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Sunday, January 27, 2008

Illinois Human Rights in the Village of Lombard, Du Page County, USA

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.

Saturday, January 12, 2008

Heinous Hate Crimes in the Village of Lombard Du Page County, Illinois United States of America

U.S. Department of Housing and Urban Development
Office of Fair Housing and Equal Opportunity
Midwest Regional Office, Region V
Ralph H. Metcalfe Federal Building
77 West Jackson Boulevard – Room 2101
Chicago, Illinois 60604-3507 , United States of America
To Whom It May Concern

Your Ref: U.S. HUD Inquiry Complaint No.237371 for Gardenia C. Hung, M.A. and the late Mr. Roberto Hung, J.D., father who was injured and disabled at home, 502 S. Westmore-Meyers Road, Lombard, Illinois 60148-3028, December 21-22, 1996, only three (3) months after the cash purchase of the same Lombard Historical Bungalow in September 1996. Gardenia C. Hung and Family are legal resident homeowners, U.S. citizens in the Village of Lombard, Du Page County, Illinois United States of America. Email: gardenia359@hotmail.com

Dear Yolanda Calicutt, U.S. HUD, Midwest Regional Office, Region V, To Whom It May Concern:

My name is Gardenia C. Hung, M.A. For your information and for the record, I have 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 Hanigan, 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 this 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. The Village of Lombard refuses 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 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.

I have provided other examples of discrimination in Fair Housing Practices by the Village of Lombard—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.

Wednesday, January 9, 2008

"De Laudibus Legum Angliae"--"In Praise of the Laws of England"--Sir John Fortescue (c.1395-c.1477)"Common Law: Past, Present, Future, and Beyond"

Part I, Courtesy Article "De Laudibus Legum Angliae" on the 400th Anniversary of the Jamestowne Settlement in Virginia , 1607-2007 USA
Courtesy Article: "De Laudibus Legum Angliae"--"In Praise of the Laws of England"--Quote from Sir John Fortescue (c.1395-c.1477)"Common Law: Past, Present, Future, and Beyond..." written by Gardenia C. Hung, M.A.,B.A.


The legal grounds of common law are based "in its beginnings lost in the mist of the history of northern Europe and Scandinavia, touched by the influence of the Roman Empire and the history of the English peoples who are frequently invaded by cross-cultures who remained, intermarried with the local citizens and greatly affected their customs and habits."

While the Romans ruled Britain for almost 400 years, the development of the Justinian code and of the Roman law was still 100 years away before they left England . During 600 A.D., the English were converted to Christianity and canon law became established in England . Canon law, as a judicial system of the church, has been a significant factor in English legal history and has acquired a name all of its own--equity.

For many years, two (2) parallel courts existed in England , courts of equity, which were free to apply principles of conscience, and common law courts. The "common law" is so called because it was "commonly" applied throughout the kingdom of England in the King's Court.The last successful cross-cultural invasion of England was by the Normans over the Saxons in 1066 A.D., fought over the Battle of Hastings.

Since the 11th century A.D., the English were able to develop their own legal system in a typical English manner--they avoided the method of trying to write down all known laws on paper." The English won the protection of their own basic civil rights from their rulers, as noted in the Magna Carta endorsed and signed by King John in 1215. From that time onwards, the English applied justice, equity, and fairness in the developing courts, with trials by jury for contests between individual citizens disputing over property, personal injuries and contracts.

At other times, acts of Parliament defined specific crimes and prescribed penalties. Judges and members of Parliament established British English laws gradually by legal precedents. The result is then what is known still today as "common law": that is to say, custom, tradition, decisions by judges in specific cases and acts of Parliament.This legal system based on "common law" has been well established for the last 400 years in the United States of America , between 1215 A.D. and 1607 A.D., when the British arrived and settled in Historical Jamestowne, Virginia.

For the American colonists, legal experience differed according to the background of the settlers. Since lawyers were few at the time, important cases were heard and decided in London , England . For the last 400 years, "common law" has become the most important root of the American legal system founded on solid judicial grounds from England and imported to the United States of America , during the 17th century through the 21st century and beyond...

Common law has been practiced throughout the kingdom by the King's Court as long as the English languages has been used by the Angles, the Jutes, the Saxons, and the Normans, influenced by Latin and Greek, as well as by the Celts--the Welsh, the Irish, the Scots, and the Cornish--all Gaelic-speaking tribes who were natives of the British Isles before the English settled in the United Kingdom.The Angles and the Jutes invaded England from Denmark . The Saxons traveled from Saxony which is now known as Germany . And the Normans sailed across the English Channel from France ...

Following the Saxon invasion from Germany , the word "Anglii" and " Anglia " became part of the language as used by the Celts to refer to the invaders. One hundred and fifty years after the first raids, King Aethelbert of Kent was named "rex Anglorum" by Pope Gregory. Since then, these people have been called "Angelcynn" (Angle-kin) and their language was "Englisc". By 1000 Anno Domini, the country was generally known as "Englaland", the land of Angles .The development of the English language moved the practice of common law throughout the invasions of England and the cross-cultural revolutions which took place before and after the year 1066 A.D., marked by the Battle of Hastings, fought between King Harold II and King William I.

According to "The Story of English" by Robert McCrum, William Cran, and Robert McNeil, the Mother tongue known as English was brought to Britain by Germanic tribes, the Angles, the Saxons, and the Jutes, influenced by Latin and Greek when St. Augustine and his followers converted England to Christianity. The English language has been subtly enriched by the Danes, and finally transformed by the Normans . French-speaking William I of Normandy , also known as the Conqueror who won the battle of Hastings over Harold II in 1066 A.D.

In "The History of the English-speaking Peoples", Sir Winston Churchill stated: "We must never cease to proclaim in fearless tones the great principles of freedom and the rights of man, which are the joint inheritance of the English-speaking world and which through the Magna Carta, the Bill of Rights, the habeas corpus, trial by jury, and the English common law, find their expression in the Declaration of Independence, (of the United States of America)".

During the first week of May 2007, Queen Elizabeth II and Sir Philip, Duke of Edinburgh were hosted by President George W. Bush and First Lady Laura Bush during their visit to Historic Jamestowne, Virginia , Kentucky , and Washington , D.C. They celebrated the 400th Anniversary of the British settlement since 1607, when the first English settlers arrived to the British Colonial fort, sited by Captain John Smith and "Matoakah" Pocahontas, Chief Powhatan's Native American Indian Princess, and African-American slaves in North America and Canada, during the 17th century.

An example of "common law" is the concept of "conversion" which defines an intentional tort to personal property (same as "chattel") where the wrongdoers' unjustified, willful interference with the "chattel" deprives the owner of the possession of such "chattel". The owner must have actual possession or immediate right to possession since the time of the wrongful misuse, alteration, or abuse occurred.

Interference in common law "conversion" means the exercise of dominion over another's chattel. Intent to dispossess the owner of the chattel is not a required element of the claim. In other words, intentional removal of another's chattel under the mistaken belief that it belongs to the wrongdoer, does not relieve the wrongdoer of liability under conversion.

Stealing something from someone else is one form of conversion. However, conversion is not limited to theft. Conversion can also be accomplished by moving, transferring, discarding, hiding, vandalizing or destroying another person's chattel. Merely using another person's chattel can be grounds for conversion in certain cases.Legal remedy for conversion is usually in the form of damages restitution equal to the fair market value of the chattel at the time of conversion.

Conversion is an interference with another's ownership of property. It is a general intent tort, not a specific intent tort. That means that the intent to take or otherwise deal with the property is enough to support the claim. The standard remedy and relief for conversion is a judgement for damages in an amount equal to the fair market value of the property. Punitive damages are also possible to be assessed because conversion is an intentional tort.

To be continued...

Sources:

From the Law Library of my father, Mr. Roberto Hung, J.D.You and the Law. A Practical Guide to Everyday Law and How It Affects You and Your Family. Advisory Editor Henry V. Poor, Associate Dean of Yale University Law School, 1967-1972. Reader's Digest Association, Inc., New York , 1971.Family Legal Guide. A Complete Encyclopedia of Law for the Layman. Reader's Digest Association, New York , 1971.Periodical, "The Week", May 18, 2007 on the “400th Anniversary of Jamestowne , Virginia ”.Periodical, "Newsweek". Ideas, "Ties of Blood and History: Sir Winston Churchill", February 26, 2007.McCrum, Robert et al. The Story of English. BBC Public Television Series.The Illinois Sheriff, Spring 2005. "Roots. A Historical Perspective of the Office of the Sheriff". DeKalb County Sheriff Roger Scott.Fortescue, John (1394-1477). De Laudibus Legum Angliae. In Praise of the Laws of England .http://www.answers.com/topic/commonlawCanada's Court System, Department of Justice Publication.American Heritage Dictionary.Village of Lombard, et al. vs. Hung et al., Eighteenth Judicial Circuit Court, 505 North County Farm Road, Wheaton, IL 60187, County of Du Page, State of Illinois, United States of America.Churchill, Winston. A History of the English-Speaking Peoples.Roberts, Andrew. A History of the English-Speaking Peoples since 1901.
Courtesy Article

Part II: Intentional tort--Conversion and trespass as “action in trover”

An intentional tort arises from deliberate invasion of another person’s rights, causing injury without just cause or excuse. For instance, the new neighbor drives backward into the owner’s fence posts between the adjoining driveway and damages the existing fence on the first moving day into their new home. The owner of the damaged fence posts can sue the new neighbor for repeatedly driving into the owner’s fence posts with a van, a lawnmower, or deliberate carelessness.

Intentional torts include interference with a person’s freedom of movement, defamation of character (libel and slander), invasion of privacy, interference with property rights, misuse of the legal process, fraud, and the intentional infliction of emotional distress.

Trespass is a tort, a civil wrong because it interferes with a person’s property rights. For instance, the new neighbor’s son jumps the fence adjoining the owner’s property repeatedly without permission. Or, the Lombard Police Department in Du Page County, Illinois allows intruders, strangers, terrorists, and criminal repeat offenders to jump the owner’s fence into the backyard, under approval of the Village of Lombard, Town Hall staff, and the Village Manager, Bill Lichter, President Bill Mueller, including Trustee for District 5 Ken Florey, and others, without the authorization of the Hung Family as owners of the real estate property.

Common law “tort” action features unreasonable interference with the interests of another. For instance, intentional infliction of emotional distress is a tort. Case-in-point, John Carpenter, the neighbor calls the Lombard Police Department on the Hung Family when the daughter arrives one evening, last summer 2006, and walks into the backyard—there was nothing wrong in the backyard, at the house, or with the daughter of the late Mr. Roberto Hung, J.D.

An injured person may sue anyone who commits a tort against him/her to collect damages—money to compensate for the wrong.

Trespass is an unlawful intrusion that interferes with someone else’s possession of property. A trespass gives the property owner the right to bring a civil lawsuit and collect money damages for the interference and for any harm caused. Some states in the U.S.A. have laws that make trespass a crime and prosecute illicit access entry into property with punitive fines, sanctions, and imprisonment. Generally, a trespass is committed on real property (real estate or land and everything that is attached to it), but a trespass can also be to personal property (all other forms of property) as well.

Criminal trespass is accomplished by violence or tends to be a “breach of peace”. Some statutes consider any unlawful entry on another person’s real estate property as a criminal act. When the trespass involves violence or injury to a person or property, it is always considered criminal, and penalties may be increased for more serious or malicious acts. Criminal trespass is prosecuted in the State of Illinois by punitive fines, sanctions or imprisonment or both.

The standard remedy in an action for trespass to chattels is a judgment for an amount equal to the value of loss or use of the property. Damages from a trespass claim are based on the harm caused to the owner’s property, rather than the general value of the chattel. Under common law, many acts can constitute both “conversion” and “trespass” as “action in trover”.

Conversion as an “action in trover” under English common law is an ancient, historical form of legal action to recover possession of personal property, and its practice to settle disputes, contests, and arguments, has developed our modern sense and interpretation in the application of common law in the 21st century and beyond.

Action in trover is the technical name for a lawsuit to recover damages incurred for a wrongdoer’s “conversion” (wrongful taking, misuse, abuse, alteration or destruction) of personal property belonging to someone else. In trover actions, the measure of damages is normally in proportion to the value of the property at the time of conversion.

Legal “action in trover” is a remedy for conversion or the wrongful appropriation of the owner’s personal property. During the course of the 16th century, “action in trover” developed as a special form of legal action in a case.

Trover damages are measured in proportion to the market value of the property, plus compensation for deprivation of use, and compensation for other losses naturally and proximately caused by the wrongful taking of another’s property. The owner can also recover interest that would have been earned by the money value of the object and any expenses incurred in attempting to recover the property.

Another example of common law is “negligence per se”, that is to say behavioral conduct which is evidence of an unreasonable action (or failure to act) that causes injury to a person or damages to his/her property. Negligence per se, as carelessness in itself, is behavior that falls below the standards set by law for protecting others against risk or harm. As a result of “negligence per se”, anyone who is injured, or whose property is damaged because of someone else’s negligent act or failure to act, is entitled to bring a civil lawsuit against the wrongdoer, for an “action in trover”.

In itself, negligence is a state of mind involving carelessness, forgetfulness, inattentiveness, refusal to perform duties and obligations required by law and professional standards.

In negligence law, a person has an obligation and duty to exercise reasonable care for the physical safety and for the property of others people.

Negligence per se involves “misfeasance” which is to say, the improper doing of an act, and “nonfeasance”, that is to say, the failure to perform the required duty. In cases involving “imputed negligence”, the first person in charge may have a duty to see that the second person in force exercises care in regard to any third party or property. Thus, “imputed negligence” falls upon the first person when the second person fails to perform the duty of care for the third person, “vicariously”. In the same way, “respondeat superior”, in Latin, illustrates a principle of law that holds an employer liable and responsible for anything that an employee does during the course of employment. Case-in-point, the Village of Lombard is responsible for all its employees’ actions and non-actions, at all times.

When a person suffers harm because of someone else’s negligence, the same person can sue the negligent person and make him or her pay for the harm, damages and/or losses caused. Given that the negligent person owed the injured party a duty to use care; that he/she violated that duty by failing to act according to the required standard of care; and that the party incurred injury or that property was damaged as the result of the negligent person.

In the doctrine of “negligence per se”, the violations of statutes by the negligent person creates a case for legal action in itself, by default. In order for this doctrine (of negligence per se) to operate, the statute which has been violated must have been designed to prevent the type of injury or damaged suffered by a victim of crime, abused by another person due to “negligence per se”.

Case-in-point, in the legal action for Village of Lombard v. Hung, et al., the Plaintiff is subject to “negligence per se” for the violations of Illinois statutes pursuant to consumer service fraud, breach of the Fair Housing agreement contract, and Lombard real estate liability for the sale of old houses in Du Page County, Illinois, USA.

Since 1993, in the Village of Lombard, the Hung Family real estate property and all family members, have all been injured, disabled, and damaged due to the Village of Lombard’s failure to provide the duty of care, according to the required standard of care; and the Hung Family members and real estate property have all been victims of crime as a result of “negligence per se” by default in the Village of Lombard, Du Page County, Illinois, USA.

English common law is based on legal court precedents. Each legal cause of action is decided by a judge to establish a precedent which may be used as a guide for other judges to make subsequent decisions. Thus common law is active, dynamic, functional, and constantly evolving in time, upon legal precedents.

Traditionally, English common law was unwritten, “lex non scripta”—not written as a body of law; however, nowadays, there are extensive, historical, and contemporary compilations of the English common law for the 21st century and beyond.

Common law follows natural reason, logic, and man’s sense of justice, equity, and fairness. It is adopted by men and women to regulate legal behavior in social settings, disputes, contests, and arguments. Common law action is a civil lawsuit between opposing parties over a real legal issue in which the relief (help) requested as remedy is generally money granted as an award for damages.

Common law developed after the French Norman Conquest in 1066 A.D. as the law common to the whole of England, rather than the local law used by the Saxons, the Angles, the Jutes, and the Celts. As the court system became established later under King Henry II, and judges decisions became recorded in law reports, the doctrine of precedents developed[1].

Historically, common law is a system of laws that prevails in England and in all countries colonized by Great Britain and the British Commonwealth. The concept of “common law” is derived from the medieval theory that the law is administered by the King’s Court which represented “the custom commonly used throughout the realm”, in contrast to the custom of local jurisdiction that was applied in local or manorial courts. According to Sir John Davies (1`569-1626), “it was nothing else but the Common Custome of the Realm” quoted in Preface to Reports, (1612). Later, Sir John Fortescue declared that the “realm has been continuously ruled by the same customs as it is now”, as noted “In Praise of the Laws of England”, c. 1470, in the original title, “De Laudibus Legum Angliae” in which the English Chancellor of the High Court of England discussed royal and political control, “sovereignty”, in response to the problem of tyranny, as presented by St. Thomas Aquina and Ptolemy of Lucca. Thomas Aquina exposed the idea of “De Regimine Principum” among the highest goals of medieval political thought—Sir John Fortescue sustained that while England was a “dominium politicum regale”, France, its secular opponent, represented a simple “dominium regale”. As the most important exponent of English political thought in the 15th century, Sir John Fortescue expressed simply that in contract to France, in England, the King was subject to the same right that the monarch approved with the two Chambers of Parliament, whose consensus was also necessary in order to establish taxes (11)—Sir John Fortescue, “De Laudibus Legum Angliae” as “In Praise for the Laws of England”, Chapters IX and XVIII[2].

English common law developed from legal usage within three (3) English courts as follow: the King’s Bench, Exchequer, and the Court of Common Pleas. The King’s Bench originally litigated the crown’s business (including criminal matters and had jurisdiction to correct errors from other courts of record). The Exchequer of Pleas, involved primarily revenue matters. Then, in a narrower sense, the common law was the body of law administered in Westminster Hall by the twelve (12) judges of the three superior courts of law. These were the Common Pleas, whose position as the prime court of civil suits had been secured by the Magna Carta (1215) and which continued to attract most civil litigation until the 18th century. The common law administered in these three (3) courts contrasted with “equity” as practiced primarily in the Court of Chancery. The Court of Chancery was originally designated as a “Court of Conscience”, concerned with securing justice in individual cases, rather than following strict rules[3].

In “Roots,” the role of the sheriff is presented as “the oldest continuing, non-military, law enforcement entity in the history of England”. In the 9th century, “shires” were municipal and administrative kingdoms divided by the King of England and assigned to trusted representatives. The shire representative appointed by the King protected his interest and the people of his particular land territory. In medieval English, the appointed trustees were called “reeves” as “guardians of the shire”. Historical usage of the words “shire-reeve” together, derived the contemporary term for the concept of “sheriff”, as we know their office of service today, before and after the French Norman invasion of England in 1066 A.D. In the past, the sheriff was responsible for keeping the peace, collecting taxes, maintaining jails, arresting fugitives, maintaining lists of wanted criminals, serving orders and writs for the King’s Court.

According to DeKalb County Sheriff Roger Scott, “the responsibilities of the office of the sheriff in England ebbed and flowed, depending on the mood and needs of kings and government”. The Magna Carta (1215) signed by King John restricted and circumscribed the responsibilities and duties of the sheriff in his times.

In the British Commonwealth, as well as in America, the concept of the sheriff has been adopted with the common law, through time, space, and physical presence. In the American colonies settled by the British since 1607 A.D., sheriffs were also appointed following the role model of English government. The first sheriff in the United States of America has been noted to be Captain William Stone, appointed in 1634 for the Shire of Northampton in the colony of Virginia. The first elected sheriff was William Waters in 1652 for the same shire. The word “shire” was used in many of the Commonwealth colonies, before the word “county” replaced its usage[4].

Under English common law, notaries public also provide another timeless office of service for the legal court system and the community at large. Since the Roman Republic, in the past, notaries public have drawn important documents and records writing for business and employment. During the times of the Roman Empire, notaries public were known under various titles in Latin, such as “scriba”, “cursor”, tabularius”, “tabelio”, “exceptor”, “actuaries”, and “notarius”, according to the historical times in which they lived and the duties performed. Notaries public are subject to regulation by law since the later days in Ancient Rome. Some of the notarial acts have been granted degrees of authenticity to be designated as public instruments and were required to be kept as records to be deposited in public archives for the government[5].

Notaries public are commissioned by the State of Illinois, Office of the Secretary of State Jesse White. Their term of office is four (4) years from the time of commission.

Throughout history, in the early past, notaries public were well known functionaries during the times of the great Charlemagne who vested notarial acts by scribes with public authority and provided notaries public appointments by his deputies in every locality in their territories. Charlemagne provided that each bishop, abbot, and count should have a notary public.

In England, appointed notaries public acted as “conveyancers”, before the French Norman Conquest in 1066 A.D., as shown by the fact that a grant of lands and manors was made by King Edward the Confessor, to the Abbot of Westminster by a charter written and attested by a notary public. In Great Britain, notaries public are authorized to administer oaths, and this official power is vested by statute.

The laws of the United States of America, under the Constitution and under God is similar, for notaries public and is often declared by the statutes of the various states and other jurisdictions.

It is my opinion that common law is established in the history of languages with the legal tradition of the past, interpreted in the present as precedents, to be preset in the future and beyond…the 21st century.

English common law is based on timeless, immemorial customs and legal practices founded on natural reason, persuasion, and logic. According to Edward Coke, “reason is the life of the law, nay, the common law itself is nothing else but reason”—from the First Part of the Institutes of the Laws of England or A Commentary upon Littleton by Edward Coke. Edited by Francis Hargrave and Charles Butler, (London, 1794).

Common law, within the context of its core principles, is perceived to be “timeless”. It is derived from legal authority “throughout the kingdom” as stated by Sir William Blackstone (1723-1780), in his Commentaries on the Laws of England, (1765-1769).

After the Civil War, U.S. Supreme Court Chief Justice Oliver Wendell Holmes wrote a book called, “The Common Law” (1881), in order to recognize that law evolved and that it was a byproduct/ consequence of historical events, rather than simply the result of reason. According to Oliver Wendell Holmes, “a moment’s insight is a life’s experience”. Holmes’ book “The Common Law” focuses on experience rather than logic and has been compared as a legal analog to Charles Darwin’s “Origin of the Species” which discusses biological processes, rather than divine ones. Oliver Wendell Holmes helped to popularize the understanding that law evolves…through time, space, physical presence, and beyond the 21st century.

After the Second World War, there was a growing interest in the use of the common law as a tool for social reform. While some academics spoke of the legal process—the belief that there were methods of common law and statutory interpretation that were independent of politics existed—other academics and jurists on both ends of the political spectrum urged judges to use their common law power to remake the law on its foundations. Where once judges had wielded the law to limit corporate liability, some began to expand “tort” law to facilitate recovery of damages and losses for injured parties in hazardous conditions, as victims of crime, to dangerous drugs to professional malpractice.

Now in the 21st century, Modern America continues to practice “common law” as a byproduct of generations of judicial decisions and during the course of time and beyond. Common law is understood to be the result of judge-made innovations, interpretation, application, and perception of the circumstances involved in judicial case review. However, a more conservative conception of the common law has been re-emerging in the U.S. Supreme Court under Chief Justice John G. Roberts and fellow jurists, scholars, and colleagues during 2007. During the first term of office appointed by President George W. Bush, Chief Justice John G. Roberts moved the U.S. Supreme Court toward a new conservative direction within the context of President Bush’s “faith-based initiative”.[6]

Since 1607, and for the last 400 years, judges still grapple and deliberate with new legal actions and struggle to apply precedents. Modern day judges are still using, applying, and interpreting the English common law system to date as a legal foundation to establish law practices for justice, equity, and fairness under the Constitution of the United States, and under God, throughout the 21st century and beyond…in the spirit of the times. Zeitgeist!


Sources:From the Law Library of my father, Mr. Roberto Hung, J.D.You and the Law. A Practical Guide to Everyday Law and How It Affects You and Your Family. Advisory Editor Henry V. Poor, Associate Dean of Yale University Law School, 1967-1972. Reader's Digest Association, Inc., New York, 1971.Family Legal Guide. A Complete Encyclopedia of Law for the Layman. Reader's Digest Association, New York, 1971.Periodical, 'The Week', May 18, 2007 on the “400th Anniversary of Jamestowne, Virginia”.

Periodical,” The Week”. July 6-13, 2007. News. Main Stories. “The Roberts Court Chars a new direction”.
Periodical, 'Newsweek'. Ideas, 'Ties of Blood and History: Sir Winston Churchill', February 26, 2007.

McCrum, Robert et al. The Story of English. BBC Public Television Series.The Illinois Sheriff, Spring 2005. 'Roots. A Historical Perspective of the Office of the Sheriff'. DeKalb County Sheriff Roger Scott.Fortescue, John (1394-1477). De Laudibus Legum Angliae. In Praise of the Laws of England.http://www.answers.com/topic/commonlawJohn Marshal School of Law in Chicago, Illinois, USA.

Canada's Court System, Department of Justice Publication.American Heritage Dictionary.Village of Lombard, et al. vs. Hung et al., Eighteenth Judicial Circuit Court, Chancery Division, 505 North County Farm Road, Wheaton, IL 60187, County of Du Page, State of Illinois, United States of America.Churchill, Winston. A History of the English-Speaking Peoples.Roberts, Andrew. A History of the English-Speaking Peoples since 1901.
QPB Dictionary of Ideas. Quality Paperback Book Club. (New York: Helicon Publishing Ltd., 1995 in the United Kingdom under the title The Hutchinson Dictionary of Ideas), page 108, Common Law.

Cambridge text in the History of Political Thought, CUP, 1997. Law: Sovereignty in the British Doctrine (From Bracton to Dicey). Notes by Joaquin Varela Suanzes in http://www.murdoch.edu.au/elaw/issues/v6n3/suanzes63_%20notes.html

Fortescue, John. The Governance of England: Otherwise called the Difference between an Absolute and Limited Monarchy. Editor Charles Plummer. London: Oxford University Press, 1885. Reprinted 1999 by the Law Book Exchange, Ltd.
Anderson’s Manual for Notaries Public. Fifth Edition. Gilmer, Wesley, Jr., B.A., M.S.L.S., J.D. W.H. Anderson Company. Cincinnati, 1966.

Richard, Tom, PhD. Professor Emeritus of Linguistics, University of Wisconsin, USA.Hung, Gardenia C., M.A., B.A., Communications, Languages & Culture, Inc., 502 S. Westmore-Meyers Road, Lombard IL 60148-3028 USA. Email: http://us.f314.mail.yahoo.com/ym/Compose?To=GardHn@netscape.net

[1] QPB Dictionary of Ideas. Quality Paperback Book Club. (New York: Helicon Publishing Ltd., 1995 in the United Kingdom under the title The Hutchinson Dictionary of Ideas), page 108, Common Law.
[2] Cambridge text in the History of Political Thought, CUP, 1997. Law: Sovereignty in the British Doctrine (From Bracton to Dicey). Notes by Joaquin Varela Suanzes in http://www.murdoch.edu.au/elaw/issues/v6n3/suanzes63_%20notes.html
Fortescue, John. The Governance of England: Otherwise called the Difference between an Absolute and Limited Monarchy. Editor Charles Plummer. London: Oxford University Press, 1885. Reprinted 1999 by the Law Book Exchange, Ltd.
[3] http://www.answers.com/commonlaw
[4] The Illinois Sheriff. Spring 2005. A magazine published by the Illinois Sheriff Association. “Roots. A Historical Perspective of the Office of the Sheriff”. By DeKalb County Sheriff Roger Scott. Pages 6-7.
[5] Anderson’s Manual for Notaries Public. Fifth Edition. Gilmer, Wesley, Jr., B.A., M.S.L.S., J.D. W.H. Anderson Company. Cincinnati, 1966. Chapter 1, Page 2.
[6] The Week. July 6-13, 2007. News. Main Stories. “The Roberts Court Charts a new direction”.

Focus on Essential Issues for the Right to Repair Lombard Historical Real Estate Property in the State of Illinois, Du Page County, USA

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’ RESPONSE/ANSWER TO SUMMONS
COUNTERPOINT: AT ISSUE LEGAL MEMORANDUM IN OPPOSITION FOR THE DEFENDANTS’ COMPULSORY COUNTERCLAIMS TO SETOFF/OFFSET THE VERIFIED COMPLAINT FOR DEMOLITION AND FOR INJUNCTIVE RELIEF FROM PLAINTIFF ON LEGAL GROUNDS FOR “ACTION IN TROVER”, CRIMINAL CONVERSION OF PROPERTY, CONSUMER SERVICE FRAUD, BREACH OF THE FAIR HOUSING PARTNERSHIP RESOLUTION CONTRACT, REAL ESTATE LIABILITY FOR LOMBARD OLD HOUSES
MOTION TO DISMISS AND STRIKE, “DEMURRER”
Defendants’ Do Not Plead Guilty;
Defendants’ Objection to Wrongful Citations for Lombard Municipal Violations
PURSUANT TO THE HATE CRIMES LOCAL LAW ENFORCEMENT ENHANCEMENT ACT, VICTIMS OF CRIME ACT, ILLINOIS HUMAN RIGHTS ACT WITH PROTECTIONS IN HOUSING UNDER THE LAW; U.S. department of housing and urban development act (hud); USA PATRIOT ACT: pRESERVING LIFE AND LIBERTY (2001); Defendants’s COMBINED §2-615 MOTION TO STRIKE AND §2-619 MOTION TO DISMISS BASED ON WRONGFUL CHARGES, MALICIOUS PROSECUTION, ABUSE OF THE LEGAL PROCESS AND PURSUANT TO ILCS 720 5-31 PRESUMPTION OF INNOCENCE AND PROOF OF GUILT;
Attn. Honorable Judge, Chancery Division To: Honorable 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, 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

DEFENDANTS’ RESPONSE/ANSWER TO SUMMONS
COUNTERPOINT: AT ISSUE LEGAL MEMORANDUM IN OPPOSITION TO SUPPORT THE DEFENDANTS’ COMPULSORY COUNTERCLAIMS TO SETOFF/OFFSET THE VERIFIED COMPLAINT FOR DEMOLITION AND FOR INJUNCTIVE RELIEF FROM PLAINTIFF ON LEGAL GROUNDS FOR “ACTION IN TROVER”, CRIMINAL CONVERSION OF PROPERTY, CONSUMER SERVICE FRAUD, BREACH OF THE FAIR HOUSING PARTNERSHIP RESOLUTION CONTRACT, REAL ESTATE LIABILITY FOR LOMBARD OLD HOUSES

Defendants hereby represented by Gardenia C. Hung, Trustee for the Roberto Hung Supplemental Care Trust, as Defendant PRO SE, legal Lombard resident Homeowner and Taxpayer in Du Page County, U.S. citizen at 502 S. Westmore Avenue, Lombard, Illinois 60148-3028, USA, and as a Du Page County Notary Public, commissioned by the State of Illinois, appear in person to respond/answer in opposition to the Plaintiff’s Verified Complaint for Demolition and for Injunctive Relief to deny, dispute, and oppose each and every other allegation, since facts of evidence, laws, and prior court decisions for these consolidated actions do not support the Verified Complaint as follow:
· Count I, Demolition for Dangerous and Unsafe Building
· Count II, Statutory Injunction
· Preliminary Injunction and Permanent

Defendants hereby present a Motion to Dismiss and Strike the Verified Complaint
for Demolition and for Injunctive Relief based on the following legal grounds:
1. Technically, Plaintiff raises false arguments, contrary-to-facts of evidence which are incomplete and lack valid, legal foundation, in order to incriminate the Defendants in malicious prosecution and abuse of the legal process, pursuant to ILCS 720 5-31, Presumption of Innocence and Proof of Guilt. Consequently, Defendants do not plead guilty to each and every allegation presented in the Verified Complaint, since none of the persons in the Hung Family has been at home when the Village of Lombard et al. and other accomplices as Plaintiff have arranged and authorized access entry to cause extensive damages and losses to the Lombard property at 502 S. Westmore Avenue and Washington Blvd., in Du Page County, Illinois, USA, purchased and paid in full with cash retirement funds by the late Mr. Roberto Hung, J.D. in September 1996 with eldest daughter, Gardenia C. Hung as a witness.
2. On legal merits, Defendants present opposition to same Verified Complaint since facts of evidence, laws, and prior court decisions do not support any of the Plaintiff’s Motion for Demolition and for Injunctive Relief which raises false arguments which lack foundation since Gardenia C. Hung already has presented the Hung Family’s proposal for Restoration, Remodeling, Repair and Re-Construction of the distressed Hung Family Real Estate Property, due to “Criminal Conversion” used by Plaintiff as “Access to Crime”, authorized and arranged by the Lombard Police Department, under Chief Raymond Byrne, and the Fire Department Bureau of Inspectional Services, Keith Steiskal, under Chief George Seagraves, with accomplices John and Eva Carpenter, sons, handymen, construction associates, friends, and others from the community-at-large in Du Page County, Illinois.
3. Defendants hereby present Objections with their Motion to Dismiss and Strike, before the 18th Judicial Circuit Court, in order to “demurrer”, dispute, and oppose the Verified Complaint for Demolition and for Injunctive Relief, based upon 2007 Construction Statistics Reports and public records which indicate that for Lombard Historical Real Estate Property --“it is more expensive to demolish and destroy real estate property at today’s prices and cost of construction materials, than to restore, repair, and rebuild historical real estate property”—“which can be remodeled and reconstructed for damages and losses” due to disaster, disrepair, “Conversion of Property” as an “Access to Crime” caused and authorized by Plaintiff under Lombard unethical real estate service practices.
4. Defendants deny and dispute the same Verified Complaint based on Plaintiff’s speculations which state improper opinions, based on lack of foundation for irrelevant arguments, contrary-to-fact.
5. Furthermore, Defendants, hereby represented by Gardenia C. Hung continue to oppose, deny, and dispute each and every allegation in the same Verified Complaint based on additional Objections to the Plaintiff’s “Improper Character References” and lack of facts of evidence for the false concern about the health risk and safety of Gardenia C. Hung, in order to prevent the Defendants from residing, inhabiting, and protecting the Hung Family Real Estate Property after Plaintiff has caused and authorized SBC Telephone Company in Illinois/Indiana, Edward Westenholtz, and other trespassers, intruders, criminals, vandals, and other accomplices to jump the backyard fence, adjoining the Carpenter family driveway, in order to damage and destroy existing roofing structures and penetrate the Hung Family Real Estate Property in Lombard, Du Page County, Illinois, USA.
6. Defendants hereby present legal Compulsory Counterclaims to Setoff/Offset the Plaintiff’s Verified Complaint for Demolition and for Injunctive Relief that arises from “Action in Trover” and is otherwise connected with the same real estate controversy over the Hung Family Real Estate 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.
7. WHEREBY, 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.

DEFENDANTS’ HEREBY ESTABLISH COMPULSORY COUNTERCLAIMS TO SETOFF/OFFSET THE VERIFIED COMPLAINT FOR DEMOLITION AND FOR INJUNCTIVE RELIEF FROM PLAINTIFF PRESENTED BY THE DEFENDANTS ON LEGAL GROUNDS FOR “ACTION IN TROVER”, CRIMINAL CONVERSION OF PROPERTY, CONSUMER SERVICE FRAUD, BREACH OF THE FAIR HOUSING PARTNERSHIP RESOLUTION CONTRACT, REAL ESTATE LIABILITY FOR LOMBARD OLD HOUSES. Defendants’ Do Not Plead Guilty; Defendants’ Objection to Wrongful Citations for Lombard Municipal Violations PURSUANT TO THE HATE CRIMES LOCAL LAW ENFORCEMENT ENHANCEMENT ACT, VICTIMS OF CRIME ACT, ILLINOIS HUMAN RIGHTS ACT WITH PROTECTIONS IN HOUSING UNDER THE LAW; u.s. department of housing and urban development act (hud); the homeowners repair act, housing and community development act (1974), federal fair housing acts, the federal trade commission act (FTC, 15 USC § 45 et seq. and 16 CFR, subsequent illinois statutes for consumer service protection against consumer service fraud, deceptive business practices, and prohibited practices established by the illinois general assembly, under the constitution of the united states and under god. subsequent to the USA PATRIOT ACT: pRESERVING LIFE AND LIBERTY (2001); Defendants’s COMBINED §2-615 MOTION TO DIMISS AND §2-619 MOTION TO DISMISS BASED ON WRONGFUL CHARGES, MALICIOUS PROSECUTION, ABUSE OF THE LEGAL PROCESS AND PURSUANT TO ILCS 720 5-31 PRESUMPTION OF INNOCENCE AND PROOF OF GUILT;
DEFENDANTS’ STATEMENTS OF FACT
Pursuant to the Constitution of the State of Illinois, Article I, in the Bill of Rights, Gardenia C. Hung and the Hung Family, are entitled to the same laws for protection of their real estate property under God and the United States of America , as follows:
Section 2.- Due Process and Equal Protection. No person shall be deprived of life, liberty or property without due process of law nor be denied the equal protection of the laws.
Section 8.1.- Crime Victims’ Rights.
Section 12.- Right to Remedy and Justice. Every person shall find a certain remedy in the laws for all injuries and wrongs which she/he receives to her/his person, privacy, property or reputation. She/He shall obtain justice by law, freely, completely, and promptly.
Section 15.- Right to Eminent Domain. Private property shall not be taken or damaged for public use without just compensation as provided by law. Such compensation shall be determined by a jury as provided by law.
Section 20.- Individual Dignity. To promote individual dignity, communications that portray criminality, depravity or lack virtue in, or that incite violence, hatred, abuse or hostility toward, a person or group of persons by reason of or by reference to religious, racial, ethnic, national or religious affiliation are condemned.
Plaintiff, as the Village of Lombard, et al. is barred from pursuing the cause of action stated in the Verified Complaint for Demolition and for Injunctive Relief under the State of Illinois applicable statutes of limitations for Negligence Per Se actions for “Criminal Conversion of Property” owned by the Defendants, since the hateful, heinous crimes occurred more than two (2) years ago and have been taking place repeatedly and continuously for the last fourteen (14) years, from 1993 through 2004, 2005, 2006, and to date, in 2007.
· On Count I, Demolition of Dangerous, Unsafe Building, Defendants deny, dispute, and oppose, each and every allegation of the Plaintiff’s Verified Complaint for Demolition of Dangerous and Unsafe Building, on legal grounds for information and belief, based on the Tort of Conversion and unethical business real estate practices, since the Village of Lombard, the Police Department under Chief Raymond Byrne, the Bureau of Inspectional Services Inspector Keith Steiskal, the Fire Department under Chief George E. Seagraves, neighboring accomplices John and Eva Carpenter and sons with friends, handymen, associates, and family, have all criminally, maliciously, and deliberately altered in “Conversion” and damaged the Hung Family Real Estate Property at 502 S. Westmore Avenue and Washington Blvd. in Lombard, Du Page County, to cause a disaster, disrepair, and distress in the same property for the purpose of the depreciation of equity value since 1993 through 2004, 2005, 2006, and to date in 2007. This Lombard brick bungalow house with 3-stories, 2-car garage, and 4-car driveway, has been misused, abused, and victimized as an “Access to Crime”, along with all the Defendants who have been subject to personal injury surrounding homeownership of the same Lombard real estate property.
· On Count II, Statutory Injunction, Defendants deny, dispute, and oppose each and every allegation of the Plaintiff’s Verified Complaint for Statutory Injunction, on legal grounds, information, and belief based on the Plaintiff’s Intentional Interference with the Defendants Personal Health, Well Being, and Right to Privacy in Real Estate Property Rights, which constitutes a “Private Nuisance” by the Village of Lombard et al., John and Eva Carpenter and Family, who are adjoining neighbors by the driveway at 504 S. Westmore-Meyers Road in Lombard, SBC Telephone Company in Illinois/Indiana, Edward Westenholtz, and the community-at-large in Du Page County, Illinois—-who have been all harmful and destructive of the Hung Family Real Estate Property. For the record, Plaintiff interferes with the Defendants’ peace of mind due to constant harassment, hateful and heinous criminal acts, malicious prosecution, and abuse of human rights in housing and the abuse of the legal process.
· On Count III, Preliminary and Permanent Injunction, Defendants deny, dispute, and oppose each and every allegation of the Plaintiff’s Verified Complaint for Preliminary Injunction on legal grounds, information, and belief based on the Plaintiff’s Breach of Duty for Consumer Service Fraud, Deceit, and Misrepresentation of the Village of Lombard residential homeowners’ services by “Criminal Conversion” of Real Estate Property owned by the Hung Family which has been altered, damaged, and victimized to become a distressed Lombard house, improperly “Induced” with Lombard Police “Access to Crime” arranged with drugged addicts as trespassers, intruders, repeat offenders as criminals, vandals, and real estate trickery, deception, and fraud in the sale of property by the Village of Lombard et al. who authorizes damages and losses to the Hung Family Property in order to depreciate the equity value of the same real estate property. For the record, Plaintiff interferes and constantly invades Gardenia Hung’s privacy since 1993 and to date in 2007, for the last fourteen years (14) years; furthermore, the Village of Lombard et al. interferes with the Defendants’ reputation and is subject to “Defamation of Character”, “Slander” and “Libel”. In addition, Plaintiff is also subject to and liable for interference with the Defendants’ Real Estate Property Rights, causing undue real property theft, burglary, annoyance, inconvenience, discomfort, and even “Personal Injury” to the Defendants which have been abused, victimized, kidnapped, set up for accidents, hospitalized, disabled, and even murdered. Plaintiff, as the Village of Lombard et al., to include the neighbors John and Eva Carpenter and sons, the community-at-large in Lombard and in Du Page County constitute for the Defendants a “Private Nuisance” which is arranged by the Lombard Police Department, under Chief Raymond Byrne and District 5 Police in particular, and Keith Steiskal, Lombard Fire Department Bureau of Inspectional Services, under Chief George Seagraves, and other accomplices reported to U.S. law enforcement agencies under terrorism, bioterrorism, threats, coercion, and intimidation of the Hung Family members which is punishable and prosecuted by law in the State of Illinois, under the Constitution of the United States, under God. Whereby Defendant and the Hung Family require a public apology from Plaintiff, the City of Lombard et al.
Defendants’ Statements of Legal Authorities
Defendants assert the following affirmative defense on valid legal grounds supported by U.S. legal authorities and international courts of law for human rights around the world, beyond a reasonable doubt, based upon the preponderance of evidence on public record and on file for the following legal case actions consolidated in the U.S. Supreme Court and in the 18th Judicial Circuit Court, in the County of Du Page, in the State of Illinois, United States of America, as follow:
Case No.:2007CH001284 Consolidated, Case No.:2006OV005982, LO25448NT; Case No.:2006OV005983, LO25449NT; Case No.:2006OV004446, LO12418NT; LO12419NT
DEFENDANTS HEREBY ESTABLISH LEGAL GROUNDS BASED ON INFORMATION AND BELIEF FOR LEGAL “ACTION IN TROVER”, CRIMINAL CONVERSION OF PROPERTY AS ACCESS TO CRIME, CONSUMER SERVICE FRAUD, BREACH OF THE FAIR HOUSING PARTNERSHIP RESOLUTION CONTRACT, REAL ESTATE LIABILITY FOR LOMBARD OLD HOUSES; Defendants’ Do Not Plead Guilty;
Defendants’ Objection to Wrongful Citations for Lombard Municipal Violations
PURSUANT TO THE HATE CRIMES LOCAL LAW ENFORCEMENT ENHANCEMENTE ACT, VICTIMS OF CRIME ACT, ILLINOIS HUMAN RIGHTS ACT WITH PROTECTIONS IN HOUSING UNDER THE LAW; u.s. department of housing and urban development act (hud); USA PATRIOT ACT: pRESERVING LIFE AND LIBERTY (2001); Defendants’s COMBINED §2-615 MOTION TO STRIKE AND §2-619 MOTION TO DISMISS BASED ON WRONGFUL CHARGES, MALICIOUS PROSECUTION, ABUSE OF THE LEGAL PROCESS AND PURSUANT TO ILCS 720 5-31 PRESUMPTION OF INNOCENCE AND PROOF OF GUILT; SUBSEQUENT TO THE FOLLOWING U.S. LEGISLATION:
· 815 ILCS 505/1 ET SEQ. CONSUMER FRAUD AND DECEPTIVE BUSINESS PRACTICES ACT (CFDBPA). 815 ILCS 505/2. PROHIBITED PRACTICES. 815 ILCS 510/1 ET SEQ. UNIFORM DECEPTIVE TRADE PRACTICES ACT (UDTPA)
· FEDERAL TRADE COMMISSION ACT (FTC), 15 USC § 45 ET SEQ. AND 16 CFR
· COMMON LAW CONVERSION
· COMMON LAW FRAUD
· DOCTRINE OF NEGLIGENCE PER SE
· FAIR HOUSING ACT (1968)
· HOUSING AND COMMUNITY DEVELOPMENT ACT (1974)
· FAIR HOUSING AMENDMENTS ACT (1988)
· FEDERAL FAIR HOUSING ACT (TITLE VIII OF THE CIVIL RIGHTS ACT OF 1968)
· U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT ACT (HUD)
· ILLINOIS HOME REPAIR ACT
· National Environmental Policy Act (NEPA) (1969)
· THE CONSTITUTION OF THE UNITED STATES OF AMERICA, FIRST SECTION, FOURTEENTH AMENDMENT, FIFTH AND SIX AMENDMENTS
· THE CONSTITUTION OF THE STATE OF ILLINOIS . ARTICLE I. THE BILL OF RIGHTS
· FAIR CREDIT BILLING ACT
· THE MAGNUSON-MOSS WARRANTY FEDERAL TRADE COMMISSION ACT (FTC) (15 U.S.C. §2302)
· THE FREEDOM OF INFORMATION ACT (FOIA) 5 U.S.C. § 552, AS AMENDED BY PUBLIC LAW NO. 104-231, 1100 STAT. 3048, WHICH ALLOWS VICTIMS OF CRIME TO ACCESS INFORMATION FROM CRIMINALS WHO PERSECUTE THEM.
· THE ILLINOIS EQUAL JUSTICE ACT. 30 ILCS 765/1 ET. SEQ. THE ACT RECOGNIZES THAT EQUAL ACCESS TO OUR LEGAL SYSTEM IS A BASIC RIGHT FOR ALL ILLINOIS RESIDENTS, REGARDLESS OF THEIR INCOME. THE ACT PROMOTES A RANGE OF INNOVATIVE, COST-EFFECTIVE STRATEGIES FOR MEETING THE CIVIL LEGAL NEEDS OF ALL ILLINOIS RESIDENTS. THE ACT ALSO CREATED THE ILLINOIS EQUAL JUSTICE FOUNDATION TO DISTRIBUTE FUNDING APPROPRIATED BY THE STATE OF ILLINOIS TO SUPPORT LEGAL AID PROGRAMS.
· FAIR CREDIT BILLING ACT
Pursuant to the Constitution of the State of Illinois, Article I, in the Bill of Rights, Gardenia C. Hung and the Hung Family, are entitled to the same laws for protection of their real estate property under God and the Constitution of the United States of America , as follows:
Section 2.- Due Process and Equal Protection. No person shall be deprived of life, liberty or property without due process of law nor be denied the equal protection of the laws.
Section 8.1.- Crime Victims’ Rights.
Section 12.- Right to Remedy and Justice. Every person shall find a certain remedy in the laws for all injuries and wrongs which he receives to her/his person, privacy, property or reputation. She/He shall obtain justice by law, freely, completely, and promptly.
Section 15.- Right to Eminent Domain. Private property shall not be taken or damaged for public use without just compensation as provided by law. Such compensation shall be determined by a jury as provided by law.
Section 20.- Individual Dignity. To promote individual dignity, communications that portray criminality, depravity or lack virtue in, or that incite violence, hatred, abuse or hostility toward, a person or group of persons by reason of or by reference to religious, racial, ethnic, national or religious affiliation are condemned.
WHEREBY, Defendants support this Motion to Dismiss and Strike the same Verified Complaint for Demolition and for Injunctive Relief, with the Defendants’ Compulsory Counterclaims to Setoff/Offset, not only to deny, dispute, and oppose each and every one of the Plaintiff’s allegations, but also to accuse the Plaintiff as the Village of Lombard et al. of the charges for “Criminal Conversion” of the Hung Family Real Estate Property, which now in 2007, remains as a Lombard real estate property, criminally damaged and distressed due to the Village of Lombard’s accountability for Consumer Service Fraud, breach of the Fair Housing Partnership Resolution contract and liability for Lombard Real Estate Old Houses in Du Page County, Illinois, USA.

COUNTERARGUMENT: IN SUPPORT OF THE DEFENDANTS’ MOTION TO DISMISS AND STRIKE THE VERIFIED COMPLAINT FOR DEMOLITION AND FOR INJUNCTIVE RELIEF AND TO ESTABLISH COUNTERCLAIMS TO SETOFF/OFF SET THE SAME VERIFIED COMPLAINT
Please Take Notice that Plaintiff as the Village of Lombard, represented by Counsel Howard C. Jablecki et al. from the Law Firm of Klein, Thorpe, and Jenkins, Ltd. is legally liable and “Guilty” of the Tort of “Criminal Conversion” in this legal “Action in Trover” surrounding the Hung Family Real Estate Property at 502 S. Westmore Avenue, Lombard in Du Page County, Illinois, USA. The Village of Lombard and other accomplices have all “misused and borrowed” Hung Family assets and real estate property without authorization, permission, or legal power of attorney issued by Gardenia C. Hung or any of the Defendants in this legal matter.
For the record, Plaintiff is deliberately and criminally responsible for altering with disaster, destruction, damages, and losses, the Lombard historical bungalow owned by Gardenia C. Hung as Defendant(s), since the Hung Family Real Estate Property was purchased by her late father, Mr. Roberto Hung, J.D.,--former attorney, judge, and prosecutor--in 1993 and paid fully in 1996 with cash retirement funds at the First State Bank of Maple Park in Illinois, witnessed by his eldest daughter, Gardenia C. Hung, an Illinois Notary Public. Let it be known that during June 1998, the late Mr. Roberto Hung was murdered at Vencor Northlake Hospital in Northlake, Cook County , Illinois , following hospitalization at Elmhurst Memorial Hospital in Elmhurst , Du Page County, Illinois . The Roberto Hung Supplemental Care Trust was legally settled and closed during January 1999 before presiding Judge Robert E. Byrne in the 18th Judicial Circuit Court, in the County of Du Page, State of Illinois, United States of America. Gardenia C. Hung was the appointed Executor, as Trustee with Robert S. Hung. The Village of Lombard and other accomplices have been harmful as destructive service operatives who are directly responsible and liable for the Hung Family Real Estate Consumer Service Fraud, Damages, Losses, and Disrepair for Lombard Plumbing Failure, Roofing and Landscaping Criminal Activity, Sabotage and Destruction of All (9) Nine Motor Vehicles owned by the Hung Family and registered under the State of Illinois, Office of the Secretary of State, Motor Vehicles and Drivers License Facilities, in order to depreciate real assets for distressed real estate property belonging the Defendants so that they lose equity value as resident homeowners in Lombard, Du Page County, Illinois, USA.
Plaintiff interferes with the Hung Family’s legal possession of real property and homeownership as an “Access to Crime” which is subject to prosecution for altering and misusing this Lombard historical bungalow to arrange criminal activity, as evidenced by the visible damages and losses in excess of $50,000, as follow:
· Plaintiff has been instrumental in the removal and damage of existing public utilities, that is to say, Lombard residential telephone lines, electricity, gas, water service, sewage, waste management, etc. without the authorization or permission of the Hung Family.
· Plaintiff as the Village of Lombard et al. has arranged disrepair and damages through trespassers and unauthorized access entry into the Hung Family Real Estate Property, in order to depreciate the same Lombard historical bungalow as a distressed property to lose the Hung Family homeowners’ equity value upon sale of the same by the Village of Lombard realtors.
· Defendants are hereby establishing Counterclaims to Setoff/Offset the Verified Complaint for Demolition and for Injunctive Relief as a legal demand for financial restitution and cash relief as full compensation from the Plaintiff for “Criminal Conversion” of the Hung Family Real Estate Property for the last (14) fourteen years, from 1993 through 2004, 2005, 2006, and to date in 2007.
· Plaintiff as the Village of Lombard is subject to prosecution for “Breach of Duty” on legal grounds, facts of evidence, and belief for Negligence Per Se. The Village of Lombard and other accomplices refuse services, do not respond, and act unreasonably, unlawfully, unethically, and criminally arranged by the Lombard Police Department, under Chief Raymond Byrne and the Lombard District 5 Police, John and Eva Carpenter, handymen, associates, public utility operatives for Nicor Gas, Commonwealth Edison Electric Company, SBC Telephone Company in Illinois/Indiana, Edward Westenholtz, the Village of Lombard Water Service and Sewage under Public Works, Waste Management of Illinois, Keith Steiskal and Chris Hanigan for the Bureau of Inspectional Services, Lombard Fire Department, under Chief George Seagraves, and the community-at-large in Lombard and Du Page County, Illinois.
· Plaintiff’s carelessness directly has caused damages, losses and disrepair to the Hung Family Real Estate Property in Lombard, as well as personal injury, forced hospitalization arranged by the Lombard Police Department, physical disabilities, and other inconveniences to the Defendants themselves in this legal response to the Verified Complaint filed by Counsel Howard C. Jablecki et al. on behalf of the Village of Lombard.
· For the record, Defendants are currently suffering from economic losses and damages, criminal disrepair in real estate property, personal injuries, and psychological distress as human beings, due to the Plaintiff’s malicious and insidious “Criminal Conversion” of the Hung Family Real Estate Property in Lombard, Du Page County, Illinois, USA.
· The Village of Lombard et al. and All Employees as Plaintiff, have violated legal terms of service and management without authorization, legal power of attorney, or permission from Gardenia C. Hung for the Hung Family Real Estate Property in Lombard.
· Let it be known that Gardenia C. Hung does not suffer from any of the health-related allegations cited and reported by Keith Steiskal and George Seagraves for the Bureau of Inspectional Services under the Lombard Fire Department.
· By law in the State of Illinois and under the Constitution of the United States, Defendants are entitled to recover in cash all damages and losses equal to the value of the Hung Family Assets and Real Estate Property for the last (14) fourteen years from Plaintiff, as the Village of Lombard, as Counterclaims to Setoff/Offset the Verified Complaint for Demolition and for Injunctive Relief; plus the reimbursement of all court costs, fees, and extraneous legal expenses incurred by the Defendants during the course of all legal proceedings involving the same Lombard historical bungalow, since 1993 to date in 2007, for the last (14) fourteen years.
· Defendants hereby establish Counterclaims to Setoff/Offset the same Verified Complaint for Demolition and for Injunctive Relief as a response/answer in this legal “Action in Trover”, in order to recover all damages and losses, as well as compensate “Personal Injury” during the course of “Criminal Conversion” of the Hung Family Real Estate Property by Plaintiff as the Village of Lombard et al., who have altered, misused, borrowed and kept real property, abused, and victimized not only the Lombard Historical Bungalow, but also members of the Hung Family and others, based on facts of injury, forced hospitalizations, information, and belief.
· All the Defendants hereby demand a personal and written apology from Plaintiff as the Village of Lombard, et al. in Du Page County, Illinois, USA.
WHEREBY, DEFENDANTS ET AL. PRAY FOR FINANCIAL REMEDY AND MONETARY RELIEF AS COMPULSORY COUNTERCLAIMS TO SET OFF/OFFSET THE VERIFIED COMPLAINT FOR DEMOLITION AND FOR INJUNCTIVE RELIEF AGAINST THE PLAINTIFF, AS THE VILLAGE OF LOMBARD . DEFENDANTS DENY, DISPUTE AND OPPOSE EACH AND EVERY ALLEGATION PRESENTED BY THE PLAINTIFF IN ORDER TO DEMAND THE COURT’S PROTECTION, WITH PRELIMINARY AND PERMANENT INJUNCTIVE RELIEF, SO THAT PLAINTIFF “CEASE AND DESIST” HARASSMENT AND INTERFERENCE ARRANGED BY THE VILLAGE OF LOMBARD ET AL. WHO IS SUBJECT TO CRIMINAL PROSECUTION, IN JUSTICE, EQUITY, AND JUDGEMENT AGAINST THE PLAINTIFF’S VERIFIED COMPLAINT FOR DEMOLITION AND FOR INJUCTIVE RELIEF ON ALL COUNTS. WHEREFORE, DEFENDANTS, GARDENIA C. HUNG, ROBERT S. HUNG, ET AL. PRAY THAT THIS MOTION TO DISMISS AND STRIKE EACH AND EVERY COUNT IN THE VERIFIED COMPLAINT FOR DEMOLITION AND FOR INJUNCTIVE RELIEF FILED BY THE PLAINTIFF, BE SUSTAINED FOR 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, 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 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 $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 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 June 9th, 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: June 9, 2007 Signed by:____________________________________
(Reserved Signature) Gardenia C. Hung, M.A.

In the County of Du Page , in the State of Illinois
United States of America

Saturday, January 5, 2008

Illinois Homeowner's Constitutional Right To Repair Real Estate Property

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’ RESPONSE/ANSWER TO SUMMONS

Attn. Honorable Judge, Chancery Division To: Honorable 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, 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

DEFENDANTS’ MOTION FOR OBJECTION TO THE VERIFIED COMPLAINT FOR DEMOLITION AND FOR INJUNCTIVE RELIEF

Now comes Gardenia C. Hung as Pro Se, once again, on behalf of the Defendants to present this Motion for Objection to the Plaintiff’s Verified Complaint for Demolition and for Injunctive Relief 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, 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;
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 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
This Court’s order on Monday, November 29, 2007 by Judge Kenneth Popejoy, based on “improper use of language and fancy legal terms” which is so deficient as to require a Judicial Review for Reconsideration pursuant to legal, constitutional grounds.

Defendants hereby object to the Verified Complaint for Demolition and for Injunctive Relief in this petition to redress grievances as victims of crime. Consequently, 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).
Defendants hereby 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.
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 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 for Objection to the Verified Complaint for Demolition and for Injunctive Relief, based upon constitutional grounds, as noted, and proposed plans for restoration and historical preservation of Lombard real estate property at cost by 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, upon judicial review for reconsideration with justice, equity, and fairness, under God. Defendants petition for additional relief and financial remedy 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 November 26, 2007, 10H11AM
Signed by: __________________________ Gardenia C. Hung, M.A.
In the County of Du Page, State of Illinois, United States of America
______________________________________________
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. ROBERTO HUNG, J.D.

I. BRICK BUNGALOW HOUSE WITH 3-LEVELS: 1ST FLOOR, 2ND FLOOR, BASEMENT, GARAGE
A. FIRST FLOOR.- FOYER/LOBBY FRONT.- DAMAGED DOOR LOCK,SHUT
1. CEILING PANELS STAINED, CRACKED
2. GLASS WINDOW PANES, 6TH WINDOW SOUTH, CRACKED GLASS
8TH WINDOW SOUTH, CRACKED GLASS
3. DOOR BELL IS BROKEN
4. DOOR KNOB IS BROKEN, FORCED
5. DOOR PANEL, STAINED BY FORCED ENTRY
6. DOOR LOCK/KNOB IS BROKEN, FORCED
7. FRONT STEPS, CHIPPED CONCRETE
8. BRICK BASE NEEDS TUCKPOINTING
B. LIVING ROOM.- 25-GALLON AQUARIUM, DEAD FISH, POISONED CLOROX
1. FLOOR-DRILLED HOLE BY UNAUTHORIZED CABLE CONTRACTOR
2. SOUTH WALL SEEPAGE, PEELING PAINT, CRACKED WALLS
3. SOUTH WALL DAMAGE TO ELECTRICAL WIRING SYSTEM
4. CEILING CRACKED, PEELING PAINT
C. DINING ROOM
1. CEILING BULGING TILES, FALLING TILES ON THE WEST CORNER
2. WINDOW GLASS BULLET HOLE, UPPER LEFT GLASS PANE, CRACKED
GLASS WINDOW PANE
3. CARPETING.- WALL-TO-WALL DAMAGE
D. MASTER BEDROOM
1. COLLAPSED CEILING OVER TEAK QUEEN-SIZE BEDROOM SET, VANITY
(2) CHEST OF DRAWERS, (2) NIGHT STAND TABLES, (2) LAMPS
2. WALLS DAMAGED BY MOLD, MILDEW, WATER SEEPAGE
3. CARPETING WALL-TO-WALL DAMAGED
E. CORRIDOR
1. FLOOR WARPED WOODEN PLANKS TO BE REPLACED
2. CARPETING WALL-TO-WALL DAMAGED
3. CEILING GYPSUM COLLAPSED, CRACKED
4. ELECTRICAL WIRING SYSTEM DAMAGED BY WATER SEEPAGE
F. BATHROOM
1. CEILING COLLAPSED WHEN PLUMPING PIPES AND FIXTURES BURST
DUE TO EXCESSIVE WATER PRESSURE UNGAUGED BY THE LOMBARD
WATER DEPARTMENT AND PUBLIC WORKS
2. CEILING WOODEN STRUCTURE DAMAGED BY WATER SEEPAGE
3. PLUMBING PIPES AND FIXTURES DAMAGED
G. GUEST BEDROOM (SOUTHWEST FACING BACKYARD) STUDY
1. CLOSET IS DAMAGED BY PLUMBING PIPES BURSTING DUE TO
UNGAUGED WATER PRESSURE
2. WATER SEEPAGE IN CLOSET ACCESS TO PLUMBING PIPES SHARED BY
THE BATHROOM AND THE BASEMENT LEVELS.
G. STOLEN CLOTHING, BOOKS, FAMILY PHOTOGRAPHS, DOCUMENTS
U.S. DEPARTMENT OF LABOR FILES BELONGING TO GARDENIA C. HUNG
H. KITCHEN
1. SINK PLUMBING PIPES ARE TURNED OFF
2. FLOOR TILES ARE CRACKED, WATER-LOGGED, TO BE REPLACED
3. CEILING PAINT CRACKED, PEELING
4. REFRIGERATOR IS DAMAGED
5. DISHWATER IS DAMAGED
6. DISHES ARE BROKEN
I. BASEMENT
1. PLUMBING PIPES BURST DUE TO UNGAUGED WATER PRESSURE
2. COLLAPSED CEILING, CRACKED, EXPOSED PIPES, MOLD, MILDEW
3. WATER SEEPAGE, HUMIDITY, MOLD, MILDEW
4. WALLS CRACKED, PEELING PAINT
5. GLASS VENTS CLOSED/OPEN SCREENS BROKEN, TO BE REPLACED
6. (2) REFRIGERATORS DAMAGED – VERTICAL UPRIGHT/HALF FRIDGE
7. POOL TABLE GREEN MAT IS DAMAGED
8. BAR DAMAGED DUE TO COLLAPSED CEILING, MOLD, MILDEW
9. WASHING MACHINE IS DAMAGED
10. HEATING FURNACE SYSTEM/AIR CONDITIONING IS DAMAGED
11. STORAGE ROOM, BOOK SHELVES, STOLEN BOOKS BY INTRUDERS
12. STORAGE ROOM INSULATION TO BE REPLACED, FINISHED
13. LAUNDRY ROOM, CEILING FIXTURE PANEL CRACKED, BROKEN
14. CEILING PANEL PULLED DOWN
15. WALL PAINT CRACKED, PEELING
J. BACK PORCH.- INTRUDERS USED A HEAT TORCH ON PAINT BEHIND DOOR
CRACKED WOODEN BEAM BY THE WINDOW
1. CEILING LEAKAGE ON RAINY DAYS
2. LIGHT FIXTURE AND ELECTRICAL SYSTEM IS WATER DAMAGED
3. DOOR BELL IS BROKEN, FORCED, PULLED OUT BY INTRUDERS
4. DOOR BELL WIRING IS PULLED OUT
5. DOOR SCREEN IS DAMAGED, INSIDE, OUTSIDE, TORN OFF FROM HINGES, DROPPED OFF, TO BE REPLACED
6. PORCH DOOR IS DAMAGED, CRACKED PAINT, PEELING TO BE REPLACED
7. GLASS DOOR KNOBS DAMAGES TO BE REPLACED
II. SECOND FLOOR
1. STAIRS, STEPS.- WOODEN, WATER STAINED, GLASS DOOR KNOB IS
DAMAGED, BROKEN
2. WALLS, CEILING PAINT CRACKED, PEELING
3. STORAGE ROOM INSULATION IS DAMAGED BY INTRUDERS TO BE
REPLACED AND REFINISHED
A. STUDY/HALF BEDROOM
1. PAINT CRACKED, PEELING
2. DAMAGED TO PROFESSIONAL COMPUTER PC EQUIPMENT, STOLEN
CD-ROM DRIVE. STOLEN DOCUMENTS FROM MR. ROBERTO HUNG
B. BEDROOM
1. CLOSED IS DAMAGED BY WATER SEEPAGE, MOLD, MILDEW,
CRACKED WALL
2. CEILING LIGHT FIXTURE CRACKED AND BROKEN GLASS OVER BED
C. KITCHEN
1. CEILING CRACKED AND PAINT PEELING CAUSED BY HEAT TORCH USED BY INTRUDERS, TRESPASSERS AND UNAUTHORIZED ENTRIES
D. PANTRY, TO BE RESTORED, REMODELED, REPAINTED, REFINISHED
1. PANTRY CEILING PAINT CRACKED, PEELING, MOLD, MILDEW
2. PANTRY STORAGE DOOR CRACKED, MOLD, MILDEW, REPLACE
E. BATHROOM, PLUMBING PIPE FIXTURES BURST FROM 2ND TO 1ST FLOOR
PAINT CRACKED, PEELING, TO BE RESTORED, REMODELED, REDONE
F. LIVING ROOM FURNITURE STAINED AND DAMAGED
1. CEILING CRACKING, FISSURE UNDER ROOFING STRESS
2. WALL RETAIN HUMIDITY, MOLD, MILDEW
III. GARAGE
1. GARAGE DOOR OPENER IS BROKEN, DAMAGED, SEARS BRAND
2. REPLACE GARAGE DOOR
3. LAWN MOWER IS DAMAGED, BROKEN POWER STRING
4. ALUMINUM SIDING POST (LEFT) IS CRACKED, BROKEN
5. WOODEN-FRAME STRUCTURE IS DAMAGED BY HUMIDITY
6. CONDUIT FOR ELECTRICAL WIRING WAS PULLED DOWN
7. DAMAGE TO NINE (9) MOTORIZED AUTO VEHICLES, CARS, SUV, MOTORCYCLE, LAWN MOWER, ETC.
8. NEW ROOFING FOR GARAGE TO MATCH THE HOUSE IN AGED REDWOOD SHINGLES
IV. BACKYARD
1. ROOFING DAMAGE TO ROOFING SHINGLES, WOODEN STRUCTURE, WIRING, GUTTERS, DUCTWORK
2. T.V. ANTENNA FOR COMMUNICATIONS KNOCKED DOWN BY CABLE CONTRACTOR HIRED BY THE VILLAGE OF LOMBARD AND UNAUTHORIZED BY THE HUNG FAMILY OR G.C. HUNG
3. SIDE ROOFING DAMAGE
4. FENCE DAMAGED BY EVA AND JOHN CARPENTER & SONS, AS WELL AS BY INTRUDERS, TRESPASSERS JUMPING THE FENCING POSTS WHICH ARE DAMAGED AND SPLINTERED BY SBC TELEPHONE COMPANY AND OTHER INTRUDERS AND CRIMINALS
5. FENCE POSTS ARE BROKEN, SPLINTERED, KNOCKET OUT, KICKED IN
6. GRASS LAWN TRAMPLED, FLOWER BED BORDERS DAMAGED


LOMBARD DAMAGES & LOSSES TO HUNG FAMILY REAL ESTATE PROPERTY, ASSETS, AUTOMOBILES, MOTORIZED EQUIPMENT, ETC. FROM 1993-2007
MEMO OVERVIEW FROM GARDENIA C. HUNG, M.A.
TYPED ON TUESDAY, NOVEMBER 19, 2006, 10:55:35 AM
_________________________________________________

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
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.



Attn. Honorable Judge, Chancery Division To: Honorable 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, 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 INTENT

Pursuant to Supreme Court Rule 90(c), Defendants intend to offer the following documents attached hereto into evidence as Exhibit C for Contracts A-1, B-1, and C-1, as proof of proposed plans for Restoration, 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.


CONTRACT A-1
ZSC INSURANCE RESTORATION SERVICE, LLC.
P.O. Box 56553, Chicago, Illinois 60656-0553
ZeesGroup.com
Job Information:
Date: 11/09/2006
Name: Gardenia C. Hung
Address: 502 S. Westmore-Meyers Road, Lombard, Illinois 60148-3028

SCOPE OF WORK:
I. Roofing - $ 8,750.00
1. Tear off existing shingles.
2. Supply and Install ice and water shield.
3. Supply and Install felt paper.
4. Supply and Install new shingles IKO Cambridge 25, Laminated Design, Organic & Fiberglass Asphalt Shingles, Color for Aged Redwood.
5. Install New Aluminum Flashing around chimney.
6. Supply and Install 4 Mushroom Vents.
7. Replace Rotten Wood - $ 1,350.00
· 25 Years warranty on shingles; - 5 Year Limited Labor Warranty
II. Supply and Install Aluminum Gutters, Soffit, Fascia and Down-spouts - $ 7,350.00
III. Plumbing work to be done: $165.00 per hour per plumber + cost of material - Estimated $20.700.00
IV. Electrical work $125.00 per hour per technician + cost of material – Estimated $ 8,500.00
V. Debris removal.
1. Supply 30 yard dumpster - $ 650.00
2. Loading the dumpster - $ 650.00
VI. Drywall replacement where needed due to water damage - $ 7,500.00
VII. Painting to be done at $65.00 per hour + cost of material - Estimated $ 10,700.00

Payment Schedule:
we propose hereby to furnish material and labor – complete in accordance with specifications above,
for the sum of: $ 66,150.00

Dated and Signed on November 2006, Signed December 2006,
Updated and Signed on January 2nd, 2007

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Lombard, DuPage County, Illinois, United States
Lombard resident homeowner in DuPage County, Illinois USA