Read how a Black judge William Stewart Boyd has violated not only his oath and duties to the Illinois Supreme court Rules but oath to the United States Constitution.
As a Masonic Brethern (Boyd) has violated every creed of the fraternal order of the Brotherhood.
My Brother Mr Kabir whom have never had troubles with the laws never been locked up for any reasons who works at the United States Post office downtown Chicago as a Personal Assistant for over 31 years to the Postmaster Chicago District for the United States Postal Service with very near perfect attendance. One of his primary responsibilities is to make sure that all mailboxes are cleared by seeing to to it the mail has arrived at the post office for the next day delivery.
He studied at Morehouse College for 4 years School of Medicine, Master Mason, Past Master, Current Worshipful Master, Officer in Royal Arch Chapter, Officer in Knights Kadosh Consistory, Officer in 32nd Degree Consistory, Prominent member of Ancient Egyptian Arabic Order of the Nobles of the Mystic Shrine, Prominent member of the Lions Club of America. Director of Lodge "Feed The Homeless Program" in conjunction with the Salvation Army, Director of Lodge Coat Drive for Kids Program in conjunction with The Chicago Public Schools.
He filed for a Divorce (Petition for Dissolution of Marriage) April 20, 2018.
Bernadette was served June 7, 2018.
Bernadette went before judge Renee Goldfarb June 13, 2018 to have her fees waived, the judge granted her a fee waiver to answer the summons without paying any fees.
41 days had elapsed, a Motion for Default was filed with the proper Notice court day was July 20, 2018.
Bernadette appeared in court with her attorney Joan S. Colen with no answer to the summons Petition for Dissolution of Marriage she and her attorney had prepared a counter-petition for Dissolution of Marriage the basis of her "fraudulently" saying she had no knowledge of any divorce proceeding being filed against her.
That because of the legitimacy of Cazembe's Divorce Petition being properly filed and Bernadette was in fact IN DEFAULT, Joan filed a frivolous motion to DISMISS his Petition.
The proper motion Objecting and Striking Bernadette's Motion via her attorney was filed July 23, 2018, court date was July 30, 2018.
Judge Boyd unlawfully DENIED Cazembe's Motion for Default and unlawfully DISMISSED his Petition for Dissolution of Marriage and ORDERED him to respond to Bernadette's attorney Counter-Petition for Dissolution of Marriage.
Unlike the FBI indicting Alderman Edward Burke for attempted Extortion on Burger King owners in this case Boyd was successful using his robe allowing a white attorney to EXTORT MONEY from Cazembe by filing false documents in the court in the guise as maintenance fees for Bernadette.
Judge Boyd became so rageful filled with Contempt unlawfully REMANDED Cazembe into custody primarily because he did not amend his Petition for Dissolution so as to save Boyd from the crime of enforcing court orders outside of his jurisdiction, and ordered he remain in jail until he paid $6855.24.
Now this white attorney Joan realizing the control she has on Boyd and the Demonic Hate he has for men of color went before Boyd with this very document detailing every "Fraudulent Act" perpetrated at Brother Kabir is expecting the judge to continue to vent his hateful rage at an innocent Masonic Brethern by REMANDING him back into custody because in Cook County Courts racist white men controlling the Democratic Party will not admonish Boyd due to his intimate untouchable status with allegedly Alderman Edward Burke.
On Friday February 8th Boyd Denied the Motion Objecting and Striking the Petition for Rule to Show Cause et al. He said "What do you mean by "Fraud" as it is mentioned in your motion"? Brother Kabir explained that he was acting in a Bias manner denying everything you filed and granting everything the attorney filed not questioning a thing, Boyd said Motion DENIED with vicious hate in a manner to humiliate him for speaking up to what was done wrong, he demonstrated a hate for Cazembe being a man speaking up to him, there was nothing MASCULINE about his behavior or character.
Boyd continuously threatened Cazembe in court reminding him "YOU KNOW WHAT IS GOING TO HAPPEN TO YOU IF I FIND YOU IN CONTEMPT OF COURT AGAIN? at least 3 times then he said, "YOU KNOW WHAT IS GOING TO HAPPEN TO YOU DON'T YOU? and YOU KNOW WHAT, I AM GOING TO DO TO YOU? at least 2 or 3 times.
When Cazembe tried to explain to Boyd that his Affidavit clearly showed he was not able to pay $1700.00 a month due to outstanding debts, Boyd got MAD! told him he had to give her something or make a "GOOD FAITH EFFORT"
Because Cazembe is everything Boyd is not as a man, he is making it clear in his ruling he is GOD and nobody can touch him!
O lord My god is there any help for the W's son?
IN
THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT,
DOMESTIC RELATIONS DIVISION
CAZEMBE KABIR,
Petitioner/
Counter-Respondent,
18 D 3208
BERNADETTE KABIR,
Respondent / Counter -Petitioner .
MOTION FOR DEFAULT AND/OR
DISCOVERY SANCTIONS
Bernadette Kabir, Respondent/ Counter-Petitioner, by and
through her attorney, Joan S . Colen, respectfully requests that this Court
find Petitioner/ Counter-Respondent in default or, in the alternative, enter an
appropriate order sanctioning for his failure to comply with this Court ' s
discovery rules and order, pursuant to Illinois Supreme Court Rule 219 (c) 
In support of this
motion, Respondent/ Counter-Petitioner 
states as follows :
states as follows :
Procedural History of the Case
1. On
April 20, 2018, Petitioner/ Counter-Respondent
(hereinafter
"Cazembe") filed a Petition for Dissolution of Marriage, pro se. The
Petition alleged five separate grounds for dissolution, none of which was
irreconcilable differences .
2. On
June 7 , 2018, Respondent/ Counter-Petitioner (hereinafter
"Bernadette") was served with summons and a copy of the Petition. On
June 13, 2018, Bernadette filed her pro se Appearance .
3. On
July 20, 2018, Cazembe filed a Motion for Default Prove-Up, based on the fact
that Bernadette had not filed an Answer to his Petition for Dissolution.
4. Also
on July 20, 2018, counsel for Bernadette filed her Additional Appearance as
well as Counter-petition for Dissolution of Marriage and a 2-615 Motion
to Strike Petitioner' s Petition for Dissolution of Marriage .
5. On
July 23, 2018, Cazembe filed a Motion Objecting and Striking to Bernadette's
Counter -Petition for Dissolution of Marriage Due to " Fraudulent"
Misrepresentations.
The Objection was based on the assertedly "
fraudulent admission" in
Bernadette 's Counter-Petition that
"With the exception of Cazembe's Petition for Dissolution of Marriage in
the instant case, Bernadette is unaware of any Petition for Dissolution of
Marriage pending in this or any other county or state .
"
6. On
July 26, 2018, Bernadette filed a Motion for Temporary Maintenance .
7. On
July 30, 2018, the Court denied Cazembe's Motion for Default and gave him 21
days to respond to the Motion to Dismiss, setting it for hearing on August 27,
2018. The Court also gave Bernadette leave to file her Counter -Petition, gave
Cazembe 21 days to respond to Bernadette's Motion for Temporary Maintenance,
and ordered Cazembe to serve his financial affidavit and supporting documents
within 14 days .
8. On
August 16, 2018, Cazembe filed a "Motion for Disqualification of Judge for Cause Due to
' Fraud' (Civil Rights Violations) and or Prejudice pursuant to S. H. A. 735
ILCS 5/2-
1001 (a) (2, 3) and to Vacate all
Orders due to Trespassing upon the Laws' Court never had Jurisdiction Orders
are 'Void' a 
Nullity' " (hereinafter
referred to as "SOJ Motion") . That
Nullity' " (hereinafter
referred to as "SOJ Motion") . That
-2-
Motion was heard by Judge Arce on August 27, 2018 and was
denied. The case was then sent back to Judge Boyd, but Cazembe did not return
to Judge Boyd's courtroom after leaving Judge Arce ' s courtroom. Judge Boyd
set a hearing on the Motion to Dismiss and the Motion for Temporary Maintenance
for September 11, 2018 .
9. On
August 28, 2018, Bernadette served Standard Marital Interrogatories and a Request to Produce Documents on
Petitioner .
10. On
September 5, 2018, Cazembe re-filed his Motion Objecting and Striking to Bernadette's Counter-Petition
for Dissolution of Marriage Due to " Fraudulent"
Misrepresentations .
11. On
September 11, 2018, the Court heard and granted Bernadette's Motion to Dismiss Cazembe's
Petition for Dissolution and gave him 21 days to file an Amended Petition for
Dissolution. The Court also ordered Cazembe to pay temporary maintenance based
on statutory guidelines and continued the case to October 15, 2018 for status .
12. On
September 26, 2018, Cazembe filed a Motion to Reconsider Judge Arce s Order denying his SOJ Motion .
13. On
September 27, 2018, having received no responses to the initial discovery
requests, counsel for Bernadette sent a 201k letter to Cazembe .
14. Also
on September 27, 2018, Bernadette filed a Petition for a Rule to Show Cause
alleging that Cazembe had failed to pay any maintenance .
15. On
October 2, 2018, having still received no response from Cazembe to discovery,
Bernadette filed a Motion to Compel Answers to Discovery and served Notice on
Cazembe that the motion
-3-
would be presented to the Court on October 9, 2018 .
16. On
October 9, 2018, Judge Boyd transferred the matter back to Judge Arce for
hearing on Cazembe s motion to reconsider the denial of his SOJ motion. Judge
Arce heard the matter and denied the motion to reconsider. Judge Arce also sent
the case back to Judge Boyd for further proceedings. Judge Boyd entered and
continued Bernadette' s Motion to Compel and Petition for Rule to Show Cause to
October 15, 2018 .
17. On
October 15, 2018, Cazembe failed to appear in court . The Court set a hearing
on Bernadette 's Motion to Compel and Petition for Rule to Show Cause the Motion on December 18,
2018 . That Order further stated that Cazembe 's failure to appear would result
in a default order being entered against him. Counsel for Bernadette sent a
copy of that Order to Cazembe both by email and by U.S. mail on October 15,
2018 .
18. On
October 29, 2018, Bernadette filed a Motion for Exclusive Possession of Marital
Property, set for initial presentment on November 8, 2018, on which date the
motion was set for hearing on December 18, 2018 . Cazembe was not in court on
November 8 , but counsel for Bernadette sent him a copy of the Order both by email and by U.S. mail on November 8 , 2018 .
19. On
November 26, 2018, Cazembe filed a Motion to Reinstate his Petition for Dissolution of Marriage and noticed it for initial presentment on December 10, on which date the motion was set
for hearing on December 18, 2018 .
20. On
December 18, 2018, the Court denied Cazembe 's Motion to Reinstate his Petition
for Dissolution, but granted him an additional 14 days to file an Amended
Petition for Dissolution of Marriage. The Court Cazembe was found in contempt
of court for failure to pay court-ordered maintenance and ordered that he be
taken into custody, with a purge of posting $6855 . 24, the amount of unpaid
maintenance as of that date. The Court continued the case to December 21, 2018
for status on the purge. Bernadette's pending Motion to Compel and Motion for
Exclusive Possession of Marital Property were entered and continued .
21
. On December 21, 2018, Cazembe did not appear
in court but had posted bond and been released from custody. Bernadette s
pending Motion to Compel and Motion for Exclusive Possession of Marital Property were continued to January 18, 2019 for
hearing .
22
. On January 13, 2019, Cazembe served his
Financial
Affidavit and copies of various bills and other statements
on Bernadette's counsel. On January 15, 2019,
he served an amended Financial Affidavit .
23.
On January 18, 2019, Cazembe did not appear in
court .
The Court granted Bernadette exclusive possession of 13140 S
. Eberhart and ordered Cazembe to respond to the Interrogatories and Request to
Produce Documents that had been served on him on August 28. 2018 within 14
days, or by February 1, 2019 . The case was continued to February 8, 2019 for
status, and Cazembe was ordered to appear in court on that date. Counsel for Bernadette
sent a copy of that Order to Cazembe on January 18, 2019.
24.
Also on January 18, 2019, Bernadette filed a
second Petition for Rule to Show Cause because Cazembe had not paid maintenance
for the month of January, 2019. The Petition is
-5-
noticed up for initial presentment on February 8, 2019 .
25. On February 5, 2019, Cazembe filed a Motion Objecting
& Striking Defendant ' s Petition for Rule to Show Cause Due
to "Fraud" on the Court Court Having No Jurisdiction Orders
are a Nullity Extension of Time to Submit Interrogatories &
Counter Issuance for Rule To Show Cause and Impose Sanctions
Pursuant to Supreme Court Rule 137". The Motion
was noticed for initial presentment on February 8, 2019.
Motion for Default
26. As
of the filing of this Motion, Cazembe has failed to file an Amended Petition
for Dissolution of Marriage, despite having been given two opportunities to do
so after his original Petition for Dissolution of Marriage was dismissed
pursuant to 735 ILCS 5/2-615.
27. As
of the filing of this Motion Cazembe has failed to file any response to the
Counter -Petition other than his original "Motion Objecting &
Striking Respondent 's Counter -Petition Due to
' Fraudulent' Misrepresentations & Issuance of a Rule
to Show
Cause for Sanctions and or Remand Pursuant
to Supreme Court Rule 137" which he subsequently re-filed. That objection
and motion to strike is baseless and should be stricken with prejudice
.
28. As
of the filing of this Motion, Cazembe has failed to appear on 4 of the last 5 court dates .
Motion for Sanctions
29. As of the filing of
this Motion, more than 14 days have elapsed since the January 18, 2019 Order
compelling Cazembe to
-6-
respond to the Interrogatories and Request
to Produce that were served on August 28, 2018 and Cazembe has not responded to
either the Interrogatories or the Request to Produce .
30. Cazembe's failure to
comply with this Court ' s Order is unreasonable and wilful .
WHEREFORE, Respondent/
Counter-Petitioner Bernadette Kabir respectfully requests that this Court :
A. Enter
an Order finding that find Petitioner/ Counter-Respondent Cazembe Kabir is in default and
setting this matter for a prove-up hearing ;
B. Enter
sanctions against Petitioner/ Counter-Respondent Cazembe Kabir for failure to
comply with discovery rules and orders . In particular, Respondent/
Counter-Petitioner Bernadette
Kabir requests :
That the Court debar
Petitioner/ Counter-Respondent Cazembe Kabir from maintaining any claims or
defenses with respect to his financial circumstances ;
B. That the
Court debar Petitioner/ Counter-Respondent Cazembe Kabir from filing any other
pleading relating to any financial issue ;
c. That all claims or defenses asserted in
Petitioner/Counter-Respondent Cazembe
Kabir' s Motion Objecting & Striking Respondent 's Counter-Petition Due to
' Fraudulent' Misrepresentations & Issuance of a Rule to Show Cause for
Sanctions and or Remand Pursuant to Supreme Court Rule 137 be dismissed with
prejudice;
D. That
a judgment by default be entered against
Petitioner/ Counter-Respondent Cazembe
Kabir as to all claims asserted in the Counter-Petition for Dissolution of Marriage
;
E. That
the Court order Petitioner/ Counter-Respondent
Cazembe Kabir to pay for Respondent s
attorneys fees to prepare this Motion ;
That the Court order Petitioner
to pay a monetary penalty in an appropriate amount; and
G. That the Court enter such other or further
Orders as it deems just and equitable .
Respectfully submitted,
Petitioner
JOAN S. COLEN #41149
77 W. Washington Street Suite 1712
Chicago, Illinois 60602
312. 701.1075
jsc@joancolenlaw. com
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