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FILED
5/21/2020 9:14 AM
DOROTHY
Atty BROWN
No. 17177
CIRCUIT CLERK
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COOK COUNTY, IL
FILED DATE: 5/21/2020 9:14 AM 2020D003302
COUNTY DEPARTMENT, DOMESTIC RELATIONS DIVISION
9298475
IN RE THE MARRIAGE OF: )
)
CHRISTINE LEZCANO, )
Petitioner, )
) No. 2020D003302
and )
)
CHRISTOPHER LEZCANO )
Respondent. )
PETITION FOR DISSOLUTION OF MARRIAGE
NOW COMES the Petitioner, CHRISTINE LEZCANO, (hereinafter referred to as
“Petitioner”) by her attorney, PEGGY M. RADDATZ, and for her Petition for Dissolution of
Marriage against the Respondent, CHRISTOPHER LEZCANO (hereinafter referred to as
“Respondent”) having been duly sworn, state as follows:
1. That the Petitioner is 36 years of age, employed as a Coder at Advocate Healthcare.
She is presently residing in Chicago , Illinois and has been residing in the State of
Illinois for the last ninety (90) days consecutively.
2. That the Respondent is 35 years of age, employed as a Trucker Recruiter for the
Hub Group and he is presently residing in Chicago, Cook County, Illinois.
3. That the parties were lawfully joined in marriage on May 18, 2017, in Chicago,
Cook County, Illinois and that said marriage was therein registered.
4. That two children were born to the parties during the marriage, namely; AL having
been born in 2019 and AL having been born in 2017. The parties did not adopt any
children during the marriage and the Petitioner is not pregnant.
5. That certain irreconcilable differences have caused the irretrievable breakdown of
the marriage of the parties and all attempts at reconciliation have failed and any
FILED DATE: 5/21/2020 9:14 AM 2020D003302
further attempts at reconciliation would be impractical and not in the best interest
of the parties.
6. That in and during the marriage, the parties acquired certain marital property
including, but not limited to, bank accounts, and 401k’s.
7. That the Petitioner has acquired certain non-marital property, including, but not
limited to various items of personal property including the non-marital home where
the parties reside with the two minor children.
8. That it is in the best interests of the minor children that they continue reside with
the Petitioner, their mother on a temporary and permanent basis, and that their
mother make all day-to-day decisions and all major decisions regarding their health,
medical, educational , extracurricular activities, and religious matters.
9. That the Respondent, is gainfully employed earning substantial income, and is well
able to provide maintenance to the Petitioner and child support for the minor children
in accordance with the statues regarding child support and maintenance contained in
the Illinois Marriage and Dissolution Act.
10. That the Petitioner is without sufficient financial resources to pay her own attorney's
fees and costs, and that the Respondent has sufficient financial resources to contribute
to and pay her costs and attorney's fees incurred herein.
11. That there are various debts which were incurred during the marriage and those
marital debts need to be paid..
WHEREFORE, the Petitioner, CHRISTINE LEZCANO, prays as follows:
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A. That a Judgment of Dissolution of Marriage be awarded the parties dissolving the
marriage;
FILED DATE: 5/21/2020 9:14 AM 2020D003302
B. That the Court award both parties the temporary and permanent parenting times with
the minor children of the parties;
C. That the Petitioner be awarded temporary and permanent child support and payment
for daycare expenses from the Respondent;
D. That the Respondent be ordered to contribute towards the minor children’s healthcare
out of pocket health care expenses and costs;
E. That the Petitioner be awarded maintenance, both temporary and permanent, in an
amount commensurate with the Illinois Marriage and Dissolution Act from the
Respondent;
F. That the Petitioner be awarded her just portion of the marital property of the parties.
G. That the Petitioner be assigned her non-marital property;
H. That reasonable costs and attorney's fees be assessed against the Respondent, both
temporary and permanent in reasonable amounts;
I. That the debts incurred by the parties be assigned to the party who has the greater
income to pay them; and
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J. For such other and further relief as equity deems just.
FILED DATE: 5/21/2020 9:14 AM 2020D003302
__________________________________
CHRISTINE LEZCANO
__________________________________
Peggy M. Raddatz
Attorney at Law
Peggy M. Raddatz
Attorney for Petitioner/CHRISTINE LEZCANO
512 W. Burlington Avenue, Suite 1
LaGrange, Illinois 60525
708-352-0089
Lawher@aol.com
Attorney No. 17177
4
CLIENT VERIFICATION
CHRISTINE LEZCANO, being first duly sworn, on oath deposes and says that she is the
FILED DATE: 5/21/2020 9:14 AM 2020D003302
Petitioner in the above-captioned cause, that she knows the contents of the foregoing Petition for
Dissolution of Marriage, and that the same are true except as to matters alleged to be on
information and belief and that as to these he believes them to be true.
___________________________
CHRISTINE LEZCANO
ATTORNEY CERTIFICATION
PEGGY M. RADDATZ, the attorney, hereby certifies that pursuant to Supreme Court Rule
137, states that she has read the above and foregoing pleading, that to the best of her knowledge,
information and belief, formed after reasonable inquiry, said pleading is well grounded in fact and
is warranted in existing law or a good faith argument for the extension modification, or reversal of
existing law, and that said pleading is not interposed for any improper purpose, such as to harass
or cause unnecessary delay or needless increase in the cost of litigation.
____________________________
PEGGY M. RADDATZ
Peggy M. Raddatz
Attorney for Petitioner/CHRISTINE LEZCANO
512 W. Burlington Avenue, Suite 1
LaGrange, Illinois 60525
708-352-0089
Lawher@aol.com
Attorney No. 17177
5
Preview
FILED 5/21/2020 9:14 AM DOROTHY Atty BROWN No. 17177 CIRCUIT CLERK IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COOK COUNTY, IL FILED DATE: 5/21/2020 9:14 AM 2020D003302 COUNTY DEPARTMENT, DOMESTIC RELATIONS DIVISION 9298475 IN RE THE MARRIAGE OF: ) ) CHRISTINE LEZCANO, ) Petitioner, ) ) No. 2020D003302 and ) ) CHRISTOPHER LEZCANO ) Respondent. ) PETITION FOR DISSOLUTION OF MARRIAGE NOW COMES the Petitioner, CHRISTINE LEZCANO, (hereinafter referred to as “Petitioner”) by her attorney, PEGGY M. RADDATZ, and for her Petition for Dissolution of Marriage against the Respondent, CHRISTOPHER LEZCANO (hereinafter referred to as “Respondent”) having been duly sworn, state as follows: 1. That the Petitioner is 36 years of age, employed as a Coder at Advocate Healthcare. She is presently residing in Chicago , Illinois and has been residing in the State of Illinois for the last ninety (90) days consecutively. 2. That the Respondent is 35 years of age, employed as a Trucker Recruiter for the Hub Group and he is presently residing in Chicago, Cook County, Illinois. 3. That the parties were lawfully joined in marriage on May 18, 2017, in Chicago, Cook County, Illinois and that said marriage was therein registered. 4. That two children were born to the parties during the marriage, namely; AL having been born in 2019 and AL having been born in 2017. The parties did not adopt any children during the marriage and the Petitioner is not pregnant. 5. That certain irreconcilable differences have caused the irretrievable breakdown of the marriage of the parties and all attempts at reconciliation have failed and any FILED DATE: 5/21/2020 9:14 AM 2020D003302 further attempts at reconciliation would be impractical and not in the best interest of the parties. 6. That in and during the marriage, the parties acquired certain marital property including, but not limited to, bank accounts, and 401k’s. 7. That the Petitioner has acquired certain non-marital property, including, but not limited to various items of personal property including the non-marital home where the parties reside with the two minor children. 8. That it is in the best interests of the minor children that they continue reside with the Petitioner, their mother on a temporary and permanent basis, and that their mother make all day-to-day decisions and all major decisions regarding their health, medical, educational , extracurricular activities, and religious matters. 9. That the Respondent, is gainfully employed earning substantial income, and is well able to provide maintenance to the Petitioner and child support for the minor children in accordance with the statues regarding child support and maintenance contained in the Illinois Marriage and Dissolution Act. 10. That the Petitioner is without sufficient financial resources to pay her own attorney's fees and costs, and that the Respondent has sufficient financial resources to contribute to and pay her costs and attorney's fees incurred herein. 11. That there are various debts which were incurred during the marriage and those marital debts need to be paid.. WHEREFORE, the Petitioner, CHRISTINE LEZCANO, prays as follows: 2 A. That a Judgment of Dissolution of Marriage be awarded the parties dissolving the marriage; FILED DATE: 5/21/2020 9:14 AM 2020D003302 B. That the Court award both parties the temporary and permanent parenting times with the minor children of the parties; C. That the Petitioner be awarded temporary and permanent child support and payment for daycare expenses from the Respondent; D. That the Respondent be ordered to contribute towards the minor children’s healthcare out of pocket health care expenses and costs; E. That the Petitioner be awarded maintenance, both temporary and permanent, in an amount commensurate with the Illinois Marriage and Dissolution Act from the Respondent; F. That the Petitioner be awarded her just portion of the marital property of the parties. G. That the Petitioner be assigned her non-marital property; H. That reasonable costs and attorney's fees be assessed against the Respondent, both temporary and permanent in reasonable amounts; I. That the debts incurred by the parties be assigned to the party who has the greater income to pay them; and 3 J. For such other and further relief as equity deems just. FILED DATE: 5/21/2020 9:14 AM 2020D003302 __________________________________ CHRISTINE LEZCANO __________________________________ Peggy M. Raddatz Attorney at Law Peggy M. Raddatz Attorney for Petitioner/CHRISTINE LEZCANO 512 W. Burlington Avenue, Suite 1 LaGrange, Illinois 60525 708-352-0089 Lawher@aol.com Attorney No. 17177 4 CLIENT VERIFICATION CHRISTINE LEZCANO, being first duly sworn, on oath deposes and says that she is the FILED DATE: 5/21/2020 9:14 AM 2020D003302 Petitioner in the above-captioned cause, that she knows the contents of the foregoing Petition for Dissolution of Marriage, and that the same are true except as to matters alleged to be on information and belief and that as to these he believes them to be true. ___________________________ CHRISTINE LEZCANO ATTORNEY CERTIFICATION PEGGY M. RADDATZ, the attorney, hereby certifies that pursuant to Supreme Court Rule 137, states that she has read the above and foregoing pleading, that to the best of her knowledge, information and belief, formed after reasonable inquiry, said pleading is well grounded in fact and is warranted in existing law or a good faith argument for the extension modification, or reversal of existing law, and that said pleading is not interposed for any improper purpose, such as to harass or cause unnecessary delay or needless increase in the cost of litigation. ____________________________ PEGGY M. RADDATZ Peggy M. Raddatz Attorney for Petitioner/CHRISTINE LEZCANO 512 W. Burlington Avenue, Suite 1 LaGrange, Illinois 60525 708-352-0089 Lawher@aol.com Attorney No. 17177 5