3303 —Notice of Maton 2871 ~Centfieae of Maling Fle (@or6r16)ccDR Noos IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, DOMESTIC RELATIONS DIVISION In Re the [XJ Marriage [] Civil Union ([] Support of (1 Parentage (_] Other JESSE JACKSON JR. ) Petitioner, And ) No. ) SANDRA JACKSON ) Respondent. ) NOTICE OF MOTIO’ TO: Jessica Bank Interlandi Schiller DuCanto & Fleck 200 North LaSalle Street, 30" Floor Chicago, Illinois 60601 On April 28, 2017 at _9:30_a.m., or as soon thereafter as counsel may be heard, I shall appear before the Honorable Carole K, Bellows, or any judge sitting in his/her stead, in courtroom number 1602 in the courthouse located at Richard J. Daley Center, 50 W. Washington Street, Chicago Illinois and present the attached pleading requesting: Motion for Voluntarily Dismissal. Attorney Signature: Name: Berger Schatz, LLP ‘Attorney for: Jesse Jackson, Jr. Address: 161 North Clark Street, #2800 City, State, ZIP: Chicago, Illinois 60601 Telephone: (312) 782-3456 Attorney Code No. 42030 Email Service: emailnotice@bergerschatz.com CERTIFICATE OF SERVICE The undersigned hereby certifies, under penalties as provided by law pursuant to Section 1-109 of the Code of Civil Procedure, that this Notice of Motion together with the documents referred to therein, were served by the undersigned on the above-named party via e-mail from ally RergerSchatz.com to chicagoservice@sdflaw.com before 5:00 p.m.,on April 2, 2017.IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT, DOMESTIC RELATIONS DIVISION IN RE THE MARRIAGE OF: ) JESSE JACKSON JR., } Petitioner, } and } No. 16D 6506 SANDRA JACKSON, } Respondent, } MOTION FOR VOLUNTARY DISMISSAL Petitioner, JESSE JACKSON, JR. (“Jesse”), by his attomeys, Berger Schatz LLP, pursuant to 735 ILCS 5/2-1009, and in support of his Motion for Voluntary Dismissal, states: 1. Jesse filed a Praceipe for Summons on or about July 14, 2016. 2. Jesse filed a Petition for Dissolution of Marriage on or about December 12, 2016, which remains pending and undetermined, Respondent, SANDRA JACKSON (“Sandra”), has not yet filed a Response to the Petitioner for Dissolution of Marriage. 3. Jesse desires to dismiss his Petition for Dissolution of Marriage. 4, Jesse has an absolute right to voluntarily dismiss this cause of action. 5. Specifically, Section 5/2-1009 of the Illinois Code of Civil Procedure states, as follows: The [Petitioner] may, at any time before trial or hearing begins, upon notice to each party who has appeared or his attorney, and upon payment of costs, dismiss his action or any part thereof as to any defendant, without prejudice, by order filed in the cause.6. Pursuant to Section 5/2-1009, Jesse is prepared to tender legally authorized and applicable costs to Sandra upon dismissal. 7. Trial of this cause has yet to commence. WHEREFORE, Petitioner, Jesse Jackson, Jr., respectfully requests that this Court: A. Enter an Order voluntarily dismissing this action without prejudice; B, Conducting a hearing to determine what costs, if any, should be paid pursuant to Section 5/2-1009 and applicable case law; and C. Granting such to Petitioner such other relief as this Court deems appropriate. Respectfully submitted, Jesse Jackson, Jr. BY: 3 analanHemtr, Berger Schatz LLP, His Attorneys Berger Schatz LLP 161 North Clark Street Suite 2800 Chicago, Illinois 60601 (B12) 782-3456 Attorney No. 42030 Attomeys for Jesse Jackson, Jr. emailnotice@bergerschatz.com