Thursday, August 2, 2012

Okay, let’s rehash the law of who is famous and who is not……..


Dear Gloria;
Thank you for your very kind response regarding what I am doing to try to move along the dismissal/nonsuit of 09 P 4585, which Ken will agree should have been dismissed 2.9 years ago, right?
In any case, I know you and [entity] have your panties in a bit of a bunch over the pleadings I draft for you completely pret a porter–ie, ready to wear or use.
I did [entity's] because she asked me for help in an emailing whining she had no help.
I did yours well, because I think you need to file that and I wanted to make it easy for you.
I know as a reporter you were told “don’t ever use anyone’s likeness or name without permission”, blah, blah, BUT it isn’t as simple as that and the newsworthy exception is very broad.  I assure you I am not using your name (which you keep on telling me and Ken you’re famous anyway so it shouldn’t be a problem) to trade off or palm off some sort of success or promotion for myself.  You would tell me that wouldn’t work anyway because your name and fame well out shrowds mine at any time.  And well, personally, I don’t care about fame, money, blah, blah, or I wouldn’t be doing this and Ken wouldn’t either. (In fact, I still have to figure out how to pay rent this month, oh well, that’s another day for sure).
Also, the companies that produce those shows are not in it to test the bandwith of that case law.  They aren’t looking to get to the edge or test the waters because that would be expensive and a waste of time outside their focus.  BUT when you have a lawyer doing a blog, what do I care.  You think CF’s gonna sue me with the famous 10 page table of torts she’s involved in?  Gimme a break.  Right now, except for the last little squeal, she’s laying low on a case that has been sans jurisdiction for 3 years now!
I’d worry about you, except there’s the fact you mostly like to do cases pro se, you write motions with no less than a dozen unrelated topics in them, you give spontaneous speeches to the court also with no less than 10 unrelated topics in the speech, you don’t trust or listen to lawyers, so that’s an easy one there.  Not worried.  It’s okay tho, because in the Probate case, I personally enjoyed a lot of your speeches with 10 unrelated topics, but I was there for entertainment value and blogging, not lawyering.
Plus, I think it’s somewhat duplicitous don’t you, for me to be in the area of law and afraid that someone will sue me over something stupid?  Well, I see other lawyers whine about getting sued for their tortious behaviors and I think they need to put on big boy under pants.
Besides, the levels of views on the blog today was outstanding.  My dear readers must really love all of this–so for them, I’m going to publish your comments AND everything everyone has been whining about all over again.
You didn’t think I was a weenie lawyer, did you?  Naw, I still got all my teeth.
take care
JoAnne
PS–and while I’m publishing all this stuff again, I want to esp. dedicate it to Gloria, Cynthia and Lucinda who need a real lesson in First Amendment rights.  See Alvarez case and the Pentagon Papers or just watch the movie.  Yep, just checked, Pentagon Papers is on Netflix, as well as Daniel Ellsburg’s “Most Dangerous Man in America” and another documentary I have not seen (Shouting Fire, I put in in my queue).  Your homework is for Gloria, Lucinda and Cynthia to watch these and get back to me tomorrow.  That’ll keep you all up!  I also like the Wikileaks guy and you should read his bio on Wikipedia.  Another one of my heroes.  I think they’re doing a movie or there was a book or something.  He’s great.
From: GLORIA Jean SYKES
Sent: Aug 1, 2012 6:46 PM
To: “kenditkowsky@yahoo.com” , Lucinda , NASGA , “joanne@denisonlaw.com” , Tim Lahrman NASGA , matt senator kirk , LUCIUS VERENUS , states attorney , Sherrif Dart , Elaine NAsga
Cc: scott evans , “k_bakken@att.net” , Chicago Tribune , savage@suntimes.com
Subject: RE: Joanne Denison’s Contrived “Motion to Dismiss/Non Suit for Lack of Sodini Jurisdiction”
Dear All,
I have been involved in the publishing world since 1983 and the broadcast industry since 1975 and there one rule any reputable journalist must obey:  never publish a person’s likeness or name without prior permission in writing (rights agreements) unless of course that person is a public figure such as politicians, the Pope and/or Brittany Spears.  What we can do and we do do legally is used documents and or publicized recordings of men and women, to thoroughly report stories. That said, a reputable writer/author/reporter will not call a person x, unless there is evidence which the blogger, reporter, et al, produces along with the statement, and most of the time we don’t say it, we quote someone who has given us permission to publish their name and likeness and obviously what they have said.  That said, today’s journalist or blogger crosses the line often, and all to often uses adjectives to describe a person or persons that may appear to defame, but in the Sykes case, there are over 12 volumes of verified court documents where [entity] and her colleagues have defamed and discredit me with ease, in order to create the appearance of their client, Carolyn Toerpe being the good daughter, and I am the bad daughter and my mother in her petition for an order of protection was ‘confused’ as to which daughter is which.
I’m a human lie detector, or so I’ve been called by colleagues who has, in the past been able to point to people’s lies and get them to ultimately tell the truth.  The truth, you know is not always spoken, but often in the eyes, the actions, the reactions and body and facial movements of people.  What drives me up a wall is when people LIE to me, LIE to the court, LIE for their own personal gain.  I was once standing before [certain judge], and I appeared before her only after I rattled off my customary I do not waive my rights to jurisdiction, and then the Sodini requirements, attorney [entity] was lying about documents filed, and blabbing as he does, puffed up like a peacock and arms tightly crossed in front of him  (sure sign of a person who doesn’t believe what he or she is saying).   I blurted out, “LIAR” and as mouths dropped, Schmiedel backed off from the bench and mumbled, “I’m going to sue you for libel…”.  Adam Stern rushed to his rescue and said, “He didn’t say that…” and I dropped the documents I was holding to disappear from the bench.  Judge Stuart gave me an opportunity to leave the courtroom, where I was able to compose myself.  There are serious consequences to the LIES we tell and in the Sykes case the life of a once vibrant, loving, healthy, active, involved woman, my mother, is at stake.
I’m not defending JD: nor am I taking the side of Lucinda, who I do respect.  What is needed her is a sense of civility for all people, even people we don’t agree with.  I personally would love to get Cynthia Farenga in a room and ask her questions.  I’m certain she wouldn’t agree to that: she wouldn’t wont to go down that rabbit hole as there’s no telling what will bite her.  That said, a hard truth is better than a soft lie.  The hard truth is this:  Cynthia Farenga and Adam Stern agreed to disregard, cover-up, destroy the ‘truths’ in the Sykes case in order to comply with an agreement between them and Toerpe and Toerpe’s attorneys  for financial gain.  Hiding behind what they believe is ‘immunity’ they will and have stopped at nothing to cause me great harm, financial loses, and in their sociopathic minds, silence me and walk away with the Lumbermen’s money, my home and my  mother’s home.  Although the Illinois Probate Act of 1975 mandates that after the appointment of a guardian, the GAL’s are automatically dismissed, in order to protect the law firm of Fiscal and Kahn, who made a similar agreement, CF and AS have lied to every Judge since, every law enforcement agency and even the political elite, telling them that notices were served, they were reappointed to the case because of me (transference is a clear sign of LYING and guilt), and meanwhile, Toerpe had retained five attorneys from Fischel and Kahn, Leslie ? for the adversary in the bankruptcy court, and of course Harvey Jack Waller and his son:   Technically my mother is paying for 10 attorneys to keep her isolated, drug her, steal her home and her estate, destroy all people my mother loves and trusts, and, ultimately, murder her!
Cynthia Farenga, Adam Stern, Peter Schmiedel, Deborah Jo Soehlig, Amanda Brynes, and the other two male attorneys from Fischel and Kahn, have not put in for one dime however, which is curious, don’t you think?  There is a confidential settlement agreement which lays out how each of these attorneys will get paid, and I will make that available at the proper time: I refused to sign the agreement and AS, PS, CF and my attorney at the time JB attempted to file an in camera statement stating that I am bi polar and mentally ill.
What I’m trying to say is that JoAnne Denison can write her little head off as long as she doesn’t put words in my mouth, in another person’s mouth and when she uses adjectives, she backs it with evidence.  FYI Toerpe stopped me from paying the mortgage on 6014 and then she stopped paying the mortgage on 6014 and claimed in her inventory she was paying, but I am certain she is paying attorney fees instead.  Law firms like Fischel and Kahn do not work for free and they do not have a pro bono department: a friend called and was turned away.  “Times are tough,” she was told, et al.  Ironically, I talked to attorney Peter Schmiedel about hiring him in October/November 2009 and his firm declined to take my case.  I watched him defend for Elizabeth on the Lydia Taylor case and was impressed.  In fact in that case he argued the Struck case to get his client visitation: in the Sykes case he attempted to use it to stop me from associating with my mother.
I don’t like JD’s tactics, but I am mad as hell at the trickery used by Cynthia Farenga, ADam Stern, et al.  I don’t think JD is trying to influence any person as the Probate Court has dug in and is sanctioning this lawlessness.  I also thin that we need to be civil and present the “truth” the “facts’ in a professional manner.  Name calling is childish: the documents speak for themselves.
Cynthia Farenga, Adam Stern, Peter Schmiedel have spent a lifetime over the past three years defaming and discrediting me, attorney Kenneth Ditkowsky and even JoAnne Denison: it is their cottage industry of ‘business-as-usual’ sanction by the Court.  That said, at least JD is publishing the transcripts, documents filed with the court and proven over and over again that there are and were not Sodini notices and therefore, the Court has held proceedings without jurisdiction.  The orders are void.  There is no guardianship and that is what is important.
Show me the proof and I will present in a reputable forum, but CF, AS, PS cannot provide one ounce of evidence.  They got the court to deny me a right to have witnesses or bring evidence to the attention of the court, meanwhile they’ve froze my assets, stole my homestead and a good portion of my property of my estate and the worse thing, they won’t let my mother see or talk to me and have perpetrated undue influence on her that is damming.  They’ve told my mother that I ‘abandoned’ her and that I ‘stole’ her home, her property, and all her money.
I will be filing documents tomorrow, and at the end of the week, and next week too.  There was and is no Sodini notices and Cynthia Farenga, Adam Stern and Peter Schmiedel know this.  No one is trying to ‘influence’ the ARDC or the Court.  We just want an honest investigation.  The truth leaves tracks and it’s time to go down the rabbit hole.  Unfortunately for Cynthia Farenga, Adam Stern and Peter Schmiedel and Deborah Jo Soehlig and Amanda B, and Joel Brodsky, what respectable investigators will find will bit each one in the ass — the truths will also save my mother’s life.  That is all I care about.
Does anybody want to join me in saving my mothers life?  Saving her life will save the lives of thousands of innocent elders and disabled people!
JD take my name off of and take Cynthia Farenga’s name off the document you wrote.  Now you have a template for any victim or hero to use in cases like the Sykes case.  It’s just that a template.
God bless us all.
Gloria Jean Sykes
Bon Ami Productions, Inc.
773.910-3310(cell)
773.631-9262 (fax and office line)
Date: Wed, 1 Aug 2012 15:19:23 -0700
From: kenditkowsky@yahoo.com
Subject: Re: Joanne Denison’s Contrived “Motion to Dismiss/Non Suit for Lack of Sodini Jurisdiction”
Thank you for your comment directed to Ms.Denison.
No attorney can ever stand quietly when he believes that an injustice is being done.    It is my opinion that you are misconstruing Ms. Denison’s actions and postings and thereby doing her an injustice.   What we have in the Sykes case is a situation in which a senior citizen has been deprived of her liberty, her property, civil and human rights in complete derogation of the ‘Rights of Man’ and the United States Constitution.   (The Illinois Statutes and Probate Act also are violated)
What has happened in the Sykes case is beyond belief – In point of fact any fair minded person looking at the record, reading the transcripts etc would remark:  “HOW CAN THIS OCCUR IN THE UNITED STATES OF AMERICA.”  (I believe that you and your organization have expressed this sentiment and have worked to attempt to allievate this terrible fiasco)
In fact anyone looking into the case has to notice on day one that the case is not only unusual but basic civil rights were and are ignored.  The Illinois Legislature in order to address the issue of seniors being railroaded into unwanted and un-needed guardianships set up some jurisdictional criterion.
From day one the two [important entities] ignored the jurisdictional criterion and it appears joined the plenary guardian in actions which in my opinion are deplorable and unconscionable.  If you want a taste of what was promulgated read a random three or four of Gloria Sykes’ e-mails.
The net effect of the actions taken by the [entities] and the plenary guardian has been to deny not only Mary of her rights, but Gloria Sykes as well.   What is particularly interesting is the fact that what was done was done without jurisdiction.   Required basic jurisdictional steps have been routinely ignored.   The one jurisdictional challenge was by me and it was successful.
Ms. Denison has requested [entity] to do what a lawyer (or judge) should have done on Day one – as there is no jurisdiction – ask for dismissal of the case.  In my opinion it is a procrustean application of political correctness to suggest that requesting a court appointed GAL to correct a mistake (whether intentional or not) is not entirely appropriate.  Is [entity] such an ‘august person’ that like the queen of England it is treason to suggest that she cannot be wrong?   I do not think so.    Moreover – drafting a document so that [entity] can effortlessly correct the problem of lack of jurisdiction and continued violation of Mary Sykes’ civil rights is also entirely appropriate.
No one ever said or posted (or implied ) that [entity] attorned, agreed, or signed the documents that Ms. Denison prepared.   In fact [entity] refused to participate in the remediation.    In fact [entity] refused to participate in the call for an honest, complete and comprehensive investigation of the Sykes case.   We ‘peons’ do not understand such complexities.   All we understand is it is wrong to deny grandma of her liberty and property.   It is wrong to attempt to intimidate.   It is wrong to bear false witness.   It is wrong to loot grandma’s estate.   We do not accuse [entities], or even Ms. Troepe of anything – all we ask is for an honest, complete, and comprehensive investigation.
Instead of the necessary investigation that will vindicate the Sykes family, the Sykes neighbors and the Sykes friends, we have gotten intimidation in the form of sanction motions (now moot and dismissed for lack of jurisdiction), complaints to the disciplinary boards, and violations of our First Amendment Rights.  One of the attorneys retained by Gloria Sykes pointed out that every attorney has been threatened with disciplinary proceedings and possible loss of his/her license.   Even the Gulag of Russia were not that brazen!  The brown shirts were more subtle!   (yes I know you are part of choir – but a lawyer has to pompous – it is part of the definition)
It is unfortunate but the Sykes case is not isolated or unique.  The September GAO report details a bunch of similar cases and people writing to blogs have reported even more.    Mr. Wyman published a book concerning his mother’s experiences and several other have started blogs.  I am starting to avoid railroad crossings and I check the showers to make certain that water is the liquid that is being delivered.
Let me leave you with the parting thought:  If [entity] is in good faith she has nothing at all to fear from an honest complete and comprehensive investigation hy law enforcement.    If [entity] is in good faith she is aware that the Sodini protections of the probate act were not afforded Mary Sykes and therefore as they are jurisdictional she will either sign the documents drafted by Attorney Denison or draft her own so as that Mary Sykes can be free and Gloria Sykes can get her life back.
Ken Ditkowsky
www.ditkowskylawoffice.com
From: Michigan Advocacy Project <michiganadvocacyproject@gmail.com>
To: NASGAmembers@yahoogroups.com; Kenneth Ditkowsky <kenditkowsky@yahoo.com>; JoAnne M Denison <joanne@denisonlaw.com>
Sent: Wednesday, August 1, 2012 4:14 PM
Subject: Re: Joanne Denison’s Contrived “Motion to Dismiss/Non Suit for Lack of Sodini Jurisdiction”
TO: JOANNE DENISON, Attorney
RE: YOUR COMPOSING AND INTERNET POSTING OF A FAKE LEGAL DOCUMENT (“MOTION TO DISMISS” to Cook County, IL, Probate Division), IN WHICH YOU ASCRIBE AUTHORSHIP OF THE “MOTION” TO ANOTHER ATTORNEY (WHOM YOU HAVE PUBLICLY DEFAMED IN THE PAST), TO FURTHER YOUR OWN AGENDA:
http://marygsykes.wordpress.com/2012/07/31/for-cynthia-farenga-motion-to-dismissnon-suit-for-lack-of-sodini-jurisdiction/
Along with readers of the “marygsykes” blog, National Association to Stop Guardian Abuse-e-group members and numerous other recipients of the email (below), I have read your recent display of defamatory sarcasm against one of several attorneys involved in Mary G. Sykes’ guardianship proceedings.  Despite your intrepid, illusory wordsmithing, I “see through your brain like I see through the water that runs down my drain.”  *
You have been attempting to influence the course of probate and attorney disciplinary proceedings in less-than-admirable ways.  (Purportedly, due to lack of “standing” with the court at this time, you cannot file the “Motion” you wrote and the [agency] is investigating a complaint about your professional conduct.)  While some people might suggest that you have every right ‘under the U. S. Constitution’ to declare and foster denigrating opinions about others to the world, without consequence, I disagree.  Regardless of your views about the court’s ‘jurisdiction’ and authority to supervise this vulnerable person’s care and estate, intentionally ‘putting words in someone else’s mouth’ to intimidate or coerce that person (‘official’ or otherwise) into taking an action that s/he has not elected to take independently is ethically unsound.  More specifically, were your intentions true, you might have simply called [entity], on the phone and discussed your idea – or written a proper letter to her – or made an appointment at her office.
Perhaps you have taken a mini-course in Anti-Defamation Law and hope to outwit your perceived legal opponents by writing scathing commentaries, unchecked.  Perhaps you plan to produce a bundle of biased letters for the [agency], as distractions from attorney conduct issues.  Perhaps you just believe that recklessly libeling anyone who does not vociferously agree with you or your legal protégé du jour is ‘OK’; I don’t.  (If I had not read my phrases on the “marygsykes” blog, extrapolated without context or permission, I might have reserved comment at this time.)  A ‘for entertainment only’ disclaimer on a blog entry does not suffice when misrepresenting the intentions of others in print, no matter how imaginatively.  “Entertainment” like this is bad for guardianship victims and their families, everywhere.
I am copying [entity] with this letter; please do not construe this common courtesy as an expression of allegiance toward any party or the court.
Sincerely,
Lucinda P. Lambert
* Bob Dylan, “Masters of War”
P.S.  Kenneth Ditkowsky originated the Denison email.  As NASGA’s Moderator passes Mr. Ditkowsky’s emails through the e-group, this so goes this “Reply All,” with exception of [entity].
From JoAnne:
Sorry, but with my own blogs I don’t follow the one above.  No offense.  Just no time.
BUT, I did respond to Lucinda as follows:
Dear Michigan Advocacy Project
I can answer that.  You know, I really hate to do all the typing work to get all my pleadings done.  I would like someone to type up all my Motions, Notices of Motion, Certificates of Service.  Ken will attest to the fact, it just drudgery.  I like typing the argument best and reading and using the cases.  The rest is well, busywork.
[entity] asked me for help.  She said she had no one to help her because “there were too many conflicts”.  There aren’t because as officers of the court, we have to ensure that everyone’s constitutional rights are attended to.
The post makes it clear that I am helping [entity] out and I did the document for her to help her out. She needs help.
Um, this is a blog.  There is no “public defamation.”  I did not call another atty any per se defamatory names such as slut, whore, addict, etc.  Did you know that courts are starting to say even calling someone gay isn’t defamatory?
In any case, you seem to have a lot of anger, but not a lot of direction, and certainly not anything much legal to say.
Blogs, the news and all sorts of publications are protected by the First Amendment.
Further, you seem to ignore the fact that I know Gloria, I know the family and I know what I am saying to be true.  And why are you trying to protect poor [entity] and [agency].
They can deal with what I say.  And in any respect, it’s not particularly scathing.  With respect to the average journalism out there you see on the evening news, cable and what not, I’m pretty Marvin Milktoast.
But if it gets you reading, go for it!
thanks for emailing me with your concerns.  i do appreciate your reaching out.  I don’t know if I can answer all your emails because I’m busy protecting Mary and Gloria, but we’ll see if I can help you out too.
Peace,
JoAnne
PS–And what kind of an Advocacy project are you when you promote courts that operate without due process, constitutional protections for years.  You need to think about this before you seek to “help” people.
PPS–I’m not sure I understand your concerns that I am “improperly influencing” a bunch of (corrupt) [entities]?  I really don’t get that.  I think you can improperly influence someone of limited or fragile mind, such as a child (not my kids, they were all smart alecks and brats), but an adult?  an attorney? are you kidding?  last I looked [entity] was a big girl.  And [entity] at [agency] is a big girl too.  What you said is kind of insulting to them, in a way.  I hope you see that.  It’s as if you’re assuming someone snatched their brains away and we should all protect them for that.  Hmmm maybe you do have a point, but not in the way you might have thought.  Peace.
PPPS–any psychologist and linguist will tell you sarcasm is a valid, useful and necessary form of communication in any society.  It’s only teachers that don’t like it because it makes the whole class laugh.
—– Forwarded Message —–
From: marygsykes <donotreply@wordpress.com>
To: kenditkowsky@yahoo.com
Sent: Monday, July 30, 2012 8:33 PM
Subject: [New post] For [entity]–Motion to Dismiss/Non Suit for Lack of Sodini Jurisdiction
New post on marygsykes
For [entity]–Motion to Dismiss/Non Suit for Lack of Sodini Jurisdiction
by jmdenison
Dear Readers;
Below inline and via a link you can find the entitled motion I sent to [entity] today.
We are all hoping she will file this motion and do the right thing.
If it were me, I would hate to do it, but I would do it.  I have had to do this before, and it’s a killer thing to do, but an atty has to explain to the client why s/he will dismiss for lack of jurisdiction, and then do it.
It’s horrible.  It’s a do over or start again, but it MUST be done.
Let’s wait and see what happens.  If she does it, it will most likely be the end of this blog.
JoAnne
PS – if [entity] does not do it, I will send another to Gloria and then to Kathy and then to whomever is an “interested party” to attack that jurisdiction.  This is a serious, constitutional, due process flaw in the case ab initio.
PPS – the link:
https://docs.google.com/open?id=0B6FbJzwtHocwTmJQdU5IU1dPYkU
https://docs.google.com/open?id=0B6FbJzwtHocwTmJQdU5IU1dPYkU
link to exhibits:
https://docs.google.com/open?id=0B6FbJzwtHocwbE9CQmNhelBnQjg
https://docs.google.com/open?id=0B6FbJzwtHocwbE9CQmNhelBnQjg
Attorney Code _____________
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT, PROBATE DIVISION
In Re the Estate of
Mary G. Sykes,
An Alleged Disabled
No.: 09 P 4585
Hon. Jane Louise Stuart
NOTICE OF EMERGENCY MOTION
To: See attached service list:
Please take notice, that on _August 1, 2012, the undersigned will appear before the Honorable Judge Jane Louis Stuart or any judge sitting in her stead in the courtroom usually occupied by her in Room 1814 of the Richard J Daley Center, Chicago, Illinois, and present the attached EMERGENCY MOTION TO DISMISS/NON SUIT FOR LACK OF SODINI JURISDICTION, and true and correct copes of which are attached hereto and served upon you.
RESPECTFULLY SUBMITTED,
_______________________________
[entity name, address, fax and email]
Attorney Code #14,867
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT, PROBATE DIVISION
In Re the Estate of
Mary G. Sykes,
An Alleged Disabled
No.: 09 P 4585
Hon. Jane Louise Stuart
EMERGENCY
MOTION TO DISMISS/NON SUIT FOR LACK OF SOLDINI
JURISDICTION/LACK OF PROPER NOTICE OF HEARING ON
PETITION FOR GUARDIANSHIP
This motion is brought by [entity] pursuant to Probate Code 735 755 ILCS § 5/11a(f) requiring written Notice for any Hearing on Guardianship be provided by the Petitioner in the matter to all close relatives (as defined by the Probate Act) and served no less than 14 days in advance of the hearing.  The one and only necessary ground for this motion is that Petitioner, Carolyn Toerpe, and her attorneys of record, failed to serve ANY close relatives as required under this Probate Code section with ANY written form of notice 14 days in advance of the hearing date, as declared in the attached pleadings recently brought to my attention.
The grounds for this motion are:
1.      The Illinois Probate Act 755 ILCS § 5/11a:
(f) Notice of the time and place of the hearing shall be given by the petitioner by mail or in person to those persons, including the proposed guardian, whose names and addresses appear in the petition and who do not waive notice, not less than 14 days before the hearing.  755 ILCS § 5/11a. (Emphasis added).
2.     The Illinois Probate Act define the required notice be served upon adult children     and siblings of the Respondent.  In the above case, Mary G. Sykes has two adult     sisters, Ms. Yolanda Bakken and Ms. Josephine DiPietro, as well as a daughter     Gloria Sykes who should have been served under 755 ILCS § 5/11a.
3.     Attached is a declaration, Exhibit A, from one of the elder sisters, Ms. Bakken,     attesting to the fact that she was not served in accordance with 755 ILCS § 5/11a     (f).
4.     Attached hereto is a second declaration, Exhibit B, from the adult daughter Ms.     Gloria Sykes (“Gloria”) attesting to the fact that she was not served any Notice of     Hearing on Petition as provided for in 755 ILCS § 5/11a(f).
1.     The case, In re Sodini, (cite) (Exhibit C, hereto), makes it clear that these notices are     jurisdictional in nature and must be served strictly in compliance with the procedure     set forth by the Illinois State Legislature.  In Sodini, the adult sisters were not served with proper notice and the case was dismissed for want of jurisdiction.  (Cite).
2.     WHEREFORE, I respectfully request that
a.     The above cause of action be dismissed/non suited for lack of jurisdiction;
b.     All orders, including an Order to invalidate Ms. Gloria Sykes’ Power of Attorney be voided Ab Initio.
c.     All orders freezing Gloria’s assets be voided Ab Initio
d.     Mary be allowed to freely return to her home.
e.     Carolyn Toerpe be barred from conducting any mental or psychological examination on Mary G. Sykes.
f.     Carolyn Toerpe be permanently barred from ever filing an Illinois CCP 211 or its equivalent until further order of the court and for good cause shown, bearing in mind she instigated, continued and fomented a Probate Cause lacking jurisdiction since December 7, 2009 or nearly three (3) years, causing great harm, stress and hardship to Mary G. Sykes and her immediate family;
g.     And for any additional relief and remedies deemed proper by this honorable court.
RESPECTFULLY SUBMITTED,
_______________________________
[entity name, address, phone and fax]
CERTIFICATE OF SERVICE
The undersigned herewith certifies that a copy of the foregoing Pleading entitled MOTION TO DISMISS/NON SUIT FOR LACK OF SOLDINI JURISDICTION/LACK OF PROPER NOTICE OF HEARING ON PETITION FOR GUARDIANSHIP was served upon the following parties on this ___ day of July, 2012 by the methods noted below:
[name and address of counsel appearing and:]
Ms. Gloria Sykes
6014 N. Avondale Ave
Chicago, IL 60631 via USPS first class mail (postage prepaid) and email
___________________________
[entity]

1 comment:

  1. This woman is a scam artist that claims to be an attorney. She has been disbarred for fraud, malpractice, and many other things. Do not support this woman. She will claim her case is up for appeal, but that is not true. There is no appeal, this has been ruled on several times. She is a disgusting human being, to try to steal from an old woman. Her real name is Joanne Marie Denison, and she attempts to practice law (still) illegally in Illinois. This is all public on the ARDC website. She also claims to be an arm chair psychologist in people's homes (without a license), and a mechanical engineer (without a degree). The truth is, she is corrupt and is now trying to blame everyone that disagrees with her or dares to tell her she is insane. Do not buy her book or read her blog.

    ReplyDelete