Dear Readers;

And in the grand style you have come to expect from this blog, where the ARDC has suggested that perhaps they don’t like it when I make up a pleading that someone cannot just do as an honest, ethical atty (see the blog where CF squeaks when I prepare a Motion to Dismiss for Lack of Jurisdiction for her signature–you think she wet her pants that day), let’s try this on for Attys Haspel and Opryszek who seemed to totally flubbed their Answers to KDD”s Requests to Admit that were filed with extraordinary obfuscations, dishonesty and evasion.  If this is the best the ARDC can do—I’m just saying.

If any of us were that dishonest to a cop or other judicial official, our butts would be in jail.  You all know that.  But when the clout that is, asks for a flub, that’s what these two august ladies did–producing a fudging flub.

Now, if you’re an honest atty (and this is for all you new attys out there–unless you’re told to do it or else your job, you might be tempted to do what the ARDCatty-minions did, but I’m telling you, trash your job and quit–it’s better in the long run).

I’ve already told everyone that works for me if they EVER do anything like what the ARDC did, I WOULD HAVE THEIR HIDES! This includes the answers to the RFA, the bogus motion to Disqualify KDD and the Motion to Stike KDD’s discovery.  It’s all bogus and has no place in the Illinois court system.

Being dishonest and disingenious has no place in my office.  Leave that on the doormat.

So see below what HONEST attorneys do. They KNOW how to say the word ADMITTED.  They don’t fudge on it and don’t play ridiculous games.

Disgusting.  But if you don’t have the law, the facts or any case, play a lot of games and hope the tribunal is too stupid, mortified or has to go out and buy some ethics, morals and a backbone, and they can’t find the “cash for cars” store or whatever.

JoAnne

BEFORE THE  ILLINOIS ATTORNEY REGISTRATION  AND DISCIPLINARY COMMISSION

In Re:
JOANNE MARIE DENISON
Attorney-Respondent
Reg. No. 6192441    Commission No. 2013 PR 0001

PETITIONER ARDC’S ANSWERS TO
ATTY-RESPONDENT’S REQUESTS TO ADMIT
To:    Atty Joanne Denison, Respondent
1512 N. Fremont St, #202
Chicago, IL 60642
via email joanne@denisonlaw.com
And Ken Ditkowsky: ken@ditkowskylawoffice.com – who was wrongfully DisQ as my attorney in a rubber stamp proceeding wherein the Tribunal used their “I ♥ ARDC” rubber stamp.  Try reading the cases next time.

As to matters referred to in case above-entitled;
1)    That in the Sykes case referred to in the Complaint filed herein all the required notices provided for by Ill.Rev.Stat.1989, ch. 110½, par. 11a–10(f); see In re Guardianship of Sodini (1988), 172 Ill.App.3d 1055, 123 Ill.Dec. 67, 527 N.E.2d 530.”  In re Estate of Steinfeld, 158 Ill. 2d 1, 13, 630 N.E.2d 801, 807 (1994) were not served on the persons who were required to be served with the said notices.
RESPONSE: ADMITTED.  The ARDC has carefully reviewed the blog at http://www.marygsykes.com, has finally figured out that the Declarations of the elder sisters and the younger daughter have been published for many long months on this website, they full indicated that the allegations contained in the ARDC complaint filed January 8, 2013 are completely FALSE and made up by persons at the ARDC having a biased interested in the matter and the ARDC humbly apologizes for prosecuting fully innocent and honest attorneys such as the likes of JoAnne Denison and Ken Ditkowsky and promises to never knowingly engage in such nefarious actions again.  Further the ARDC ADMITS that the blog, http://www.marygsykes.com is and was fully transparent and publishes supporting domentation, includng pleadings, affidavits and declarations of all probate victims and their families–whereas the ARDC’s blog is biased, one sided and does not permit comments or any supporting documents.  It only posts conclusory, self serving statements of nefarious persons such as the likes of Attys Cynthia Farenga, Adam Stern, Probate judges Stuart and Connors who have been for many years, listed as “most wanted” which is not a laudatory position on NASGA and other highly respected probate watcher websites and blogs.  The ARDC is fully and completely ashamed of the fact it has not before admitted this is the honest and complete truth in the matter.
2)    That the facts contained in the affidavits that are attached to the motion to dismiss the instant complaint filed herein and executed by Gloria Sykes are true.
RESPONSE: ADMITTED.  The ARDC possesses no information to the contrary and has carefully review this declaration

3)    That the facts stated in the affidavit attached to the Motion to Dismiss filed herein executed by Scott Evans are true.

See answer to No. 2 above
4)    That the facts stated in the affidavit attached to the Motion to Dismiss filed herein executed by Yolanda Bakken are true.

Ditto and more humble pie.
5)    That the facts stated in the affidavit attached to the Motion to Dismiss filed herein executed by Josephine DiPietro are true.

Ditto and extra shame and humility for the fact that the Probate Courts on the 18th floor continue to turn a blind eye when elderly siblings are wrongfully and strenuously prevented from contacting an alleged disabled.  Disgusting.
6)    That the Circuit Court Common Law Record and Docket maintained by the clerk of the Circuit Court of Cook County does not contain any evidence of service of the notices required to be served upon the siblings of Mary Sykes or the younger daughter of Mary Sykes such as a certificate or return of service for the notices required by 755 ILCS 5/11a – 10f.

RESPONSE: ADMITTED.  The ARDC has gotten its sorry and lame a** butt over to probate and found that the Blog http://www.marygsykes.com only speaks the truth.
7)    The the Administrator of the Illinois ARDC has found or has in his possession any tangible evidence that contradicts the sworn statements (affidavit) authored by Gloria Sykes attached to the Motion to Dismiss as exhibit 2.
See answer No. 6 above.
8)    That all citizens, including lawyers, enjoin the privileges and immunities of the First Amendment to the United States Constitution.

RESPONSE: ADMITTED.: Not only do US citizens enjoy the protections and immunities of the First Amendment to the US constitution and the relevant Article of the Illinois Constitution, but the ARDC will vigorously defend and protect against any miscreants from alleging nefarious and sleazy complaints against honest, ethical Illinois lawyers that blog and speak out against corruption and bring to light corruption in order to eliminate it.  The ARDC is not afraid of the words “corruption”, “Greylord” or even “Greylord II” which is the highest priority for the ARDC to investigate–the immunities and protections of Illinois senior citizens and the disabled.

9)    That all citizens, including lawyers, have the right to communicate to whomever is willing to listen to the facts involving corruption of judicial officials.
RESPONSE: ADMITTED.  This is and should be a highest priority of the ARDC and Attys Denison and Ditkowsky are and shall remain fully protected.

10)    That the Administrator of the Illinois ARDC has found no independent tangible evidence that any statement concerning ‘judicial officials’  disseminated  by JoAnne Denison and  referred to on her blog is not substantially true.  By independent we mean not a self-serving statement of Cynthia Farenga, Adam Stern, Miriam Solo, Peter Schmiedel et al.
RESPONSE: ADMITTED.

11)    That the Illinois ARDC was not given jurisdiction by any agency of the State of Illinois to censor the writings or other First Amendment exercises by lawyers.
RESPONSE: ADMITTED.  The free speech of lawyers is one of the greatest and most formidable protections in a democratic country, and when those protections are erroded, the country is likely to sink deeply into fascism and totalatarianism.  The ARDC fully agrees that DEMOCRACY IS NOT A SPECTATOR SPORT. (Quote from League of Women Voters–now we are attorneys and we’re only louder and mouthier).
12)    That the Illinois ARDC is required to give credence and follow the mandates of the Illinois Supreme Court and the Illinois Appellate Court.  (Simply put – we are asking you to admit whether or not Court rulings are the Law or if the ARDC can just ignore the Court Rulings).

RESPONSE: ADMITTED.
13)    That the Illinois Supreme Court in a published opinion wrote:
“The court acquires jurisdiction over the allegedly disabled person by personal service upon him of a copy of the petition and summons not less than 14 days before the hearing. (Ill.Rev.Stat.1989, ch. 110½, par. 11a–10(e); see McCormick v. Blaine (1931), 345 Ill. 461, 178 N.E. 195.) It is also a jurisdictional requirement that the petitioner give notice of the time and place of the hearing by mail or in person to the nearest living relatives of the allegedly disabled person not less than 14 days before the hearing. Ill.Rev.Stat.1989, ch. 110½, par. 11a–10(f); see In re Guardianship of Sodini (1988), 172 Ill.App.3d 1055, 123 Ill.Dec. 67, 527 N.E.2d 530.”
In re Estate of Steinfeld, 158 Ill. 2d 1, 13, 630 N.E.2d 801, 807 (1994)
RESPONSE: ADMITTED.  While the ARDC is not required to admit statements of law, the ARDC will fully and completely admit that this law should be applied to each and every probate jurisdiction case inquiry–and this will include the likes of Sykes, Bedin, Wyman, Gore, Tyler and others.
14)    That the Circuit Court record in re: the Estate of Sykes contains no documents that indicate that the statement of the Supreme Court was complied with by the Carolyn Troepe prior to the appointment of her as plenary guardian of Mary Sykes.
RESPONSE: ADMITTED.  No one has ever supplied us with the crucial evidence, including the likes of the august and vernerable attys Farenga, Stern, Judges Stuart and Connors.
15)    That Illinois ARDC has received numerous citizen complaints concerning the conduct of Cynthia Farenga and Adam Stern.
RESPONSE: ADMITTED.  While citizen complaints are typically understood to be protected and confidential, too many have been published on http://www.marygsykes.com that we can ignore.  We read the blog to file complaints against KDD and JMD, so we must admit we have read the “numerous” complaints already published on that blog.  It is indeed shamefuly that attys and judges act so badly in the hallowed courts of Illinois and we readily admit it and are sorry.
16)    That the Illinois ARDC has taken no action on any of the complaints by citizens (including Gloria Sykes, Scott Evans,  Kenneth Ditkowsky, etc) against Cynthia Farenga and Adam Stern.
RESPONSE: ADMITTED.  See above.
17)    That the Illinois ARDC has received complaints by Cynthia Farenga and Adam Stern against lawyers who have attempted to investigate the Sykes case or who have requested law enforcement to investigate the Sykes case including but not limited to respondent and her attorney.
RESPONSE: ADMITTED.
18)    That the Illinois ARDC has brought charges against lawyers (including the instant respondent JoAnne Denison) who have requested law enforcement to investigate the Sykes case.
RESPONSE: ADMITTED.  Admitted.  It was and is a shameful means to shut up and censor lawyers that speak out against corruption and we promise to never do that again.
19)    That in bringing the ARDC charges the ARDC investigators have not attempted to ascertain if the charge that the Probate Division of the Circuit Court from time to time was not in compliance with the Illinois Supreme Court statement, to wit:
“The court acquires jurisdiction over the allegedly disabled person by personal service upon him of a copy of the petition and summons not less than 14 days before the hearing. (Ill.Rev.Stat.1989, ch. 110½, par. 11a–10(e); see McCormick v. Blaine (1931), 345 Ill. 461, 178 N.E. 195.) It is also a jurisdictional requirement that the petitioner give notice of the time and place of the hearing by mail or in person to the nearest living relatives of the allegedly disabled person not less than 14 days before the hearing. Ill.Rev.Stat.1989, ch. 110½, par. 11a–10(f); see In re Guardianship of Sodini (1988), 172 Ill.App.3d 1055, 123 Ill.Dec. 67, 527 N.E.2d 530.”  In re Estate of Steinfeld, 158 Ill. 2d 1, 13, 630 N.E.2d 801, 807 (1994)

RESPONSE: ADMITTED.  And again, this is a shameful and sorry state of affairs in Illinois and it is no wonder that Illinois has the most sitting governors gone to prison for corruption.  And it also bespeaks the most lawyers and attorneys in the US gone to prison, retired or surrendered law licenses due to Greylord.  SOP and SNAFU are well alive and fully functional in Illinois government.
20)    Citizens including lawyers and in particular JoAnne Denison have a first amendment right to request and the investigation of the Sykes case.
RESPONSE: ADMITTED.
21)    That the non-compliance with the criterion expressed by the words:
The court acquires jurisdiction over the allegedly disabled person by personal service upon him of a copy of the petition and summons not less than 14 days before the hearing. (Ill.Rev.Stat.1989, ch. 110½, par. 11a–10(e); see McCormick v. Blaine (1931), 345 Ill. 461, 178 N.E. 195.) It is also a jurisdictional requirement that the petitioner give notice of the time and place of the hearing by mail or in person to the nearest living relatives of the allegedly disabled person not less than 14 days before the hearing. Ill.Rev.Stat.1989, ch. 110½, par. 11a–10(f); see In re Guardianship of Sodini (1988), 172 Ill.App.3d 1055, 123 Ill.Dec. 67, 527 N.E.2d 530.  In re Estate of Steinfeld, 158 Ill. 2d 1, 13, 630 N.E.2d 801, 807 (1994)
Deprives the Circuit Court of jurisdiction and the actions of Farenga, Stern, et al a deprivation of the liberty, property, civil rights and human rights of Mary Sykes, a person entitled to the ‘parens patrie’ protections of the State.
RESPONSE: ADMITTED.  And we know that Mary is NOT in a happy situation.  We admit her advance directives were to die in her home in Chicago–a home, family, friends and neighborhood she loved and was an intimate part of since the 1950’s.  Our not caring one whit about that is extraordinarily shameful and inexcusable.  We deeply and humbly apologize for not rectifying that horrible injustice at our earliest opportunity by conducting an investigation sooner and disciplining the likes of Farenga, Stern, Stuart and Connors.
Respectfully Submitted,
________________________

________________________

_________________________

__________________________

__________________________

______________________________

______________________________

(How many lines do I have to make for attorneys to apologize for the wrongs and injustices they have propogated against myself, Atty. Ditkowsky and MOST IMPORTANT, the families of Sykes, Wyman, Bedin, etc. and others?)  That’s why I’m making this form downloadable in RTF.  So the ARDC can add in all the lines they need. I hope every atty at the ARDC will sign and post as a comment on the blog or email to me for posting. )
Each of the attorneys at the ARDC who knew this and did nothing,
including Atty Leah Black, Administrator Jerome Larkin (who should give all his awards back as being no inspiration whatsoever to his future work), Attys Haspel and Opryszek and any others at the ARDC that look the other way and ignore patent injustices in the world of probate that terrorize senior citizens, the disabled and their families.

And here’s the RTF file, just in case they find morals, honesty, forthrighness, can utter the word “admitted”, can take out a loan and buy a backbone or whatever they need to answer Requests to Admit honestly and with the word ADMITTED, which they still can hardly seem to find.

RTF file so the ARDC can answer KDDs Requests to Admit HONESTLY

And what’s playing on the radio?  Billy Joel and his song “honesty”

Honesty is such a lonely word
Everyone is so untrue
Honesty is hardly ever heard
And mostly what I need from you

And how apropos, for me, for KDD and for the seniors and their families out there that depend upon HONESTY and JUSTICE from the courts

Not very exciting.  They basically spend taxpayers dollars to tell me they won’t email anything and they don’t have efiling.  As you are aware, I also asked them for some time to chat about the case and get some information from them, but their letter seems to imply they’re not much interested in that.

See the letter below

Letter from ARDC that they DO NOT do email

and my and Ken’s reponse is below.

Dear Jessica and Sharon;

I sent a copy of my email to Ken, and he suggested the below, and you know he’s right, so I’m adopting that too as my response to your letter.

He thinks I should make it clear the two of you need to write up a complaint against yourselves for not investigating Mary Sykes who has been deprived of her liberty, property, human rights, civil rights and deserves to go back home and live with Gloria as she had for 10 years. The missing funds should also be investigated.  There is a money trail you know.  It’s all on the blog and I know Gloria has sent the ARDC numerous complaints only to have them end up in the huge vortex of ARDC circular files.  John Wyman I know has sent complaints to the ARDC, or I have for him.

I also have to add in Carol Wyman and Katherine Spera and atty Sharon Rudy and atty Kim Timmerwilke McKenzie who know these case are without jurisdiction.

Did you get John Wyman’s book?  I knew right away when I read that book there was jurisdiction clearly lacking because the hearing was to be on 7-9-09 but on 7-6-09 the hearing was set to that same day, without notice to anyone and Powel Wyman, a known abuser was appointed Guardian.  Amazing, utterly amazing.

Dominic Spera’s complaint will be forthcoming soon as we determine the massive damage Sharon Rudy has foisted upon him and his family, and poor Katherine Spera most of all who sits in a nursing home where she never wanted to be.And yet the ARDC does nothing about it.

I hope and pray someday the ARDC will take these horror stories of deprivation of liberty, property, human rights and civil rights seriously.  These are not just the elderly, frail and infirm but they are human beings whose rights should never have been violated in the first place.

thanks

joanne

cc:  http://www.marygsykes.com

www.ditkowskylawoffice.com

Dear Jessica;

I just got you snail mail letter today and please confirm that there is nothing else you have sent me since the last pleading I received which I believe was (gotta check those scans) your motion to strike discovery.

The reason why I ask and I have to use email is basically our postal lady I think is blind and walks very slow with a limp. I think she has trouble with our building because she has to walk up 5 stairs.  She’s real nice and all, but she does skip days and she often puts the mail in the wrong slot, which wouldn’t normally be a problem, except for the fact that some of the tenants in our building are architects and we have Claire Simon here and many of them are either out of town for days, or they only work a few days a week.  I’m sure she has a family to feed and all so I don’t want to complain about her because she’s nice.  But statistics are that 95% of the mail gets delivered in 5 days and the rest is unknown as to where that goes. 

So please do not depend on my mail because you will be sorely disappointed.

Since I do patent work and deal with high tech companies and inventors most of the time, 95% of my correspondence is via email so I don’t have a problem with the mail situation in my building.

Also, I am adopting Ken’s Discovery because I think he did a really good job and he is a wonderful, wonderful lawyer.  Don’t you agree?

Let me know if you want me to file a formal appearance with respect to that Motion to Strike so the discovery can get done.

I can redo the part about not having the warning. Do you really want that?

Of course, if you request it, I can snail mail your stuff.  But I hate it when attys tell me (and this happens more frequently than one might think) “I didn’t get it” and then it’s a do over and everything gets pushed back.  Arrrrgh.

Besides all of this email and efiling will be coming any day now, I’m sure so we all have to be prepared and Johnny on the Spot (or is that Jane on the Spot too since 1972 and the EEOC!)

Hmm, just wondering.

So, just let me know.  And I’m also looking forward to a little chat about this case with you ladies soon, so let me know when we can do a little coffee or tea talk.

And I am looking for a new attorney specializing in First Amendment rights, I send out about 20 emails a day but so far NSL.  Most just respond and have a few words (or paragraphs) about your complaint I will not repeat here.  Some cannot be published.  I also have received quite a few phone calls, but no takers yet on the rep thing. I will let you know first thing though.

thanks and take care and have a blessed day

joanne

cc:  MaryGSykes blog

and tells me not to use his name because it’s “too risky.”

Love it, well I’m taking the risk for all of you out there.  Keep me in your thoughts and prayers as this case develops.

Dear C_____;

OKay to publish your comments?  Withour without your name?

I have a real battle with the ARDC and you know they are on very shaky ground with my blog.

thanks so very much for your support and keep on reading my blog.  I unearth more and more stories everyday.

take care

joanne

—–Original Message—–
From: Anonymous
Sent: Feb 27, 2013 11:05 AM
To: joanne@denisonlaw.com
Subject: corruption

Good on you Joanne.  I have practiced for 40+ years, during most of which I have been frustrated with courts who, though not patently corrupt, are at the very least guilty of benign neglect while paid fiduciaries, their minions and their representatives looted the estates of the helpless.  Until recently, in [state redacted] private fiduciaries were given a free hand until corruption was exposed in M**** [county redacted] County.  Corruption is corruption whether active or passive.  We need real reform.  Hang in there.

Signed [name and address redacted]

From Joanne;

You know its a sorry state of affairs in the “land of the free and brave” when even LAWYERS are afraid to speak out against corruption, patent or covert, begin or active–it’s all the same.  JUSTICE WAS NOT DONE.  Judges that don’t follow the laws, GAL’s that tell the court uninventoried assets are imaginary rather than conducting an investigation.  Seniors kept wrongfully from their homes in guardianships lacking jurisdiction.

Day in and day out I hear these stories, some I can publish, some I can redact, some I cannot because the families are too embarrassed, fear reprisals, whatever, they ask me not to publish their stories so I don’t.  I live with their horrors and their injustices.

From: kenneth ditkowsky
Sent: Feb 26, 2013 7:05 PM
To: JoAnne Denison , Cynthia Farenga , Peter Schmiedel , Adam Stern
Subject: FYI

http://www.ditkowskylawoffice.com/

Well, in the continuing vein, if you don’t have a real case, the ARDC just snail mailed me this (uuugh–snail mail, who uses it unless absolutely forced to do so?)

ARDC Motion to Strike Discovery Requests

You know, most attorneys know you have to answer Requests to Admit so they will not be automatically deemed admitted by operation of law.  You’re all supposed to do a Notice of Filing and file them in Cook County Circuit Court and then also file the Answers that way because there have been tons of argument over when they were served and when they must be returned under the seminal case of Bright v. Dicke

The ARDC should know all that.

But apparently, that is their grounds for striking Ken’s perfectly good discovery.

I have never pulled that one before and I’m not going to.  Unless opposing counsel answers them late, I’m not going to kick up a fuss. Most of the time, there’s a judge there noting the fact you are just being petty. At least that’s my experience.  Unless it’s substantive, don’t mess with it.

One of my biggest issues is not serving everything by email and asking if someone needs a paper copy (ie, a need to waste paper and trees), and if you’re going to serve discovery, at least turn over the original documents so answers can be typed directly in.

Other than that, who cares about trying to get rid of discovery. It gets you to the merits of a case quickly and it SHOULD be used.  Freely, without pettiness.

I have no idea why the Administrator is fighting discovery and does not want any.  It makes absolutely no sense to me.

And they could have asked me first if I wanted to file an appearance or strike my discovery–I would have replied I’d file an appearance for the purpose of moving along discovery, if they wanted that.

So tomorrow, we need to wast more trees, pixels and what not and get this done–even though I have actual clients to help out who are laboring under a lack of jurisdiction in Probate court.

I have real matters to attend to.  And if the ARDC thinks that by flinging paper at me, somehow these cases will suddenly attain jurisdiction because I am distracted, they have another thing come.

I work all day, late every day, late into the night.  And then I get up again the next day just to be sure some august senior of ours is not deprived of life, liberty, property, human and civil rights.

Perhaps the lovely ladies at the ARDC think this will never happen to them–they will never be the little old lady with a paid in house, paid up bank account, assets, safe deposit boxes, and along comes a greedy aspiring plenary guardian ready to jump in and engage in all the horror stories you, my readers have written me about.  The most shocking by far is operating a court without jurisdiction–no summons and complaint, affidavit of service, no Sodini 10(f) notices to all your relatives.  Only the greedy, no need to inventory relatives will get that notice.  Someday they might be in Carol Wyman’s nursing home, being sexually assaulted at night for days in a row, wanting to go home, but being shot up with Risperdol, Halodol–held down and fighting it–all against her will.  And then finally, with a severe loss of blood (down one pint and near death), she is severely beaten with a face and torso full of bruises and she manages to escape and her beloved sons–John and William drive into the night 1200 miles cross county to save her.

The ARDC ladies say I am lying.  I am not.  Everything I have said to you all is true and the proof is up on this blog.

Want the proof of the nursing home beatings upon Mrs. Carol Wyman?

Carol Wyman Beating Report

And someday when the likes of Atty Jessica Haspel, Atty Jerome Larkin, and Atty Opryszek are in a nursing home (and we KNOW how dangerous those for profit places are) and they don’t want to be there, and they are beaten and sexually abused and they want to go home, but they have no money because someone uninventoried THEIR wealth conveniently and secretly and the GAL’s pipe “it’s imagined, it’s imagined” to the court,

YOU KNOW I WILL BE THERE FOR THEM AND THEIR CHILDREN.

and don’t think you all are immune, I already know at least 3 attorneys with wealthy fathers and mothers WHOSE PARENTS WERE PUT INTO A NURSING HOME BY A STATE GUARDIAN, THE GUARDIANS ARE FEASTING OFF THE ESTATE, AND MOM AND DAD ARE BEING ISOLATED and their advance directives were they never wanted to go to a nursing home.

Don’t think because you’re an attorney, you are immune.  These attorneys did well in court, were well liked by judges, but the minute they stepped into probate their world was turned upside down.

And don’t think for a minute the attorneys at the ARDC will come running to your rescue and do your junk for free and believe in the justice of it all.  For every 10 attorneys coming through my office, 95% look the other way and don’t want to get involved in doing something for free that is difficult, complex and with the ARDC on my back, dangerous.

Very few do what Ken and I do.

JoAnne