IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

COUNTY DEPARTMENT, DOMESTIC RELATIONS DIVISION

IN RE: THE PATERNITY OF:

XXXX., a minor born: XXXXXXXX
____________________________________
FATHER,
Petitioner,
No.
v.
Cal:

MOTHER,
Respondent,

COMPLAINT AT LAW TO ESTABLISH PARENT-CHILD RELATIONSHIP,

ALLOCATION OF PARENTING TIME, PARENTAL DECISION-MAKING
RESPONSIBILITIES, and for other relief

NOW COMES the Petitioner, FATHER (“XXXXX”), on his own pro se, and

in support of his Complaint at Law to Establish Parent-Child Relationship,

Allocation of Parenting Time and Parental Decision-Making Responsibilities,

pursuant to 750 ILCS 45/1 et. seq., and the Illinois Marriage and Dissolution of

Marriage Act, respectfully states unto this Honorable Court as follows:

1. This Court has jurisdiction of the parties hereto, and of the subject

matter hereof;

2. FATHER, is the Petitioner named herein and that he has continued to

reside in Cook County, Illinois for at least ninety (90) days preceding

the commencement of these proceedings;

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3. MOTHER, is the Respondent to this Complaint at Law for Paternity

and the movant in a Petition filed by her for an Order of Protection

and is presently a resident of Cook County, State of Illinois;

4. That the Parties had an exclusive intimate and sexual relationship,

which as a direct result of same, the parties’ one (1) minor child was

conceived and is currently age seven (7);

5. MOTHER gave birth to one (1) child; XXXXXXXXX (“XXXX”) on

August 8th, 2010 and has been residing with XXXXX and XXXXXXXX

her whole life in XXXXX, Illinois in the County of XXXX;

6. The Illinois Birth Certificate does properly reflect the minor child

having the Petitioners surname but there is no Voluntary

Acknowledgement declaring Petitioner as the biological father over

XXXX; however Petitioner has raised and fostered XXXX since her

birth and prays for an order declaring him to be XXXXX father;

7. No other complaints for paternity are pending between the parties to

this cause;

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8. The parties’ one (1) minor child is not the subject of any other child

parentage proceeding pending before another division of the circuit

court regarding same;

9. There are not presently any formal arrangements between the parties

concerning the allocation of decision-making, allocation of parenting

time or support of the infant child, XXXXX;

10. FATHER is a nurturing, loving and supportive parent who is a fit and

proper person to have the sole decision-making responsibility of the

parties’ one minor child named herein;

11. FATHER alleges that MOTHER on May 14th, 2018 obtained an Order

of Protection from the Cook County Circuit Court – District Five (5)

under case no. 18 OP XXXXX against him declaring her and the

parties’ child as protect parties as well as temporary possession of

the parties’ residence;

a. XXXXX was completely oblivious and unaware of any Order of

Protection being entered against him;

b. On May 14th, 2018 shortly after MOTHER obtained said Order of

Protection XXXXX went to the parties’ home and allowed him to

gather belongings for work that day, have a civilized discussion

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 with XXXXXXXXX about their domestic issues, and give their

daughter XXXX a kiss goodbye as he was getting ready for work;

c. During the entire exchange in subparagraph (b) XXXXXXXXX

never contacted the XXXXX Police Department and further never

advised FATHER of the existence of said Order of Protection;

12. FATHER further states that MOTHER wrongfully transferred $10,000

USD from his bank account to an account that was in her name

claiming issues of an old debt due to her and openly admitting that

she had been having sexual relations with a contractor hired by

FATHER behind his back;

13. It is the contention of FATHER that the allegations filed by MOTHER

were manufactured to cloak her infidelity and to further her agenda

with the respect to the $10,000 she stole from FATHER;

14. FATHER seeks temporary and permanent sole-allocation of parental

responsibilities over X.Y. citing MOTHER’s emotional instability and

poor character which could hinder the emotional growth and stability

of CHILD;

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 15. FATHER is further respectfully asking this court to enter a sanction

against MOTHER for filing a frivolous Order of Protection in violation

of Illinois Supreme Court Rule 137.

WHEREFORE, Petitioner, FATHEER, pro se prays for the following relief

from this Honorable Court:

1. That this Honorable Court enter an order declaring FATHER to be the

biological father over CHILD the parties’ minor daughter;

2. For the entry of an order denying all relief sought by MOTHER in her

Application for an Order of Protection;

3. For the entry of an order granting him sole-allocation of parental

responsibilities over CHILD and residential possession;

4. For the entry of a declaratory order deeming MOTHER to have filed a

frivolous action and to enter a sanction against her for filing said action;

5. Such other and further relief as the court deems equitable and just.

________________________________________
FATHER, pro se

FATHER, pro se

Chicago, Illinois
(XXX) XXX XXXX Mobile

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 VERIFICATION

STATE OF ILLINOIS )
) SS:
COUNTY OF COOK )

Under penalties of perjury as provided by law pursuant to Section 1-109 of

the Code of Civil Procedure, the undersigned certifies that the statements set
forth in this instrument are true and correct, except as to matters therein stated
to be on information and belief and, as to such matters, the undersigned
certifies as aforesaid that I verily believe the same to be true.

DATED: _____________________________
________________________
XXXXX,XXXXXXX pro se

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