Defendants' Motion for a Fourth Objection to the Verified Complaint for Demolition and for Injuctive Relief in Opposition to the Motion to Strike

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

THE VILLAGE OF LOMBARD, an Illinois Municipal Corporation, et al.,
Plaintiff,
vs.
GARDENIA C. HUNG, ROBERT S. HUNG, as Trustees of the Trust Agreement Designated as Roberto Hung Supplemental Care Trust, JEFFREY D. PAPENDICK, a tax purchaser, and NON-RECORD CLAIMANTS AND UNKNOWN OWNERS ,
Defendant )
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) Case No.: No. 2007 CH 001284

DEFENDANTS' MOTION FOR FOURTH OBJECTION TO THE VERIFIED COMPLAINT IN OPPOSITION TO THE PLAINTIFF'S MOTION TO STRIKE

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

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

Dated this 16th day of April, 2008




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