The November 2, 2026 verified motion challenges the factual foundation of the Secretary of State’s driving-relief denial and demands preservation of the records behind it. The case is Allababidi v. Giannoulias, No. 2026 CH 01421, Cook County Chancery Division, Calendar 3, Judge Allen Price Walker. The administrative decision under review is dated February 5, 2026, File J-03014-25.
2026 11 02 verified giannoulias motion · public reading copy. 2026 11 02 supplemental exhibits 1 3 · public reading copy.
The ten-ground audit
The underlying court-filed pages show the contradictions directly. Finding 7(c), R. 5, says: “Petitioner refused to provide testimony regarding his history of symptoms.” Transcript page 17, R. 24, records answers of “No” to the symptom questions. Finding 13, R. 6, cites 9(a) as a reason for denial, while Finding 9, R. 5, has no subparagraph (a). Compare the court-filed findings R. 4–6 with transcript R. 23–25 · six source pages. These pages retain the original record numbers, transcript line numbers, and April 17 clerk markings.
The motion places the grounds enumerated in Finding of Fact 13 beside the certified administrative record. Its central argument is that the decision depends on reasons contradicted by the transcript, reasons borrowed from an evaluation the agency declined to credit, and a cited subparagraph—9(a)—that is absent from Finding 9.
- Findings 7(a) and 7(c): the motion compares statements that the petitioner refused testimony with answers in transcript pages 16–18, certified-record pages 23–25. See motion pages 3–4.
- The evaluator’s identity: the motion points to the hearing transcript identifying Douglas Allen and the evaluation’s identification of Allen’s Family Counseling, against the agency’s statement that the evaluator was unknown. See motion pages 3 and 5.
- Finding 9(a): Finding 13 lists that subdivision as a reason for denial; the motion identifies Finding 9’s actual text at certified-record page 5. See motion page 4.
- Extra-record material: the motion asks the reviewing court to strike Exhibit 1 to the State’s memorandum under 735 ILCS 5/3-110 and to review the agency’s stated reasons. See motion pages 2 and 8–11.
These are extremely concerning questions about the integrity of administrative fact-finding: whether the reasons used to deny relief accurately represent the record the agency certified. The motion’s comparisons identify exact findings and transcript pages for inspection.
Two county email failures and the August 3 search response
Paragraphs 31–33 document separate delivery failures for county prosecutors Francis DeRosa and Nicholas Shepherd, then connect the preservation request to the Attorney General’s FOIA response. Read the dated email-record chronology and exact server responses.
The sources identify distinct actors: Giannoulias is the Secretary of State named in the administrative-review case; DeRosa and Shepherd are county prosecutors; Elizabeth J. Ptacek signed the Attorney General’s FOIA letter. Keep each act with its actual actor.
The relief requested
The motion seeks outright reversal under 735 ILCS 5/3-111(a)(5), restoration of driving privileges, exclusion of the challenged material, preservation of the specified FOIA search and intake records, and retention of jurisdiction over the pending Rule 137 motion. It identifies December 29, 2026 as the next setting. Its signature, verification, and certificate of service are dated November 2, 2026.
The selected Desktop binder contains 1,039 pages, organized into court filings, orders, separately identified proposed orders, correspondence exhibits, and 71 retrieved email bodies. Operator vault · original chronological appendix. Operator vault · original November 2 packet.