows:
I ALLEGATIONS
if-
THIS COURT HAS JURISDICTION OF THE SUBJECT MATTER AND OVER ALL NECESSARY PERSONS. WITH
APPROPRIATE VENUE, BECAUSE:

A. U? Petitioner resides
State of 42U/J0O

OR

« Petitioner resides at l 7 £ f r . S VJ AflaT HDQtLJ9^* the County of ^ ^

State of _, the person on whose behalf
this Petition is brought, resides at .S&&\ £
in the County of <-&&& State of JU-lbOt S
*;
£ OR

u Petitioner's address is omitted pursuant to statute.

B. sides at
Respondent herein resides County of LQKer

C. Respondent stands in relationship to the Petitioner as:

G Spouse: G Former spouse: Parent;
O Child; G Stepchild; *
G Sharing or f<°£Jjj£^]L^&fiOBB«i ^ Having or allegedly ~ Other person related by
a common ^WfilSrTflMflJQ having a child in common: Wood or marriage.

PETITION FOR ORDER OF PROTECTION: 1 of 5 Pages 171 37A REV 9/89

-COPY-LAKE COUNTY CIRCUIT CLERK-COPY-
Afetirt.^^.r. ■.- ..~^.i.;.,i^.'^i^.a^
-COPY-18 N. COUNTY WAUKEGAN IL-COPY- l±i*t»i-,a»i-4, ,^A n M t a ^ i .-■s.^tiSttS
 ML iCASE NO.

D Q There is no other pending court aciion involving the parties

OB
Jfl There is aiiothcr nending court action involving the parties m .(iL^J^JX JjJ**Jt- .Court,
County of M y l y ? - . __-____,_ .'. State <>f ; p . U AJy \ *
known as Case No. ( t t C r II 1 4

E.'J&The Court has jurisdiction over the children because:

This state
is the home state of child at the nine of the commencement of this proceeding, or
Gb. had been the child's home stase within 6 months before commencement uf the proceeding and the child is absent
from this State because of his removal or retention by a person claiming his custody or for other reasons, and
a parent or person acting as parent continues to live in this State: OR
a 2. It is in the best interest of the child that a court of this State assume jurisdiction because the child and his parents.
or the child and at least one contestant, have a significant connection with this State, and there is available in
this State substantial evidence concerning the child's present or future care, protection, training, and personal
relationships; OR
a 3. The child is physically present in this State and
C a. the child has been abandoned, or
Gb. it is necessaiy in an emergency to protect the child because he has been subjected to or threatened with mistreat­
ment or abuse or is otherwise negSected or dependent. OR
r-»-
:• 4. It appears that no other state would have jurisdiction under prerequisites substantially in accordance with paragraphs
1., 2., or 3., or another state has declined to exercise jurisdiction on the grounds that this State is the more appropriate
forum to determine the custody of the child, and it is in the best interest of the child that this Court assume jurisdiction.

F.-fi Venue in civil proceedings is appropriate Utecause:

D Petitioner resides in the County of Lake. State of Illinois; OR
D Respondent resides in the County of Lake, State of Illinois; OR
□ The alleged abuse occurred in the County of Lake, State of Illinois; OR
paT The Petitioner is temporarily located in the County of Lake, State of Illinois, to avoid further abuse, and could
not obtain safe and adequate temporary housing in the county of his/her residence.

PETITIONER ALLEGES AS TO RESPONDENT THAT:

O. J8 The following individuals are alleged to be persons who need to be protected from abuse by Respondent:

V4iQt?t*,\ MipfrftA; Wlr&ty,

H. X Respondent has acted in the following manner towards the Petitioner:
I. Details of incidents) of abuse (including time and place): _ , >
NfcS smug QrtQisjmtQ
o^m^ W&?fra Su-&n<£ octw*?^ A^>
2 Effect off incidents) on Petitioner
incidemxs) pi

^ ^
j^M^pj> r^ife,
000987000031

P E T m 0 M F 0 R 0 R D E R C t/t-37B REV. 9/89

m ^ ^ ^ ' C O U N T Y CIRCUIT CLERK-COPY-
I c O P Y - 1 8 N . COUNTY WAUKEGAN IL-COPY-
 *f-f . ':-jifo?A8fr*fc'ff • - ';^'f'r':.,';';; '--'^
.u -,..

p Petitioner should be granted exclusive possession of the residence, the special venue rules ot *ec 2Wfh) of IDVA (applicable ~>! %•£
/ only in civil proceedings) having been met. because: *&i$:i
~~
u Petitioner has a right to occupancy arid Respondent h;<s no right to occupancy.
issv'wr

f "'
.Sir
:
OR
Both parties have a right to occupancy. and. considering the risk of further abuse by Respondent interfering with
the Petitioner's safe and peaceful occupancy, the balance of hardships favors the Petitioner because of the follow­
ing relevant-factors:
I
at" O Availability, cost, safety, adequacy, location, and other characteristics of alternative housing for each party
ST'' •j and any minors or other dependents, and/or
Kf" Q Effect on each party's employment, and/or
O Other factors, as follows:

a--;
^Respondent should be prohibited from entering or remaining present at Petitioner's school, place of employment
or i >
"*-* toft* SkJfa-fr 4frM 6 I A » 0 flvr fei^o ■ because:
")25 ^Respondent has no right to enter/remain present at such placets); OR
' O The balance of hardships favors the Petitioner in prohibiting the Respondent from entering or remaining at
such placets).
K. G The likelihood of future abuse would be minimized by appropriate counseling.
L. Q There exists a danger that the minor child/ren will be removed from this jurisdiction or concealed within the Suite.
IT M. D Unless Respondent is ordered to return or to not remove the minor child/ren. there exists a danger that the minor child/ren
will be:
□ Abused or neglected; and/or
s*
D Separated in an unwarranted manlier from the child's/children's primary caretaker; and/or
:$ i D Utiprotecte^aVwJhis/fcer/dwir well-being.
N. $. l*f\^J&\ -3» H&l&t&fc should be considered the primary caretaker of the minor child/ren
O. Cj Respondent has knowledge of toe^hereabowts of or access to the minor child/ren.
** '•"'* 4 -- ,3fi T^r sho^d be srmtede^I^i^^t^$aisipa/)f the fojlowimnpersonal,:
TR-awer. <dk^ . iw., "
icwwBsitTSKysvn^Tag^
because:
O Petitioner, but not Respondent, owns such property.
OR
& - . > • ■ • C Sharing die property creates a further risk of abuse or is impractical, the balance of hardship favors temporary
possession by Petitioner, and
D Petitioner and Respondent own the property jointly, or
□ The property is alleged to be marital property and a proceeding has been Filed under the 1MDMA
Q. Q An Order for protection of the following personal property:

should be granted because:

Q Petitioner, but not Respondent, owns such property.
OR
C The balance of hardships favors Petitioner, and
O Petitioner and Respondent own the property jointly, or
O The.property is alleged to be marital property and a proceeding has been filed under the IMDMA.
D Petitioner does not have sufficient resources to support herself/himself, and/or the minor child/ren and Respondent is
able to provide such support.
G As a direct result of the above described abuse. Petitioner has suffered certain losses and incurred certain expenses.
s.
-» wmrn
■III llil
P&mpH f OR ORDER ■ * * * * " * * * * • * » * -* *• *" t71-37C
' ' W 0 ^ ' - & ^ ^ - ^ -COPY-LAKE COUNTY CIRCUIT CLERK-COPY-
^^^^^^^M-COPY-IB N . COUNTY WAUKEGAN I L - C O P Y -
r#l^#iiP
 g^pjSfoi^fHfW!^^ wm
CASE NO.

T. " Disclosure of Petitioner's address would risk further abuse to her hun or to another pr-ilnied t w n . " -u«.n iiivjosurc
would reveal the confidential address oi a shelter lot domestic violence victims
U. HI There is a threat to the safety and well-being of Petitioner's familv or household when Respondent enters or remains
on the premises while under the influence of alcohol or drugs
V. C Other allegations:

REMEDIES REQUESTED

PETITIONER REQUEST^.THAT THE COURT FIND THAT THBjFOLLOWING AR.E PROTECTED PERSONS,
u i v n t n n c y u c o w i n n i i n c t u u n i rirw i n « i inBirui.Luninu 1QJ- rr^yj i r,\tjr.u rr.imi.14 /« -.> ,
CM\$nrvl wyL.teuJ* /Vfliftac. &*0to HB-iVteuCj Ma&mUMek
YVve/SfrflrV N&) tW-t^n *
FURTHER. PETITIONER REQUESTS THE ENTRY OF AN ORDER OF PROTECTION SETTING FORTH THE
FOLLOWING REMEDIES:
tfs I. With respect to Petitioner and other Protected Persons. Respondent he prohibited from commuting the following
^Physical abuse; JvHarassment; QfJ Interference with personal liberty.
GJ Intimidation of a dependent; G Willful deprivation
3 2. Petitioner be granted exclusive possession of the residence and Respondent be prohibited from entering or remaining
at the premises located at _
% 3. Respondent be prohibited from entering or remaining at / ?.S^*-T *•*' - JMt~T W*- (i,, ^■i?^*(^iJ^
-£*-*- ,__, while any Protected
Person is present.
Z2 4. Respondent be ordered to undergo counseling for a period of time to be determined *>y this Court [Sot available in
Emergency Order]
D 5. Temporary legal custody of the minor child/ren
be awarded to and visitation by Respondent be determined
• by the
Court. [Temporary Legal Custody not available in Emergency Order]
O 6. Respondent be prohibited from removing the minor child/ren
.... from the State or concealing
them within the State.
D 7. Respondent be ordered to appear in this Court with/without the child/ren on a date certain
G 8. Respondent be ordered to:
D Return the minor child/ren i.« the phssual wire ol

G Not remove the minor child/ren from

the physical care of
§§ 9. Petitioner be granted exclusive temporary possession of the following items of personal property and Respondent be ordered
to deliver to Petitioner said property that is in Respondent's possession or control, to wit
CLQTUA^ T.V.. Shxieo , HbtH C<JtM„£}A/tyJh^
Zl 10. Respondent be ordered not to take, transfer, encumber, conceal, damage, or otherwise dispose ol any ot the following
real or personal property:

G i l . Respondent be found to have a legal obligation to support, and be ordered to pay temporary support for Petitioner and or
the minor chiW^RmMnnBnies. as follows: $ per starting
payable thrd^JW W w l * the Circuit Court. [Not available in Emergency Order]

PETITION FOR ORDER C B " " " " c n T i i M i . - - . « «

J
1/1 37D RE.V 9/89
-COPY-LAKE COUNTY CIRCUIT CLERK-COPY-
- C O P Y - 1 8 N . COUNTY WAUKEGAN I L - C O P Y -
 < »
A CASE NO.

O 12. Respondent be ordered to pay $ respecting losses and expenses within the scope of
sec. 214(b)ft 2) of the 1DVA. (M* available in Emergency Order]

-0>. j5.
"ffuff Qljwnj Lit
U14. Respondent be prohibited from entering or remaining at the household or residence
while under
the influence of alcohol or drugs and so constituting a threat to the safety and well-being of any Protected Person.
Additional Allegations for Emergency Orders Only
^ 0 1(i) For above requested remedies 1, 3, 6. 7. 8, 10. 13 and 14, the harm which that remedy is intended to
prevent would be likely to occur if respondent were given any prior notice, or greater notice than was
actually given of petitioner's efforts to obtain judicial relief.
Z <ii) For above requested remedy 2. the immediate danger of further abuse of petitioner by respondent if
petitioner chose or had chosen to remain in the household while respondent was given any prior notice
or greater notice than was actually given, outweighs the hardship to respondent of an emergency order
granting petitioner exclusive possession of the residence or household.
£ (iii) For above requested remedy », improper disposition of the personal property would be likely to occur
if respondent were given any prior notice or greater notice than was actually given of petitioner's
effort to obtain judicial relief, or that petitioner has an immediate and pressing need for possession of
that property.
WHEREFORE. Petitioner moves this honorable Court to grant the relief requested in this Petition.

XptL /J.tiaAj
Signature of Petitioner
<X
>
V a
Signature of Attorney or State's Attorney

The undersigmxl. being first duly sworn upon oath, deposes and states that the contents of the foregoing Petition for Order
of Protection are true and correct.

Attorney Name
utorney i
Attoi \ At J. SUBSCRIBED AND SWORN to before me
Address JE2: .'iPM^i. *&> 6>mr 2
City
Phone

Attorney Signature

PETITION FOR ORDER C ™ P Y - L A K E COUNTY CIRCUIT CLERK-COPY- 171 37E REV. a/as
I c O P Y - 1 8 N . COUNTY WAUKEGAN IL-COPY-
 a Independent Proceeding
D Other Civil Proceeding
{Specify)
i
O Criminal Proceeding
O Juvenile Proceeding

FINDINGS
ORDER OF PROTECTION
Q-'flmergency Q Interim D Plenary

[Finding solely applicable toon ex pane Emergency Order]

£ The Court, having examined the Petition filed in this case, as well as ihepersonpresenui^thepetitKm. under oath. FINDS THAT;
D The averments presetted ate sufficient to grant the relief ordered.

■'■?*

The Court, luving eumined the Petition filed in this case and luving conducted a hearing thereon, under oath. FINDS THAT:

It ba&jurisdiction of the subject matter and over all necessary persons in these proceedings pursuant to:
EnOVA D UCCJA:

, has/have buen abused by Respondent, a family or household member as defined in the IDVA.

SanLabtue has consisted of:

€?Physical abuse; O Harassment: D Interference with personal liberty; G Intimidation of a dependent; G Willful deprivation

QXDT Theft
pZj*^ M UuAf^isLA<h <UsrtJ^x<L

E. The Court has considered the nature, frequency, severity, pattern and consequences of past abuse and the likelihood of future
abuse to Petitioner or any member of Petitioner's or Respondent's family or household.

F. For the remedy of Exclusive Possession of the Residence:

(WCtitioner has a right to occupancy and Respondent has no right to occupancy.
OR
O Both parties have a right to occupancy, and considering the risk of further abuse by Respondent interfering with Petitioner's
fe and peaceful occupancy and all other relevant factors, the balance of hardships favors Petitioner.

G. For the remedy relative to prohibitions on Respondem from entering or remaining present at Petitioner's school, place of employment.
or other places «times when Petitioner is present:
to enter/remain present at such place(s): or
|ps favors Petitioner in prohibiting Respondent from entering or remaining at such ptace(s).

FMDfNBS • ORDER OF PROTECTION: 1 of 3 Pngnn 17V106 A l « V 9/89

• 1

-COPY-LAKE COUNTY CIRCUIT CLERK-COPY-

-COPY-18 N. COUNTY WAUKEGAN IL-COPY-
!
"*~*'' , ~7" T "'™ r ' , ' ,,!,wm *™^

LJ H Foe Ae craned) of coucuebnf. Ac tikeliiuxki jl' ruiuic jtHi.ir uuuld Or niimrni/cd hi jppropriaic . nunvfiin^ ser. icc\

U l For Ac remedies oi Fnuporjrv Legai Ci itndy. Removal M CofKeaJrnem of Child Oriler to Appear >>t Pri>M.jl Care of Child.
Acre o u t ) a UrafOT A M a m m n ;iufcj «dl h»r |Otrr* applwabU f*u(e«r|
''. ADwcd or neglected
£ I f t o p t t l y ref&uvcd (HX»I A n jtmtdacuoo ot unpmpc£l> cstocealed wtthm ih* Sijic
' lopropttfj tsgywated f i « n Ac cliiki pnutiry eareuxer

L^ I For Ac rwaofae* df Tewp****-* «*%& CamoCy. Removal or Concealment of CrukJ. Or.k- ■ Apcar. or Physical O r e of Child.
_______ iv or has been the primary caretaker of such minor ctaM/ren.

„ * Fwr A r m n l ) of Eastatnc Possr:*M«i» »f Feisonal Property. as lisSed in Ac Petition

:
, ftnww. sw AH Bctpwaieoi. twm osft iwropetty
OR
1 Sfcartrvf Oar property create* a fwrEtecir t t Ot afattc «r IS impractical and the balance of hardships favors temporary possession
» j Pet#«*ef. aad
Pwwauwt and Respondent O M ) life voperrii jmnrrs :w
The prwptffly » aliened w hr ssafm property and a proceeding has Nren (.-led u tder the I M D M A

U l For A r i t m d t rf PrtjaeciMo of Propurr as lined in Uic F*HMM»

" Pcwajx* * M opt R n p w I M . ™ri-. M K * profern
OB
T V tutamr of tWdsfapi f a t w i P M W W C T and
I ' WWMWW artrl Respondent owaj the wflpen) jnvwl v IM
T V prrjfcrty « aUcen) w be mane.'' property and a pn*.redmfi h*s v e n fried under the I M D M A

._, M F * A t t t n o i v ■.)! tappvn Ropnotlort ban a legal uMifatrnti N> provide support in Petitioner i m l ' i i . the minor

L.! "* Fof Ae remedy nd p a y — <*l tmiet. a» a d«!<ici rcwii of the aftwtc. the Peinmner has wittered [he following losses

.. O fa* tnt KftHoH o» PnttH^mna of F,Mry. KMpPii»ilriBl eonuiiuHrt i ihreai in rhc safety and well-hems of Prrnioner or Peiilioner's
thM>es> h» ewewm: or i*mamm$ m 0K reMdlerai* «♦ fvwiehotd *hile under rhc influcrKe of akoh.il or drugs

w F ~.„,»™, ,._____— , ,™ ^ — _ . r* «i«*Se to ^nrvjf rhc PctitKm fjfi htsher <>»n tvhalf due ID age or disabling

LJ O f V dntittUMT «sf FcUJutiBfT'* adtlrrvs »«ild) I'm* a!hi»«e of « m t w m h e r i<f the lannl> or household or woulil reveal the
WMiAraHBial iMtn% at t vhefiet hi* dumrtht '»n«rote s Ktims

Lj ft M i n e fees iirr \hudrpnjnu Prr*en!t*ii iml-.\ *»isesf Deferred

D $ The ter4Ji>p n> Resyowient if rgmeuVie*) . , .. . . .. ..

• o r fraHKd. wtmaMialty o«ri««i:|h* A t harftitepto Pewmnrr m Hie loik-mnj; manner .

f&mrx. 7-uuP-tnr Ufa/&?£%&

fei:-^ :.- ■■■■

:■ ■■■.-,■. v,..-. a / . . - , „ e l , n „ -^—i - - j , 'nal frin M if laaiiiaa" fiTB^^ilialaaMi^^trtrtriftjB IliaaatiiteTfihifailfti aaliat" ~ '-" - ri "' ---'-■ ■'■' - - — - ■ - ' '- l " J ^ J -aaYflirtj*iafwiliaalaaaiffi

-COPY-LAKE COUNTY CIRCUIT CLERK-COPY-

-COPY-18 N. COUNTY WAUKEGAN IL-COPY-
 Tvy+sei^sw? ■fpmnpp PPSBSP
*ww?«*!m

EMEROENCY ORDERS ONLY

&U FFor each of the remedies allowable under Emergency Order* of Protection, the harm which that remedy is intended to prevent
I
would be likely to occur if Respondent were given any prior notice, or greater notice than was actually given, of Petitioner's
efforts to obtain judicial relief.

E M ^ F «For the remedy of Exclusive Possession of the Residence, the immediate danger of funlit • abuse if Petitioner chooses or has
chosen to remain in the residence or household, while Respondent was given any prior notuc or greater notice than was actually
given, outweighs the hardship to flespoideni

D W For the remedy of Exclusive Possession of Personal Property, an improper disposition ol the propeny would be likely to occur
if Respondent were given any pnor notice or greater notice than was actually given of Petitioner's efforts to obtain judicial relief.
or Petitioner has an immediate ami pressing need !•» possession of the property

APPUCABLE TO ALL TYPES OF ORDERS

TRANSFERS. RESERVATIONS. OR DENIALS (which shall be set out in an order!

CD I Requests for the following remedies are to be transferred by order to

as being a Court which ordinarily addresses such matters

Q II. Rulings on the following remedies are to be expressly reserved by this Court

Q III. Relief with respect to the following remedies is to be denied for the following reasons

Date:.

000987000028

FINDINGS ■ ORDER OF PROTECTION: 3 of 3 t/t-106C HEV 9/89

-COPY-LAKE COUNTY CIRCUIT CLERK-COPY-

-COPY-18 N. COUNTY WAUKEGAN IL-COPY-
Mm^mmtmtmm
 ppllilpliNi
BEAR OOJVN VflU ARE MAKING 6
IN THE CIRCUIT COURT OF LAKE COUNTY

People ex rel.
on behalf of
lelf and/or on behalf of .--*

c^.ite.92 F 9 8 7
Petitioner

-vs~
D Independent Proceeding
D Other Civil Proceeding
iSprcify)
,J
I LE 9
O Criminal Proceeding
(J Juvenile Proceeding
Respondent
LEADS NO
:UIT
1
PETITIONER ADDRESS CITY

6r2/9^aJe £ J L .
Pvtf CJ (Check if omitted pursuant to Statute)
RESPONDENT ~-^ . ->. ADDRESS p. CITY^
CAtoc X SPI22JI&I rJ
Birthdaie Sex Race Hciglni Weight Hair Eyes Social Security Number

&| frits r w S'7" 135 GixA^fi

(if known)

EMERGENCY ORDER OF PROTECTION

ANY KNOWING VIOLATION OF ANY ORDER OF PROTECTION FORBIDDING PHYSICAL ABUSE. HARASSMENT.
INTIMIDATION OF A DEPENDENT. MTEfiVERENCE WITH PERSONAL LIBERTY. WILLFUL DEPRIVATION. OR
GRANTING EXCLUSIVE POSSESSION OF THE RESIDENCE OR HOUSEHOLD IS A CLASS A MISDEMEANOR. ANY
KNOWING VIOLATION OF ANY ORDER AWARDING LEGAL CUSTODY OR PHYSICAL CARE OF A CHILD. OR
PROHIBITING REMOVAL OR CONCEALMENT OF A CHILD MAY BE A CLASS 4 FELONY. ANY WILLFUL VIOLA­
TION OF ANY ORDER IS CONTEMPT OF COURT. ANY VIOLATION MAY RESULT IN FINE OR IMPRISONMENT.

(Definitions of prohibited conduct on Page 3 )

and their family members em protected by this Order: O f f f l \ S \ \MA J» TSWKXA -.

imHLmnw^
WmNst-K
fi"
As to service of this Order, Respondent: "tflnus't be servsd Qserved in open Court

Date, time and place for further hearing:

Date: Courtroom No. ClQZ-

Lake County Conrtboum, WankegBB, II MOSS

This Order was issued on This Order will expire (t»r be subject to I.KAOS renewal) >>n

£. Date

f: EMERGENCY ORDER Of PROTEP „T „ „ „ ™ „ v 171 280A REV. 9/89

£ . _ , -COPY-LAKE COUNTY CIRCUIT CLERK-COPY-
i--..: ^ | M ^ ^ I 9 ^ i _ C O P Y - 1 8 N . COUNTY WAUKEGAN I L - C O P Y - > ST^-S ATTORNEY ;..;>« •-..■r .
¥&.;:
YOU ARE M <POPIE3
BASED ON THE FINDINGS COURT. D WHICH WERE MADE O R I K Y FOR TRANSCRIPTION. OR
Q WHICH ARE SET OUT IN A SEPARATE INSTRUMENT FILED WITH THE COURT. AND WITH JURIS
DICTION OF THE SUBJECT MATTER AND OVER ALL NECESSARY PARTIES. IT IS HEREBY ORDERED
THAT:*

I. With respect to all Protected Penan*. Respondent is prohibited from the following:
*
j&fhytical abuse: Jj^Harassmem^krterfercncc with personal liberty; C Intimidation of a dependent: IS. Willful deprivation.

y(f 2. Petitioner is granted exclusive possession of (he residence and Respondent shall not enter or remain in the household or premise.
located at ^SlBlcd tm Page I o* Prtilloorr'ft Addre**; D <Mtwr:
[Krmrttf ion ao> agnt ottr u> pnptitr |
X ' Respc^isprohimtedfrome*
placets) of emptoymem. namely
or at
r^jggg. ■ w&ttygm-tt . while any Protected Person is present

D 6. Respondent is prohibited from removing the minor child/ren_

from Illinois or concealing them within Illinois

(9T7. Respondent is ordered to IMifUpom No,. 3^7- he County Courthouse,

Waaktftoa. Illlaoln on _
with/without the minor child/ren.
- fv&tltZ AM'PM

Q 8. Respondent is ordered to:

r. Return the minor child/ren to the physical care of.
~ Not remove the minor child/ren
from the physical care of_

& 9.
^tv&r&gftr. ;m of the following items of personal property

and. further, if Respondent has possession or control of any of such property. Respondent shall promptly make it available
to Petitioner. [Remedy does not affect ntte to property.)
■■a
D 10- Respondent is prohibited from taking, encumbering, concealing, damaging or otherwise disposing of the following property

except as explicitly authorized by the Gum C Further. Respondent is prohibited from improperly using theflpancialor other ■ !

resources of on aged member of tfce family or household for the profit or advantage of Respondent or any other person.

D 13. Respondent is further ordered and/or enjoined as follows:

m
D 14. Respondent is prohibited from remaining at the household ot residence located at □ as Stated above-. Q Other:

under (he influence of alcohol or drugs and so constituting

.while
a threat to the safety and well-being of any Protected Person.
i
sL.4. 5 , 11, 12 of the o
.Q*M*Jt
D Custody DMonetary Losses OOther

NOTICE: Upon 2 days notice to Petitioner or such shorter notice as the Court may prescribe, a Respondent subject to an Emergency
y.
Order of Protection issued under the IDVA may appear and move the Court to re-open that Order and to re-hear the original or amended
Petition. Any motion to re-open shall be supported by affidavit.

■w ™») 4 , 1 ^ 3 -
Name

Attorney for

Address ^ l*faL{L Vf City U / f l t ^ j f O n 3&>. Uok\ r . , ^ No TM-t&M 7 i

EMERGENCY ORDERj Off .■**■■*« I — * •• • » _ _ -

"if S j ^ - j & g j g g r a -COPY-LAKE COUNTY CIRCUIT CLERK-COPY-

171288B REV. 9/69
1
0 ffl^lf$ATTOfcWf;*>:., .......^
^ - C O P Y - 1 8 N . COUNTY WAUKEGAN I L - C O P Y -
W- v-v;
* BEAR OQWN yQU ARE MAKING 0

DEFINITIONS C>F PROHIBITED CONDI < I

PURSUANT TO THE ILLINOIS DOMESTIC WOLENCE A( I Or IVK6

"Abuse" mean* physical abuse. harassment, intimidation til a dependent ».:r uncmr with personal Jiftcrty of willful deprivation.
but does not include reasonable direction ol a minor child by j p.jrrnt ,i jxtvm m U u pareniis

"Physical abuse" includes vcxual abuse and incut.

(1) knowing or rccklcs-. use of physical furce. confinement or n slraun
(2) knowing, repeated and unnecessary sleep deprivation. or
(3) knowing or reckless conduct wtach create* an immediate risk ol physical harm

"Harassment" means knowing conduct which is nut neccssar> «o accomplish a purpose that is reasonable under the circumstances.
would came a reasonable person emotional distress, and docs cause emotional distress to the petitioner Unless the presumption
is rebutted by it preponderance of the evidence, the following types of conduct a/e presumed to cause emotional distress:
(I) creating a distrubaiKe at petitioner's place of employment.
12) repeatedly telephoning petitioner* t place of employment, home or residence.
(3) repeatedly following petitioner about in n public place or places.
(4) repeatedly keeping petitioner under surveillance by remaining present outsuk: his or her home, school, place of employment.
vehicle or other place occupied by pcttuoaer or by peering in petitioner's windows.
<5) repeatedly threatening to improperly remove a child of petitioner's from the jurisdiction, improperly concealing that child
from petitioner or making a single such threat following an actual or attempted improper removal or concealment; or
(6) threatening physical force, confinement or restraint on one or more occasions.

"Interference with personal liberty" means cwimutting or threatening physical abuse, harassment, intimidation or willful depriva­
tion so as to compel another to engage in conduct from which she or he has a right to abstain or to refrain from conduct in which
she or he has a right to engage.

"Willful deprivation" means willfully denying n person who because of age. health or disability requires medication, medical care.
shelter, food, therapeutic device, or other physical assistance, and thereby exposing that person to the risk of physical, mental ot
emotional harm, except withregardto medical core or treatment when the dependent person has expressed an intent to forgo such
medical care or treatment. This paragraph doss not create a new affirmative duty to provide support to dependent persons.

"Intimidation of a dependent" means subjecting a person who is dependent because of age. health or disability to participation in
or the witnessing of: physical force against another or physical confinement or restraint of another which constitutes physical abuse
as defined in this Act. regardless of whether ffo; abused person is a family at household member

OTHKR DEFINITIONS

7. "Family or Household Members" includes spouses. former spouses, parents, children, stepchildren and other persons related by
blood or marriage, persons who share or formerly shared a common dwelling and persons who have or allegedly have a child in common.

8. "Petitioner" may mean not only any named petitioner for the order <>l proicction and any named victim of abuse on whose behalf
the petition is brought, but also any other person protected by this Act.

9. "Adult with disabilities" means an adult prevented hy physical or mental disability or advamed age from taking apptopnate action
to protect himself or herself from abuse by a family or household member. A person may be an adult with disabilities for purposes
of this Act even though he or she has never been adjudicated an incompetent adult However, no proceeding may continue on behalf
of an adult with disabilities over that adult's objection, unless such proceeding is approved by his or net legal guardian, if any

0009S7000025

e^GEHCY ORDER OF ^ E C T K * ^ ^ CIRCIJIT C LERK-COPY- 171286C REV. 9/89

fc^ilffley Icopylif N. SESnr WAUKEGAN IL-COPY- 0 STATES ATTORNEV

 im IBB cutcoyt coats or THE
HIlKIHfJIU JUDICIAL CIRCUIT, UIKE COUNTY, ILLINOIS

Petition*
stitioner/Plaintiff F
-ys- GEN. NO.
CQfUQ S~QPl22l(liZJ TTT1
Respondent/Defendant

9DHKSS - ORDER OF PROTECTION

To the above-named Respondent/Defendant:

You are hereby summoned and required to file an answer in this case, or otherwise file
your appearance in the office of the Clerk of this Court, located at 18 North County Street,
Waukegan, Illinois, within 7 days after service of this summons, exclusive of the day of
service. IF YOU FAIL TO DO SO, AN ORDER OF PROTECTION, BY DEFAULT HAY BE ENTERED AGAINST
YOU FOR THE RELIEF ASKED IN THE PETITION, WHICH HAY INCLUDE THE ENTRY OF A TWO YEAR PLENARY
.<
■ A
ORDER OF PROTECTION.
This summons must be returned by the Officer or other person to whom it was given for
service, with endorsement of service jtnd fees, if any, immediately after service. If service
cannot be made, this summons shall be returned so endorsed.
This summons may not be served later than 30 days after its date.

WITNESS: SALLY D. COFFELT, Clerk of

said Circuit Court, and the seal thereof I
at Waukpgan, Illinois.
DATED: X M A Y 4 - ft

Clerk of thje Circ

Plaint iff'svAttttftteJ: relfri GJ&ftbcU\

Attorney's State ID No
No.

Address 4/s ,v4iA</grC ktedP

-UtoH'
Telephone Number mx-wj
W. 171-107 3/87 Date of Service: ___ 19
(To be inserted by o f f i c e r on copy l e f t
■ person.)
-COPY-LAKE COUNTY CIRCUIT CLERK-COPY-
- C O P Y - 1 8 N . COUNTY WAUKEGAN IL-COPY- ^^g^iSl^j^xssfeV"*^
STATE OF ILLINOIS ) 9
) ss U IN THE CTRCm/COURT OF THE NINETEENTH
A f 4 y r 4 i c ] ^ j i A w T T , LAKE COUNT?, ILLINOIS
COUNTY OF L A K E )
9 2 F 98*7
Cr\tL\STiKA J . ^Pffti^hA
Plain
-vs- GEN. NO.
■Qxtoc J. SPi-z-ziasa: }
Defendant )
PETITION A.VD ORDER TO SPE OR DEFEND AS POOR PERSON

Now comes "Q//21 AT'/Vfl J . *$T» tS^ , pursuant to Supreme

Court Rule 298, and on oath states:
1. My occupation or means of subsistence is: p<D£>iEi£Sk

2. My income for the previous year was: $ 3 6>g)P

3. The source and amount of income I currently expect is Jp/LflBSr?'

4. The persons dependent upon me for support are: f>1j£glp

5. The nature and value of property owned by me is:

(a) Real: /Qpft'g
(b) Personal: Cu>rh:& — ft 1 7 fap&. &MW) # 7 ~
6. During the preceding year, I have petitioned for permission to sue as a
poor person in the following matters:

None Other

7. I am unable to pay the costs of this suit.

8. I have a meritorious claim or defense.
WHEREFORE, petitioner prays this Court to grant h^X* leave to sue as a
poor person. 1

Signed and Sworn to before me

1 V 1
Petitioner
OFFiriAL
TER C. :-. r , :'c~.,
-^
'•' 7 / J ) ->;
ORDER
Permission i s hereby (granted) (ck»4e<i)- petitioner to sue as a poor person, and
The Slmiiirrif.fwye County ( i s ) (to-not) ordered to serve process upon
defendant w i t h ^ ^ | 0 0 0 2 9

The County of Lake ( i s ) ( i s not) ordered to pny costs djf service by publication.

2
»ated: ^ / f / f " Enteru^tl^ L i t * t J p ? ,

SR^M^SS^S^SSS- m>i«9 3/B'

£ - t t ! ? W 5 ^ P ^ ^ ' ^ ^ v ^ ^ ^ g ' ' ^ '*'■' ^ ■ • ■""■* v ' ; ---' : '-' ■■"•■■■-: '■■.-'■■■ •.■•:■:.;,■■:.■.■■•■-■■■■-- *.'«*
A
P
^ d £ i ^ i » Y M YOU ARE MAKWO ^ ^
IN THE CIRCUIT COURT OF LAKE COUNTY

icmiti
_ on brtrfi ( of
^ILZKIQ! «ff nt'Of «m behalf o<

^U^ii^ PvaK Peuioarf

Ci.«« N o

^5> Indtptratem Proceeding

_ Olhtr Civil Pmxcdiftg
< iSprnfw : V
KMtf^. s,Pi^?:ȣ) ... Comma! PnxcrUing
. Juvenile Proceeding * ^

Ik ADS NO _

% *
PETTTIONEK ADDRESS CITY

i 75^5 VJ, Dwrm*

C)w&** &S- <Cbcck if omnicJ putviam »o Suiute)

RESPONDENT ADDRESS ctnr

CAJU?<- J , ^ pi^ZZi g £ \ 1 7 4 7 ^ K/.DQflifM e-£Z6
Buthdwe Set Race Weight Hair Ey« Social Secunty Number

G)i2ks~ F S'7"
OR1MLR OF PROTECTION
4.V.2 INTERIM 4«to y>PLEN/
«ARY

ANY KNOWING VIOLATION OF ANY OttOBIt OF PROTECTION FORBtDDtNG PHYSICAL ABUSE. HARASSMENT.
INTIMIDATION OF A DEPENDENT. CYTSRFlEnENCE WITH PERSONAL LIBERTY. WILLFUL DEPRIVATION. OR
GRANTING EXCLUSIVE POSSESSION OF THE RESIDENCE OR HOUSEHOLD IS A CLASS A MISDEMEANOR. ANY
KNOWLNG VIOLATION OF ANY ORDER AWARDING LEtiAL CUSTODY OR PHYSICAL CARE OF A CHILD. OR
PROHIBITING REMOVAL OR CONCEALMENT OF A CHILD MAY BE A CLASS 4 FELONY. ANY WILLFUL VIOLA­
TION OF ANY ORDER IS CONTEMPT OF COtTTT ANY VIOLATION MAY RESULT IN FINK OR IMPRISONMENT.

(Definitions of prohibited conduct on Pttge 4 )

.CUAJH /VU£

A? to service ol this Order, Pesrrondenf: Oii:5t t» '.(?rv«!d terved in opcr> Cour-

J?3
Dale .time and place for further hewing [if Ordtr u an Imtnm out]

Dae Time Courtroom No

Latit < ountj (oortboaM, Waakrftaii. II 60085

rhis' MM This Order will cftpire iorbe subject in LOADS rentwah on:

Date. ■w Jf4i/if,ftT4 »- IIIOOOM

s-
INTERIM/PLENARY ORDER OF PROTECTION: 1 ol 4 P i o * . 171-789A REV 9/89
Ik':. WHITE - CIRCUIT CLERr _ C 0 P Y - L A K E COUNTY C I R C U I T CLERK-COPY- »LD STATE'S ATTORNEY
■^^•a^iw-r^^iAtftiMrtUi -COPY-18 N. COUNTY WAUKEGAN IL-COPY- •i^^1s*tZJi±^z^^s^iM.
 BASED ON THE FINDINGS OF THIS COURT. Zl WHICH WERE MADE ORALLY FOR TRANSCRIPTION. OR
O WHICH ARE SET OUT IN A SEPARATE INSTRUMENT FILED WITH THE COURT. AND WITH JURISDIC
TION OF THE SUBJECT MATTER AND OVER ALL NECESSARY PARTIES IT IS HEREBY ORDERED THAT

I. With respect to all Protected Persons. Respondent u. prohibited from the following
*5N Physical abtM:$KHaraisaiemrjj\lntcrierence with personal liberty, i Z Intimidation of a dependent, C Willful deprivation.

D 2. Petitioner tsgrsmed exclusive poue^Jun or ilicrcsidm:ear^

looted arfofitated ©• Pet* I e» Pettt»o»ec'ii Addrr**: Q Other:

(Jtmnfv dort <w agtrt mk to ptnprnt)

Li 3. Respondent is prohibited from entering or rertainittg at th* rtrnonii ■< n.i n«. _«qh~iW«> ——U.I ■ _j»
placed ot«i»*>yment. jyrfy- fijiAU/n UcStpUAAs^^ 4 * 3 1 ly(lkWD <H/€_ \
or at (J*AAn*Jt. t ^ L < . while any Protected Person it present.

.; 4. Respondent is ordered to undergo counseling at

for a duration of

O S. Temporary legal custody of the minor child/ten

is awarded to
in the best interest of the children, subiect to visitation on the following days and times

Respondent shall pick up and return the children to

An affidavit accepting supervisory responsibility Having been filed by

he'she is approved to supervise said visitation

J 6. Respondent is prohibited from removing the minor child/ren

from Illinois or concealing them within Illinois

G 7. Respondent is ordered to appear in Courtroom No. at Lokr County Courthouse.

WMfcegen. IIU»ot» on at AM/PM
with/without the minor child/ren

D 8. Respondent is ordered to:

lj Return the minor child/ren to the physical care of .
D Not remove the minor child/ren
from the physical care of

G 9. Petitioner is granted exclusiyerossession of the following items of personal progeny j y ' * ° \ PQC/Co j

and. further if Respondent has possession or control of any of such property. Respondent shall promptly make it available
to Petitioner. [Remedy daex not affect title to property. \

O 10. Respondent is prohibited from taking, encumbering, concealing, damaging or otherwise disposing of the following property

. except as explicitly authorized hy the Court

~ Further. Respondent is prohibited from improperly using thefinancialor other resources of an aged member of the family
or household for the profit or advantage of Respondent or any other person

G 11. Respondent is ordered to pay temporary support for G Petitioner and/or C the minor child/ren of the parties as follows
$ —. per. starting payable through the Clerk of the Circuit Court

Q 12. Respondent liluUSftil IMIpiyl petitioner $ as actual monetars compensation for losstes)
suffered as a direct result of the abuse.
T Further. Respondent is ordered to pay court costs in the amount of $ and attorney fees in
the amount it % in connection with any action to obtain, modify, enforce, appeal or reopen any order
of protection

^mmmmmm OR "COPY-LAKE COUNTY CIRCUIT CLERK-COPY-

19 N
•tsJmtfcrS&W && ' COUNTY WAUKEGAN IL-COPY- SOLD STATFS ATTORNEY
BEAR TOWN YOU ARE MAKING

D 13 it
' °*WJ£
tHJWgf
-1 IA Respondent it prohibited from remaining 31 the Household n resilience located Jit Q Moled on Pag* t as Petitioner's Addrts*;
QOtbtr: while
under the influence of alcohol or drugs JJMI SO constituting .1 ihrcal to the satety and well-being •>! any Protected Person

Zj. 15 The relief requested In parjqr«|:h(s) 4 . 5, 11, 12 of ihe petition are (OENttO) (RESERVID). becausr:
11 Coui >s»l inq OSupport
L) Custody ClHont'tary Losses I I Other

PLENARY ORDERS ONLA

It Otder is a Plenary one. it shall remain in effect until Jv* /1 I !T 1 r e 1/

1 7»Two years following date of entry of such Order, such expiration date being ' *7TT^ 'Pi I ' ' \ . or
such earlier date, as ordered by the Court, such expiration date being
2 Final judgment in conjoined proceeding is rendered
5 Final judgment in conjoined proceeding r. modifwd
■i Termination of any voluntary or involuntary commitment or until
I urn t« exceed 2 \eun\
5 rinal disposition when a Bond Forfeiture Warrant has issued. or until whichever first occurs.
\twt to exceed 2 yrarj|
6 . Expiration of any supervision, conditional discharge, probation, periodic imprisonment, parole, or supervised mandatory release
7 Expiration ol a term of imprisonment set by this Court

NOTICE Upon 2 dayi notice to Petitioner, or such shorter notice as the Court may prescribe, a Respondent subject to an Interim Order
of Protection issued under the IDVA may appear and move the Coun to re-open that Order and to re-near the original or amended Petition.
Any motion to re-open thai] be supported by affidavit

Date. <^-A?-9.
Judge

Name frtrrfc*i k,JStei3stf>J

Attorney for ftiifrivi fru
Address . tirvMi^ hfc
City -^*jjfhfK \ &*—kOO J~»
Telephone jmtmii,i±- ^ - H

IMTERIM/PtENARY OF _ c o p Y _ T AK._ rrkT_.T_v _TT,„ 171-28SC REV.*

COUNTY CIRCUIT CLERK-rrvDv
V-UTX-IJAKE
WHITE CWCW - C O P Y - 1 8 N . COUNTY WAUKEGAN I L - C O P Y ^ " *" °°lD S W E 5 M1Gm
' * A
MWW
DEFINITIONS OF PROHIBITED CONDUCT
PURSUANT TO THE ILLINOIS DOMESTIC VIOLENCE ACT OF 1986
"Abuse" means physical abuse, harassment, intimidation of a dependent, interference with personal liberty or willful deprivation
but does not include reasonable direction ol a minor child by a parent or person in toco parentis

2. "Physical abuse" includes sexual abuie ami means: ■ %

(1) knowing or reckless use of phyiucal force, confinement or restraint:

(2) knowing, repeated and unnecesiary sleep deprivation; or

3
(3) knowing or reckless conduct which creates an immediate risk of physical harm.

''Harassment" means knowing conduct which is not necessary to aoBomplish a purpose that is reasonable under the circumstances.
I
would cause a reasonable person emotional distress: and does cause emotional distress to the petitioner Unless the presumption
» rebutted by a prepondercoce of the evidence, the following types of conduct are presumed to cause emotional distress:
<I) creating • distrttbancc at petitioaer't> place of employment;
(2) repeatedly tetephonisg petitioner's place of employment, home or residence;
I
(3) repeatedly following petitioner about in a public place or places;
(4) repeatedly keeping petitioner under surveillance by remaining present outside his or her home, school, place of employment.
vehicle or other place occupied by petitioner or by peering in petitioner's windows;
(5) repeatedly threatening to improperly remove a child of petitioner's from the jurisdiction, improperly concealing that child
from petitioner or making a single such threat following an actual or attempted improper removal or concealment.
(6) threatening physical force, oonfmemem or restraint on one or more occasions.

"Interference with personal liberty" means ootnmhting or threatening physical abuse, harassment, intinudation or willful depriva­
tion so as to compel another to engage in conduct from which she or he has a right to abstain at to refrain from conduct in which
she or he has a right to engage.

"Willful deprivation" means willfully denyiag a person who because of age, taalm or disability requires medication, medical care.
shelter, food, therapeutic device, or other physical assistance, and thereby exposing that penon to the risk of physical, mental or
emotional harm, except with regard to medical care or treatment when the dependent person h a expressed an intent to forgo such
medical care or treatment. This paragrafQi does not create a new affirmative duty to provide support to dependent persons.

"urtinudation of a dependent" means subjecting a person who is dependent because of age, health or disability to participation in
or the witnessing of: physical force against another or physical confinement or restraint of another which constitutes physical abuse
. "* a
as defined in this Act. regardless of whether the abused person is a nattily or household member.
■■»*:

.■■?4
OTHER DEFINITIONS 3
■u
7. "Family or Household Members" includes spouses, former spouses, parents, children, stepchildren and other persons related by
blood or marriage, persons who share orformerlysrtared a comnioo dwelling and persons wfjo taw

8. "Petitioner" may mean not only any named petitioner for the order of protection and any named victim of abuse on whose behalf
the petition is brought, but also any other person protected by this Act.

9. "Adult with disabilities" means an adult prevented by physical or mental disability or advanced age from taking appropriate action
to protect himself or herself from abuse by o family or household member. A person nay be an adult with disabilities for purposes
of this Act even though he or she has never been adjudicated an incmmietemachih. However, no proceediiig may contimte on behalf
•-3
"-Sis
of an adult with disabilities over that adult's objection, unless such proceeding is approved by his or her legal guardian, if any.
I
M

P^TeWM/PUrlAHY OR0ER OF PROTECTION: « of 4 Panes 171-289D «EV,

'^^Siais*:V*^ £ANArT*.« RESPOHDEM PINK PfcllllONER QOLO • STATER A T T O ^ ^ 1 '
i,**'- ■ _COPY«LAKE COUNTY CIRCUIT CLERK-COPY-
-COPY-18 N. COUNTY WAUKEGAN IL-COPY-
 K-*Bifftf : ^ V - f -2-M>as5fc3

*¥>?

ois
The. matter of:
, 4 ^ P A * Q L J . SPJZZIRRI
Petitioner
and GEN. NO 92F987

CHTIISTIHAYJ;^ *RATT
LAUREL HAIBECK J
. i|.'i:;^|ii^Bpiond«nt i ^ i y^-

BEET f«$^
^?f *3
' ■ »i

Now cojte#3Ilj^§iM ,:
and through'" :>4
attorn«yi:5^rafflB^^a^^:iih4
of
.i^ti-ti6ns-the Court, and in
W$$&*#?&ftvov*
r •8ai#|^^li!3iftrM1 i *S^e^as follows:
*&PfcF*p*
fc»*»*^gat
'"'Iff
^^t^#^ep^?and the P e t i t i o n e r were
l|^^ce]dAand an award of custody of the
i$as; granted t o the P e t i t i o n e r , CAROL *•: .sill
* > . ■:■

^iBi6^:.J-*-'^PIZZIRRI-»^erpin s t a t e s that
-■■■■>m
15 «t»
»*lffi^^ in th
i ^ S w i ^ a l r ^ ^ n o ^ Children 5;:/
M i M l f e r n ' M#y W f 1969 ,aftd ^ rv
$©fe$ugust: 6^ 1S7M and CIPRIAHAV-f
£ ^i :19fo:$ r e s i d e "with t h e "*
^tteGpt for CHRISTINA J. PRATT.
lioi? iafroutMay 8, 1992 an Order of Protection
l^jigljt agttitist Pe t i t l o n e r , CAROL J. SPIZZ rRRI,
*%'HaibirtJk on behalf of CHRISTINA PRATT.
L Haibeck had no standing to bring an
:#r6te^t^6S against CAROL J. SPIZZIRRI on
^ f y ^ ^ S ^ ( ^ : ^ R A l T . Uwrel Haibeck i s
'H. he'iglltTOi ;Q# P e t i t i o n e r .
[
5*$
m jb^e*: va^atiiig the Order of Protection
lJCla^S*XiW^ii^r i s s t i l l a minor and
l#u£ ^ e l p i ^ p i i t y of her mother CAROL J.
I who ^ t i i f e ^ e t a i n s custody over said
> i<&&

£*S i l l hearinj|)|jfe;held concerning the

M stive :^igMsiyy^|^ parent, CAROL J

};M.1S

-COPY-LAKE COUNTY CIRCUIT CLERK-COPY-

-COPY-18 N. COUNTY WAUKEGAN IL-COPY-
 That CHRISTINA PRATT has recently needed medical
7. attention and her mother is concerned about
CHRISTINA'S health. CAROL SPIZZIRRI remains the
custodial parent notwithstanding the order of
protection brought by Lawrel Haibeck.

CAROL SPIZZIRRI asserts the defense of privilege to

8. use reasonable force to discipline a child and
parental immunity. The restatement (second) of
Torts Section 1H7 states the general principle as
follows: n A parent is privileged to apply such
reasonable force or to impose such reasonable
confinement upon his child as he reasonably
believes to be necessary for its proper control,
training or education."

The neighbor LAWREL HAIBECK is attempting to stand

in&ocg» parentis" on behalf of CHRISTINA PRATT. We
alijeige that LAWREL HAIBECK does not intend to
assume all thus full lawful obligations which are
incintent to the parental relationship.
Be&ow^are facts and circumstances that need to be
aftd&&s%ed to determine if LAWREL HAIBECK stood H n
-.nnr, ,.,*,«„ +Y>B Order o f
Ff3S£&ti£i»h was i s s u e d .
Relationship to CHRISTINA PRATT of LAWREL
A.
'I^tenf of LAWREL HAIBECK to assume parental
B. duties and responsibilities
c Exercise of.Parental duties and
*
I J f f l S S S ^ * M 5JSSfeKHS5S5;
■.:m

P. CHRIS™
"SJTipwt with CHRISTINA PRATT on regular
E.
Exercise of educational responsibilities
F*
G.
towards CHRISTINA PRATT.
niseinline of CHRISTINA PRATT.
a
H. Discipx-u'e ui PupT«5TTNA PRATT was cared for
I. Length of time CHRISTINA PKAii w
3. Financial support of C H R I S T ™ r HRTSTINA
Medical Insurance coverage on CHRISTINA
K. Emotional dependency of CHRISTINA PRATT on
LAWREL HAIBECK.

-COPY-LAKE COUNTY CIRCUIT CLERK-COPY-

-COPY-18 N . COUNTY WAUKEGAN IL-COPY-
 ■afe^w*3.* i

10. That the custodial parent CAROL SPIZ2IRR2 is prepared

m; to provide food, shelter, clothing, medical care and
education to her daughter, a minor, CHRISTINA PRATT. '1
11, There is no showing that CAROL SPIZZtRRI acted
staliciously in disciplining CHRISTINA PRATT and in
bringing ni$d«sneai)ior charges against CHRISTINA PRATT.
This was reasonable "due Moderation" conduct by the
m
mother who is concerned with CHRISTINA'S welfare.
it,
12. be
liable xo one xirjirc-vu uy vine v,..*-«w parent
nay also be liable for his or her child tort committed
with the parents knowledge and acquiescence or in which
the child is considered the parents agent,

WHEREFORE the Petitioner CAROL SPIZZIRRI prays tor the

following relief:
A. That the plenary Order of Protection entered on May 18,
1992 be vacated.
B. That the petitioner be granted custody of her daughter
or in the alternative that a conciliator be appointed to
review the circumstances of the relationship of the
parties.

Under penalties as provided by law pursuant to Chapter 110,

Section 1-109 of the Code of Civil Procedure, the undersigned
certifies that the', statements set fcrth in this Petition are true
and correct, except as to matters therein stated to be
information and belief and as to such matters the undersigned
certifies as aforesaid that: she verily believes that same to be
true.

f-v

1
-■-I

Law 0ffic« Simon

Attorney fi ner
29 N. Genel . .
Waukegan, IL 60085
(708) 263-6000

sSafe 1\-'S -COPY-LAKE COUNTY CIRCUIT CLERK-COPY-

mi^^iMmimMm-COPY-18 N. COUNTY WAUKEGAN IL-COPY-
 ■w
wm-t :' t\?M>f5j >V£K

fPi
m?t m- i!lFFIDA?IT

BE rm9JS!OTEED££D, that CAROL SPI2ZIRRI, the undersigned

£*V"> '"* deponent, being of legal age does hereby depose and say under
tw
oath as follows:
HI

icT'"" "^ , Pursuant to Illinois Revenue Statute Ch. «*0, ?312-2M(C)

| ^ / ^ r 1 ' ^ ,11989). CAROL SFiZZIR&I is ifiling this Affidavit alleging a

y
"5
^'is*"^*'-',"a*ritoriott8 defense to tlhc Order Of Protection issued on May 18,
1992.

1. The Child CHRISTINA PRATT did not have a clear right

that heeded t o be protected.
2. CHRIS|pK^ jipRATF wast not about to suffer great immediate
and |^rej>arabl<e haara unless an injunction was granted.
3. T h e r e s a s no showing that CHRISTINA PRATT was
&uac&]0$>i& | t o irreparable damage i f the injunction did
: £ ■>- ** * - not .!§§§£<:
M. Pursiiiiijftit^t<> People ex rel* Edwards v. Livingston
{19^^^-111. 2d JJ01, 2H7 N.E. 2d «*17, the courts
decialoi^ Supports the view that a third party seeking
* J

T0"0^^M^a§ r e t a i n custody of a c h i l d over the

Hi
sup^M#>:*ight of the natural parent must demonstrate
good^ic^se or reason to overcome the presumption that a
parei|^4l^ift a superior right to custody and father ( or
per^0Mf^|ting in Loco Parentis) must show that i t i s
s best i n t e r e s t that a third party be
!?Jsare, custody and control of the minor.

, *&$&^ ! " u
*£«,
&!« r,:,

•^T&liPSKJ!r, -'- ^ * frrt. frM ->' - J „-

-COPY-LAKE COUNTY CIRCUIT CLERK-COPY-
- C O P Y - 1 8 N . COUNTY WAUKEGAN I L - C O P Y -
 t!-''--f||j:/
states that a child
t r i ( h H 2 ) of the IMDMA
Sect ,tflCbllZl o person ox»«*
S. .,-..«. ran be commenced by a P
I

In « « . * - cas y ^ variaM factorB>

M «« «. »«. '«" o n of t h e OiW.

including -»» — «» «* , 8 i C a ^ a8 the duration
,.. ^ - — •* r — » - - - therelore,

^ n a t ^ or « » ^ - - ° s -X-r. « «
.. - «if xthe standing statute
the wording; ©» n e f t n e parents,
child U U « - ^ s i c a l « . « - » of one
* „ i « to *ee* custody.
standing *»» «"* e x l 6 s n e ha d pnysical

6. Tnere«o~, * - « « « f1; * pur8uant to *

— - —"■:::::: i———
dlvo rc«J-*-* • * " ^ xo b r in 6 t„e
enable » • » HAX^CK. - « « ^ ^ custody
order of Protection against
of CHMSTIHA PRATT.

CA: L Spiz^iR^1

§
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Under p e n a l t i e s a s p r o v i d e d by law p u r s u a n t t o C h a p t e r 11C,

Section 1-109 o f t'r.e Code of C i v i l Procedure, the undersigned

c e r t i tier, t h a t the statement:: set forth !n ' h i s P e t i t i o n are true

and c o r r e c t , except as t o m a t t e r s t h e r e ! : , s t a t e ' ! t o be

i n f o r m a t L •:,:•, -tr-.i t . e l i - S a n d a:;, t o .such c o t t e r s *.':.•• im !«*rsi»,r;ec:

certifi^i; a:. a f o r e s a i d that ;.»rn; v e r i l v b e l i e v e s . '.:: >.* sajr.e t•• be

true.

VHtr.es:> my h a n d u n d e r t h e p e n a l t i e r , of perjufV

this // day of i * * A , 1 3 7 ^".

I

S t a t e of Illinois )

Countv of Lake )

Then personally appeared CAROL, SPIZZIPRI who acknowledged

the foregoing, before me.

Uortty&ab&ie

My C o m m i s s i o n E x p i r e s : /y6/^<

Law Office of Donald Simon

29 N. Genesee Street
•
Waukegan,
(708) 263-(

-COPY-LAKE COUNTY CIRCUIT CLERK-COPY-

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CAROL SPIZZIRMt .
Petitioner
GEN.NO. 92F987
vs.
CHRIST IMA J. PRATT,
LAUREL HAIBECK,
!*»»•"' Respondent

Peter Staben
KOTICE O P MOTION
Laiwrel Haibeck
flit Jfi
TOs 1T586 « . Dartmoor D r .
Srayalake, IL 60030
tfaukegan, IL 600BS

.M. or as
On
u n
. 19j!_. at *2*L
l U m i .. M f, .
soon thereafter a s counsel oiay b e heard, I shall appear before t h e
Honorable J u d g e Hartel t or any judge sitting in h i s •13

stead, in t h e courtroom usually occupied by h i m In the Circuit Court

Room N o . 302 . C o u r t House, tfaukegan, Illinois a n d presents t h e

attached Petition t o vacate the Order of Protection and a s k this

Honorable Court t o h a v e a hearing instanter regarding the issue

of custody.

Name: fflfflAM) STHOH

Attorney f o r : CAROL SPT7.V.TRRT
Address: ?8 Hnrth flenpspe
City: WankHgan. XL fiCHUlS
Telephones (708) 2M-M0u

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