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IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, DOMESTIC RELATIONS DIVISION IN RE THE MARRIAGE OF JESSE JACKSON, JR. ) Peti ) ) & s ‘and ) No. 16D 006506 o'., ) aoe B SANDRA JACKSON, ) co) ) inoue Respondent. ) a NOTICE OF SERVICE OF SUBPOI ‘ w TO: Jessica Bank Interlandi Schiller DuCanto at Fleck 200 North LaSalle Street 30 Floor Chicago, Ilinois 60601 Please tke-métice that on September 19, 2016, we issued a Subpoena In A Civil Matter for Records Only, to thé following, a copy of which is hereby served upon you: Cell Co. Partnerships dibya Verizon Wireless 180 Washington Valley Road Bedminster, New Jersey 0792 Balm Omi ‘One of the Attorneys for Jesse Jackson, Jr. AFFIDA’ SERVICE The undersigned non-attomey states under oath that on September 20, 2016, before 5:00 p.m., this Notice of Service and accompanying Subpoena in a Civil Matter were placed in the U.S, Mail at 161 North Clark Street, Chicago, Illinois, with first class postage prepaid, and directed to all partics of record at the address set forth above. tee is Shi dk Mak. Holly/L. Clark Subscribed and sworn to before me this120th_-day of September, 2016. Noiary'Public Pete, ANGELA 9, CHAMBERS: or Seviciat Seat PY usin Sine ets Barry A. Schatz ‘ai ommnasion Exares Berger Schatz, LLP : " “Qerover 1, 2017 161 North Clark Street, Suite 2800 Chicago, Ilinéis-69601 (312) 782-3456 ‘Ally No. 26828 IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, DOMESTIC RELATIONS DIVISIO} IN RE: MARRIAGE OF JESSE JACKSON, JR., Petitioner, No: 16 D 6506 2B and SANDRA JACKSON, Rs OBJECTION AND MOTION TO DISMISS ACTION FOR DISSOLUTION OF MARRIAGE DUE TO LACK OF PERSONAL JURISDICTION AND LACK OF SUBJECT MATTER JURISDICTION NOW COMES the Respondent, SANDRA JACKSON (“Sandra”), by and through her counsel, SCHILLER DU CANTO & FLECK LLP, pursuant to Sections $(2-209, 52-301, and 5/2-619 of the Illinois Code of Civil Procedure (735 ILCS 5/2-209, 5/2-301, and 5/2-619), Section 5/401 of the Illinois Marriage and Dissolution of Marriage Act (“IMDMA”) (750 TLCS 5/401), and the Uniform Child-Custody Jurisdiction and Enforcement Act (“UCCJEA”), 750 ILCS 36/101 et seg, and for her Objection and Motion to Dismiss Action for Dissolution of. Marriage filed by the Petitioner, JESSE JACKSON, JR. (“Jesse”), objects to this Court's exercise of personal jurisdiction over Sandra and over the subject matter of this action and moves to dismiss this action, In support thereof, Sandra attaches her Affidavit as Exhibit “A” as to facts not of record and states as follows: OVERVIEW 1. This action should be dismissed because this Court lacks jurisdiction over iction over this action under both the IMDMA and Sandra’s person and subject matter juris UCCIEA. Sandra is a not a resident of Ilinois. She has been a resident of Washington, D.C. 1 2139003 %, e 9 since on or about 2013, Sandra was not served with Summons in Illinois, and no other basis, exists for this Court to exercise jurisdiction over Sandra's person. 2, Additionally, Jesse is not a resident of Illinois and was not an Illinois resident at the time this action was commenced. Consequently, this Court does not have subject matter jurisdiction over this action pursuant to the IMDMA because neither party is a resident of Minois. Furthermore, this Court lacks subject matter jurisdiction pursuant to the UCCJEA to make an initial child-custody determination because the parties” children have always resided in is the children’s home state and the only state Washington, D.C. Therefore, Washington, D. with jurisdiction to make an initial child-custody determination. 3. Both judicial efficiency and the orderly administration of justice are best served by dismissing this action instanter due to lack of personal and subject matter jurisdiction so as to permit a court of competent jurisdiction in Washington, D.C. to resolve these matters in their entirety pursuant to the Complaint for Legal Separation, Absolute Divorce, Child Custody, Child Suppoit, Alimony, Suit Money and Other Relief filed by Sandra on November 3, 2016 in the Superior Court of the District of Columbia. Factual Background: 4. The parties were married on June 1, 1991 Two children were bon to the parties as a result of the marriage, namely J.D.J., 5. currently age 16, and J.L.J., currently age 13. 6. ‘The marital residence where the children have resided since birth is located in Washington, D.C. The children have resided in the marital residence in Washington, D.C. with a parent or person acting as a parent for over six consecutive months immediately before the commencement of this action. 2139003 7. The children are enrolled in school in Washington, D.C. where they have attended school since kindergarten. 8 The children’s doctors, tutors, and friends are all located in Washington, D.C. 9. On information and belief, Jesse resides in Washington, D.C. Jesse’s Finoncial Affidavit dated August 10, 2016 certifies that his home address is in Washington, D.C. A copy of Jesse’s Financial Affidavit is incorporated herein by reference as “Exhibit B.” Jesse has resided in Washington, D.C. commencing on or about 2013. 10, Sandra also resides in Weshington, D.C. and has been a resident of Washington, D.C. since on or about 2013. Sandra temporarily resided in Alderson, West Virginia where she was incarcerated from on or about October 2015 through September 2016. During her incarceration, Sandraalways intended to return to her permanent residence in Washington, D.C., and since September 2016, Sandra has resided in the marital residence in Washington, D.C. with the minor children. 11, Sandra is registered to vote in Washington, D.C., where she has been registered since on or about 2013. Jesse is also registeted to vote in Washington, D.C. 12, Sandra voted in Washington, D.C. in the 2014 mayoral election and the 2016 general election. 13, Sandra has maintained a Washington, D.C. driver's ficense since on or about 2013. 14, Sandra’s vehicle has been registered in Washington, D.C. since on or about 2013. 15, The marital residence which is owned by Sandra and Jesse is located in Washington, D.C., and the parties also own a studio condominium located in Washington, D.C. 2i39003 16, In 2015, the parties filed only Federal and Washington, D.C. income tax retums because Washington D.C., not Illinois, was both parties’ state of residence. 17. Both parties" probation officers are located in Washington, D.C., and both parties" criminal defense attorneys are located in Washington, D.C. 18, Both parties’ bank accounts are located in Washington, D.C 19... Even while living in Chicago, both parties directed their mail to their Washington, D.C. residence, including bills for their house in Chicago. Procedural History: 20.» On July 14, 2016, Jesse commenced this action by filing a Praecipe for Summons. To date, Jesse has not filed a Petition in this matter. 21. -OwsAugust 11, 2016, Sandra received a Summons while in Alderson, West Virginia where she was incarcerated, 22. On September 2, 2016, Sandra, through counsel, filed her Appearance (Limited) in this matter for the sole purpose of contesting jurisdiction. 23. On September 2, 2016, Sandra, through counsel, filed her Motion for Extension of ‘Time to Answer or Otherwise Appear Pursuant to 735 ILCS 5/2-301 (“Motion for Extension of Time”). 24. On September 14, 2016, this Court entered an order granting Sandra 45 days to liction in accord with 735 ILCS $/2-301. A copy of said Order is file an objection to ju attached hereto as “Exhibit C.” On October 28, 2016, this Court entered an order granting Sandra an extension of ten (10) days to file her objection to jurisdiction. A copy of said Order is attached hereto as “Exhibit D.” 2139003 25. On November 3, 2016, Sandra, through counsel, filed in the Superior Court of the District of Columbia her Complaint for Legal Separation, Absolute Divorce, Child Custody, Child Support, Alimony, Suit Money and Other Relief. COUNT I: OBJECTION AND MOTION TO DISMISS ACTION FOR DISSOLUTION OF MARRIAGE DUE TO LACK OF PERSONAL JURISDICTION 26. Sandra restates and tealleges Paragraphs 1 - 25 of the Overview as and for Paragraph 26 herein. 27. This action should be dismissed because this Court lacks personal jurisdiction over Sandra 28. Section 5/2-301 of the Illinois Code of Civil Procedure provides the procedure for objecting to persona! jurisdiction as follows: (@) Prior to the filing of any other pleading or motion other than a motion for an extension of time to answer or otherwise appear, a party may object to the cour’s jurisdiction over the party's person, either on the ground that the party is not amenable to process of @ court of this State or on the ground of insufficiency of process or insufficiency of service of process, by filing a motion to dismiss the entire proceeding or any cause of action involved in the proceeding or by filing a motion to quash service of process. Such a motion may be made singly or included with others in a combined motion, but the parts of a combined motion must be identified in the manner described in Section 2-619.1. Unless the facts that constitute the basis for the objection are apparent from papers already on file in the case, the motion must be supported by an affidavit setting forth those facts, 29. In accordance with 735 ILCS 5/2-301(a), prior to the filing of any other pleading ‘or motion in this case, with the exception of her Motion for Extension of Time, Sandra is filing the instant Objection and Motion to Dismiss, which objects to the jurisdiction of the Illinois court, over her person in connection with the Praecipe for Summons filed by Jesse, 30, Sandra moves for dismissal of this action based upon Section 5/2-619(a)(9) of the Ilinois Code of Civil Procedure, which states, in pertinent part, as follows: 210023 Defendant may, within the time for pleading, file a motion for dismissal of the action or for other appropriate relief upon any of the following grounds. If the grounds do not appear on the face of the pleading attacked the motion shall be supported by affidavit: (9) That the claim asserted against defendant is barred by other affirmative matter avoiding the legal effect of or defeating the claim. The “other affirmative matter” is that Illinois does not have personal jurisdiction over Sandra, and therefore, cannot enter a Judgment for Dissolution of Marriage and order a property distribution to which Sandra is bound. 31. “The burden of proving a valid basis for the assertion of jurisdiction over a nonresident defendant rests with the party seeking to impose jurisdiction.” RW, Sawant & Co. v. Alllied Programs Corp., 111 Ill. 2d 304, 310 (1986). 32, Jesse Tas failed to meet his burden of proving a valid basis exists for this Court to exercise jurisdiction over Sandra. 33. Section 5/2-209 of the Illinois Code of Civil Procedure, 735 ILCS 5/2-209, provides the bases upon which an Illinois court acquires personal jurisdiction over a defendant. 34. “Specifically, “in determining whether an Illinois court may assert personal jurisdiction over a nonresident defendant, Illinois courts employ a two-prong analysis to evaluate whether the facts of the case meet the requirements for (1) personal jurisdiction under the Illinois long arm statute and (2) due process under both the United States and Illinois Constitution.” Hanson v, Ahmed, 382 Ill.App.3d 941, 943 (1 Dist. 2008) (internal citations omitted). 35. Jesse’s Praecipe for Summons does not allege that 735 ILCS 5/2-209(b) provides a basis for Illinois to exercise personal jurisdiction over Sandra, nor does such a basis exist. 36. Subsection 5/2-209(b) states as follows: (b) A court may exercise jurisdiction in any action arising within or without this State 2139003 against any person who: (2) Is a natural person present within this State when served; (2) Is a natural person domiciled or resident within this State when the cause of action arose, the action was commenced, or process was served; (3) Is a corporation organized under the laws of this State; or (4) Is a natural person or corporation doing business within this State. 735 ILCS 5/2-209(b). 37.’ Sandra was not personally served with Summons while present in Lllinois as required by Subsection 5/2-209(b)(1) 38. Jesse’s Praecipe for. Summons does not allege that Sandra is either domiciled or residing in Ilinois as required by Subsection 5/2-209(6)(2).. 39, Furthermore, based on the facts stated in Sandra’s Affidavit attached hereto and incorporated herein, Illinois was not Sandra’s domicile or residence at the time she received a Summons, nor is Illinois Sandra's state of residence or domicile today, 40. Residence is defined as a person's “permanent abode” or the “place one considers ‘home. Garrison v. Garrison, 107 Ill. App. 2d 311, 314 (2nd Dist. 1969), “Of paramount importance in determining whether a given place is or is not one’s residence is the intent of that person to live there as his permanent home.” /d. A domicile is established by physical presence in a place in connection with an intention to remain there. Jn re Adoption of SS. & RS. 167 111.24 250, 260 (1995), Black's Law Dictionary defines “domicile” in pertinent part as “the place at which a person has been physically present and that the person regards as home; a person's true, fixed, principal, and permanent home, to which that person intends to return and remain even though currently residing elsewhere.” Domicile, Black’s Law Dictionary (10th ed. 2014) 41, As substantiated by the facts outlined in Sandra's Affidavit, Washington, D.C. has isos been Sandra's residence and domicile since on or about 2013, well before this action was commenced, as Washington, D.C. is where Sandra lived and always intended to remain her permanent home, 42. Jesse's Praecipe for Summons does not allege that Sandra is doing business in Ilinois as required by Subsection 5/2-20%(b)(4), nor does any factual basis exist with respect to same. stant case, 43. Subsection 5/2-209(b)(3) is inapplicable to the 44, Additionally, Jesse’s Praccipe for Summons does not allege thet this action for dissolution of marriage arose from Sandra doing any of the acts enumerated in 735 ILCS 5/2- 209(a), the Ilinois long-arm statute, which would submit Sancra to the jurisdiction of an Illinois court. 45. Specifically, as applicable to this dissolution of marriage action, Section 5/2- 209(a)(5) states as follows: (a) Any person, whether or not a citizen or resident of this State, who in person or through an agent does any of the acts hereinafter enumerated, thereby submits such person, and, if an individual, his or her personal representative, to the jurisdiction of the courts of this State as to any cause of action arising from the doing of any of such acts: (5) With respect to actions of dissolution of marriage, declaration of invalidity of marriage and legal separation, the maintenance in this State of a matrimonial domicile at the time this cause of action arose or the commission in this Sate of any act giving rise to the cause of action; 46. Jesse's Praecipe for Summons does not allege that he and Sandra maintained a matrimonial domicile in Illinois at the time this cause of action arose or that Sandra committed in Mlinois any act giving rise to the cause of action. 47. To the contrary, at the time Jesse commenced this action by filing his Praecipe for Summons on July 14, 2016, Sandra was a resident of Washington, D.C., which has served as 2139003 Sandra’s residence and domicile since on or about 2013. 48. Therefore, 735 ILCS 5/2-209(a) does not provide a basis for Illinois to exercise personal jurisdiction over Sandra, 49. Jesse’s praecipe for summons does not allege that any other constitutionally permissible basis for jurisdiction exists that would subject Sandra to the jurisdiction of an Tlinois court, nor does any such basis exist. 30, Based on the above-cited authority, Illinois lacks jurisdiction over Sandra's person 51, Therefore, this Court should enter an order dismissing this action due to lack of personal jurisdiction. 52, Santira’s Affidavit is attached hereto and incorporated herein as “Exhibit A.” WHEREFORE, the Respondent, SANDRA JACKSON, prays for the following relief, instanter: A. That this Court enter an order dismissing this action due to lack of personel jurisdiction; and B. _ Forsuch other and further relief as this Court shall deem equitable and just. COUNT, MOTION TO DISMISS ACTION FOR DISSOLUTION OF MARRIAGE DUE TO LACK OF SUBJECT MATTER JURISDICTION PURSUANT TO 735 ILCS 5/2-619 53. Sandra restates and realleges Paragraphs 1-25 of the Overview and Paragraphs 26 ~ 52 of Count I as and for Paragraph 53 herein. 54. Pursuant to 735 ILCS $/2-619(a)(1), this Court should dismiss this action because this Court lacks jurisdiction over the subject matter of this action. First, pursuant to 750 ILCS 5/401, this Court lacks jurisdiction to enter a Judgment dissolving the parties’ marriage because 9 213903 . neither party is a resident of the State of Illinois, nor was either party a resident of Illinois at the time this action was commenced. Additionally, pursuant to the Uniform Child-Custody Jurisdiction and Enforcement Act (“UCCJEA”), 750 ILCS 36/101 et seg., this Court lacks jurisdiction to make an initial child-custody determination, 55. Section 5/2-619 of the Minois Code of Civil Procedure (735 ILCS 5/2-619) provides for the dismissal of an ection based on lack of subject matter jurisdiction. Section 5/2- 619 provides, in pertinent part, as follows (@) Defendant may, within the time for pleading, file a motion for dismissal of the action or for other appropriate relief upon any of the following grounds. If the grounds do not appear on the face of the pleading attacked the motion shall be supported by affidavit: (1) That the court does not have jurisdiction of the subject matter of the action; provided the defect cannot be removed by a transfer of the case to a’coutt having jurisdiction. Lack of Subject Matter Jurisdiction Under the IMDMA 56. Pursuant to Section 5/401 of the IMDMA (750 ILCS 5/401), one of the spouses must be a resident of Illinois for at least 90 days at the time the action is commenced or a finding is made in order for this Court to enter a Judgment of Dissolution of Marriage. Specifi section 5/401(a) of the IMDMA states, in pertinent part, as follows: (a) The court shall enter a judgment of dissolution of marriage when at the time the action was commenced one of the spouses was a resident of this State or was stationed in this State while a member of the armed services, and the residence ot military presence had been maintained for 90 days next preceding the commencement of the action or the making of the finding: Irreconcilable differences have caused the irretrievable breakdown of the marriage and the court determines that efforts at reconciliation have failed or that future attempts at reconciliation would be impracticable and not in the best interests of the family lly, 57. Pursuant (o Section 5/411 of the IMDMA, this action was commenced when Jesse filed his Praecipe for Summons. 2139003 10 58, At the time this action was commenced and continuing to present, neither party has been a resident of the State of Illinois. Affidavit 59, On information and belief and based on the facts stated in Sandra's attached hereto:and incorporated herein, at the time this action was commenced and continuing Lintil the present, Jesse was and continues to be-# resident of Washington, D.C. Jesse resided in Washington, D.C. commeneing in 2013. Jesse did not file an Illinois income tax return in 2015 but instead filed a Washington, D.C. tax return on the basis that he was a resident of Washington, D.C. Additionally, Jesse stated on his Financial Affidavit that he resides in Washington, D.C. 60. As substantiated by the facts outlined in Sandra’s Affidavit and legal argument summarized in Count I and incorporated herein, Sandra was not a resident of the state of Ilinois at the time this-action.was commenced but was instead a resident of Washington, D.C. and ‘temporarily residing in Alderson, West Virginia due to her incarceration. Sandra has maintained her residency in Washington, D.C. to the present day. 61, Neither party is an [linois resident or was an Illinois resident at the time this action was commenced. Therefore, this Court should dismiss this action based on a lack of subject matter jurisdiction under the IMDMA. Lack of Subject Matter Jurisdiction Under the UCCJEA 62.. Illinois lacks jurisdiction under the UCCJEA to make an initial child-custody determination. Instead, Washington, D.C. is the only state with jurisdiction to make an initial child-custody determination because Washington, D.C. is the children’s home state 63. Section 36/201 of the UCCIEA provides the jurisdictional basis for Illinois to make an initial child-custody determination, Section 36/201 of the UCCJEA states as follows: (@) Except as otherwise provided in Section 204, a court of this State has jurisdiction to make an initial child-custody determination only if: iT 2139003 (1) this State is the home state of the child on the date of the commencement of the proceeding, or was the home state of the child within six months before the commencement of the proceeding and the child is absent from this State but a parent or person acting as a parent continues to live in this State; (2) a court of another state does not have jurisdiction under paragraph (1), or a court of the home state of the child has declined to exercise Jurisdiction on the ground that this State is the more appropriate forum under Section 207 or 208, and: (A) the child and the child's parents, or the child and at least one parent or a person acting as a parent, have a significant connection with this State other than mere physical presence; and (B) substantial evidence is available in this State concerning the child's care, protection, training, and personal relationships; (3) all courts having jurisdiction under paragraph (1) or (2) have declined to exercise jurisdiction on the ground that a court of this State is the more appropriate forum to determine the custody of the child under Section 207 0F-208;.0r (4) no court of any other state would have jurisdiction under the criteria specified in paragraph (1), (2), or (3). (b) Subsection (a) is the exclusive jurisdictional basis for making a child-custody determination by a court of this State. (©) Physical presence of, or personal jurisdiction over, a party or a child is not necessary or sufficient to make a child-custody determination. 64, Section 36/102 of the UCCJEA defines “home state” as follows: "Home state" means the state in which a child lived with a parent or a person acting as a parent for at least six consecutive months immediately before the ‘commencement of @ child-custody proceeding. In the case of a child less than six months of age, the term means the state in which the child lived from birth with any of the persons mentioned. A period of temporary absence of any of the mentioned persons is part of the period. 65. As stated in the Overview section and incorporated herein, the children have lived in Washington, D.C. since their birth, including living in Washington, D.C. with a parent or person acting as a parent for over six consecutive months immediately before the commencement of this action, ‘Therefore, Washington, D.C. is the children’s home state 12 ieee Washington, D.C. is the only state with jurisdiction to make an initial child-custody determination pursuant to Sandra’s Complaint for Legal Separation, Absolute Divoree, Child Custody, Child Support, Alimony, Suit Money and Other Relief, which remains pending and undetermined in the Superior Court of the District of Columbia 66. Furthermore, a court in Washington, D.C. with jurisdiction has not declined to exercise jurisdiction. Accordingly, Subparagraphs 750 ILCS 36/201(a)(2)-(4) are inapplicable. 67. Therefore, this Court should dismiss this action based on a lack of subject matter jurisdiction under the UCCIEA. Wherefore, the. Respondent, SANDRA JACKSON, prays for the following relief, instanter: A. For'the entry of an Order dismissing this action for lack of subject matter jurisdiction pursuant to the IMDMA and UCCJEA; and B, For such other and further relief as this Court shall deem equitable and just. (CHILLER DILCANTO & FLECK LLP Attorneys for YY: JESSICA BANK INTERDANDI ‘SCHILLER DU CANTO & FLECK LLP ‘Attorney No, 26828 Attorneys for Respondent 200 North LaSalle Street, 30° Floor Chicago, llinois 60601-1089 ‘Telephone No. (312) 641-5560 Facsimile Telephone No. (312) 641-6361 Service by Facsimile Transmission Will Be Accepted 13 i393 STATE OF ILLINOIS) ) COUNTY OFCOOK ‘Under penalties as provided by law pursuant to 735 ILCS 5/1-109, 1 certify that the statements set forth in this instrument are true and comect except as to matters therein stated 10 be on information and belief and as to such matters I certify that I verily believe the same to be ‘rue, Rept 8 lit ‘SANDRA JACKSON isso ‘Auy No. 26828 IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, DOMESTIC RELATIONS DIVISION SANDRA JACKSON, IN RE: MARRIAGE OF ) ) JESSE JACKSON, JR., ) ) Petitioner, ) ) No: 16D 6506 and ) ) ) ) ) Respondent, AFFIDAVIT OF SANDRA JACKSON IN SUPPORT OF HIER OBJECTION AND MOTION TO DISMISS ACTION FOR DISSOLUTION OF MARRIAGE DUE TO LACK }F PERSONAL JURISDICTION AND LACK OF SUBJECT MATTER JURISDICTION I, SANDRAJACKSON, herein certify under penalty of perjury pursuant to Section 1- 109 of the Illinois Code of Civil Procedure as follows: L ‘The Petitioner, JESSE JACKSON, JR. (“Jesse”), and I were married on June 1, 1991 2. Two children were born to Jesse and I as a result of our marriage, namely J.D.J., currently age 16, and J.L.J., currently age 13, 3. The marital residence where our children have resided since birth is located in Washington, D.C. Our children have resided in the marital residence in Washington, D.C. with a parent or person acting as a parent for over six consecutive months immediately before the ‘commencement of this action, 4. Our children are enrolled in school in Washington, D.C. where they have attended school since kindergarten, 5. Our children’s doctors, tutors, and friends are all located in Washington, D.C. 6, On information and belief, Jesse resides in Washington, D.C. Jesse’s Financial Affidavit dated August 10, 2016 certifies that his home address is in Washington, D.C. Jesse 1s EXHRIT 29008 i a ; fae resided in Washington, D.C, commencing on or about 2013. 7. Lalso reside in Washington, D.C..and have been a resident of Washington, D.C. nia where I was since on or about 2013. I temporarily resided in Alderson, West Vi incarcerated from on or about October 2015 through September 2016. During my incarceration, I always intended to return to my permanent residence in Washington, D.C., and since being released from. prison, I have resided in the marital residence in Washington, D.C. with our minor children, 8. Lam registered to vote in Washington, D.C., where I have been registered since on or about 2013. Jesse is also registered to vote in Washington, D.C, 9. +L voted in Washington, D.C. in the 2014 mayoral election and the 2016 general election. 10. Lhavé maintained a Washington, D.C. driver’s license since on or about 2013. 11, My vehicle has been registered in Washington, D.C. since on or about 2013. Jesse and 1 own is located in Washington, D.C., and 12. The marital residence w we also own a studio condominium located in Washington, D.C. 13, In 2015, Jesse and I only filed Federal and Washington, D.C. income taxes because Washington D.C., not Illinois, was both of our state of residence. 14, The probation officers for both Jesse and myself ate located in Washington, D.C., and both of our criminal defense attomeys are located in Washington, D.C. 15. The bank accounts for both Jesse and myself are located in Washington, D.C 16, Even while living in Chicago, Jesse and I directed our mail to our Washington, D.C. residence, including bills for our house in Chicago. 17. On July 14, 2016, Jesse commenced this action by filing a Praecipe for Summons. 16 213903 ‘To date, Jesse has not filed a Petition in this matter. 18. On August 11, 2016, I received a Summons while in Alderson, West Virginia ‘where [ was incarcerated. 19. On September 2, 2016, through counsel, I filed my Appearance (Limited) in this riatter for the sole purpose of contesting jurisdiction, 20, On September 2, 2016, through counsel, I filed my Motion for Extension of Time to Answer or Otherwise Appear Pursuant to 735 ILCS $/2-301 (“Motion for Extension of Time”). 21. On September 14, 2016, this Court entered an order granting me 45 days to file an n in accord with 735 ILCS 5/2-301. On October 28, 2016, this Court objection to juris entered an order granting me an extension of ten (10) days to file my objection to jurisdiction. 22. On Noveriber 3, 2016, through counsel, I filed in the Superior Court of the District of Columbia my Complaint for Legal Separation, Absolute Divorce, Child Custody, Child Support, Alimony, Suit Money and Other Relief. FURTHER, AFFIANT SAYETH NOT. ‘Under penalties as provided by law pursuant to 735 ILCS 5/1-109, 1 certify 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, I certify that I verily believe the seme to be corn Ife SCHILLER DU CANTO & PLECK LLP Attomey No, 26828 ‘Attorneys for Sandra Jackson 200 North LaSsile Street, 30th Floor Chicago, Illinois 60601-1089 Telephone No, (312) 641-5560 Facsimile Telephone No. (312) 641-6361 ‘Serve by Farsialle Taasristion Wil Be Accepted ‘SANDRA JACKS! 7 2139003 Exhibit “B” Incorporated Herein By Reference SIT IN THE CIRCUIT COURT OF COOK COUNTY ILLINOIS COUNTY DEPARTMENT, DOMESTIC RELATIONS DIVISION IN RE THE MARRIAGE OF: ) ) JESSE JACKSON, JR., ) Pefitioner, ) No. 16D 6506 and. 4) ) SANDRA JACKSON, ) Respondent, ) ORDER "Conformed Copy" ‘This cause coming on for presentment on Respondent's Motion for Extension of Time to ‘Answer ot Otherwise Appear Pursuant to 735 ILCS 5/2-301, eounsel for parties present, and the Court being fully advised in the premises; ITIS HEREBY ORDERED: qd) Q) Address: City/State: Telephone: 2088851_L.doex Respondent is granted 45 days to file an objection to jurisdiction in accord with, 735 ILCS 5/2-301, Status date 11/1/2016 af 9:30 am, 26828 Schiller DuCanto & Fleck LLP Responedent 200 N. LaSalle St, 30th FL Chicago, I. 60601 312-641-5560 ENTERED: SEPTEMBER 14,2016 DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY EXHIBIT ca ose Mine te danas clei ' ae ORDER Thus Easgibe C a byis, poiaaie a ent gn Respoleen?s Mena beer ‘abntis psi nee Leisure fires ae ad Fae Cail A ae oe despoelent v3 Grcaneot 9 ap bf pind i Ay sihie non UF Okerd Ay im ify 2. OC Sttua clase. Now. |, 29/6 ad #5bai ENTERED: r i c ore, Dat | rE | ‘a 1h od’ Sudge Rigel jyqges No, “5° DOROTBY mown, CLERK OF THE CIRCUFT COURT ‘OF COOK COUNTY, ILL] INOIS ue my Dsuten Whom - COM LN in atCOME nt IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS | COUNTY DEPARTMENT, DOMESTIC RELATIONS DIVISION IN RE THE MARRIAGE OF ) | JESSE JACKSON, JR. ; | Deion, } and } No. 16D 006506 i SANDRA JACKSON, ; Respondent, } : AGREED ORDER This cause properly before the Court, the parties being in agreement, counsel for Respondent present and the Court being fully advised in the premises, IT IS ORDERED: (1) -Respondent is granted an extension of ten (10) days to file her objection to jurisdiction pursuant to 735 ILCS $/2-301 and therefore said objection shall be filed and served on or before November 10, 2016, (2) Status is set for November , 2016 at 9:30 am, the November 1, 2016 status date is hereby stricken. Date: —ENTERED ‘ENTERED: OCT 28 2015 BERGER SCHATZLLP (Firm ID 42030) Attomeys for PETITIONER 161 N, Clark Street, Suite 2800 Chicago, llinois 60601 (312) 782-3456 (312) 782-8463 facsimile Service via email only accepted at: emailnotice@bergerschatz.com EXHIBIT O Aity No. 26828 IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, DOMESTIC RELATIONS DIVISION IN RE: MARRIAGE OF JESSE JACKSON, JR., Petitioner, No, 16D 6506 and SANDRA JACKSON, Respondent. NOTICE OF FILING Barry Schatz, Esq, Brenidan J. Hammer, Esq 4 Berger Schatz 161 North Clark Street, Suite 2800 Chicago, IL 60601 Email: emailnotice@bergerschatz.com PLEASE'TAKE NOTICE that on November 10, 2016, an Objection and Motion to Dismiss Action for Dissolution of Marriage Due to Lack of Personal Jurisdiction and Lack of Subject ‘Matter Jurisdiction was filed in the Office of the Clerk of the Cireuit Court of Cook County, Hlinois on behalf of Respondent, a copy of which is hereby served upon you. ‘The undersigned states that on November 10, 2016, I served this Notice of Filing, together with the documents referred to therein, to each person to whom it is directed, as follows: [] by personal delivery; and/or (] by depositing the same in the U.S, Mail at 200 North LaSalle Street, Chicago, Minois, with proper postage prepaid; and/or [] by facsimile machine; and/or [& by email notice to emailnotice@bergerschatz.com. Under penalties as provided by law pursuant to 735 ILCS 5/1-109, 1 certify that the statements set forth in this instrument are true and correct Susan Kmiecik SCHILLER/DU CANTO & FLECK LLP Aitomeys for Respondent 200 North LaSalle Street, 30th Floor Chicago, Ilinois 60601-1089 Telephone No. (312) 641-3560 Facsimile No. (312) 641-6361 Service by Facsimile Transmission Will Be Accepted Service Preferred at: chicagoservice@sdflaw.com 22491 Order 02/24/05) CCG N02 IN THE CIRCUIT COURT 9F COPK COUNTY, ILLINOIS i 1@ 2 GS06 Shp ont JACKSop) \ % ” Lee 8S— oe i pas Coat Pr statis, owe “This Comat, scene a Pullpadunal gr rs oeneleys. [ aces 4274 a JESSE 1S GeAvTEeD ZO DAB TO Fie AND SERLE WS ReSQse 1 THE oBlécnon $ Monon Te Osu Fikeo BP SALONA. ole & ) Hats TB DISMISS ons SARDAAS CBJECTION § NeTow 13 SET Pos. -BEcem 4) BLOAT F:30AMF Ob BP seri NG of HEAL LG om og [ECON F TOW, omey No @O3O Name BELG ER SCHATZ ENTERED: ‘Address L City/Stae/Zip CH ICAGD, LL Gogol. ef. Telephone: B20 2- emailnolile O berger sehel an DOROTHY BROWN, CLERK OF THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS

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