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XXX
MOTION TO CONTINUE – 1
XXX
Attorneys’ Business Address
City, ST ZIP Code
Phone | Fax
Email
IN THE CIRCUIT COURT FOR COOK COUNTY, ILLINOIS
MUNICIPAL DEPARTMENT – FIRST DISTRICT
CITY OF XXX, A MUNICIPAL
CORPORATION,
Plaintiff,
vs.
XXX; AND
UNKNOWN OWNERS; AND NON-RECORD
CLAIMANT,
Defendants
Case No .:XXX
XXX
XXX
XXX
XXX
MOTION TO
CONTINUE
Dated this XXX
Respectfully Submitted,
____________________________________XXX
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XXX
MOTION TO CONTINUE – 2
NOTICE OF MOTION TO CONTINUE
TO THE ABOVE-ENTITLED COURT AND ALL INTERESTED PARTIES AND THEIR
ATTORNEYS OF RECORD HEREIN:
` PLEASE TAKE NOTICE that on the XXX at XXX am, or as soon
thereafter as the matter may be heard in Room 1704 at the Circuit Court for Cook County located
at the XXX
will bring on for hearing his Motion to Continue on the grounds that it is the first time Anthony
will be requesting for a continuance of this case; no party will be prejudiced in regard to the
continuance; this Motion will help streamline the issues for trial; and Anthony will be prejudiced
if this Motion is not granted.
This Motion is brought under XXX which provides as follows: “On good
cause shown, in the discretion of the court and on just terms, additional time may be granted for
the doing of any act or the taking of any step or proceeding prior to judgment. The
circumstances, terms and conditions under which continuances may be granted, the time and
manner in which application therefor shall be made, and the effect thereof, shall be according to
rules.”
This Motion is based upon this Notice of Motion, the attached Memorandum of Points in
Support of Motion to Continue, the pleadings and records on file in this matter, upon any
evidence which this Court may take judicial notice, and such further oral and/or documentary
evidence as may be presented at the time of the hearing on the Motion.
Dated this XXX
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ANTHONY CARIDI’S MOTION TO CONTINUE – 3
Respectfully Submitted,
____________________________________
XXX
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XXX MOTION TO CONTINUE – 4
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF ANTHONY
CARIDI’S MOTION TO CONTINUE
A party seeking a continuance, whether contested or uncontested or stipulated to by the
parties, must make the motion as soon as reasonably practical once the necessity for continuance
is discovered. Anthony submits that a trial court has broad discretion in allowing or denying a
motion for continuance. XXX.
The exercise of such discretion will not be disturbed on appeal unless there has been a
manifest abuse of discretion. XXX.
Such discretion must be exercised with due regard for all interests involved and a refusal
to grant a continuance which has the practical effect of denying the movant due process is a
reversible error. Courts are liberal in granting continuances when the facts as in this present case
justify such continuance.
A critical consideration in determining whether or not a continuance should be granted is
whether the party seeking the continuance has acted with diligence. XXX. Due diligence can be seen in the Food
Not Bombs Free Skool N.F.P. ministry work done by Anthony.
The Food Not Bombs Free Skool N.F.P Ministry work will be located in Illinois,
Chicago. It is a Market Church ministry and will operate a Mobil Technician Service owing to
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ANTHONY CARIDI’S MOTION TO CONTINUE – 5
the adverse effect that the pandemic has had on it. The church applied for the SBA Targeted
EIDL Advance Application Number XXX.
The other church project is supporting a self-sustained Student Internship Core. This is
because the church believes that investing in children is investing in power. However, the church
will require the assistance of congressional, religious, and community representatives to address
its needs. This is especially regarding the SBA Grant EIDEL Disaster Loan Approval and the
needs of the community. The Student Internship Core will be designed to create jobs for students
in their chosen vocation and the students will work in teams. This will be part of developing
models within their chosen career skills.
The Two-by-Two Ministry of the church will also provide individual education designed
in cooperation with communication leaders, teachers, churches, police caps, and other non-
profits to coordinate ongoing Children Educational that is reflective of children’s capacity to
learn at an early age. The church also intends to protect the Children’s Rights for educational
standards that provide an equal learning opportunity to Integrated education that include 5
foreign languages.
Student Ministry designed to work with Student Interns that include and require
Community outreach that will support our repair shop , and other Student Purpose Economy
work related plans, requiring working collaboration’s with Religion, Business and Law
Enforcement to organize; costumer base that will support the student, this model helps the
Community across the board) using modern science and Economic principles to keep the
Educational Needs of Children current and provide Effective Mental, Emotional and Spiritual
Support.
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XXX MOTION TO CONTINUE – 6
Profits from the Church’s economic educational Ministry will be placed in God’s
Storehouse Covenants Fund that supports Students Internships, first to Mentor Children and the
families of Children that are on Track. The SBA grant and loan are earmarked to acquire needed
Equipment for our Automotive Purpose Economy Internships. The church will come alongside
the Community and demonstrate that Jesus is a mastermind marketer provided instructions that
are not against business, but against the Money Changers, and that using biblical principles to
demonstrate that Mentorships are well-established covenants for both Religious or Non-
Religious Content.
The Student CORE provide Students a Sustainable Community-based Economic Models
that support our Two By Two Tutoring, Mentoring, and Counselling for Children and the Family
of Children that are off Track and establish preventive education at all levels To counter the
effects of existing and expanding business policies that undermine Human Values that hurt
students, retirees and deny excess to immigrants, that built our country and contribute need
resources our mission is to bolster human right and counter-economic policies that undermine
human Value and Rights I have made a shortlist that include:
o Offshoring/ loss of productivity gains at every level that hurt.
o Automation and advanced AI/Robotics will continue to displace millions of entries and
high-level service, tech, and professional jobs that undercut wages, lower our purchasing
power, undermine our treasury and already weak social security system.
o Loss of Tax revenue from Jobs, Spending, and economic growth is passed on as
governments raise existing and imposes new regulatory fees.
o Organized Cartels: World wide networks will further thrive as Robotics displace us from
our work and other roles (Saudi Arabia has already granted citizenship to the first robot –
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XXX MOTION TO CONTINUE – 7
Sophia). Japan has a 10-year lead on China with one million robotic workers and robotic
revenue produces 70 billion in revenue. Meanwhile, China has 5G spy systems that ticket
jay walkers.
o Loss of Jobs and Jobs training, and Tax Shortfalls aids in establishing conditions for
organized crime activities, and causing their influence to flourish.
o International cartels. In addition to illegal smuggling of Drugs Guns and Drug making
operations, they register thousands of corporate shell companies that operate under
wholesale Distribution tax exemptions (this is the number one cause of tax revenue loss)
and provides perfect legal cover for money laundering that further exploits our
communities.
The Core provides Churches a process to organize community business, economic and
social development resources that include knowledge, Purchasing Power and Management skills
to develop a Localized Circular Economy that benefits students of all ages, minimize teacher
burn out, through the internship program that brings a large talent pool of children and provide
law enforcement a seat at the guidance table and administer programs that reward community
members
Localized Church Business partnership is an alternative Community financial system that
rewards achievement that rivals Sports and Entertainment Culture and establishes Church culture
working within IRS Rules to develop Covenant Funds as a special Purpose fund that protects
present and future rights such as intellectual property rights.
Food Not Bombs Free Skool N.F.P Ministry is based in Illinois hence the tax measures of
the state will be applicable to it. Accordingly, the Property Tax Code provides that property used
exclusively for religious purposes will qualify for exemption as long as it is not used with a view
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XXX MOTION TO CONTINUE – 8
to profit (35 ILCS 200/15-40(a)). In this context, the term “exclusively” refers to the primary
purpose for which the property is used.
This section of the Property Tax Code applies to property owned by religious institutions
and used in furtherance of the religious institutions’ functions or services, including churches,
religious schools, orphanages, convents, and, in applicable situations, housing facilities for
religious officials and their families (35 ILCS 200/15-40(b)). If the property used for religious
purposes is determined to be operating with a view to profit, that use destroys any eligibility for
property tax exemption. For example, if a property owner intends to earn a profit resulting from
its religious activities, or by leasing the property, then that property is not eligible for property
tax exemption.
From the preceding, the church qualifies to be exempted from paying tax. This is because
the church is a religious institution and will be used in furtherance of the religious institution’s
functions or services. The church will also be careful not to be involved in profitable operations
to avoid being excluded from being eligible to be exempted from tax.
Further, having established that the church will be a non-profit institution, the church,
through an advocate will file an application through an administrative filing process. The
application process begins with filing an application with your local County Board of Review
containing all of the required materials. The application will then be reviewed by the Board of
Review and a recommendation is made to the IDOR as to whether the property should be granted
property tax exemption. The IDOR does not need to follow the Board of Review’s
recommendation and conducts its own analysis of the application.
If the application and accompanying documentation sufficiently establish the applicant
organization’s qualification for exemption, it should be approved. However, if the application is
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XXX MOTION TO CONTINUE – 9
denied by the IDOR, the church will proceed with an administrative appeal and, potentially, a
subsequent court appeal. Once a real estate tax exemption is successfully obtained, exempt
organizations must file annual affidavits with their local County Assessor’s offices by a specific
deadline in order for their exemptions to continue. The exempt ownership and use of the property
must remain unchanged.
REASONS WHEREFORE, PREMISES CONSIDERED, XXX respectfully requests
this Honorable Court to grant this Motion to Continue until [INSERT DATE]. A continuance is
in the interest of fairness, justice, and judicial economy.
Dated this XXX
Respectfully Submitted,
____________________________________
XXX
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XXX MOTION TO CONTINUE – 10
VERIFICATION
I, XXX being duly sworn depose and say that I have read the foregoing Motion to
Continue and know the contents thereof. That the same is true of my own knowledge except as to
those matters and things stated upon information and belief, and as to those things, I believe
them to be true.
_________________________________
(Sign in the presence of a Notary Public)
Sworn to and subscribed before me this XXX
______________________________
Notary Public
________________________________________
(Printed name of Notary Public)
My Commission Expires: ____________________
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