Bank of America v. Ishak

2025 IL App (1st) 232197-U
CourtAppellate Court of Illinois
DecidedFebruary 10, 2025
Docket1-23-2197
StatusUnpublished

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Bluebook
Bank of America v. Ishak, 2025 IL App (1st) 232197-U (Ill. Ct. App. 2025).

Opinion

2025 IL App (1st) 232197-U

No. 1-23-2197

Order filed February 10, 2025.

First Division

NOTICE: This order was filed under Supreme Court Rule 23 and is not precedent except in the limited circumstances allowed under Rule 23(e)(1). ______________________________________________________________________________ IN THE APPELLATE COURT OF ILLINOIS FIRST DISTRICT ______________________________________________________________________________ BANK OF AMERICA, ) Appeal from the ) Circuit Court of Plaintiff-Appellee, ) Cook County. ) v. ) No. 22 M1 117907 ) MELAD A. ISHAK, ) The Honorable ) Timothy W. Wright III, Defendant-Appellant. ) Judge Presiding.

JUSTICE LAVIN delivered the judgment of the court. Presiding Justice Fitzgerald Smith and Justice Pucinski concurred in the judgment.

ORDER

¶1 Held: We affirm the judgment of the trial court as appellant has failed to furnish a sufficient record such that error can be determined.

¶2 Defendant Melad A. Ishak appeals pro se from the trial court’s entry of default judgment

in favor of plaintiff Bank of America in its action to collect on a credit card debt. On appeal,

defendant contends that the default judgment was entered due to his “non-presence” and the trial

court failed to acknowledge his circumstances on the day of the hearing. Defendant further No. 1-23-2197

contends that summary judgment should be entered in his favor because plaintiff failed to meet

professional and legal standards and violated the terms of its credit card agreement. We affirm.

¶3 The record on appeal does not contain a report of proceedings. The following facts are

gleaned from the common law record.

¶4 On September 8, 2022, plaintiff filed a consumer debt complaint against defendant seeking

damages of $11,6713.79, for failure to pay a credit card debt.

¶5 The record contains an affidavit of a special process server filed in the circuit court on

April 12, 2023. The special process server averred that on April 7, 2023, an alias summons and

complaint was left with defendant’s mother at defendant’s usual abode.

¶6 The alias summons stated that the next court date was 10 a.m. on July 6, 2023, in Room

1101. Also attached was Circuit Court of Cook County, First Municipal District Civil Division

General Order 2020-12, Amended (General Order 2020-12). General Order 2020-12 states,

relevant here, that effective July 6, 2020, all civil cases would be heard via Zoom, and listed

courtroom “ZOOM MEETING IDS AND PASSWORDS.” The list of courtrooms appeared on a

two-page document, with courtroom 409 on the first page and the remaining courtrooms listed in

numerical order on the second page.

¶7 On May 1, 2023, defendant filed a pro se appearance.

¶8 On May 23, 2023, defendant appeared pro se and plaintiff appeared through counsel. The

trial court set a status date of June 27, 2023, at 11 a.m. in Room 1101.

¶9 On May 21, 2023, plaintiff emailed defendant notice regarding a June 27, 2023, hearing in

Room 1101 to be held “via zoom conference (please see attached zoom instructions).” Attached

was, relevant here, a copy of General Order 2020-12.

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¶ 10 On June 27, 2023, the trial court held an initial case management conference. Defendant

appeared pro se and plaintiff appeared through counsel. The court ordered the parties to the Early

Resolution Program and continued the case until August 1, 2023.

¶ 11 On July 6, 2023, plaintiff emailed defendant a notice of the August 1, 2023, hearing in

Room 1101 at 11 a.m. The notice stated the hearing would be held “via zoom conference (please

see attached zoom instructions),” and attached, relevant here, a copy of General Order 2020-12.

¶ 12 On August 1, 2023, the trial court transferred the case to the presiding judge for further

proceedings because the case was not settled. The court’s order reflected that defendant was

present. On August 9, 2023, the cause was transferred to Room 1102.

¶ 13 On October 10, 2023, plaintiff filed a motion for default judgment. Attached was a “Notice

of Motion” stating that on October 24, 2023, at 2 p.m. in Room 1102, plaintiff’s counsel would

present the motion for default judgment “via zoom conference (please see attached zoom

instructions)” and attached a copy of General Order 2020-12. The proof of service stated that the

notice was served on defendant by email and contained a certification pursuant to section 1-109 of

the Code of Civil Procedure (735 ILCS 5/1-109 (West 2022)).

¶ 14 On October 24, 2023, plaintiff’s counsel appeared before the trial court. The court granted

the motion for default and entered judgment against defendant in the amount of $11,671.79 plus

court costs.

¶ 15 On appeal, defendant contends that plaintiff “used” defendant’s nonattendance in the

“correct” courtroom to convince the trial court to grant the motion for default judgment. He argues

that he was not present at the hearing because “complex court documents” sent by plaintiff left

him “very” confused by the change of “Zoom room” from 1101 to 1102, which had a different

-3- No. 1-23-2197

Zoom identification and password. He contends that he waited in Room 409 for three hours and

attaches copies of screenshots from his phone in support. Defendant further contends plaintiff

failed to meet professional and legal standards and violated its credit card agreement. He asks this

court to vacate the default judgment and enter summary judgment in his favor as he was not heard

by the court “due to unintentional mistake.”

¶ 16 As a preliminary matter, our review of defendant’s appeal is hindered by his failure to fully

comply with Illinois Supreme Court Rule 341 (eff. Oct. 1, 2020). While defendant’s brief contains

a narration of the case from his point of view, it lacks cohesive legal arguments, reasoned bases

for those arguments, and citations to the record in violation of Rule 341(h). See Ill. S. Ct. R.

341(h)(6), (7) (eff. Oct. 1, 2020). “Arguments that do not comply with Rule 341(h)(7) do not merit

consideration on appeal and may be rejected by this court for that reason alone.” Wells Fargo

Bank, N.A. v. Sanders, 2015 IL App (1st) 141272, ¶ 43. Accordingly, to the extent that defendant’s

brief fails to comply with Rule 341(h)(7), his arguments are forfeited.

¶ 17 Moreover, defendant has attached copies of screenshots to his brief that were not presented

to the trial court and therefore cannot be considered on appeal. See Jackson v. South Holland

Dodge, Inc., 197 Ill. 2d 39, 55 (2001) (documents not submitted to the circuit court are not properly

a part of the record on appeal and cannot be considered on appeal).

¶ 18 Considering the content of defendant’s brief, it would be within our discretion to dismiss

his appeal. Zale v. Moraine Valley Community College, 2019 IL App (1st) 190197, ¶ 32. However,

because we understand the issues defendant wishes to raise and have the benefit of a cogent

appellee’s brief, we choose to consider the discernible merits of the appeal. See Twardowski v.

-4- No. 1-23-2197

Holiday Hospitality Franchising, Inc., 321 Ill. App. 3d 509, 511 (2001). That said, the deficiencies

in the record still prevent us from reaching this appeal on the merits.

¶ 19 On appeal, the appellant, in this case defendant, has the burden to provide a complete record

for review in the appellate court to support his claim of error. Foutch v. O’Bryant, 99 Ill.

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Related

Twardowski v. Holiday Hospitality Franchising, Inc.
748 N.E.2d 222 (Appellate Court of Illinois, 2001)
Foutch v. O'BRYANT
459 N.E.2d 958 (Illinois Supreme Court, 1984)
Jackson v. South Holland Dodge, Inc.
755 N.E.2d 462 (Illinois Supreme Court, 2001)
Corral v. Mervis Industries, Inc.
839 N.E.2d 524 (Illinois Supreme Court, 2005)
Wells Fargo Bank, N.A. v. Sanders
2015 IL App (1st) 141272 (Appellate Court of Illinois, 2015)
Zale v. Moraine Valley Community College
2019 IL App (1st) 190197 (Appellate Court of Illinois, 2019)

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Bluebook (online)
2025 IL App (1st) 232197-U, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bank-of-america-v-ishak-illappct-2025.