Category: Abuse of the Legal Process



Labor Day on the first day of September 1, 2014 reminds me how I have worked in Du Page County and in the Village of Lombard before September 2, 1993, when I was employed by Carmen Alonso Kenny & Associates as a Certified Legal Interpreter and Translator for Du Page County Arbitration Center for Workers’ Compensation, Traffic Court at 421 North County Farm Road and the 18th Judicial Circuit Court at 505 North County Farm Road in the City of Wheaton. I also worked at the old courthouse in Geneva, and the new courthouse in St. Charles for the Kane County Judicial Center, including Batavia. Plus, I was assigned interpreting and translation in Elgin and Joliet in Will County; as well as court-appointed legal interpreting in Waukegan, Lake County, and in Woodstock, McHenry County, and beyond to LaSalle County, and DeKalb, in Illinois. For more than twenty (20) years, I have been a commissioned Illinois Notary Public for Cook County first, then for Du Page County by the Illinois Secretary of State and the County Clerk’s Office.
While reading the Chicago Tribune, I found out that Interlate Systems Inc. and Pan Blanco in Elgin, Aurora, and Batavia, owned by Brad White, a former College of Du Page employee who was hiring a Certified Interpreter and Translator in English, Spanish, French, and Portuguese. I was interviewed and hired as a Certified Legal Interpreter and Translator by Jacquie Guiter and Rene Hofsteder at the Interlate Systems Inc. office which was located in Elgin Downtown, along Route 30, not far from the Elgin Police Station.
Before and after I got married to Nathan Scott Wittler Patriquin, I was working full-time, free-lance, and part-time on different jobs, occupations, and business sectors in the City of Chicago, Cook County, and outlaying suburbs of Du Page County, Kane County, Lake County, Will County, McHenry County, LaSalle County, DeKalb, and at my home business office.
In addition, I was working for Berlitz Schools at 2 North LaSalle Street in the City of Chicago with Milanka who was the Berlitz Method Trainer, Josepha and June, the receptionist. Then, I was assigned by Berlitz to teach for Beth, the Director, upon assignments from Sally at the Water Tower Place across from the John Hancock Center. Afterwards, Beth moved the Berlitz office to Hinsdale and later opened another Berlitz school in Oak Brook, Du Page County, Illinois USA. Beth at Berlitz assigned me to teach Berlitz Junior at the Butler Middle School on York Road, across from the Oak Brook Country Club and also at Brook Forest Elementary School, along 31st Street in Du Page County, Illinois USA.
After my Father, Mr. Roberto Hung purchased the Lombard Historic Brick Bungalow at 502 South Westmore-Meyers Road and Washington Boulevard, I was driving to and from work upon assignment for Certified Legal Interpreting and Translation, Teaching, Cross-Cultural Training, Consulting Language Social Media jobs for clients, Marketing Localization for AIM Translations managed by Karen in Bloomingdale, and other language work for Business Access Translation managed by Rosa Ridderbusch in Zurich, Illinois.
While I was working all day during mornings, afternoon, and evenings, Nathan Scott Wittler Patriquin and my Father, Mr. Roberto Hung, allowed intruders to roam, ransack, steal, and scatter business documents, a community certificate from the Chinese American Service League, personal belongings, an 18 Karat Gold Bracelet which has been heirloom jewelry that my Grandmother and family had given to me, fashion clothing, intimate apparel, and miscellaneous business and teaching resources which have been stolen and removed from my personal use by the Lombard Police Department and the Illinois Court Houses in Du Page County, Cook County, and other places in the Chicagoland area. I have even lost my Minolta Camera Flash, JVC Digital Film Cassettes, and other teaching media from my work environment after I moved to the Village of Lombard on September 2, 1993.
I have also lost two (2) Tennis Rackets and Tennis Balls, a Tachikara Volleyball, Golfsmith Putting Golf Club, Golf Shoes, Golf Balls, and many other valuables which have been stolen from my Lombard home, allowed by the Lombard Police Department in District 5, York Township, Du Page County, Illinois USA.
In 1992, my Mother Mrs. Gardenia Fong Ramos and my youngest brother Robert S. Hung with his boyfriend Paul Rathe purchased a Lombard home with homeowners’ credit and a cash down deposit of $10,000 given by my Father Mr. Roberto Hung from his IRA retirement funds. Then, they moved to the Lilac Town with a Pomeranian dog near Sunset Knolls Park District on Finley Road, Sacred Heart Catholic Church on Elizabeth Street, and Lilacia Park near Main Street in the Village of Lombard, Du Page County, Illinois USA. Randy Stob is the Lombard realtor who sold my brother Robert the real estate property in Du Page County and deliberately set out to bring the rest of the family of Mr. Roberto Hung Juris Doctor, his Daughter, and Husband to buy a Lombard home in Du Page County, Illinois.
When Paul Rathe, a young urban gay who lived on Roscoe Street near Halsted Street, Boys Town and Lakeview in Chicago, convinced my youngest brother and mother to buy a Lombard home and move to the western suburbs in Du Page County during 1992, he did not tell them that buying Lombard real estate would cause chronic health and medical problems for them, long-term disease, psychiatric problems, violence against women, assault, physical abuse, biomedical and bio-sexual transgendered studies, hospitalizations, traumatic brain injuries, head concussions, tragedy, family death, and abuse of human rights in housing under the law in York Township, Illinois, USA.
Paul Rathe introduced my brother and mother to Baird & Warner realtor Paulette Weininger who found a Lombard home for them at 342 West Harrison Street near Sacred Heart Catholic Church on Elizabeth Street, Finley Road and Main Street close to Walgreens, near the Du Page County Crisis Unit, a Medical Group Practice located at 440 South Finley Road and Washington Blvd. in the Village of Lombard, Illinois 60148 USA. Linda Schuster who lived in Westmont was the girlfriend of Paul Rathe who referred my brother and mother to buy a house in Village of Lombard, also known as Lilac Town for the annual Lilac Parade celebration near Main Street in Spring time.
Randy Stob, the Lombard realtor who sold them the real estate property at 342 West Harrison Street near Elizabeth Street and Finley Road, began to encourage my brother Robert S. Hung and my Mother to bring other people in the family, to include her Daughter with her father and husband to buy Lombard real estate property in Du Page County, Illinois USA.
Since my Mother and Brother purchased Lombard real estate property from the same Lombard realtor, I have been kidnapped four (4) times during the course of employment and from my Lombard home in District 5, York Township, Du Page County, upon return from working by friends of the Lombard realtor and his associates in the Du Page Realtors Association in Illinois USA.
I had already worked as a Certified Legal Interpreter and Translator in Wheaton, Geneva, Oak Brook in Du Page County, as well as St. Charles, Batavia, Elgin, Aurora in Kane County, and DeKalb, Illinois.
During June 1993, Mr. Roberto Hung started looking to purchase real estate property for a home in Du Page County near my brother and mother in Lombard, Illinois. After my Father, myself, and my husband purchased a historic Lombard Brick Bungalow at 502 South Westmore Avenue and Washington Boulevard, near Saint Pius X Catholic Church, we began to invite and entertain family and friends at our Lombard home in District 5, Du Page County, Illinois USA. During April 1994 and Lilac Time, the family of Mr. Roberto Hung Juris Doctor entertained and hosted Nathan S. Wittler’s retired Christian missionary parents, Reverend Melvin A. Wittler and Mrs. Nancy Wittler Patriquin who were travelling in the Chicago area and the United States on furlough from Istanbul, Turkey, in the Middle East.
In addition, my Mother’s youngest sister, Mrs. Xiomara Fong Ramos de Zayas from Santiago de Cuba, was invited to visit the Village of Lombard for six (6) months to stay with her oldest sister whom she had not seen in more than twenty (20) years—our family had left Cuba during the Catholic Freedom Flights and arrived in Miami, Florida on July 19, 1971. My parents, Mr. Roberto Hung and Mother Mrs. Gardenia Fong Ramos, chose to relocate to Chicago, Illinois sponsored by Catholic Charities.
After my Mother’s sister, Aunt Xiomara Fong Ramos de Zayas, visited the Village of Lombard in 1994, I was kidnapped after I completed an interpreting assignment for Interlate Systems Inc. in Aurora, Kane County, Illinois USA. I was working as a Certified Legal Interpreter and Translator, also as commissioned Illinois Notary Public for more than twenty (20) years, working with Action Translation Bureau managed by Joseph Raudonis in Palos Heights, Carmen Kenny & Associates in Arlington Heights, Interlate Systems Inc. in Elgin and Batavia, Kane County, and other translation agencies affiliated to the Chicago Area Translators Association (CHICATA) and the American Translators Association (ATA) under the aegis of the Federation of International Translators (FIT).
My name is Gardenia C. Hung, estranged spouse of Nathan Scott Wittler Patriquin, DOB December 27, 1958, Age 55 years old, eldest daughter of the late Mr. Roberto Hung Juris Doctor and his surviving widow Mrs. Gardenia Fong Ramos, DOB February 2, 1938, a disabled, retired senior citizen, 76 years of age, who was transferred from Elmhurst Memorial Hospital during the year 2006 to the Chicagoland area unbeknown to me, her first daughter who is a Lombard resident homeowner and was living at 502 South Westmore Avenue and Washington Boulevard in District 5, York Township, Du Page County, Illinois 60148-3028 USA.
Eight (8) years have passed since I last saw my Mother, Mrs. Gardenia Fong Ramos, who is now a disabled senior citizen living on the north side of Chicago, 48th Democratic Ward, in the Edgewater neighborhood, near Loyola University, Lake Shore Campus by Lake Michigan, Illinois USA.
I am a Lombard resident homeowner and Catholic parishioner near St. Pius X Catholic Church, who was helping my Mother Mrs. Gardenia Fong Ramos, widow of the late Mr. Roberto Hung Juris Doctor, after her forced hospitalization to the Psychiatric Ward in the care of Dr. McKenna and Social Worker Tilary at Illinois Masonic Medical Center by Jim Wilbrot, Sally, Timothy Tromasina, James and his friends in Oak Park, who committed her with the Chicago Police Department on Addison Street near Halsted Street , In the Lakeview and Boys’ Town neighborhoods during 2005.
I have not seen My Mother since January 12, 2006 when I found her injured at our Lombard Brick Bungalow, 502 South Westmore-Meyers Road and Washington Boulevard, across Mrs. Shimek’s green home and Robyn’s brick brownstone.
Eight (8) years have passed since the Du Page County Clerk Gary King told me that my Mother was dead, but I did not believe him when I replied that my Mother was not dead. Du Page County and Cook County Social Workers and other medical facilities in Illinois have not contacted me as my Mother’s daughter and next-of-kin family member, even when my Mother was staying with me as a Lombard resident during November and December 2005, and January 2006.
Copyright 2014 GHung’s Blog. All Rights Reserved.


Communications, Languages & Culture, Inc. is a Consulting Social Media Arts Communications service provider since 1994.



Mr. Roberto Hung Juris Doctor & Family

Mr. Roberto Hung Juris Doctor & Family have been Lombard resident homeowners, taxpayers in York Township, DuPage County, Illinois 60148 USA


Gardenia Hung-Wittler is the Lombard Victim of Criminal Disaster and Abuse of U.S. Constitutional Civil Rights and Human Rights by the Village of Lombard Police and Fire Department during the Disaster Demolition of the Hung Family Lombard Real Estate at 502 South Westmore-Meyers Road & Washington Boulevard, in DuPage County, Illinois 60148 USA

My name is Gardenia Hung-Wittler, a Lombard Resident Homeowner and U.S. Citizen, Victim of Criminal Disaster and Abuse of U.S. Constitutional Civil Rights and Human Rights by the Village of Lombard managed by David Hulseberg and caused by the Lombard Police and Fire Department since my father, Mr. Roberto Hung purchased the Lombard Historic Brick Bungalow from September 1993 until the criminal disaster demolition on November 5, 2008 arranged by Keith Steiskal and Chief George Seagraves from the Lombard Fire Department. The Village of Lombard is refusing to provide lodging, storage, and/or compensation for the criminal disaster demolition, the stolen property by the Lombard Police Department and others, and/or all the damages and losses incurred by Gardenia Hung-Wittler for the Estate of Mr. Roberto Hung and Family to include the company professional assets and equipment for Communications, Languages & Culture, Inc. During 2008 and 2009, I, Gardenia Hung-Wittler have not been notified nor received any of the legal Court Notices, Summons, and/or documentation regarding legal issues and criminal acts surrounding the stolen property at 502 S. Westmore-Meyers Road at the Estate of Mr. Roberto Hung & Family. For the record, I am an Illinois Notary Public in DuPage County, commissioned by the State of Illinois.

Gardenia Hung-Wittler is reporting abuse of U.S. Constitutional Civil Rights and Human Rights to appear as a Lombard resident homeowner and U.S. citizen, with rights to be informed and be included in the briefings regarding the legal matters surrounding criminal acts and actions against the Lombard Real Estate Property at 502 S. Westmore-Meyers Road in DuPage County, Illinois USA. During 2008, 2009, and 2010, and including previous years, the Village of Lombard and DuPage County in Illinois have been excluding from participating in the legal briefings, summons, court appearances, and other criminal matters and actions involving the Lombard Police and Fire Department.

I, Gardenia Hung-Wittler have not received any court orders, notices, or legal briefs regarding the criminal disaster and stolen property owned by the Estate of Mr. Roberto Hung and Family, to include Communications, Languages & Culture, Inc. The Village of Lombard has not been mailing any letter of apology, response to compensation and restitution, or provisions for the Lombard Victim of Criminal Disaster requesting lodging, storage facility, and cash remuneration for all stolen household items, damages, and losses incurred by the Estate of Mr. Roberto Hung and Family to include the company professional office assets for Communications, Languages & Culture Inc. in DuPage County, Illinois USA.

Upon review, all the professional electronics are useless and inoperative, which includes Hewlett Packard, Compaq Pressary, Sony, computers, faxes, printers, and other electronics have been broken and damaged when the cables were pulled out forcefully, and yanked out during the Disaster Demolition on Tuesday, November 4, and Wednesday, November 5, 2008. On that day, the Taxi that the Village of Lombard arranged to pick me up, left early and did not pick me up at the Motel 66 located on Roosevelt Road near Ardmore Avenue in Villa Park. The Taxi left me behind at the Motel 66 and did not return to pick me up, but got paid for the day by the Village of Lombard, even when I was not in the taxi as a passenger.

I, Gardenia Hung-Wittler have been donating the remaining disaster items to the Salvation Army, AMVETS, St. Vincent De Paul, St. Pius X Catholic Church, Lombard United Methodist Church, Helen M. Plum Library, Villa Park Library, Addison Public Library,York Township Community Center, the Harvard Evangelical Free Church of Villa Park, and other people, groups, and organizations.

Overall, I, Gardenia Hung-Wittler have become a Lombard Victim of Criminal Disaster and Abuse of Human Rights arranged by the Village of Lombard David Hulseberg, the Lombard Police and Fire Department, Keith Steiskal and George Seagraves, among others not revealed to me as a public information required for a Lombard resident homeowner and taxpayer. The Village of Lombard abuses U.S. Constitutional Civil Rights by excluding Gardenia Hung-Wittler from legal court proceedings, hearings, appearances, and court summons. I have not received any letter of apology from the Village of Lombard David Hulseberg or the court orders informing me as a Lombard resident homeowner, victim of criminal disaster, of the crimes and compensation issues to be addressed by the Lombard Police and Fire Department in DuPage County, Illinois USA. I have not been invited to attend Victims Panels or any Victims of Crimes Support Groups in DuPage County, Illinoisn USA.

Please note that all the assets and belongings for Gardenia Hung-Wittler on behalf of the company Communications, Languages & Culture, Inc. have been reported as tax-related and owned by the company in the Village of Lombard, DuPage County, Illinois USA.

Therefore, I, Gardenia Hung-Wittler do hereby petition for compensation, restitution, and lodging for living quarters and storage by law as it is provided to Lombard Victims of Criminal Disasters and other victims of crimes in Illinois and throughout the United States of America.

Please respond to my petition for lodging and compensation as a Lombard Victim of Criminal Disaster, attacked by the Village of Lombard Police and Fire Department, to include David Hulseberg who excludes from civil court proceedings in this legal action surrounding the Estate of Mr. Roberto Hung and Family, and directly addresses Gardenia Hung-Wittler and the company Communications, Languages & Culture, Inc. at 502 S. Westmore-Meyers Road & Washington Boulevard, in Lombard, Illinois 60148.


YOU ARE HEREBY NOTIFIED that on Monday, May 19, 2008, I shall appear before Judge Jane Hird Mitton, Room 4005, 18th Judicial Circuit Court, Du Page County Judicial Center, 505 North County Farm Road, Wheaton, Illinois 60187, and then and there to present a Motion to Accept More Than 30 Hours of Community Service in the Village of Lombard, Du Page County, Illinois, USA

RE: Du Page County Circuit Court, Case No. 2006 CM 004292, July 26, 2006, incident caused by the Lombard Police Department, Pam Lessner, Jamila Hanif, Khadija Hanif, Javeria Hanif from Glen Ellyn, and Lombard Policemen David Thiede, Benedicsen, Virene, Schrepferman, Bob Kelly, Marciniak, against Gardenia C. Hung, M.A. who has been filing charges on Violation of Human Rights and Constitutional Rights in Lombard, DuPage County, Illinois, USA. Lombard Resident and U.S. Citizen at 502 S. Westmore Avenue , Lombard , IL 60148-3028 USA . Motion To Accept More Than 30 Hours of Community Service in the Village of Lombard

Motion To Accept More Than 30 Hours of Community Service in the Village of Lombard

My name is Gardenia C. Hung. I am a Lombard resident homeowner, taxpayer, and U.S. citizen in Du Page County, Illinois, USA. I am requesting your assistance to support my Community Service in the Village of Lombard for more than 30 hours of community service performed during 2006, 2007, and 2008 in Du Page County, Illinois, USA. On Monday, May 19, 2008 , at 9H30 a.m. I must appear at the 18th Judicial Circuit Court in Du Page County, before Judge Jane Hird Mitton, in Room 4005, 505 North County Farm Road , Wheaton , Illinois 60187 to verify more than 30 hours of community service sentenced by Judge Thomas Riggs for wrongful charges, false arrest/detention by Lombard Policeman David Thiede, Badge No. 24. Illinois Public Defender Lawanda Allen has advised that there will be a Court Hearing on a Petition to Revoke the court sentence imposed by Judge Thomas Riggs, Room 4001, and enforce court fines and fees in the amount of $604US, since I do not have any money to pay court fines and fees. I have already submitted a Certified Letter from Rev. Herb Essig at St. Pius X Catholic Church stating volunteer services provided to St. Pius X Lombard, the Council of Catholic Women, Adult Choir, Christmas Holiday Volunteers, and the shrine of Mary Immaculate Queen at St. Pius X Catholic Church, in the Village of Lombard .

Please note that the Probation Department and Peter K. Stoffels have not verified Community Service on Fridays, before Court Appearance because Rev. Herb Essig does not have office hours on Fridays or Mondays at St. Pius X Catholic Church in the Village of Lombard . For the record, Rev. Herb Essig is available at St. Pius X Church on Tuesdays, Wednesday, and Thursday.

As a Victim of Crime in the Village of Lombard , I have stated that I am suffering from abuse of the legal process, malicious prosecution, financial hardship, and discrimination by the Lombard Police Department and the Village of Lombard in Du Page County, Illinois, USA. I am requesting U.S. Congressional intervention in the Village of Lombard and before the 18th Judicial Circuit Court, presided by Judge Jane Hird Mitton and Illinois Public Defender Lawanda Allen, and the State’s Attorney on Monday, May 19, 2008 , at 9H30AM, Room 4005. I am a Victim of Crime by the Lombard Police Department and the Village of Lombard in Du Page County, Illinois , USA .

My human rights and constitutional rights in the State of Illinois have been violated in Lombard, DuPage County, Illinois as a Lombard resident and U.S. citizen residing at 502 S. Westmore Avenue, Lombard , IL 60148-3028 USA . The following is an outline narrative report describing incidents which have violated my human rights and constitutional rights in Lombard , DuPage County , Illinois .

Village of Lombard , Town Hall Lombard Police Department

255 E. Wilson Avenue Lombard Fire Department

Lombard , IL 60148-3028 USA
Lombard Bureau of Inspectional Services

BACKGROUND

I. For the record, Gardenia C. Hung has already reported this unfair and unjust incident to Rev. Herb Essig and the Friends at St. Pius X Catholic Church, since this problem took place in public, just across from St. Pius X Church where the Catholic nuns live.

I have asked for Community Support to report how the Lombard Police Department has unfairly arrested me for wrongful charges and alleged that I have committed criminal assault, obstructed a police officer, and resisted arrest on July 26, 2006. During that afternoon, I had been training for employment at the Illinois Employment and Training Center located at the Eastgate Shopping Center in Lombard. Around 4PM, three (3) young women walked into the bathroom while I was leaving and after I left, called the Lombard Police Department on their cellular telephone to report a stolen cellular telephone. The names of the three young women from Glen Ellyn are Jamila Hanif, Khadija Hanif, and Javeria Hanif, residents at 50 Briar Street #101, Glen Ellyn, Illinois 60137, who talked to Lombard Policewoman Pamela Lessner, Badge No. 710, who was driving the Lombard Community Service Truck. I have pleaded NOT GUILTY to all charges. Afterwards, Lombard Policeman David Thiede, Badge No. 24, alleged that I assaulted him with a Red Burberry umbrella, resisted a peace officer, and obstructed a peacer officer on the front lawn of St. Pius X Catholic Chuch, located at the corner of Westmore-Meyers Road and Madison Street, in the Village of Lombard, Du Page County, Illinois, United States of America. In spite of evidence presented on January 30, 2007 Judge Thomas Riggs sentenced me to thirty (30) hours of community service and additional court fines and costs in the amount of $604, six hundred and four dollars. This legal matter is currently reviewed in the 18th Judicial Circuit Court, Room 4005, before Judge Jane Hird Mitton, on Fridays, May 16, 2005, at 9H30 a.m. and has been continued for Monday, May 19, 2006 , at 9H30 a.m. to verify 30 hours of Community Service performed by Gardenia C. Hung at St. Pius X Catholic Church in the Village of Lombard during 2007-2008. For the record, Gardenia C. Hung has appeared before Judge Cary, as well as before Judge McKillip on September 29, 2006, 8H30, in Room 4001 at the DuPage County Judicial Center, 505 North County Farm Road, Wheaton IL 60187.

Gardenia C. Hung was walking peacefully home from the Illinois Employment and Training Center at 837 S. Westmore-Meyers Road, Lombard, IL 60148, Telephone (630) 495-4345, next to the Illinois Secretary of State, Jesse White Vehicle License Facility, at the Eastgate Shopping Center in Lombard when Lombard Policewoman Pam, Badge No. 710, yelled out from the white Community Police truck that I had stolen an East Indian woman’s cellular telephone at the I.E.T.C. I stopped to answer her ‘NO’ at the corner of Adams St. and Westmore-Meyers Road in Lombard and continued walking home toward St. Pius X Church. When arrived to the front lawn of St. Pius X Church, Lombard Policeman Thiede, Benedicsen, Virene, Schrepferman and Pam, all got out of their Lombard police cars to arrest me and drop all the contents of my handbags on the green lawn, along with my yellow knapsack and my red Burberry umbrella.

During the False Arrest/Detention with Wrongful Charges, Gardenia C. Hung received visible scratches on her right hand wrist, for the record. Both of her arms were twisted and wrenched by Lombard Policeman Thiede who handcuffed her without due reasons. In addition, Lombard Policeman Thiede forcefully removed a Silver Bracelet with a Christian Cross Pendant and did not return the jewelry to Gardenia C. Hung. Gardenia C. Hung wants her Christian Cross Silver Bracelet returned for her right wrist. Moreover, all the contents of (2) two red handbags were emptied on the green lawn in front of St. Pius X Catholic Church, while the Red

Burberry umbrella was thrown on the green lawn by the Lombard Police, and they searched the yellow backpack containing water bottles and personal items.

Gardenia C. Hung, does not plead guilty to Count 1, Obstructing a Peace Officer, nor Count 2, Resisting a Peace Officer, or Count 3, Assault of the Lombard Police as defined by “an open threat of bodily contact with someone without permission”. Please note that Gardenia C. Hung’s Red Burberry umbrella did not have any contact with any of the Lombard Police involved in this matter—Thiede, Benedicsen, Virene, Schrepferman, Pam, and/or Marciniak. None of the Lombard Police in this matter have been assaulted, injured or attacked by Gardenia C. Hung. While Gardenia C. Hung has been harassed, manhandled, scratched, and injured by Lombard Police Thiede who abused process for wrongful charges, false arrest/detention without foundation. The Lombard Police are at fault due to false imprisonment/detention, malicious prosecution which is to misuse the legal process to harass an individual, and interference with person by law in Illinois. Gardenia C. Hung was held at the Lombard Police Department for five (5) hours without any water or food by Lombard Policeman David Thiede, Badge No. 24.

I look forward to your support and assistance with God’s help. Thank you for your attention to this matter.

Sincerely Yours,

Gardenia C. Hung, M.A

Saturday: May 17, 2008

Village of Lombard , County of Du Page , State of Illinois , United States of America

VERIFICATION

Under penalties as provided by law pursuant to Section 1-109 of the Illinois Code of Civil Procedure, the undersigned certifies that the statements set forth in this instrument are true and correct, to the best of my ability, so help me God.

Date: May 17, 2008 Signed by Gardenia C. Hung, M.A.

In the Village of Lombard , Du Page County, Illinois , United States of America


STATE OF ILLINOIS UNITED STATES OF AMERICA COUNTY OF DUPAGE
IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT COURT

THE VILLAGE OF LOMBARD, an Illinois Municipal Corporation, et al.,
Plaintiff,
vs.
GARDENIA C. HUNG, ROBERT S. HUNG, as Trustees of the Trust Agreement Designated as Roberto Hung Supplemental Care Trust, JEFFREY D. PAPENDICK, a tax purchaser, and NON-RECORD CLAIMANTS AND UNKNOWN OWNERS ,
Defendant )
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DEFENDANTS’ MOTION FOR FOURTH OBJECTION TO THE VERIFIED COMPLAINT IN OPPOSITION TO THE PLAINTIFF’S MOTION TO STRIKE

DEFENDANTS’ MOTION FOR A FOURTH OBJECTION TO THE VERIFIED COMPLAINT IN OPPOSITION TO THE PLAINTIFF’S MOTION TO STRIKE
Comes now Gardenia C. Hung as PRO SE, on behalf of the Defendants, to present a Fourth Objection to the Verified Complaint for Demolition and for Injunctive Relief, in opposition to the Plaintiff’s Motion to Strike filed by Counsel Howard C. Jablecki, et al. and its attorneys at Klein, Thorpe & Jenkins, Ltd., during 2008 National Crime Victims’ Rights Week, pursuant to the Constitution of the State of Illinois, Preamble, Article 1, Bill of Rights, and the Fifth and Fourteenth Amendments to the U.S. Constitution, as Victims of Crime in the Village of Lombard, Du Page County, Illinois, United States of America, on legal grounds for obstruction of justice, malicious prosecution, and abuse of the legal process. The Defendants are Victims of Crime in the Village of Lombard.
For the record, Counsel Howard C. Jablecki, et al. mailed the Plaintiff’s Response with an U.S. postmark on April 10, 2008, instead of the legal date on April 9, 2008.
Please take notice that Counsel for the Plaintiff is at fault for delaying construction, restoration, and preservation plans for the Lombard Historic Brick Bungalow owned by the Estate of Roberto Hung Supplemental Care Trust and the Hung Family. Plaintiff filed a Verified Complaint on May 23, 2007, several months after Gardenia C. Hung, et al. proposed restoration, construction, renovation, and preservation stated in EXHIBIT C for Contracts A-1, B-1, and C-1, attached hereto as evidence of contractual agreement with the Zees Group.
For the record, Gardenia C. Hung as PRO SE for the Defendants is in compliance with Section 2-610 of the Illinois Code of Civil Procedure, 735 ILCS 5/2-610 (a), in denying each and every allegation of the Verified Complaint for Demolition and for Injunctive Relief presented in the Defendants’ Third Amended Response/Answer to Summons with the Defendants’ Motion to Compel a Court to Repair the Subject Property accompanied by a Third Objection to the Verified Complaint for Demolition and for Injunctive Relief.
Defendants hereby object in opposition to the Plaintiff’s Motion to Strike and reinstate their petition to redress grievances as Victim of Crime in the Village of Lombard, for all damages and losses, as well as personal injury caused by Plaintiff, the Lombard Police Department, Keith Steiskal and the Lombard Fire Department, Bureau of Inspectional Services, as well as the community-at-large in Du Page County and the State of Illinois.
WHEREBY, Defendants support the Third Amended Response/Answer to Summons as a Counterpoint at Issue Legal Memorandum in Opposition to the Verified Complaint for Demolition and for Injunctive Relief, in order to support EXHIBIT C, Contracts A-1, B-1, and
C-1 for restoration, renovation, and preservation of the Lombard Historic Bungalow, pursuant to legal grounds for “action for inverse condemnation, conversion of real property, consumer service fraud, breach of the fair housing partnership resolution contract, and real estate liability for Lombard Old Houses, in Du Page County, Illinois, United States of America.
WHEREFORE, Defendants pray for a Court Order to sustain the Motion to Compel Court Order to Repair the Lombard Historic Brick Bungalow, pursuant to legal grounds for action under the continuing damages theory, the doctrine for inverse condemnation, consumer service fraud, conversion of real property, and discrimination, subsequent to the Civil Rights Act of 1866, the Equal Rights Amendment to the U.S. Constitution, the Fifth and Fourteenth Amendments, the Constitution of the State of Illinois, Preamble, Article 1, Bill of Rights, and the Illinois Victims of Crime Act, Illinois Consumer Protection Act, Federal Trade Commission Act, 15 USC §45 et seq. and 16 CFR, the Illinois Home Repair and Remodeling Act, the Illinois Human Rights Act with Protections in Housing under the Law, Hate Crimes Local Law Enforcement Enhancement Act, Housing and Urban Development Act.
Pursuant to the Illinois statutes for Consumer Service Protection against Consumer Service Fraud, Deceptive Business Practices, and Prohibited Business Practices, Defendants hereby petition to sustain this Fourth Objection to the Verified Complaint and object to the Plaintiff’s Motion to Strike filed by Counsel Howard C. Jablecki.
In addition, Defendants pray for extraordinary remedy and relief, in the form of justice, compensation, and severance restitution for damages and losses under the doctrine for inverse condemnation, with justice, fairness, and equity to provide cash remedy and monetary relief for compensation and indemnity to the aggrieved, pursuant to 735 ILCS 5/Art. II et seq., civil practice law, and the rules of the Supreme Court in the State of Illinois, under the Constitution of the United States of America, and under God.

VERIFICATION
Under penalties as provided by law pursuant to Section 1-109 of the Illinois Code of Civil Procedure, the undersigned certifies that the statements set forth in this instrument are true and correct, to the best of my ability, so help me God.

Dated this 16th day of April, 2008

(RESERVED SIGNATURE)
GARDENIA C. HUNG,
PRO SE
502 S. WESTMORE-MEYERS ROAD
LOMBARD, ILLINOIS 60148
UNITED STATES OF AMERICA
GHUNGMA@GMAIL.COM


State of Illinois United States of America County of Du Page
In the 18th Judicial Circuit Court
Village of Lombard, an Illinois
Municipal Corporation, et. al,
All Employees, Plaintiff,
vs.
Gardenia C. Hung and Robert S. Hung, Trustees of the Trust Agreement Designated as the Roberto Hung Supplemental Care Trust, Jeffrey D. Papendick, a tax-purchaser, and non-record claimants and unknown users
Defendants
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Case No.:2007CH001284 Consolidated
Case No.:2006OV005982, LO25448NT;
Case No.:2006OV005983, LO25449NT;
Case No.:2006OV004446, LO12418NT; LO12419NT
NOTICE OF FILING MOTION
DEFENDANTS’COMBINED §2-615 MOTION TO STRIKE AND §2-619 MOTION TO DISMISS
THE VERIFIED COMPLAINT FOR DEMOLITION AND FOR INJUNCTIVE RELIEF
DEFENDANTS’ MOTION TO ACCEPT ALL LEGAL EXPENSES IN THE SUM OF $33,725.41US FOR REIMBURSEMENT OF ALL COURT FEES, COSTS, AND OUT-OF-POCKET EXPENSES FOR PAYMENT BY PLAINTIFF

Attn. Honorable Judge, Chancery Division To: Honorable Circuit Court Clerk
18th Judicial Circuit Court, Room 2005-2009 Mr. Chris Kachiroubas
505 North County Farm Road 505 North County Farm Road
Wheaton, Illinois 60189-0707 USA Wheaton, IL 60187 USA
CC: Law Firm of Klein, Thorpe and Jenkins, Ltd., Mr. Howard C. Jablecki, Lance C. Malina, Cynthia S. Grandfield, Attorneys for the Plaintiff, 20 North Wacker Drive, Suite 1660, Chicago, Illinois 60606-2903, USA; To Whom It May Concern

NOTICE OF FILING MOTION

DEFENDANTS’COMBINED §2-615 MOTION TO STRIKE AND §2-619 MOTION TO DISMISS THE VERIFIED COMPLAINT FOR DEMOLITION AND FOR INJUNCTIVE RELIEF PURSUANT TO SUPREME COURT RULE 137

Now comes Gardenia C. Hung on behalf of the Defendants to appear and petition Combined §2-615 Motion to Strike and §2-619 Motion to Dismiss the Verified Complaint for Demolition and for Injunctive Relief pursuant to Supreme Court Rule 137 for lack of foundation, improper character reference, and failure to state a public purpose for demolition and for injunctive relief, on legal grounds for Consumer Service Fraud, Conversion of Real Property, Abuse of the Legal Process, Malicious Prosecution, Obstruction of Justice, “Scienter”, i.e. Guilty Knowledge by Plaintiff as the Village of Lombard et al., All Employees, about the false representation of the Lombard Historical Brick Bungalow at 502 S. Westmore Avenue owned by the Hung Family, and omission of material fact and key evidence leading to all the damages, losses, and disrepair to real property owned by Gardenia C. Hung and Robert S. Hung, as Trustees, under the terms and provisions of the Roberto Hung Supplemental Care Trust, dated on the 3rd day of June 1997. This Lombard Historical Brick Bungalow is not a dangerous, unsafe building to the community in the Village of Lombard.

Legal Description of the Lombard Historical Bungalow Built in 1927

Parcel Identification Number 06-09-315-038. Lot 2 in George P. Hornbeck’s Re-subdivision of the part of the West ½ of the South West ¼ of Section 9, Township 39 North, Range 11, East of the Principal Meridian, according to the Plat thereof recorded on February 19, 1980 as Document No.R80-10413, in Du Page County, Illinois, United States of America.

Defendants hereby deny, dispute, and oppose each and every allegation in the Plaintiff’s Response since witnesses, statements on record, law enforcement reports, and prior court decisions for the consolidated legal actions herein, do not support the Verified Complaint for Demolition of a Dangerous Unsafe Building or the statement that the subject property is “Unfit for Human Habitation” since Gardenia C. Hung is the legal Lombard resident homeowner, currently residing and inhabiting the same premises without any hazards, safety risks and/or health concerns.

Defendants are entitled by law to restore, remodel, repair, and reconstruct the subject real estate property by law, under the U.S. Department of Housing and Urban Development Act, the Homeowners Repair Act, the Housing and Community Development Act, Federal Fair Housing Acts, and the Federal Trade Commission Act.

For the record, the Bureau of Inspectional Services represented by Keith Steiskal and Chris Haneghan for the Lombard Fire Department did not send a Legal Notice of Demolition of Repair when an unknown stranger posted a “NOT APPROVED” a blank Orange Notice without official signature or official seal from the Village of Lombard, unsigned by anyone on April 6, 2007, without due notice to Gardenia C. Hung and others noted as Defendants. Please take notice that Keith Steiskal is unqualified as a Building Code Inspector in the Village of Lombard due to Negligence Per Se and failure to respond and provide reports to Gardenia C. Hung et al. in order to fulfill the required inspectional building services and guidelines, under pretense now to be multiple violations of the Code in the Village of Lombard. Furthermore, Demolition of the subject property has not been legally authorized by the Illinois municipal code.

On May 12, 2006, Keith Steiskal arrived late for the building inspection and appeared to be “under the influence” of drugs prescribed for a flu virus infection that he told me he had—-in that condition, Keith Steiskal was unfit to perform his job, since the same behavior continued throughout 2006 and 2007.

COUNTERPOINT/COUNTERARGUMENT

Now comes Gardenia C. Hung to appear on Monday, October 29, 2007 in order to resubmit the Defendants’s Combined §2-615 Motion to Strike and §2-619 Motion to Dismiss the Verified Complaint for Demolition and for Injunctive Relief pursuant to Supreme Court Rule 137 based on the following legal grounds:

Contrary to the Plaintiff’s allegations, the Hung Family Real Estate Property is still habitable and subject to restoration, remodeling, and repair construction, under the laws of the State of Illinois, and as noted by the proposed plans submitted to the Village of Lombard and the Du Page County Board Commission by Gardenia C. Hung on record, during 2006-2007 from the Zees Group.
Demolition of the subject real estate property has not been legally authorized by the Illinois municipal code.
This cause of action is barred from execution for lack of foundation, speculation, and failure to state a public purpose for condemnation, demolition, and for injunctive relief.
Plaintiff is liable for Consumer Service Fraud, Conversion of Real Property, Abuse of the Legal Process, Malicious Prosecution, Obstruction of Justice, “Scienter”, i.e. Guilty Knowledge by Plaintiff as the Village of Lombard et al., All Employees, about the false representation of the Lombard Historical Brick Bungalow at 502 S. Westmore Avenue owned by the Hung Family, and omission of material fact and key evidence leading to all the damages, losses, and disrepair to real property owned by Gardenia C. Hung and Robert S. Hung, as Trustees, under the terms and provisions of the Roberto Hung Supplemental Care Trust, dated on the 3rd day of June 1997. This Lombard Historical Brick Bungalow is not a dangerous, unsafe building to the community in the Village of Lombard.
Pursuant to Supreme Court Rule 137, Defendants hereby petition the Motion to Accept Attorney’s Fees under §10a(c) of the Consumer Fraud Act, 815 ILCS 505/1 et seq. in the sum of $33,725.41US for reimbursement of all court fees, costs, and out-of-pocket expenses for payment by Plaintiff.

Please take notice that to date, in 2007, the Village of Lombard as Plaintiff has been abusive, unreasonable, non-responsive, and continues to act in “Bad Faith” towards the proposed restoration of this Lombard Historical Brick Bungalow owned by the Hung Family since 1993. Instead of approving financial support and facilitating construction options and services proposed by Gardenia C. Hung, Plaintiff initiated condemnation and court proceedings for Demolition and for Injunctive Relief without foundation, based on speculation, vested interests for demolition action “without stating a public purpose for this condemnation and demolition” of the same Lombard Historical Brick Bungalow proposed for restoration during 2007, 2008, and 2009.

Thus, the Village of Lombard denies homeownership rights to repair, restore, and remodel the same subject property which the Plaintiff, et al., All Employees, have targeted for damages, losses, and disrepair in conversion, as an access to crime, under the municipal pretense of providing residential services by utilities operators, police surveillance, fire prevention, community services, etc. For the record, the Village of Lombard has been destroying this subject real estate property annually by approving unauthorized services, trespassing, and criminal activity without the consent of the Hung Family. Plaintiff shows “Bad Faith”, Prejudice, and Discrimination towards this Lombard Historical Brick Bungalow owned by the Hung Family in Du Page County, Illinois, United States of America.

For the record, the Village of Lombard is denying the “bundle of legal rights of homeownership” to the Hung Family which are included in the ownership of real estate in Lombard as noted by the Hung Family and the late Mr. Roberto Hung, J.D. In other words, the Hung Family is a consumer as a purchaser of historical real estate in Lombard who has bought the rights of ownership from the former seller, Debra Sekrecki. The bundle of legal rights of homeownership include the following:
the right of possession;
the right to control the property within the framework of the law;
the right to enjoyment;
the right to exclusion (to keep others from entering or using the property);
and the right of disposition (to sell, will, transfer or otherwise dispose or encumber the property)

Consequently, Plaintiff has “defrauded” the real estate investment of the late Mr. Roberto Hung and Family by direct cause of action through all the damages, losses, and disrepair to the subject real property from 1993 through 2007. Now, fourteen (14) years after the purchase of the Lombard Historical Brick Bungalow, and the murder of the late Mr. Roberto Hung, the Village of Lombard presents legal action for condemnation, demolition, and for injunctive relief without declaring a public purpose for the proceeding. For the record, the Village of Lombard abuses the targeted property and all the Hung Family members by denying homeownership and property rights protected under federal and state constitutions, as well as by statutory provisions and by the precedents of the common law. The Constitution of the United States and the State of Illinois prohibits the taking of private property without just “payment compensation”, which must be paid to the Hung Family as homeowners, at a fair market value to be considered by the owner.

The Village of Lombard is subject to Consumer Service Fraud in Lombard real estate, breach of the Fair Housing Partnership Resolution Contract, and Real Estate Liability for Lombard old houses.

Plaintiff intentionally misrepresents material fact for real estate in such a way as to harm or take advantage of the Defendants as Lombard homeowners and consumers. That includes not only making false statements about the Lombard Historical Brick Bungalow, but also concealing or failing to disclose important facts of evidence from the past, about the subject property purchased by the late Mr. Roberto Hung with cash pension funds and by Gardenia C. Hung, his eldest daughter in the Village of Lombard, Du Page County, Illinois, U.S.A.

In this legal “Action in Trover” for conversion of real property, the Village of Lombard is liable for Negligence Per Se in the misrepresentation of material facts of evidence lading to vested interests in the condemnation, demolition, and for injuctive relief without a public purpose, or without just cash payment compensation, or the acknowledgment and inclusion of Gardenia C. Hung as a legal homeowner resident, taxpayer in Lombard.

As citizens of the United States of America, Defendants have constitutional rights against the abuse and conversion of the subject real estate property and for the protection granted to all Lombard resident homeowners and taxpayers in Du Page County, Illinois.

By law, failure to comply with Fair Housing laws by Plaintiff as the Village of Lombard, et al., may be a civil or criminal violations and constitutes grounds for disciplinary actions against the Village of Lombard as an Illinois municipal corporation, and all its employees, affiliates, associates, and investors for consumer service fraud, breach of the Fair Housing Partnership Resolution Contract, and real estate liability for Lombard old houses. In addition, the Fair Housing Act prohibits discrimination on the basis of race, color, religion, sex, handicap, family status or national origin.

For the record, Gardenia C. Hung has filed a complaint for abuse of human rights in housing under the Illinois Human Rights Act for Protections in Housing under the Law, enforced by the Illinois Department of Human Rights which is dedicated to protecting Illinois residents from discrimination in housing and abuse by the Village of Lombard and the Police Department in District 5. The Illinois Human Rights Act allows persons to choose where to live and enjoy the use of the facilities without intimidation or discrimination.

In addition, Gardenia C. Hung has filed (4) complaints for Lombard housing discrimination with HUD since June, July, and August 2007, as No.237371 against the Village of Lombard and the neighbors, John and Eva Carpenter, sons, at 506 S. Westmore-Meyers Road , and local real estate operatives, to include other accomplices, such as Keith Steiskal, Chris Haneghan, McCall at the Water Department, Robert G. Meyers, Linda Pieczynski, Raymond Byrne at the Lombard Police Department for District 5, as well as the Lombard Board of Trustees and Howard C. Jablecki for the Law Offices of Klein, Thorpe, and Jenkins, Ltd.

Please take notice that I have provided the basis for the HUD Fair Housing Complaint on legal grounds for discrimination, harassment, heinous/hate crimes, annoyance, profiling, unreasonable disturbance, and “private nuisance” caused by the Village of Lombard, and others, as follow for:
1. Threats of condemnation, demolition, and interference with the Hung Family’s real estate property by the Village of Lombard
2. Refusal to allow reasonable disaster construction repairs, remodeling, rehabilitation to the Hung Family real estate property which has been damaged by the Village of Lombard, Police Department, John and Eva Carpenter, sons, and other cable TV and utility telephone service providers, trespassers, vandals, accomplices, and repeat offenders as an “access to crime”, trespass, and conversion of the same Lombard Historical Bungalow into a distressed real estate property. The Village of Lombard is liable and subject for prosecution in this HUD complaint, in order to compensate the Illinois resident homeowner and taxpayer, Gardenia C. Hung, for discrimination and bias violence.
3. This complaint for discrimination by the Village of Lombard documents that Lombard provides different housing services which are unauthorized by Gardenia C. Hung, as legal resident homeowner and executor for the Estate of Mr. Roberto Hung, J.D. Unsolicited cable TV providers have slid on the roof and slipped off the roof tiles by the front door, falling and breaking the spinal cord with permanent injury, disability, and death—without the consent or approval for service by Gardenia C. Hung and the late Mr. Roberto Hung, J.D., or Nathan S. Wittler, ex-husband, or Robert S. Hung, son, or Mrs. G. Fong Ramos, mother.
4. The Village of Lombard refuses to mail correspondence from the Lombard Police Department and Linda Pieczynski who also refuses to answer, respond or reply to any U.S. mail, electronic mail, personal delivery of messages or answer Gardenia C. Hung as a Lombard resident homeowner and taxpayer in Du Page County, Illinois, United States of America.
5. The Village of Lombard fails to comply with the Fair Housing Act and Amendments and becomes subject for prosecution for harassing, coercing, intimidating and/or interfering with real estate property rights which are being denied to Gardenia C. Hung under threats of condemnation, demolition, and injunctive relief. The Village of Lombard is liable for unethical real estate practices set up for “panic selling” or “blockbusting” through deliberate real estate property damages and losses to the Hung Family Real Estate, Lombard Historical Bungalow, in order to force the sale of the distressed Lombard Bungalow converted by trespass into disaster and vandalized property as an “access to crime” arranged by the Village of Lombard Police Department with John and Eva Carpenter, sons and accomplices, in Du Page County, Illinois, USA.
Gardenia C. Hung, as a Defendant, is a victim of crime, discrimination, heinous/hate crimes, profiling, harassment, and private nuisance, has been reporting these real estate property attacks to U.S. Homeland Security, the Federal Bureau of Investigation, the Illinois Sheriffs Association, the Illinois Terrorist Task Force, the Illinois Human Rights Commission, and other law enforcement agencies, and humanitarian groups, from 1993 to the present, in 2007. For the record, in the Village of Lombard, examples of threats, coercion, and intimidation include the following:
· Bullet hole on upper glass window pane in the living room
· Broken fence posts, splintered wood caused by trespassers jumping over the adjoining fence by the Carpenters’ driveway at 506 S. Westmore-Meyers Road in Lombard, Illinois, 60148-3028 , Du Page County, USA
· Torched-burning front door varnish with fire, as well as back porch door, and tool shed garden door
· Chemicals burning grass lawn
· Cracked, broken light fixtures on ceilings
· Bursting Lombard water plumbing pipes due to ungauged water pressure; leaking ducts and canals with fissures in the County of Du Page, Illinois, USA
· Broken Maple Tree Branch over the Carpenters’ driveway caused by the Carpenters ABF Truck 88938 on July 11, 2007, at 8H30AM, U.S. DOT 082866, ABF Freight System, Inc.- Trailer 88938, Semi-Truck. On Wednesday, August 8, 2007, the Carpenters’ son and John Carpenter arranged to have the broken Maple Tree branch through their back gate and Robyn/Jennifer’s driveway, carried out to leave the large Maple wooden branch on the side lawn, on Washington Blvd., leaving the same to obstruct pedestrians walking path, on the sidewalk.

Other examples of discrimination in Fair Housing Practices by the Village of Lombard have been provided for heinous/hate crimes, harassment, unreasonable disturbance, annoyance, “private nuisance” experienced by Gardenia C. Hung and Family at 502 S. Westmore-Meyers Road, Lombard, Illinois 60148-3028, as victims of crime, profiling, bias violence, cruelty, and refusal to provide Lombard services to Illinois resident homeowners, taxpayers, and U.S. citizens.

For the record, let it be known that Gardenia C. Hung as a victim of crime and discrimination, bias violence, heinous hate crimes in the Village of Lombard, has never received any compensation or financial cash restitution for damages and losses to the Hung Family real estate property under the Fair Housing Act for trespass and conversion, refusal to make reasonable construction repairs given access to crime, trespass, failure to provide residential homeowner services, discriminatory property appraisals, harassment, coercion, intimidation or interference with Fair Housing Homeownership rights in the Village of Lombard by the Town Hall, the Lombard Police Department, the Fire Department Bureau of Inspectional Services, John and Eva Carpenter, sons, friends, and associates, in payment, as remedy or relief for criminal, discriminatory activities arranged against the Hung Family real property.

For reference, Gardenia C. Hung as Defendant has also filed consumer service complaints with the Federal Trade Commission Consumer Service Division, the Illinois Commerce Commission, and the Illinois Attorney General, Consumer Service Department, on record for consumer service fraud.

Defendants continue to assert and demand their legal rights as Lombard resident homeowners to recover all damages and losses for the misuse of the Hung Family Real Estate Property, which has been abused illegally, and criminally converted to distressed Lombard property by the Plaintiff who has authorized and arranged access to crime from the Lombard Police Department, the Fire Department Bureau of Inspectional Services, John and Eva Carpenter, as well as other accomplices in Du Page County, Illinois, USA.

Since 1993, Defendants have been restoring the Hung Family Real Estate Property owned by the late Mr. Roberto Hung and managed by Gardenia C. Hung and Robert S. Hung as Trustees for the Estate of Roberto Hung Supplemental Care Trust.

Defendants have been reporting and presenting all the damages and losses for restoration and remodeling construction to the Plaintiff regularly. The Village of Lombard has been Negligent and Non-Responsive to the required needs and services for construction caused by unauthorized access entry from the Lombard Police Department with Schlage Master Lock break-ins to trespass, burglarize, and steal from the Hung Family real property, assets, clothing, personal belongings, professional equipment, office supplies, etc.

Defendants hereby petition to redress grievances for all damages, losses, and disrepair caused directly by the Village of Lombard, an Illinois municipal corporation, subject to consumer service fraud by utility service operators, accomplices, and unauthorized trespassers. The Village of Lombard as subject of investigation for breach of duty, owes the Defendants the duty and service to repair at cost the same Lombard Historical Brick Bungalow owned by the Hung Family for the last fourteen (14) years, due to Consumer Service Fraud, Breach of the Fair Housing Partnership Resolution Act, Real Estate Liability for Lombard Old Houses and on legal grounds for “Action in Trover”, criminal “Conversion” of Real Property.

Consequently, the Defendants demand full restitution and cash compensation equal to the value of this Lombard property and all the damages and losses incurred by the Defendants since 1993, and during 2004, 2005, 2006, and 2007, for the last fourteen (14) years, inclusive, in the sum of two million dollars, $2,000,000, for the following Casualties and Thefts, 2006 IRS Form 4684: Property A, Lombard Brick Bungalow, 3-Level house at 502 S. Westmore Avenue, in Lombard, Illinois, acquired during September 1996, $900,000; Property B, T-Mobile Motorola RAZOR V3, Camera Telephone, acquired at Yorktown Center on December 20, 2005, in the sum of $300; Property C, 2003 Derbi Boulevard 150 CC Motorcycle, acquired on June 11, 2003, currently disabled in disrepair at Champion Cycle Center, Inc., 3625 N. Western Avenue, Chicago, Illinois 60618, in the sum of $16,071.35. In addition to damages and losses to eight (8) automobiles owned by the late Mr. Roberto Hung, Ms.Gardenia C. Hung, and Mr. Nathan S. Wittler: Buick Montecarlo, Ford Escort Station Wagon, Ford Mustang Hatchback, Chrysler Capri Sports, Geo Tracker, Nissan 200SX, Mitsubishi Galant, in the sum of $100,000.

Plaintiff’s allegations are not well grounded in fact to justify condemnation, demolition, and injunctive relief without stating a public purpose. This Lombard Historical Brick Bungalow is not a dangerous, unsafe building to the community in the Village of Lombard.

In conclusion, Defendants have stated and presented valid and legal arguments for restoration, remodeling, and repair construction of this Lombard Historical Brick Bungalow owned by the Hung Family, at the expense of the Plaintiff, known as the Village of Lombard, an Illinois municipal corporation, et al., all employees, as a direct cause of action.

Whereby, Defendants pray for remedy and relief to sustain this Combined §2-615 Motion to Strike and §2-619 Motion to Dismiss the Verified Complaint for Demolition and for Injunctive Relief pursuant to Supreme Court Rule 137, for lack of foundation, improper character reference, and failure to state a public purpose for demolition and for injunctive relief, on legal grounds for Consumer Service Fraud, Conversion of Real Property, Abuse of the Legal Process, Malicious Prosecution, Obstruction of Justice, “Scienter”, i.e. Guilty Knowledge by Plaintiff as the Village of Lombard et al., All Employees, about the false representation of the Lombard Historical Brick Bungalow at 502 S. Westmore Avenue owned by the Hung Family, and omission of material fact and key evidence leading to all the damages, losses, and disrepair to real property owned by Gardenia C. Hung and Robert S. Hung, as Trustees, under the terms and provisions of the Roberto Hung Supplemental Care Trust.
WHEREFORE, DEFENDANTS, GARDENIA C. HUNG, ROBERT S. HUNG, ET AL. PRAY TO SUSTAIN THIS Combined §2-615 Motion to Strike and §2-619 Motion to Dismiss the Verified Complaint for Demolition and for Injunctive Relief pursuant to Supreme Court Rule 137, FOR LACK OF FOUNDATION, FAILURE TO STATE A PUBLIC PURSPOSE, WRONGFUL CHARGES AND MISDEMEANORS AGAINST THE VILLAGE OF LOMBARD ET AL., IN THIS LEGAL “ACTION IN TROVER”, WITH PREJUDICE, WITHOUT LEAVE TO AMEND; AND THAT ALL DAMAGES AND LOSSES, AS WELL AS LEGAL COURT EXPENSES, COURT COSTS, IN THE SUM OF $33,725. 41US, BE COMPENSATED AND REIMBURSED TO THE DEFENDANTS FROM 1993 THROUGH 2007, FOR THE LAST (14) FOURTEEN YEARS, SINCE PLAINTIFF, THE VILLAGE OF LOMBARD, ET AL. INITIATED THE DIRECT CAUSE OF DISASTER AND CRIMINAL ACTION FOR CONSTRUCTION, DAMAGES, AND LOSSES AGAINST THE LOMBARD REAL ESTATE PROPERTY AT 502 S. WESTMORE AVENUE & WASHINGTON BOULEVARD OWNED BY THE HUNG FAMILY FROM 1993 TO THE PRESENT, IN 2007, PURSUANT TO §10a(c) of the Consumer Fraud Act, 815 ILCS 505/1 et seq., ILCS 720, 5-31, PRESUMPTION OF INNOCENCE AND PROOF OF GUILT, UNDER THE HATE CRIMES LOCAL LAW ENFORCEMENT ENHANCEMENT ACT, THE VICTIMS OF CRIME ACT, THE ILLINOIS HUMAN RIGHTS ACT FOR PROTECTIONS IN HOUSING UNDER THE LAW, U.S. DEPARTMENT OF HOUSING AND URBAN RENEWAL (HUD); 735 ILCS 5/ART. II, ET SEQ. CIVIL PRACTICE LAW AND THE RULES OF THE SUPREME COURT IN THE STATE OF ILLINOIS AND UNDER THE CONSTITUTION OF THE UNITED STATES, AS FOLLOWS FOR:
(1) GENERAL DAMAGES AND LOSSES IN THE SUM OF $2,000,OOO, TWO MILLION DOLLARS, TO INCLUDE, ESTATE RECONSTRUCTION, REHABILITATION, AND REMODELING ESTIMATEED AT A COST OF $123,200, AS NOTED IN CONTRACT C, IN CONFORMITY TO PROOF;
(2) OTHER SPECIAL DISASTER CONSTRUCTION REPAIR DAMAGES AND LOSSES IN THE SUM OF $92,480, AS EVIDENCED IN CONTRACT B, IN COMFORMITY TO PROOF.
(3) AND DEFENDANTS PRO SE ALSO PRAY FOR THE COMPENSATION OF SUCH OTHER AND ADDITIONAL DISASTER RESTORATION CONSTRUCTION DAMAGES AND LOSSES IN THE SUM OF $66,150, ITEMIZED IN CONTRACT A, IN CONFORMITY TO PROOF, AND FOR FURTHER REMEDY AND RELIEF AS THE COURT DEEMS JUST, FAIR, EQUITABLE, AND PROPER IN THIS CAUSE OF ACTION FOR DISASTER RESTORATION CONSTRUCTION CAUSED DIRECTLY BY PLAINTIFF, THE CITY OF LOMBARD ET AL., IN THE TOTAL SUM OF $281,830.
(4) WHEREBY, DEFENDANTS PRAY FOR ADDITIONAL FINANCIAL REMEDY AND MONETARY RELIEF TO BE COMPENSATED UNDER U.S. LEGISLATION BY THE PLAINTIFF, FROM 1993 TO DATE IN 2007, FOR THE LAST (14) FOURTEEN YEARS, IN THE SUM OF $2,000,000, TWO MILLION DOLLARS, IN ORDER TO SUPPORT THE DEFENDANTS COMPULSORY COUNTERCLAIMS SETOFF/OFFSET AGAINST THE VERIFIED COMPLAINT FOR DEMOLITION AND FOR INJUNCTIVE RELIEF, FOR ALL DAMAGES AND LOSSES CAUSED AND ARRANGED BY THE VILLAGE OF LOMBARD ET AL., DUE TO “CRIMINAL CONVERSION” OF THE HUNG FAMILY REAL ESTATE PROPERTY AS AN ACCESS TO CRIMINAL ACTIVITY IN LOMBARD, DU PAGE COUNTY, ILLINOIS, USA.
Respectfully Submitted and Dated this October 15th, 2007
________________________________________
(Reserved Signature)
Gardenia C. Hung, M.A. for the Defendants
On behalf of the Hung Family Estate
502 S. Westmore-Meyers Road
Lombard, IL 60148-3028 USA

Verification

Under penalties as provided by law pursuant to Section 1-109 of the Illinois Code of Civil Procedure, the undersigned certifies that the statements set forth in this instrument are true and correct, to the best of my ability, so help me God.

Date: October 15, 2007 Signed by:____________________________________ Gardenia C. Hung, M.A.


State of Illinois United States of America County of Du Page
In the 18th Judicial Circuit Court
Village of Lombard,
Plaintiff,
vs.
Gardenia C. Hung and Robert S. Hung, Trustees of the Trust Agreement Designated as the Roberto Hung Supplemental Care Trust, Jeffrey D. Papendick, a tax-purchaser, and non-record claimants and unknown users
Defendants
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Case No.:2007CH001284 Consolidated
Case No.:2006OV005982, LO25448NT;
Case No.:2006OV005983, LO25449NT;
Case No.:2006OV004446, LO12418NT; LO12419NT
NOTICE OF FILING
DEFENDANTS’ MOTION FOR RECONSIDERATION TO DISMISS AND STRIKE THE VERIFIED COMPLAINT WITH A SECOND OBJECTION TO THE SAME PLAINTIFF’S VERIFIED COMPLAINT FOR DEMOLITION AND FOR INJUNCTIVE RELIEF

Attn. Judge Ken Popejoy, Chancery Division To:Circuit Court Clerk
18th Judicial Circuit Court Mr. Chris Kachiroubas
505 North County Farm Road 505 North County Farm Road
Wheaton, Illinois 60189-0707 USA Wheaton, IL 60187 USA
CC: Law Firm of Klein, Thorpe and Jenkins, Ltd.
Mr. Howard C. Jablecki, et al. Attn. Mr. Joseph E. Birkett
Attorneys for the Plaintiff Illinois State’s Attorney
20 North Wacker Drive, Suite 1660, 503 North County Farm Road
Chicago, Illinois 60606-2903, USA Wheaton, Illinois 60187 USA
Tel. 312-984-6400; To Whom It May Concern

DEFENDANTS’ MOTION FOR RECONSIDERATION TO DISMISS AND STRIKE THE VERIFIED COMPLAINT WITH A SECOND OBJECTION TO THE SAME PLAINTIFF’S VERIFIED COMPLAINT FOR DEMOLITION AND FOR INJUNCTIVE RELIEF

Now comes Gardenia C. Hung, as Defendant Pro Se, to reinstate all of the Defendants’ responses and supporting arguments in this Motion for Reconsideration to Dismiss and Strike the Verified Complaint with a Second Objection to the same Plaintiff’s Verified Complaint for Demolition and for Injunctive Relief, on legal constitutional grounds upholding the Illinois homeowner’s right to repair Lombard real estate property pursuant to the Constitution of the United States of America, the State of Illinois Constitution, the Bill of Rights, Victims of Crime Act, Illinois Human Rights Act, Housing and Urban Development Act, Consumer Fraud and Deceptive Business Practices Act, 815 ILCS 505/1 et seq.; 815 ILCS 505/2 et seq., Unlawful Prohibited Practices; 815 ILCS 510/1 et seq., Uniform Deceptive Trade Practices Act; Federal Trade Commission Act, 15 USC §45 et seq.
Counsel Howard C. Jablecki’s response for the Plaintiff disregards U.S. constitutional issues in this legal action, since in the State of Illinois, Lombard homeowners have constitutional rights to repair Lombard Historical real estate property in the County of Du Page, United States of America. Mr. Jablecki is subject to perjury upon stating that, “In this case, Defendant Hung has not provided adequate grounds for this court to reconsider its denial of the motion to dismiss…” “Defendant Hung has alleged no newly discovered facts, no change in the law, and no error in this Court’s application of the law aside from its use of “fancy legal terms”. (Village of Lombard v. Gardenia C. Hung and Robert S. Hung, et al., Plaintiff’s Response to Defendant’s Motion for Reconsideration of Motion to Dismiss, Page 3).
For the record, Defendants petition to reinstate all legally filed evidence, as follow:
1. Defendants’ Response/Answer to Summons. Counterpoint: At Issue Legal Memorandum in Opposition to the Verified Complaint for Demolition and for Injunctive Relief to Support the Defendants’ Compulsory Counterclaims to Setoff/Offset the Verified Complaint from Plaintiff on legal grounds for “action in trover”, criminal conversion of property, consumer service fraud, breach of the Fair Housing Partnership Resolution Contract and Real Estate Liability for Lombard Old Houses.
2. Affidavit of Damages in Excess of $50,000.
3. Amended Defendants’ Response/Answer to Summons. Counterpoint: At Issue Legal Memorandum in Opposition to the Verified Complaint for Demolition and for Injunctive Relief to Support the Defendants’ Compulsory Counterclaims in the sum of $2,000,000, two million, to Setoff/Offset the Verified Complaint from Plaintiff on legal grounds for “action in trover”, criminal conversion of property, consumer service fraud, breach of the Fair Housing Partnership Resolution Contract and Real Estate Liability for Lombard Old Houses.
4. Abridged to 10 Pages, Defendants’ Response/Answer to Summons. Counterpoint: At Issue Legal Memorandum in Opposition to the Verified Complaint for Demolition and for Injunctive Relief.
5. Defendants’ Motion for Discovery, Exhibit A, to Petition Attorney’s Fees under §10(A)C of the Consumer Fraud Act for “action in trover”, in the sum of $32,497.41
6. Defendants’ Amended Petition, Exhibit B, in Motion to Accept All Legal Expenses in the sum of $33,725.41 for Reimbursement Pursuant to Supreme Court Rule 137 and §10(A)C of the Consumer Fraud Act, 815 ILCS 505/1 et seq.
7. Defendants’ Combined §2-615 Motion to Dismiss and §2-619 Motion to Strike the Verified Complaint for Demolition and for Injunctive Relief pursuant to Supreme Court Rule 137.
8. MOTION FOR DISCOVERY, EXHIBIT C, AS EVIDENCE FOR CONTRACTS A-1, B-1, AND C-1, AS PROOF OF PROPOSED PLANS FOR RESTORATION, REPAIR CONSTRUCTION, REMODELING, AND REHABILITATION IN ORDER TO BRING THE LOMBARD HISTORICAL BRICK BUNGALOW INTO COMPLIANCE WITH MUNICIPAL BUILDING CODE.
9. SUBPOENA REQUEST FOR PLAINTIFF TO PRODUCE ALL HOUSEHOLD KEYS
BELONGING TO DEFENDANTS, ET AL. AT 502 S. WESTMORE-MEYERS ROAD, LOMBARD, ILLINOIS 60148-3028, UNITED STATES OF AMERICA.
10. 1993-2007 DAMAGES AND LOSSES AT THE HUNG FAMILY REAL ESTATE AT
502 SOUTH WESTMORE-MEYERS ROAD, LOMBARD, DUPAGE COUNTY, ILLINOIS 60148-3028
MEMO OVERVIEW REPORT BY GARDENIA C. HUNG, M.A., DAUGHTER OF THE LATE MR.
ROBERT HUNG, J.D.
11. DEFENDANTS’ MOTION FOR OBJECTION TO THE VERIFIED COMPLAINT FOR DEMOLITION
AND FOR INJUCTIVE RELIEF.
12. DEFENDANTS’ MOTION FOR RECONSIDERATION TO DISMISS AND STRIKE THE VERIFIED
COMPLAINT WITH A SECOND OBJECTION TO THE SAME PLAINTIFF’S VERIFIED COMPLAINT
FOR DEMOLITION AND FOR INJUNCTIVE RELIEF.

Plaintiff’s response states improper opinions, contrary-to-fact statements, and fails to consider all of the newly discovered evidence presented and filed in conformity to proof before this court, along with all the supporting arguments reported by U.S. law enforcement agencies and the State of Illinois on behalf of the Defendants, included as a Second Objection to the Verified Complaint for Demolition and for Injunctive Relief.

Defendants hereby reinstate all the legal documentation and supporting arguments presented to date before this court, in this Motion for Reconsideration to Dismiss and Strike the Verified Complaint with a Second Objection to the same Plaintiff’s Verified Complaint for Demolition and for Injunctive Relief. For the record, Defendants have submitted into evidence as Exhibit C, Contracts A-1, B-1, and C-1, underwritten by ZSC INSURANCE RESTORATION SERVICE, LLC., P.O. Box 56553, Chicago, Illinois 60656-0553, ZeesGroup.com, in conformity to proof of the proposed plans for Restoration, Renovation, Repair Construction, Remodeling, and Rehabilitation presented during November 2006 and January 2007, by Gardenia C. Hung, in order to comply with the Village of Lombard Municipal Building Code Violations caused by the Plaintiff in this legal ‘action in trover’ and ‘conversion’ of the Lombard Historical Brick Bungalow owned by the Hung Family in Du Page County, Illinois, United States of America.
The Hung Family is seeking monetary compensation for Damages and Losses to include Contracts for Special Disaster Restoration Construction Repair Services in the sum of $281,830US contracted and underwritten by ZSC Insurance Restoration Services LLC for repair at the expense of the Village of Lombard Community and DuPage County.
Plaintiff’s Counsel Howard C. Jablecki presents false arguments based on improper opinions and hearsay, not well supported in fact to justify condemnation, demolition, and injunctive relief without affording to the Defendants the option to repair with due process and just payment in “cash” for compensation at a fair market value upon sale of the Lombard Historical Brick Bungalow owned by the Hung Family, under the Bill of Rights and the Constitution of the United States of America and the State of Illinois. Defendants as Lombard homeowners have the right to repair this Lombard Historical Brick Bungalow in Du Page County, Illinois, United States of America.
Counsel Howard C. Jablecki’s allegations for demolition and for injunctive relief do not state a public purpose or present specific plans for reuse of the Lombard Historical Brick Bungalow by the Village of Lombard, et al. The Verified Complaint fails to prove that the Lombard Historical Brick Bungalow is “Unfit for Human Habitation”, since the Hung Family has been Lombard resident homeowners since 1993 to date, in 2008, for the last 15 years now.
Consequently, Defendants have petitioned to redress grievances as victims of crime in the Village of Lombard, Du Page County, Illinois, based on constitutional grounds, as follow:
Section 11-31-1 of the Illinois Municipal Code (65 ILCS 5/11-31-1) pertaining to demolition by a municipality is unconstitutional because it does not allow the Defendants, as Lombard resident homeowners in Du Page County, Illinois, the right to repair the Lombard Historical Brick Bungalow at 502 S. Westmore-Meyers Road, owned by the Hung Family. In City of Aurora v. Meyer, 38 Ill. 2d. 131 (1967), the Supreme Court construed the statute as meaning that, “if the specific defects that render a building dangerous and unsafe ‘may readily be remedied by repair’, demolition should not be ordered without giving the owners a reasonable opportunity to make the repairs.” Furthermore, in the previous Supreme Court Rule 23 (166 Ill. 2d R. 23) order (Village of Lake Villa v. Stokovich, No. 2-00-0943 (2001), the Illinois Supreme Court in the exercise of its supervisory authority directed the presiding judge to vacate the judgment in the Circuit Court of Lake County ordering demolition and to address the Defendants that Section 11-31-1 is unconstitutional. Defendants assert that ordering demolition without giving a homeowner a reasonable time to repair her/his property without considering the cost constitutes an unlawful infringement upon rights of real estate ownership and/or a due process violation;
Section 11-31-1 constitutes an invalid delegation of legislative power in the Village of Lombard, Du Page County, Illinois, in the United States of America;
Plaintiff and Counsel, Howard C. Jablecki et al. are abusing the Court’s discretion in “scienter” with guilty knowledge, as accomplices for direct cause of action for Damages and Losses to the Lombard Historical Brick Bungalow, as noted on record, and by non-disclosure and/or exclusion of key evidence leading to the current damages, losses, and disrepair of the subject property;
This Court is abusing the Defendants, as Lombard resident homeowners, by admitting the Plaintiff’s speculation as improper opinions, not well grounded nor supported by facts of evidence for restoration and preservation of the Lombard Historical Brick Bungalow, already on record to comply with provisions of the municipal building code;
Keith Steiskal’s finding on May 5, 2006 as stated, does not validate that the Lombard Historical Brick Bungalow is dangerous and unsafe, requiring demolition under Section 11-31-1. Keith Steiskal’s “improper opinions and hearsay” under Section 11-31-1 is against the manifested weight of evidence and the Defendants’ proposed restoration plans which have sought alternative remedy and relief in the form of bringing the subject property into compliance;
This Court has erred in denying the Defendants’ Combined §2-615 Motion to Dismiss and §2-619 Motion to Strike the Verified Complaint for Demolition and for Injunctive Relief, based on the presiding judge’s “improper opinions and hearsay” about “improper language” and “fancy legal terms”, abuse of the legal process, malicious prosecution, “scienter”, negligence per se, consumer service fraud, and obstruction of justice;
The municipal ordinance violations alleged in Counts I, II, and II for Injunctive Relief do not apply to the subject property, nor are these allegations supported or warranted by existing laws under the Constitution of the United States of America, the State of Illinois Constitution, Bill of Rights, Victims of Crime Act, Human Rights Act, Housing and Urban Development Act, Consumer Fraud and Deceptive Business Practices Act, 815 ILCS 505/1 et seq., 815 ILCS 505/2 et seq., Unlawful Prohibited Practices; 815 ILCS 510/1 et seq., Uniform Deceptive Trade Practices Act; Federal Trade Commission Act, 15 USC §45 et seq., and
The Court’s order on Monday, November 29, 2007 by Judge Kenneth Popejoy, based on “improper use of language and fancy legal terms” is still so deficient as to require a Judicial Review for Reconsideration pursuant to legal, constitutional grounds under the Constitution of the United States, and the State of Illinois Bill of Rights.
Defendants hereby present a Second Objection to the Verified Complaint for Demolition and for Injunctive Relief in this petition to redress grievances as victims of crime. Please take notice that assertion by the Defendants of Lombard homeowners’ right to repair is protected under the fifth and fourteenth amendments to the U.S. Constitution and Sections 2 and 15 of the Bill of Rights of the Illinois Constitution (Ill. Const. 1979, art. I, §§2,15) which upon review supports the constitutionality of a statute de novo (Miller v. Rosenberg, 196 Ill. 2d 50, 57 (2001).
Wherefore, Defendants reinstate Combined §2-615 Motion to Dismiss and §2-619 Motion to Strike the Verified Complaint for Demolition and for Injunctive Relief, pursuant to Supreme Court Rule 137, as noted.
For the record, Plaintiff as the Village of Lombard et al. has “defrauded”
the real estate investment of the late Mr. Roberto Hung, and daughter, Gardenia C. Hung, et al. by direct cause of action in conversion of the Lombard Historical Brick Bungalow into a distressed real estate property as an “access to crime” in the Village of Lombard, Du Page County, Illinois, through conspiracy, heinous/hate crimes, damages, losses, disrepair, and personal injury, to include the murder of the late Mr. Roberto Hung. Consequently, Plaintiff owes the Defendants the obligation, the duty, and service to repair the subject property, damaged by Negligence Per Se and breach of duty, on legal grounds for “action in trover”, criminal “conversion” of real property owned by Gardenia C. Hung, to include consumer service fraud.
For the record, as noted on the Defendants’ pleadings filed in this court, the Village of Lombard and DuPage County, have contributed directly and indirectly to the extensive structural damages and losses to the Hung Family real estate property at 502 S. Westmore Avenue and Washington Boulevard in Lombard, DuPage County, Illinois, U.S.A.
Plaintiff’s allegations are not well supported in fact to justify condemnation, demolition, and injunctive relief without stating a public purpose or presenting specific plans for the reuse of the property. Thus, the Verified Complaint is incomplete, inconclusive, and invalid. The subject property owned by the Hung Family is not a dangerous, unsafe building nor a health hazard or safety risk to the community.
In conclusion, Defendants have reinstated and re-submitted a Second Amended Response to the Verified Complaint in this Motion for Reconsideration to Dismiss the Verified Complaint with a Second Objection to Demolition and Injunctive Relief, thus presenting valid constitutional arguments for historical preservation and restoration, remodeling, and repair construction of the Lombard Historical Brick Bungalow owned by the Hung Family, at the expense of the Plaintiff, also known as the Village of Lombard, et al., All Employees, accountable and liable for all damages, losses, and disrepair to the subject property as a direct cause of action, in access to crime by the Lombard Police Department.
WHEREBY, Defendants pray for remedy and relief to sustain this Motion as a Second Objection to the Verified Complaint for Demolition and for Injunctive Relief, based upon constitutional grounds, as noted, with the proposed plans for restoration and historical preservation of the Lombard Historical Brick Bungalow owned by the Hung Family, at the cost and expense of the Plaintiff.
WHEREFORE, Defendants also pray to sustain Combined §2-615 Motion to Dismiss and §2-619 Motion to Strike the Verified Complaint for Demolition and for Injunctive Relief pursuant to Supreme Court Rule 137, upon judicial review for reconsideration with justice, equity, and fairness, under God. Defendants petition for additional relief and financial remedy in affording the Defendants the right to repair Illinois real estate property, as follow for:
(1) GENERAL DAMAGES AND LOSSES IN THE SUM OF $123,200, AS NOTED IN CONTRACT C, IN CONFORMITY TO PROOF;
(2) OTHER SPECIAL DISASTER CONSTRUCTION REPAIR DAMAGES AND LOSSES IN THE SUM OF $92,480, AS EVIDENCED IN CONTRACT B, IN COMFORMITY TO PROOF.
(3) AND DEFENDANTS PRO SE ALSO PRAY FOR THE COMPENSATION OF SUCH OTHER AND ADDITIONAL DISASTER RESTORATION CONSTRUCTION DAMAGES AND LOSSES IN THE SUM OF $66,150, ITEMIZED IN CONTRACT A, IN CONFORMITY TO PROOF, AND FOR FURTHER REMEDY AND RELIEF AS THE COURT DEEMS JUST, FAIR, EQUITABLE, AND PROPER IN THIS CAUSE OF ACTION FOR DISASTER RESTORATION CONSTRUCTION CAUSED DIRECTLY BY PLAINTIFF, THE CITY OF LOMBARD ET AL., IN THE TOTAL SUM OF $281,830.
Furthermore, Defendants also pray for any other remedy and relief provided by this court with due process and just payment in “cash” for compensation at a fair market value upon sale of the Lombard Historical Brick Bungalow owned by the Hung Family; as this Court deems just, fair, and equitable due to family tragedy, hardship, and poverty as victims of crime, under the Constitution of the United States of America and the State of Illinois Constitution, Bill of Rights, with justice, under God.

Respectfully submitted by,

Gardenia C. Hung, M.A., PRO SE
502 S. Westmore-Meyers Road
Lombard, Illinois 60148-3028
United States of America

VERIFICATION

Under penalties as provided by law pursuant to Section 1-109 of the Illinois Code of Civil Procedure, the undersigned certifies that the statements set forth in this instrument are true and correct, to the best of my ability, so help me God.

Dated on January 25, 2008,
Signed by:

_________________________ Gardenia C. Hung, M.A.
In the County of Du Page, State of Illinois, United States of America


Attn. Mr. Rocco J. Claps, Director, Illinois Department of Human Rights
Governor’s Commission on Discrimination and Hate Crimes
James R. Thompson Center
100 West Randolph Street, Suite 10-100

Illinois Department of Human Rights
222. S. College, Room 101A
Springfield, Illinois 62704 USA
http://www.state.il.us/dhr

TO WHOM IT MAY CONCERN

RE: DuPage County , Village of Lombard , Illinois , Eighteenth Judicial Circuit Court, Wheaton , Case No.2007CH001284, Village of Lombard , et al. vs. Gardenia C. Hung and Robert S. Hung as Trustee of the Trust Agreement designated as the Roberto Hung Supplemental Care Trust, Jeffrey D. Papendick, a tax purchaser, and non-record claimants and unknown owners.
Illinois Sheriffs’ Summons Served on Thursday, May 31, 2007, 5H30PM
Gardenia C. Hung, M.A. Filing Charges on Violation of Human Rights in Lombard, DuPage County , Illinois , USA . Lombard Resident and U.S. Citizen at 502 S. Westmore Avenue , Lombard , IL 60148-3028 USA

Dear Illinois Department of Human Rights, Illinois Commission on Human Rights, Illinois , U.S.A. , To Whom It May Concern:

My name is Gardenia C. Hung, M.A. I am a Lombard resident homeowner, taxpayer in Du Page County, and U.S. citizen. Once again, I am writing to you in order to complain about violations of the Illinois Human Rights Act, under Housing Illinois law, the Hate Crimes Local Law Enforcement Act, and the Victims of Crimes Act by the Village of Lombard, Keith Steiskal, Bureau of Inspectional Services, Lombard Fire Department, and the Lombard Police Department due to deliberate Hate Crimes, Discrimination, Heinous Terrorist Acts planned purposely and authorized by the Village of Lombard and the Du Page County community against Gardenia C. Hung and Robert S. Hung, as well as the Hung Family Real Estate Property in Lombard, 502 S. Westmore Avenue and Washington Blvd. in Du Page County, Illinois, USA. Keith Steiskal, from the Lombard Fire Department Bureau of Inspectional Services has filed and issued Du Page County Court Summons on Count 1, Demolition of Dangerous and Unsafe Building under a “Not Approved” Notice, unsigned, unstamped by the Village of Lombard, and posted the door of the same real estate property on April 6, 2007, without due notice before Easter Sunday during 2007.

Please take notice, for the record, that since Fall 2006, I, Gardenia C. Hung, have been planning and arranging for the Restoration, Remodeling, and Repair of the Hung Family Real Estate Property in Lombard, as evidenced by the Du Page County court filings, construction plans, estimates, damages and losses reported and submitted under Illinois and U.S. laws to the Village of Lombard, the State of Illinois, and U.S. federal law enforcement agencies under, U.S. Internal Revenue Service, U.S. Homeland Security and the U.S. Department of Justice. To date, the Village of Lombard , et al. are to blame for unauthorized access entries into the Hung Family Real Estate Property in Lombard, as well as trespassing, hate crimes of terrorism, vandalism, and all criminal acts surrounding this Lombard real estate property at 502 S. Westmore Avenue and Washington Blvd. in Du Page County, Illinois; all the time, since 1993, while Gardenia C. Hung, the late Mr. Roberto Hung, father, Nathan S. Wittler, Robert S. Hung, and Mrs. G. Fong Ramos have not been present at home.

I am complaining as a Victim of Crime against the Village of Lombard and Keith Steiskal, from the Lombard Fire Department, in particular for violations against the Illinois Human Rights Act and Housing Act because they want Gardenia C. Hung to vacate the property, in order to condemn and demolish a Lombard Bungalow house that has been set for Restoration, Remodeling, Rehabilitation, and Construction since Fall 2006 and during 2007. I am asking for your assistance, support, and intervention as a Victim of Crime in Lombard, DuPage County , Illinois , United States of America under the State of Illinois and the U.S. Constitution.
Sincerely Yours,

Gardenia C. Hung, M.A.,B.A.
502 S. Westmore-Meyers Road
Lombard, Illinois 60148-3028
United States of America

My name is Gardenia C. Hung. My human rights and constitutional rights in the State of Illinois have been violated in Lombard, DuPage County, Illinois as a Lombard resident and U.S. citizen residing at 502 S. Westmore Avenue, Lombard, IL 60148-3028 USA. The following is an outline narrative report describing incidents which have violated my human rights and constitutional rights in Lombard, DuPage County , Illinois .

Village of Lombard , Town Hall Lombard Police Department
255 E. Wilson Avenue Lombard Fire Department
Lombard , IL 60148-3028 USA Lombard Bureau of Inspectional Services

BACKGROUND

I. For the record, Gardenia C. Hung has already reported this unfair and unjust incident to Rev. Herb Essig and the Friends at St. Pius X Catholic Church, since this problem took place in public, just across from St. Pius X Church where the Catholic nuns live. I asked for Community Support to report how the Lombard Police Department has unfairly arrested me and charged me criminal assault, obstructing a police officer, and resisting arrest in order to appear before Judge McKillip on September 29, 2006, 8H30, in Room 4001 at the DuPage County Judicial Center , 505 North County Farm Road , Wheaton IL 60187 .

Gardenia C. Hung was walking peacefully home from the Illinois Employment and Training Center at 837 S. Westmore-Meyers Road, Lombard, IL 60148, Telephone (630) 495-4345, next to the Illinois Secretary of State, Jesse White Vehicle License Facility, at the Eastgate Shopping Center in Lombard when Lombard Policewoman Pam, Badge No. 710, yelled out from the white Community Police truck that I had stolen an East Indian woman’s cellular telephone at the I.E.T.C. I stopped to answer her “NO” at the corner of Adams St. and Westmore-Meyers Road in Lombard and continued walking home toward St. Pius X Church. When arrived to the front lawn of St. Pius X Church, Lombard Policeman Thiede, Benedicsen, Virene, Schrepferman and Pam, all got out of their Lombard police cars to arrest me and drop all the contents of my handbags on the green lawn, along with my yellow knapsack and my red Burberry umbrella.

During the False Arrest/Detention with Wrongful Charges, Gardenia C. Hung received visible scratches on her right hand wrist, for the record. Both of her arms were twisted and wrenched by Lombard Policeman Thiede who handcuffed her without due reasons. In addition, Lombard Policeman Thiede forcefully removed a Silver Bracelet with a Christian Cross Pendant and did not return the jewelry to Gardenia C. Hung. Gardenia C. Hung wants her Christian Cross Silver Bracelet returned for her right wrist. Moreover, all the contents of (2) two red handbags were emptied on the green lawn in front of St. Pius X Catholic Church, while the Red
Burberry umbrella was thrown on the green lawn by the Lombard Police, and they searched the yellow backpack containing water bottles and personal items.

Gardenia C. Hung, does not plead guilty to Count 1, Obstructing a Peace Officer, nor Count 2, Resisting a Peace Officer, or Count 3, Assault of the Lombard Police as defined by “an open threat of bodily contact with someone without permission”. Please note that Gardenia C. Hung’s Red Burberry umbrella did not have any contact with any of the Lombard Police involved in this matter—Thiede, Benedicsen, Virene, Schrepferman, Pam, and/or Marciniak. None of the Lombard Police in this matter have been assaulted, injured or attacked by Gardenia C. Hung. While Gardenia C. Hung has been harassed, manhandled, scratched, and injured by Lombard Police Thiede who abused process for wrongful charges, false arrest/detention without foundation. The Lombard Police are at fault due to false imprisonment/detention, malicious prosecution which is to misuse the legal process to harass an individual, and interference with person by law in Illinois .

II. 18TH Judicial Circuit Court, in DuPage County , Wheaton , Illinois . Glendale Heights Field Court , Judge Thomas Dudgeon, 300 East Fullerton , Glendale Heights , Illinois , Date of Hearing Scheduled for October 19, 2006, 8H30AM. And DuPage County Judicial Center, 505 North County Farm Road , Wheaton , IL 60187 , before Judge McKillip, on September 29, 2006, 8H30AM, Room 4001.

The City of Lombard has been citing Gardenia C. Hung, on behalf of the Hung Family Real Estate for (4) Four Municipal Code Violations against the Hung Family real estate property at 502 S. Westmore Avenue in Lombard, IL 60148-3028 USA, DuPage County, as follows.

(1) Lombard vs. Gardenia C. Hung, Case No.LO12418NT, served by Lombard Police Officer No. 830, Kelly, and issued by Keith Steiskal, for the Lombard Fire Department, Bureau of Inspectional Services, who are blaming and accusing Gardenia C. Hung as the Lombard resident homeowner for municipal code building violations caused by local criminals, trespasses, and vandals in Lombard, DuPage County, Illinois, as described in the attached correspondence.
(2) No Court Notice Issued Nor Received by Mail for No. LO12419NT issued by Chris Hanigan and Keith Steiskal for the Lombard Fire Department, Bureau of Inspectional Services due to General Plumbing Damages Caused by Bursting Pipes and Excess Water Pressure Ungauged by the Lombard Water Department and Public Works. Note that Chris Hanigan wants to Condemn the Hung Property Without Due Notice or Due Process or Prior Notice to Court Hearing at Glendale Heights Field Court before presiding Judge Thomas Dudgeon. Gardenia C. Hung has not received a Court Notice for this Lombard Municipal Code Violation to Date.
(3) Lombard vs. Robert Hung, Case No.2006OV005982, LO25448NT, issued by Robert G. Meyer, from the Lombard Fire Department, Bureau of Inspectional Services for Health and Sanitation Violation as noted in the enclosed copy of the ticket. Lombard Police Officer No. 830, Kelly, and Mark Gouty were forcefully asking me to sign these ticket violations at the Lombard Metra Station, early on Friday morning, June 23, 2006, (5) five days after the same were written without due notice or advise to Gardenia C. Hung, who refused to sign or accept these (2) violation charges at 8H15AM on the platform for Chicago-bound Metra in Lombard, DuPage County, Illinois.
(4) Lombard vs. Gardenia Hung, Case No.2006OV005983, LO25449NT, Lombard Police Officer No. 830, Kelly, and issued by Robert G. Meyer, from the Lombard Fire Department, Bureau of Inspectional Services. (Same as above, (2) Violations with the same wrongful charges).

Please note that Chris Hanigan and Keith Steiskal have been instigating the condemnation of the Hung Real Estate Property without Due Notice and/or Investigation of the criminal conspiracy and the criminals surrounding this Lombard property purchased by the late Mr. Robert Hung, J.D. and myself, Gardenia C. Hung, with cash retirement funds in 1996.

In addition, Chris Hanigan and Keith Steiskal and the Lombard Fire Department, Police, and DuPage County law enforcement have not notified the Hung Family ever about the criminals and the terrorism surrounding this Lombard real estate property. In spite of the attempts to communicate by Gardenia C. Hung who has been requesting appointments to meet at the Village of Lombard Board of Trustees and the Lombard Police Department, as noted by correspondence mailed, faxed, and Emailed on record requesting information and status, without any response—none of the DuPage County departments ever respond or arrange to meet Gardenia C. Hung. Neither the Lombard Fire Department nor its Bureau of Inspectional Services have helped or assisted Gardenia C. Hung, as a Lombard resident homeowner, nor as a human being during these times of crisis.

Given that the Village of Lombard, its Police Department, its Fire Department and Bureau of Inspectional Services, and DuPage County are determined to harass, blame, and abuse Gardenia C. Hung’s human rights and constitutional for whatever reason or any excuse under false arrest/detention and wrongful charges, as well as Lombard Municipal Code Violations caused by local criminals and others, please help me address and stop Lombard and DuPage County from abusing me and other resident homeowners human rights and constitutional rights. The Village of Lombard and its departments are accomplices and perpetrators of this hateful and heinous crime against Gardenia C. Hung who has been notified to appear at the 18th Judicial Circuit Court and the Glendale Heights Field Court, pending court hearings under false arrest/detention, wrongful charges by the Lombard Police Thiede, Benedicsen, Virene, Schrepferman, Policewoman Pam, Marciniak and Alice at the Lombard Police Station before presiding Judge McKillip, at the DuPage County Judicial Center in Wheaton, Illinois; in addition to threats of wrongful violations and condemnation to remove the Hung Family real estate property, instigated by Chris Hanigan and Keith Steiskal, who are at the forefront of this injustice and inequity against the Hung Family in Lombard, DuPage County, Illinois, pending court hearing before presiding Judge Thomas C. Dudgeon at the Glendale Height Field Court on September 21, 2006, and October 21, 2006.

I look forward to your support and assistance with God’s help. Thank you for your attention to this matter.

Sincerely Yours,

Gardenia C. Hung, M.A
Tuesday: 8/29/2006 11:05:56 AM
Chicago , Cook County , Illinois

VERIFICATION

Under penalties as provided by law pursuant to Section 1-109 of the Illinois Code of Civil Procedure, the undersigned certifies that the statements set forth in this instrument are true and correct, to the best of my ability, so help me God.

Date: August 29, 2006 Signed by Gardenia C. Hung, M.A.

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