Dear Readers;

Since the posts to Cynthia Farenga were soooo popular and have bumped up readership so very much, I have decided to help Cynthia Farenga even more.

She whined she had no help.  Well, I love to help and rescue people, so see below.  I will post the .wpd and .rtf files later or if CF emails me directly.

BUT HERE IS SOME DISCOVERY THAT SHOULD HAVE BEEN SERVED ON CAROLYN TOERPE, AS THE EVENTS OCCURRED.

Now it’s sooo much later, there’s a lot of it to respond to.  Sorry, not my fault.

And please don’t write me and say I can’t publish pleadings I want CF to file, or some other such nonsense.  Ken’s published many a case and many a diatribe on our First Amendment right to free speech, and if you are part of the press (and this blog is, it is up to about 10,000 views now), there is even wider latitude to publish cyber junk.

This IS commentary, some of it is satire, but mostly it is to get the GAL’s to do their job.  Investigate the Plenary Guardian and remove her for lack of jurisdiction and all the crap she’s pulled in the clear abuse and corruption of that position.   Sheesh.

JoAnne

DISCLAIMER: GO READ THE DISCLAIMER PAGE

You will know when this has been filed or served upon a true miscreant, because KD and I will post a video of us dancing on this blog!  Fer sure, for real.  Come on, Cynthia, make us (honest) attorneys dance.

 

Attorney Code__________

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT, PROBATE DIVISION

In Re the Estate of

Mary G. Sykes,
A disabled person

Case No.: 09 P 4858

Hon. Jane Louise Stuart

CYNTHIA FARENGA’S FIRST DISCOVERY REQUESTS TO  PLENARY GUARDIAN CAROLYN TOERPE
NOW COMES GAL, Guardian ad Litem, Cynthia Farenga and respectfully requests that Carolyn Toerpe (“CT) to answer the following Interrogatories and Requests for Documents within thirty (30) days fromt he  and Requests to Admit within 28 (twenty eight) days from service thereof in accordance with Illinois Supreme Court Rule 214:
INSTRUCTIONS:
A.  Time Frame:  You are instructed to provide documents and answers all time periods that you will be challenging, discussing or commenting upon Gloria’s financial dealings with her mother, including at least 6 months prior to.  You are further instructed to provide all documents with respect to your dealings from January 2009 to present.
Where a request indicates that you are to identify a person or entity, you must provide all contact information you have in possession, including  the name and address, phone number, fax number, efax number, website address(es), email address(es)  of that person or entity.
INTERROGATORIES:
1.    Provide a listing of all financial documents in your possession, including, but not limited to, names of banks and bank records which you control or possess for yourself or Mary, financial documents, including notes, bonds and stocks, records relating to security deposit boxes, and identify the financial institution so named.
2.    State all times and methods you have used to enter Mary’s or your safe deposit or Gloria’s boxes for the time period in question and state what you found (to the best of your recollection), and if any items or things were removed therefrom.
3.    State all the times you have entered Mary’s home at 6016 N Avondale Chicago and have removed any items or things belonging to Mary and/or Gloria and state if they were taken with permission, and if so, whose permission they were taken with.
4.    Provide all contracts, documents and things which establish or tend to establish any agreement between yourself and Gloria or Mary and Gloria with respect to any financial matters or dealings.
5.    State the amount and type of financial assistance which you have provided to Mary in the past and which you intend to provide to her in the future.
6.    Provide copies of any correspondence between yourself and Mary referring or relating to any financial matters or living arrangements or support of her.
7.    State when and where you have heard Mary state she wants to go live at her home on Avondale in Chicago.
8.    Carefully identify any statements made in the attached Exhibit A, Table of Torts, which you believe to be misleading or untrue, and state all reasons for such beliefs.
REQUESTS FOR DOCUMENTS:
You are herewith directed to provide the following documents or access for copying within thirty (30) days from the date shown in the attached Certificate of Service.
9.    Financial records referring or relating to Carolyn and Mary in Carolyn’s possession or control, including, but not limited to: tax returns, financial statements, investments, bank accounts, savings accounts, annuities, insurance records, mortgage records, safe deposit box records.
10.    Provide all receipts, records and documents and things referred to in your answer to Int. No. 9, supra.
11.    Provide copies of any correspondence between yourself and Mary referring or relating to any financial matters or living arrangements or support of her.
12.    Provide all canceled checks, deposit slips, withdrawal slips, memoranda, check registers and bank statements for any and all accounts with any banks or other institutions holding money or assets, foreign or domestic, whether in the nature of checking, savings or money market funds, wholly or partially, in your name or in Mary’s name, moreover which she has a right of  withdrawal or check signing power for the period January 1, 2006, to date.  If any savings accounts, then you shall produce all savings account passbooks or, in the event of certificates of deposit, you shall produce the certificates of deposit in your name or Mary’s name all cancelled checks, deposit slips, withdrawal slips, memoranda, check registers and bank statements for any and all accounts with any banks or other institutions holding money or assets, foreign or domestic, whether in the nature of checking, savings or money market funds, wholly or partially, in the name of yourself or Mary, which you or she has a right of  withdrawal.  If any savings accounts, then you shall produce all savings account passbooks or, in the event of certificates of deposit, then you shall produce the certificates of deposit.
13.    All evidences of indebtedness reflecting debts owed by you or Mary or owed to you or Mary.
14.    All monthly statements, as well as purchaser’s receipts, for credit card accounts over which you or Mary has the right to make credit purchases for the past 24 months.
15.    All commercial paper owned by you or Mary, wholly or partially, in her name or in the name of the trustee or nominee.
16.    Statements sent to you or Mary from any brokerage firms for accounts over which you or Mary have the power to buy or to sell or which are wholly or partially in you or Mary’s name or under the name of any other person or entity.  These accounts include stocks, mutual funds, bonds, cash accounts, margin accounts, option contracts, commodities, and/or investments of every kind.
17.    Any and all trust agreements, partnership agreements or joint venture agreements by virtue of which you or Mary wholly or partially has an interest in any real estate business, enterprise or real estate venture.
18.    All gift tax returns prepared by or for you or Mary for the time period in question.
19.    All loan applications and credit applications from January 1, 2006, to the date of production made both individually by you or Mary, jointly with others and/or on behalf of any partnership or corporate entity in which he has an interest, together with all net worth and/or financial statements submitted in conjunction therewith.
20.    All evidences of money and property received by you or Mary, by inheritance or gift, including, but not limited to, copies of distribution receipts and probate signed to the values thereof at the time of receipt and all evidences pertaining to the current values.
21.    The Last Will and Testament, Inventory and Final Account filed with the court for any estate for you or Mary, was a beneficiary and copies of all federal estate tax returns and state inheritance tax returns which contain information pertaining to the property inherited by her.
22.    All books, records and documents relating to any and all expenses incurred by you or any of your businesses (whether incorporated or not), or any business in which you hold full or partial interest in, from January 1, 2006, to date, including, but not limited to, bills, cash receipts, itemized receipts, contracts, loans, expenses lists, expense records and the like.
23.    Copy of recording tape or transcription of any telephonic or other recording devices used for eavesdropping purposes.
24.    Copies of all photographs and any written or recorded statements from anyone concerning any of the issues involved in or relating to this litigation.
25.    Any and all reports, memoranda, correspondence or other documents regarding any expert examinations or reports of purported expert witnesses which you have used or considered using in this litigation.
26.    Any and all photographs, notes, letters, diaries, memoranda, reports, written statements, calendars, ledgers and all other such items or things which you now have in your possession or control which relate to any allegations you have made regarding Mary or Gloria.
27.    All documents and things in your possession (including electronic communications) which refer or related to Mary or Gloria or any of the issues or allegation in the above captioned litigation.

REQUESTS TO ADMIT:
FURTHER INSTRUCTIONS:
The term “GAL’s” refers to AS and CF (yourself) collectively.
The term CRLTO refers to the Chicago Landlord Tenant Ordinance.
The term “Estate” refers to the “Estate of Mary G Sykes” or case 2009 P 04585.
The term “White Mary House” refers to the home where Mary G Sykes lived, or 6014 N Avondale.
The term “Brown Gloria House” refers to the home where Gloria Sykes lived prior to it being destroyed by mold (and Peter Schmeidel/Chase), or 6016 N Avondale.
The term “Gloria” or “GS” means Gloria Sykes
The term “MGS” or “Mary” means Mary G Sykes
“PS” is Peter Schmeidel; “HW” is Harvey Waller; “CT” is Carolyn Toerpe; “FT” is Fred Toerpe; “CF” is Cynthia Farenga; “AS” is Adam Stern
The term “wired” means any type of corruption or preferential treatment in court, including promises of money, position, continued employment in and out of the courtroom, etc.  This also includes promises from any judge (Daley center or not), political favor, or court room employee for money, continued employment or preferential treatment.
You are directed to admit or deny the following statements within 28 days from the date of service show in the Certificate of Service attached hereto:
28.    That you have been told by GS that $4,000 was removed wrongfully from the Pullman bank account of MS in 2009 and you took no action.
29.    That you are aware that this action caused MGS to prepare a Petition for an Order of Protection against CT.
30.    That you have been told that the removal of $4,000 from the bank account of MGS was allegedly to start a retirement account for MGS.
31.    That you have been told that the removal of $4,000 from the bank account of MGS was purportedly to start a retirement account for MGS
32.    That you knew that MGS at age 90+ was ineligible for a retirement account pursuant to IRS rules, regulations and/or statutory law.
33.    That at the time, MGS was not in need of establishing a retirement account.
34.    That you did not serve any discovery upon Pullman Bank regarding the withdrawl of the $4,000.
35.    That you did not track the $4,000 from Pullman Bank to any other bank account and find out who moved it and when.
36.    That you are not interested in whether CT misappropriate $4,000 from the funds of MGS and therefore did not conduct any proper investigation.
37.    That GS paid two mortgages for approximately 10+ years.
38.    That GS paid the mortgage on 6014 for approximately 10+ years.
39.    That GS paid the mortgage on 6016 for approximately 10+ years.
40.    That the income of MGS was substantially $1900 per month in the year 2010.
41.    That the income of MGS from 2005 to 2010 was $1900 per month.
42.    That the income of MGS being only $1900 per month was insufficient to pay all the expenses of MGS.
43.    That MGS prefers to eat vegetarian.
44.    That MGS prefers to eat vegetarian and organic.
45.    That CT does not provide MGS with organic, vegetarian food which MGS prefers.
46.    That GS always fed MGS a vegetarian diet.
47.    That GS regularly bought MGS high quality vegetarian food.
48.    That GS regularly shopped for MGS at Whole Foods.
49.    That GS regularly purchased a meal plan from Ambutol in Chicago.
50.    That you are aware Ambutol prepares gourmet vegetarian meals.
51.    That GS provided MGS with gourmet vegetarian meals from Ambutol.
52.    That CT does not shop at Whole Foods for the food for MGS.
53.    That CT does not provide as many vegetarian, organic foods as she can for GS.
54.    That no GAL has ever recommended setting up a retirement account for a 90+ year old person, that you have ever head of.
55.    That you have never obtained any bank records to me from Pullman bank regarding the $4,000 withdrawal.
56.    That you were the Respondent in a Petition for an OOP in 2009.
57.    That prior to being appointed as Plenary Guardian you did not properly inform Judge Connors of this fact.
58.    That when you were appointed Plenary Guardian in Dec. 2009, you did not inform Judge Connors that the jurisdictional 14 day notice of hearing was served upon the two sisters of MGS.
59.    That when you were appointed Plenary Guardian in Dec. 2009, you did not inform Judge Connors that the jurisdictional 14 day notice of hearing was never served upon sister Josephine.
60.    That when you were appointed Plenary Guardian in Dec. 2009, you did not inform Judge Connors that the jurisdictional 14 day notice of hearing was never served upon sister Yolanda.
61.    You have never informed the court it has been acting without jurisdiction.
62.    PS has never informed the court it has been acting without jurisdiction since Dec 2009.
63.    HW has never informed the court it has been acting without jurisdiction since Dec 2009.
64.    A competent attorney would have promptly brought this issue to the court’s attention promptly after having been discovered.
65.    KD and Gloria have been repeatedly informing you that the Probate Court is acting without jurisdiction.
66.    HW has admitted that no 14 day notices were timely served on sisters Yolanda and Josephine prior to the hearing appointing CT.
67.    HW has admitted on the record that no 14 day jurisdictional notices were timely served on Gloria prior to the hearing appointing CT.
68.    That the doctor’s report presented with CT’s Petition for Guardianship in July 2009 was legally deficient in that it was not signed by a medical physician that actually conducted the examination.
69.    That Dr. Motckya who signed the CP211 form was in fact a PsychD.
70.    That Dr. Motckya who is a PsychD cannot sign a CP211 pursuant to the Probate Act for the purposes of presenting a Petition for guardianship.
71.    That you signed a CCP211 as a “PhD” when in fact you have no PhD.
72.    That counsel for GS repeatedly asked for discovery prior to your being apointed a Plenary Guardian in Dec 2009.
73.    That GS was repeatedly denied any requests for discovery prior to appointing CT as PG in Dec 2009.
74.    That you did not tell the court that GS was entitled to discovery in this case in Dec 2009.
75.    That you have never, in fact told the court GS should be allowed discovery.
76.    That AS knowingly filed a wrongful petition for sanctions against KD.
77.    When AS filed a petition for sanctions against KD, both GAL’s knew he never had appeared in the Probate Court.
78.    That the filing of ARDC complaints against KD and JMD for expressing opinions on a blog constituted a violation of the Illinois CPA. 735 ILCS § 110 et. Seq.
79.    As a GAL, the filing of that ARDC complaint against KD brings substantial liability to the Estate captioned above.
80.    A GAL that brings liability to a ward’s estate should immediately report it to the court and be removed.
81.    The reason why AS was not sanctioned by the Probate Court for filing a false Petition for Sanctions against KD is because the court is wired–or it sure looks like it.
82.    The reason why AS’s Motion to Disqualify JMD was rubber stamped by Judge Connors is because the court is wired.
83.    AS filed a Petition to Disqualify JMD as counsel for Gloria because as CF said JMD will assuredly “paper me [meaning the GAL’s to death].”
84.    JMD accordingly became the subject of a Motion to Disqualify (“MTDQ”) filed by AS and endorsed by CF because she is a competent attorney.
85.    CF and AS knew that the filing of a MTDQ JMD was wrongful and in derrogation of well established law.
86.    CF and AS misrepresented to the court they had sufficient grounds to file the MTDQ when in fact they did not.
87.    That in Dec 2009 GS had filed a number of pleadings, and AS asked the court to strike all the pleadings of GS because she was pro se.
88.    That those pleadings in Dec 2009 were in fact filed pro se and so there was no reason to strike those pleadings.
89.    That you have been informed by numerous family and friends that Gloria took excellent care of her mother for 10+ years.
90.    You have been informed that Gloria returned from California after her father died to take care of her mother.
91.    You have been informed that Gloria provided Mary with designer clothes to wear.
92.    You have been informed that Gloria provided Mary with monthly trips to the salon for hair and nails.
93.    That the Probate Court trashed Gloria’s care plan on purpose and because the proceeding was wired.
94.    That Gloria’s care plan was more than adequate and similar or exactly the same as yours.
95.    That while Gloria didn’t know the name of Mary’s one hypertension medication, she knew what a CBC was and the judge didn’t.
96.    Most people know that a CBC is a Complete Blood Count or Blood Panel and it is an essential part of a regular physical.
97.    One of the reasons the court trashed Gloria’s care plan was because Gloria lived upstairs and Mary lived downstairs at 6014 N. Avondale (“White Mary House”).
98.    CT has a two level home with a basement.
99.    The court did not have a problem with the fact that Mary’s bedroom was on the second level and the other living areas were o the first floor of CT’s home.
100.    In 2009, Mary lost 10% of her body weight due to a sore throat that lasted a week before CT dropped Mary off with Gloria.
101.    Mary subsequently required several trips to the emergency room which were not reported to the court.
102.    Gloria recognized that something was very wrong with Mary and took her to the doctor the day Mary was dropped off.
103.    That CT represented to the court that family would care for Mary during the day when she was at work.
104.    That subsequent to the appointment of CT, her daughter Kristen moved out of the home.
105.    That subsequent to the appointment of CT, FT did not want to care for Mary during the day.
106.    That subsequent to the appointment of CT, FT did not in fact care for Mary during the day.
107.    That Dr. Rabin signed and submitted a report to the court indicating Mary was incompetent.
108.    That Dr. Amdur signed and submitted a report to the court indicating Mary was incompetent.
109.    That Mr. Motckya, PsychD signed and submitted a report to the court indicating Mary was icompetent.
110.    That you reviewed these reports and agreed with their accuracy.
Each of the following questions refer to the “Doctor’s Reports” of Amdur, Rabin and Mr. Motckya, PsychD and the “Competency Examination.”
111.    You either knew or should have known at the time Mary wore custom hearing aids.
112.    Mary’s hearing was not tested before the Competency Exams were completed.
113.    You knew or should have known at the time Mary suffered from time to time with hypoglycemia or low blood sugar.
114.    A CBC or Blood Panel was not conducted immediately before any Competency Examination.
115.    That Mary’s blood pressure was never check before any competency exam.
116.    That in derogation of CT’s care plan, Mary had been put in “adult day care” for low functioning adults.
117.    That while Mary was in “adult day care” she could have been living with Gloria in her own home.
118.    That prior to this, Mary wrote checks, was involved in the neighborhood gardening club, walker around her neighborhood nearly every day, walked to and from her doctor’s office and was very involved with her community.
119.    That Mary is now isolated with limited phone calls and visits from family.
120.    That you claim that Mary is upset by Gloria when in fact Mary is upset when Gloria is around because she wants to go home.
121.    That you claim Mary is upset by Gloria when in fact Mary asks Gloria to get her an attorney so she can go home.
122.    You only saw Mary only a few times per year before summer of 2009.
123.    You only filed a Petition for Guardianship because Mary filed a Petition for a Protective Order for wrongfully withdrawing $4,000 from her Pullman bank account.
124.    That you drilled out Mary’s safe deposit box at Pullman Bank and removed gold and silver coins from the box without reporting it on any inventory filed with the court.
125.    That Gloria was also listed as a joint owner of the safe deposit box.
126.    That you have been told that valuables amounting to an estimated $1 million  were found missing from the safe deposit box.
127.    That the GAL’s have not investigated the missing contents.
128.    That you have not informed the Probate Court that you drilled out a safe deposit box owned by Gloria without her permission and removed all the contents therein.
129.    That you have not informed the Probate Court that you drilled out Gloria’s Chase safe deposit box without her permission and removed all the contents therein.
130.    That the contents of Gloria’s safe deposit box was approximately $5,000.
131.    That you have not obtained the records from Pullman (now US Bank) regarding the drilling of Mary and Gloria’s safe deposit box and provided them to the court.
132.    That you have not obtained the records from Chase regarding the drilling out of Gloria’s safe deposit box and provided them to the court.
133.    That you believe you are the Successor Trustee (“ST”) in the Mary G. Sykes Trust dated 2005(“Mary’s Trust”), when in fact you are not because Mary’s personal care physician, Dr. Patel would not sign a certificate of incompetency.
134.    That Mary’s Trust names Mary as the initial Trustee and also the Trustor which violates the Statue of Uses and renders the entire Trust document invalid.
135.    That KD and Gloria have repeatedly informed the GAL’s that Mary’s Trust is invalid because it violates the Statue of Uses.
136.    That you filed an eviction proceeding against Gloria based upon your position as ST under Mary’s Trust knowing that this trust was invalid for violating the Statue of Uses.
137.    Because you were not in fact the ST of Mary’s Trust, the eviction was wrongful.
138.    Your wrongful eviction action against Gloria has created substantial liability upon the Estate of Mary Sykes.
139.    You also turned off the gas for the White Mary House where Gloria was living in 2010, which in fact violated the CRLTO.
140.    Because you violated the CRLTO, you have brought upon the Estate a possible violation fine of $200 to $500 per day.
141.    Because you violated the CRLTO for several months, CT has brought upon the Estate a possible violation totaling more than $5,000.

142.    Because you violated the CRLTO for several months, CT has brought upon the Estate a possible violation totaling more than $10,000
143.    The GAL’s should have filed a Petition for your Removal for shutting off the gas where Gloria was living based upon these violations of the CRLTO creating massive liability to the Estate.
144.    Because AS and CF failed to remove CT for wilfully violating the CRLTO, they should have been removed as GAL’s.
145.    You are aware, In winter of 2010, PS called Chase, Gloria’s mortgage holder and told Chase the Brown Gloria House was abandoned.
146.    PS convinced Chase to “secure the property” while in fact, they trashed it.
147.    Gloria arrived home one day to find herself locked out of the Brown Gloria House, her security cameras were disabled and the security system disabled and tampered with.
148.    This is clearly inconsistent with “securing a home.”
149.    Gloria arrived home to also find that interior walls in her Brown Gloria House were trashed, rendering the property completely uninhabitable–well beyond any remaining mold remediation.
150.    Gloria arrived home one day to find all of the furnishings remaining in her brown home were put in the snow behind her home.
151.    When Gloria’s home was locked and trashed, the GAL’s were promptly informed and failed to investigate.
152.    The GAL’s have told the Probate Court the Estate has a valuable interest in the Brown Gloria House and it should be partitioned.
153.    The prior statement is in fact a complete fabrication because the GAL’s have been informed repeatedly that Gloria owned the Brown Gloria House and Gloria only put Mary G on title as a joint owner as a testamentary convenience.
154.    That all the Sykes family members that should have been listed in Exhibit A to the Petition for Guardianship, except you, agree that the Brown Gloria House is Gloria’s and the White Mary House is Mary’s.
155.    That Gloria paid the mortgages on both homes for approximately ten+ years.
156.    That you were told repeatedly Mary’s income for ten+ years was approximately $1900 per month which was insufficient for her to pay her $1000 per month mortgage, plus utilities, clothing and other expenses.
157.    The GAL’s failed to investigate the severe destruction of the Brown Gloria House because they, as well as PS, desired to ensure Gloria was rendered utterly homeless for the purpose of intimidation.

158.    The GAL’s failed to investigate the severe destruction of the Brown Gloria House because they, as well as PS, desired to ensure Gloria was rendered utterly homeless for the purpose of intimidation.
159.    The GAL’s failed to investigate the severe destruction of the Brown Gloria House because they, as well as PS, were operating in a wired courtroom.
160.    The GAL’s failed for file a Petition to Remove Carolyn for violating the RLTO because they were operating in a wired courtroom.
161.    On May 11, 2012, you informed the Probate Court that Mary’s $1 million in gold coins was “Gloria’s fiction.”
162.    At that time, you did not inform the Probate Court how sister Yolanda could confirm Mary’s ownership of the coins and how they were in the safe deposit box before CT drilled it out.
163.    At that time, you did not inform the Probate Court how sister Josephine could confirm Mary’s ownership of the coins and how they were in the safe deposit box before CT drilled it out.
164.    At that time, you forgot to inform the Probate Court how sister Yolanda could confirm Mary’s ownership of the coins and how they were in the safe deposit box before CT drilled it out.
165.    At that time, you forgot to inform the Probate Court how sister Josephine could confirm Mary’s ownership of the coins and how they were in the safe deposit box before CT drilled it out.
166.    That the GAL’s have not conducted a complete and independent asset search of your accounts or all accounts you control.
167.    That the GAL’s have not conducted a complete and independent asset search for FT’s accounts or all accounts he controls.
168.    That Mary wrote in her own handwriting (“Mary’s Directions) in Sept. 2009 that she wanted an attorney and wanted to live at home until she died.
169.    That you told the Probate Court that Mary’s Directions were dictated to her by someone else and she did not know what she was writing and this was a false statement
170.    That videos were posted on youtube.com and Vimeo.com which firmly confirm Mary’s Directions (“Videos”).
171.    Those Videos show Mary writing once again she wanted to live in her own home until she died and to have Gloria and Carolyn care for her there.
172.    You are aware that Gloria holds the last valid and enforceable Power of Attorney for Health Care from Mary. (The “POA”)
173.    This original POA document was produced in court in December of 2009 and the court ignored it.
174.    You initially told the court that this original POA document was a fake.
175.    When it shown to you and the court and it was determined it was an original and valid, Judge Connors summarily invalidated the document, without findings or a hearing.
176.    Judge Connors quipped it had to have been produced sooner–yet Gloria had mentioned it to her in several prior court status hearings and Gloria’s requests to effectuate this document were ignored.
177.    That filing a Motion to Disqualify JMD for merely notarizing a document is improper and you were aware of this at the time, but you instructed your counsel otherwise.
178.    That the notary clause in the document only stated the person appearing before the notary was in fact known to the notary to be that person and nothing more.
179.    That the GAL’s misrepresented to the court that JMD would be used to testify to show Mary’s competence or incompetence in August 2008.

180.    That JMD was never called to testify regarding the competence level of Mary.
181.    That the issues regarding the Lumberman’s funds disbursing payment in August 2008 (“Lumberman’s Settlement) are full and final and may not be attacked in any court of law.
182.    That 735 ILCS § 1401 provides in its pertinent part that an attack on a judgment must be brought within 2 years of the date of entry of judgment and therefore the Lumberman’s Settlement may no longer be attacked.
183.    That Gloria’s funds were illegally frozen in 2009, and the wrongful freeze continued to the date of this pleading.
184.    That in August of 2012 the GAL’s should have asked the court to unfreeze all of Gloria’s funds because the time to attack the Lumberman’s Settlement had passed.
185.    That in Dec 2009, HW wrongfully caused all of Gloria’s funds at Chase to be wrongfully frozen, rendering her penniless for more than a week.
186.    That the freezing of all of Gloria’s accounts in Dec 2009 in excess of the Order entered by the court was wrongful, bringing substantial liability upon the Estate.
187.    That the freezing of all of Gloria’s accounts in Dec 2009 should have created cause for the GAL’s to remove CT as plenary guarding for the wrongful actions of her counsel.
188.    That a guardian is legally responsible for the wrongful actions of her counsel.
189.    That the mortgage on Gloria’s Brown House of approx. $200,000 is likely more than the home is worth.
190.    That it is not worth partitioning this house.
RESPECTFULLY SUBMITTED,

_______________________________
Cynthia Farenga, Guardian ad Litem

Prepared By:
Name: Ms. Cynthia Farenga,
One of two Guardians Ad Litem for Mary Sykes
Atty No. ___________
1601 Sherman Ave # 200
Evanston, IL 60201
847-475-1300