I am very green as you will see in my attempt at writing a motion - I need your comments - please.
Background: I am the defendant in a specific performance case where the Plaintiff has obtained a default judgement. I hired an attorney that did me more harm than good and I have to learn how to write a motion to keep the plaintiff from taking title to my property. The Plaintiff was on the contract in two places 1) buyer: James McPartlan (as agent) 2) selling office: James McPartlan 'as nominee'. THe contract was negotiated with the buyer listed as Irene McPartlan. It was re-written with the buyer as James McPartlan (as agent). A Memorandum of Contract was filed against the title to my property and a specific performance claim was made by James McPartlan d/b/a Provident Development Group, LLC.
No where on the contract is any mention of a Provident Development Group, LLC. I am past 30 days 'for no just reason' and the plaintiff has filed a petition for attoneys fees. I can't find where he can petition for attorney's fees after 30 days. Please look and comment on my attempt at a motion - I need help.

SPECIAL AND SPECIAL APPEARANCE BY VERIFIED RESPONSE / OBJECTION TO THIS COURT’S JURISDICTIONAL CLAIM TO HEAR PLAINTIFF’S PETITION FOR ATTORNEY’S FEES/
MOTION TO STRIKE PLAINTIFF’S MOTION FOR ATTORNEY’S FEES AND DISMISS FOR FRAUD/LACK OF JURISDICTION (735 ILCS 5/2-615, 735 ILCS 5/2-619.1)
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Now come, Vicky Johnson, having been unable to find competent representation that I can afford and therefore not being represented, appearing, specially under threat, duress, and coercion, only to protect my own interests, and appearing in Propria Personae and Sui Juris herein responds to plaintiff’s Petition for Attorney’s fees and respectfully request that this Honorable Court strike Plaintiff’s Motion for Attorney’s Fees and Dismiss pursuant to Section 2-615 of the Code of Civil Procedure for lack of jurisdiction.
I, Defendant, Vicky Johnson requests that the court take Judicial Notice of the enunciation of principles as stated in Haines v. Kerner, 404 U.S. 519, wherein the court has directed that those who are unschooled in law making pleadings and/or complaints shall have the court look to the substance of the pleadings rather than the form, and also hereby makes the attached memorandum, including the related documents attached herewith, in the above-referenced case. Furthermore, I, Vicky Johnson, hereby requests this court to notify me of any sua sponte, rights or remedies I have overlooked.
In support Vicky Johnson states as follows in response to each count of Plaintiff’s petition:


LACK OF JURISDICTION
ILLEGAL PLAINTIFF/CONTRACT
2. I, Vicky Johnson, never entered into a legally binding contract with Provident Development Group, LLC and the Plaintiff has never provided evidence of a legally binding contract between Vicky Johnson and James V. McPartlan d/b/a Provident Development Group, LLC and therefore the court could not have jurisdiction in that every standing the Plaintiff claims on the alleged legal contract the judgement was entered upon is illegal and void in that:
2.1. Provident Development Group, LLC is not a legal corporation in the state of Illinois It is not registered to conduct business in Illinois and any contract entered into with Provident Development, LLC is illegal and void on it’s face. This court cannot obtain jurisdiction over an entity that does not exist.
2.2. Provident Development Group, LLC did not disclose the true identity of the corporation as required pursuant to Illinois Business Act and therefore any contract entered into with Provident Development Group, LLC is illegal and void. A party has a right to know with whom they are contracting with and it is illegal to change parties to a contract.
2.3. James V. McPartlan d/b/a Provident Development Group, LLC used misrepresentation and fraud in negotiating a contract. A contract was negotiated in good faith with the buyer being Irene McPartlan and was subsequently re-written after negotiations with the explanation that it was too messy. The buyer was changed in the rewritten contract to James McPartlan ‘as agent’ which I, Vicky Johnson reasonably assumed was the agent for Irene McPartlan. I, Vicky Johnson was never informed that the actual buyer was changed. This misrepresentation caused me to negotiate more favorably than I would have if I had known the buyer was a corporation that could reasonably be expected to afford more and to rely upon the buyer, not being a corporation and represented by itself, to be pre-qualified by the licensed real estate agent representing her and would contract in good faith.
2.4. James V. McPartlan’s real estate license was ‘inoperative’ at the time he created the alleged contract and throughout the term of the contract and therefore he was acting illegally by presenting any contract as a licensed Real Estate agent or Broker and any alleged contract created as a licensed Realtor or Broker is illegal and void.
2.5. James V. McPartlan d/b/a Provident Development Group, LLC claims on the contract to be a Real Estate agent for Provident Realty in Cary, Illinois and there is no office with that name registered to do business in Cary, Illinois. Therefore any contract created through Provident Realty is illegal and void.
3. The document accompanying the plaintiff’s petition is not properly verified in accordance with court rule 731 ILCS 5/1-109, and as such, should be striken.

LACK OF JURISDICTION
DENIED DUE PROCESS

4. Defendant Vicky Johnson has been denied due process as evidenced herein and respectfully requests this court to void and dismiss any and all orders and judgements pursuant to this action and states:
4.1. That I, Vicky Johnson, was never properly notified or served in this action as evidenced by the following:
4.1.1. I, Vicky Johnson, did not reside at 8412 Abbott Grove, Cary, IL when the alleged substitute service on Curtis Gregory Johnson took place as supported by affadavits of three persons, Josephine Mae Rogers, Charles Ellison and Vicky Johnson.
4.1.2. The alleged service on Curtis Gregory Johnson has been denied in affadavit by Curtis Gregory Johnson.
4.1.3. The alleged service on Curtis Gregory Johnson was denied in correspondance to the Plaintiff, and caused the Plaintiff to amend the Affidavit of service which was entered into the court without a written motion or notice to myself, Vicky Johnson. There is no evidence in the record of any attempt to serve notice upon the purported defendants of any intent to file amended Affidavits of Service, as required.
4.1.4. The affidavits of service are not in conformance with 735 ILCS 5/1/109, as required by 735 ILCS 5/1-202 (a) the rules and are a nullity.
4.1.5. The alleged affidavits of service are contradictory unto themselves making them inadmissible under the Rules of Evidence. Specifically, William Brogan states on one “affidavit” that he dropped the summons on the ground, and left and on the “affidavit” of substitute service William Brogan claimed to have “delivered” the documents, and explained the contents therein it is not possible for both portrayals to be accurate
5. With this court having issued the language of a final and appealable Order more than thirty days prior to the filing of the plaintiff’s petition, there is no basis or in law or in Statute for this Court to claim jurisdiction to hear this matter

6. Defendant, Vicky Johnson is entitled to an order of dismissal as a matter of law. This pettition for fees and the Complaint in this matter should be dismissed, with prejudice, due to the lack of jurisdiction. Wherefore I respectfully request this court to:

6.1. Find that this court does not have jurisdiction to hear the plaintiff’s motion in this action for failing to provide any lawful evidence of a contract between Provident Development Group, LLC and Vicky Johnson and Curt Johnson due to the failure by the plaintiff’s to state a claim for which relief can be granted, or in the alternative:. Or, in the Alternative in the event that this court finds that it has jurisdiction to hear the plaintiff’s motion, I herein object to that finding.
6.2. Dismiss this action in it’s entirety for lack of jurisdiction
6.3. Declare any and all Orders issued by this Court in this action to be void for lack of jurisdiction
6.4. Declare any and all Orders issued by this Court in this action Void for lack of jurisdiction in denying defendant, Vicky Johnson due process.
6.5. Strike the documents titled Affidavit of service and affidavit of substitute service, Amended affidavit of service and Amended Affidavit of Substitute Service for not confirming with the minimum standards required by court rules.
6.6. Order the Plaintiff James V. McPartlan d/b/a Provident Development Group, LLC to remove the Memorandum of Contract recorded on the Defendants title to her property.
6.7. Forward a copy of the record of this action, in it’s entirety, to the Lake County State’s Attorney, the Illinois Office of banks and Real Estate, and the Illinois Supreme Court for these offices to investigate the possible mail fraud, wire fraud, and other crimes that the record may show have been committed by the plaintiff, his Representatives, and others including Curt P. Rehberg, Jamie Rein, William Brogan, Hrody and Associates, Curt P. Rehberg and Associates, James V. McPartlan, James V. McPartlan, an Illinois Licenses Broker, James V. McPartlan d.b.a. Provident Development Group L.L.C., Provident Development Group Ltd. Irene Mcpartlan. This action is required pursuant to judicial Cannon 3, Illinois Supreme Court Rule 63, and RDC Rule
6.8. Any other relief this Court finds just and equitable.


Prepared and Respectfully Presented by:

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Vicky Johnson