a e e Pers IN THE CIRCUIT COURT FOR THE TWENTY-SECOND JUDICIAL CIRCUIT MCHENRY COUNTY, ILLINOIS IN RE: THE MARRIAGE OF ) FILED } JAN 25 2012 ) ioe Oo ec J ) vs. ) — Nofapv 71) ) JO ANN SUMMERKAMP, ) ) Defendant ) PETITION FOR DISSOLUTION OF E NOW COMES Plaintiff, ME individually, and by and through his Attomey, Carol L. Hill, of the law firm of LAW OFFICES OF Carot Hitt, pursuant 10 §403 of the Mlinvis Marriage and Dissolution of Marriage Act, and as and for his Petition for Dissolution of ‘Marriage states the following: 1 Phin, E's 29 years of age, resides ot McHenry, State of [kin and County of MeHenry and is employed by Pro Tech Cooling, in the Wauconda, lltinois, and has resided in the State of Tlinois continuously for twenty- nine (29) years. 2. Defendant, JO ANN SUMMERKAMP, is 28 years of age, and resides «(A HEEB ciency, State of Minos, and County of McHenry and is self-employed as a hair dresser, and has resided in the State of Illinois continuously for approximately twenty-eight (28) years. NoTice BY LOCAL RULE 9.10 spascase shone 627 FOR SGHEOPLNG. Sige couRyRpoU CA a Le. oa RTT HO APTAR WAY RESULT THESE 1 BEING DISMISSED OR AN ORDER OF \G ENTERED. Laworrice oF Caro. Hi, DEFAULT BEING &! 210 NoRTH WALKUP AVENUE, CRYSTAL.LAKe, IL 60014 €815) 444-0292, www chillfamily.com3 5 6 9. 10. i. That the parties herein were married on the 30th day of May 009, and the marriage was registered in the City of Crystal Lake, County of McHenry, and State of Illinoi ‘That no other Petition for Dissolution of Marriage, or comparable Complaint, is pending in any other county, jurisdiction or state. ‘That without cause or provocation by Plaintiff, Defendant has been guilty of extreme and repeated acts of physical eruelty against Plaintiff That without cause or provocation by Plaintiff, Defendant has been guilty of extreme and repeated acts of mentally cruelty against Plaintiff That no current arrangements exist between the parties conceming maintenance ‘That during the marriage, the parties have acquired Chevrolet Truck which should be deemed marital property. ‘That prior to marriage Plaintiff owned the residence at [MEE McHenry, State of Illinois, and County of McHenry and accrued certain military benefits by virtue of disability, and an interest in certain family owned properties given to him by gift from his grandparents, and other miscellaneous personal property, and said items should be deemed by this Court to be Plaintiff's separate non-marital property. That prior to the marriage Defendant owned a Chevy Tahoe and other miscellaneous personal property, which should be deemed her non-marital property. ‘That prior to the marriage, Defendant incurred student loans and a loan for her vehicle, which are still outstanding and should be deemed her non-marital debt, P . 2 LAw OFFice oF Canov Hitt. 210 NontH WALKUP AVENUE, CRYSTAL LAKE, IL 60014 (815) 444-0292, www chilfarily.com,12, That prior to the marriage Plaintiff incured a mortgage and note owing to Harris Bank and Loan from his parents, all of which should be deemed Plaintiff's non-marital debt. 13. That During the marriage certain debts have been incurred that are marital in nature and that each party should be required to pay any such debt he or she incurred in his or her name. 14, That during the marriage marital funds have been used to pay Defendant's pre-marital debts and that the marital estate should be credited with those sums. ‘WHEREFORE, Pint prays for the following relief: A. That a dissolution of mariage of the parties be adjudged herein. B. That both parties be barted from receiving maintenance from the other. That this court award to Plaintiff his non-marital property. ). ‘That this court award to Defendant her non-marital property; E, That this court require each of the parties to be responsible for his or her non-marital debts. F. That this Court require each of the parties to be responsible for any debt he or she has incurred during the marriage. G. That this court determine what contribution the marital estate has made to the non-marital debts of Defendant and to determine that these sums are to be credited to the marital estate and be equitably distributed. 3 Law OFFICE OF CAROI. HILL 210 NoRsH WALKUP AVENUE, CRYSTAL LAKE, IL 60014 (815) 444-0292, www chilfamily.com‘That the Court enter an Order requiring Defendant to pay all of or contribute to Plaintiff's attomey fees and costs incurred herein, I. Forsuch other and further relief'as this Court shall deem just and equitable. RESPECTFULLY SUBMITTED BY CAROL L. HILL ATTY. Reg. #6216183 ATTORNEY FOR PLAINTIFF VERIFICATION BY CERTIFICATION Under penalties as provided by law pursuant to $1-109 of the Code of Civil Procedure, the undersigned certifies that the statements set forth in this instrument are truc and correct, except as to matters therein stated to be on information and belief and as 10 such matters the undersigned certifies as aforesaid that he/she verily believes the same to be true. 4 LAW OFFICE OF CaRoL Hit, 210 NORTH WALKUP AVENUE, CRYSTAL LAKE, IL60014 (815) 444-0292, www chillfamily.com