IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT - PROBATE DIVISION

ESTATE OF
JOSEPH L. ZIARNIK,

No. 08 P 8140

A Disabled Person,
Advocacy Guardianship Services, NFP, as
Limited Guardian of the Person of Joseph L.
Ziarnik and individually, Josh Mitzen as
Director, Advocacy Guardianship Services
NFP and individually; Devon Bank as agent
for Joseph Ludwig Ziarnik under Power of
Attorney, dated April 1, 2008, as Trustee of
Joseph Ziarnik Trust, dated April 1, 2008, and
individually and Janna Dutton, as attorney for
the Estate of Joseph Ziarnik and individually.
Plaintiffs,
v.
Tammy Goldmann, Google, Inc.
Defendants.
MOTION TO AMEND PREVIOUSLY FILED
MOTION TO VACATE
Now comes Movant, Edwin J. Belz, and moves this Honorable Court for leave to
amend and file previously-filed Motion to Vacate and for reasons states:
1) On July 14, 2014 a Motion to Vacate was filed regarding the above-captioned
cause;
2) Said motion contained a scrivener's error in paragraph 4 wherein Movant
inadvertently omitted two words. Movant desires to amend said paragraph to
read "Movant was not given notice of said motion that was brought before
this Court; nor was movant given notice of hearing date". Said amended
motion is attached hereto.

Wherefore Movant prays this Honorable Court grant Movant leave to amend
previously-filed Motion to Vacate.

Edwin J. Belz

Edwin J. Belz
4407 N. Elston Ave.
Chicago, Illinois 60630
773-282-9129
Attorney No. 25663

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT - PROBATE DIVISION
ESTATE OF
JOSEPH L. ZIARNIK,

No. 08 P 8140

A Disabled Person,

Advocacy Guardianship Services, NFP, as

Limited Guardian of the Person of Joseph L.
Ziarnik and individually, Josh Mitzen as
Director, Advocacy Guardianship Services
NFP and individually; Devon Bank as agent
for Joseph Ludwig Ziarnik under Power of
Attorney, dated April 1, 2008, as Trustee of
Joseph Ziarnik Trust, dated April 1, 2008, and
individually and Janna Dutton, as attorney for
the Estate of Joseph Ziarnik and individually.
Plaintiffs,
v.
Tammy Goldmann, Google Inc.
Defendants.
AMENDED MOTION TO VACATE WITHIN 30 DAYS
Now comes Movant, Edwin J. Belz, attorney, and moves this Honorable Court to
vacate the Order of June 19, 2014, and for reasons states as follows:
1) On June 19, 2014, a motion of Defendant to Vacate Default was heard before
this Honorable Court and a Memorandum Opinion and Order were entered;
2) Said Order contains issues which directly effect movant;
3) Movant never received aforesaid Motion to Vacate Default; thus was not
given an opportunity to respond;
4) Movant was not given notice of said motion that was brought before this
Court; nor was movant given notice of hearing date.

Wherefore Movant, Edwin J. Belz, prays the Order of June 19, 2014 be vacated
and held for naught.

Edwin J. Belz

Edwin J. Belz
4407 N. Elston Ave.
Chicago, Illinois 60630
773-282-9129
Attorney No. 25663