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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

ZHU ZHAI HOLDINGS LIMITED and )

PETER PUI TAK LEE, )

)

Plaintiffs, )

)

v. ) Case No. 20-cv-4985

)

STEVEN IVANKOVICH, )

) 

Defendant. )

CITATION NOTICE 

Judgment Debtor’s last known address:

STEVEN IVANKOVICH

382 NE 191st Street

Miami, FL 33179

Name and Address of Attorneys for Judgment Creditor or Judgment Creditor: SEE BELOW

Amount of Judgment: $4,503,842.00

Name of Person Receiving Citation: Steven Ivankovich

Court Date and Time: 9:30 a.m. on March 16, 2022

Courtroom and Court Location:

Courtroom 1241, Honorable Sharon Johnson Coleman

U.S. District Court for the Northern District of Illinois

219 South Dearborn Street

Chicago, IL 60604

NOTICE: The Court has issued a citation against the person named above. The citation directs 

that person to appear in court to be examined for the purpose of allowing the judgment creditor to 

discover income and assets belonging to the judgment debtor or in which the judgment debtor has 

an interest. The citation was issued on the basis of a judgment against the judgment debtor in favor 

of the judgment creditor in the amount stated above. On or after the court date stated above, the 

Court may compel the application of any discovered income or assets toward payment on the 

judgment.

The amount of income or assets that may be applied toward the judgment is limited by 

federal and Illinois law. THE JUDGMENT DEBTOR HAS THE RIGHT TO ASSERT 

STATUTORY EXEMPTION AGAINST CERTAIN INCOME OR ASSETS OF THE 

JUDGMENT DEBTOR WHICH MAY NOT BE USED TO SATISFY THE JUDGMENT IN 

THE AMOUNT STATED ABOVE:
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(1) Under Illinois or federal law, the exemptions of personal property owned by the debtor 

include the debtor's equity interest, not to exceed $4,000 in value, in any personal property as 

chosen by the debtor; Social Security and SSI benefits; public assistance benefits; unemployment 

compensation benefits; worker's compensation benefits; veteran's benefits; circuit breaker property 

tax relief benefits; the debtor's equity interest, not to exceed $2,400 in value, in any one motor 

vehicle, and the debtor's equity interest, not to exceed $1,500 in value, in any implements, 

professional books, or tools of the trade of the debtor.

(2) Under Illinois law, every person is entitled to an estate in homestead, when it is owned 

and occupied as a residence, to the extent in value of $15,000, which homestead is exempt from 

judgment.

(3) Under Illinois law, the amount of wages that may be applied toward a judgment is 

limited to the lesser of (i) 15% of gross weekly wages or (ii) the amount by which disposable 

earnings for a week exceed the total of 45 times the federal minimum hourly wage or, under a 

wage deduction summons served on or after January 1, 2006, the Illinois minimum hourly wage, 

whichever is greater.

(4) Under federal law, the amount of wages that may be applied toward a judgment is 

limited to the lesser of (i) 25% of disposable earnings for a week or (ii) the amount by which 

disposable earnings for a week exceed 30 times the federal minimum hourly wage.

(5) Pension and retirement benefits and refunds may be claimed as exempt under Illinois 

law. The judgment debtor may have other possible exemptions under the law.

THE JUDGMENT DEBTOR HAS THE RIGHT AT THE CITATION HEARING TO DECLARE 

EXEMPT CERTAIN INCOME OR ASSETS OR BOTH.

The judgment debtor also has the right to seek a declaration at an earlier date, by notifying the 

Clerk in writing at 219 South Dearborn Street, Chicago, Illinois 60604. When so notified the Clerk 

of the Court will obtain a prompt hearing date from the court and will provide the necessary forms 

that must be prepared by the judgment debtor or the attorney for the judgment debtor and sent to 

the judgment creditor and the judgment creditor's attorney regarding the time and location for the 

hearing. This notice may be sent by regular first class mail.

/s/ Amir R. Tahmassebi

Signature of Attorney for Judgment Creditor

Amir Tahmassebi, Bar #6287787

Konicek & Dillon, P.C.

70 W. Madison, Suite 2060

Chicago, IL 60602

(312) 328-9166 (Direct)

amir@konicekdillonlaw.com

Steven Lammers, Bar #6294413

Mandel Rauch & Lammers, P.C.

704 Adams Street, Suite F

Carmel, IN 46032

(317) 581-7440 (Direct)

slammers@mhmrlaw.com