EXHIBIT 2

Case: 1:20-cv-04985 Document #: 187-2 Filed: 05/18/22 Page 1 of 8 PageID #:1374 Case: 1:20-cv-04985 Document #: 217 Filed: 06/23/22 Page 1 of 8 PageID #:2136
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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. ) 

ALIAS CITATION TO DISCOVER ASSETS TO STEVEN IVANKOVICH

ZU ZHAI HOLDINGS LIMITED and

PETER PUI TAK LEE

________________________________ 

Judgment Creditors 

 v. 

STEVEN IVANKOVICH

________________________________ 

Judgment Debtor 

Judgment Debtors’ last known address: 

STEVEN IVANKOVICH

382 NE 191st Street 

Miami, FL 33179 

Judgment Creditors’ Address c/o Their Attorney: 

Amir Tahmassebi, Bar #6287787 

Konicek & Dillon, P.C. 

70 W. Madison, Suite 2060 

Chicago, IL 60602 

(312) 328-9166 (Direct)

(630) 262-9659 (Fax) 

amir@konicekdillonlaw.com 

Steven Lammers, Bar #6294413 

Mandel Rauch & Lammers, P.C. 

704 Adams Street, Suite F 

Carmel, IN 46032 

(317) 581-7440 (Direct) 

(317) 848-6197 (Fax) 

slammers@mhmrlaw.com

Case: 1:20-cv-04985 Document #: 187-2 Filed: 05/18/22 Page 2 of 8 PageID #:1375 Case: 1:20-cv-04985 Document #: 217 Filed: 06/23/22 Page 2 of 8 PageID #:2137
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A judgment in favor of ZU ZHAI HOLDINGS LIMITED and PETER PUI TAK LEE against 

STEVEN IVANKOVICH in the amount of FOUR MILLION FIVE HUNDRED AND THREE 

THOUSAND EIGHT HUNDRED FORTY-TWO DOLLARS ($4,503,842.00), plus postjudgment interest, was entered August 17, 2021, in the United States District Court for the 

Northern District of Illinois. The amount of the unpaid judgment as of December 28, 2021 is 

$4,651,543.34. 

Attorneys for Judgment Creditors: 

Amir Tahmassebi, Bar #6287787 

Konicek & Dillon, P.C. 

70 W. Madison, Suite 2060 

Chicago, IL 60602 

(312) 328-9166 (Direct) 

(630) 262-9659 (Fax) 

amir@konicekdillonlaw.com 

Steven Lammers, Bar #6294413 

Mandel Rauch & Lammers, P.C. 

704 Adams Street, Suite F 

Carmel, IN 46032 

(317) 581-7440 (Direct) 

(317) 848-6197 (Fax)

slammers@mhmrlaw.com

Name of party to receive citation:

STEVEN IVANKOVICH

c/o Jason M. Wandner 

100 N. Biscayne Boulevard, Suite 1607 

 Miami, FL 33132 

Email: jason@wandnerlaw.com

 

NOTICE: You are directed to appear in court to be examined for the purpose of allowing the 

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

has an interest as set forth below: 

Hearing Date/Time/Location 

April 19, 2022, at 10:30 a.m. 

Courtroom 1241, Honorable Sharon Johnson Coleman 

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

219 South Dearborn Street

Chicago, IL 60604 

The Citation was issued on the basis of a judgment against the judgment debtor and in favor of 

the judgment creditors in the amount stated above. 

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NOTICE: The court has issued a Citation against the party 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 

and in favor of the judgment creditors in the amount stated above. On or after the court date 

stated above, the court may compel the application of any discovered accounts toward payment 

of the judgment. If you do not answer or come to the court date listed above, the judge may do 

one of two things: 1) issue a rule to show cause, or 2) enter a conditional judgment. If there is a 

rule to show cause court date, you will have to explain why you did not come to court on the 

court date and why you should not be found in contempt of court. If you do not come to the rule 

to show cause on the set court date, the judge may find you in contempt, and you might be 

arrested and jailed. If the court enters a conditional judgment, you will have 30 days to answer or 

appear. If you fail to do so, then the court may enter a final judgment against you. 

At your Citation hearing, you will be asked about your property and income. You will be 

sworn to tell the truth. 

You are ordered to bring these documents at the court date:

• Federal and state income taxes for the last 2 years;

• Recent pay stubs or proof of income; 

• Bank records; 

• Title to motor vehicles;

• Deed to any property you own; AND 

• Insurance Policies. 

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

and Illinois law. YOU HAVE THE RIGHT TO ASSERT STATUTORY EXEMPTIONS 

AGAINST CERTAIN INCOME OR ASSETS OF THE JUDGMENT DEBTOR WHICH MAY 

NOT BE USED TO SATISFY THE JUDGMENT IN THE AMOUNT STATED ABOVE:

(1) Money or belongings up to $4,000 (“wildcard exemption”); 

(2) Social Security and SSI benefits; 

(3) Public assistance benefits;

(4) Child support; 

(5) Unemployment compensation benefits; 

(6) Worker’s compensation benefits; 

(7) Veteran’s benefits; 

(8) Circuit breaker property tax relief benefits; 

(9) Your equity interest, up to $2,400, in any one motor vehicle; 

(10) Your equity interest, up to $1,500, in any professional books, or tools of trade; 

(11) Pension and retirement benefits and refunds; AND 

(12) Your equity interest, up to $15,000.00 in the house in which you live. 

There are specific exemptions for wages. Under Illinois law, the amount of wages that may be 

taken to pay a judgment is limited to the lower of: 1) 15% of your gross wages, or 2) the amount 

by which your weekly wages, after deductions for taxes and other allowed deductions, is greater 

Case: 1:20-cv-04985 Document #: 187-2 Filed: 05/18/22 Page 4 of 8 PageID #:1377

The Federal Tax Returns of 2021 and 2020 are on extenstion and have not been filed.

None

I have no bank accounts in my name.

I have no vechicle title.

I own property as tennant by entirety with wife Jeanette located at 235 W. Menomonee Street P.I. N. 14-33-413-004-0000

and 14-33-413-017 -0000. I do not jave a copy of the deed. My counsel will try to secure a copy and provide it to counsel

None (assuming this request if for information about life insurance).

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than 45 times the minimum wage (currently $371.25 for one week; $742.50 for two weeks; 

$804.37 for semi-monthly wages; and $1,608.75 for a month). Federal law allows the lesser of 1) 

25% of disposable wages; or 2) the amount by which disposable earnings for a week is greater 

than 30 times the federal minimum wage. 

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

I certify this Citation Notice was sent by e-mail transmission, to judgment debtor, Steven 

Ivankovich, via his attorney, Jason Wandner, on April 13, 2022. 

I certify that everything in this Citation to Discover Assets to Steven Ivankovich is true and 

correct. I understand that making a false statement on this form is perjury and has penalties 

provided by law. 

 /s/ Amir R. Tahmassebi 

Preparer’s Signature 

Preparing Attorney’s Name: 

Amir Tahmassebi, Bar #6287787 

Konicek & Dillon, P.C. 

70 W. Madison, Suite 2060 

Chicago, IL 60602 

(312) 328-9166 (Direct) 

(630) 262-9659 (Fax) 

amir@konicekdillonlaw.com 

Steven Lammers, Bar #6294413 

Mandel Rauch & Lammers, P.C. 

704 Adams Street, Suite F 

Carmel, IN 46032 

(317) 581-7440 (Direct) 

(317) 848-6197 (Fax) 

slammers@mhmrlaw.com

 

 CLERK, UNITED STATES DISTRICT COURT,

 NORTHERN DISTRICT OF ILLINOIS

(By) DEPUTY CLERK

THOMAS G. BRUTON, CLERK

April 13, 2022

DATE

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who currently do not live with me.

 who does not live with me.

Although not requested in these citations I do own membership interests in many limited liability companies

To further clarify, this response the "support " payments are made from borrowed funds or funds advanced to me by my parents.

divorce case pending

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note a foreclosure is case is pending in Cook County Ill. on this property

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