In re Marriage of Nitsche

Appellate Court of Illinois·Decided August 25, 2026·No. 2-25-0488·Unpublished

Opinion

2026 IL App (2d) 250488-U No. 2-25-0488

Order filed August 25, 2026

NOTICE: This order was filed under Illinois Supreme Court Rule 23(b) and is not precedential except in the limited circumstances allowed under Rule 23(e)(1).

IN THE

APPELLATE COURT OF ILLINOIS SECOND DISTRICT

In re MARRIAGE OF DANIELLE E. NITSCHE, Petitioner-Appellee, and

JOHN A. BOSCH, JR., Respondent-Appellant.

Appeal from the Circuit Court of Kane County.

Honorable Alice C. Tracy, Judge, Presiding.

No. 23-DN-542

JUSTICE MULLEN delivered the judgment of the court.

Justices McLaren and Birkett concurred in the judgment.

ORDER

¶1 Held: (1) Section 3 of the Illinois Uniform Premarital Agreement Act (750 ILCS 10/3 (West 2022)) does not require a party to produce a fully executed original or fully executed copy to establish that both parties signed premarital agreement; and (2)

trial court’s finding that both parties signed premarital agreement was not against the manifest weight of the evidence. Affirmed.

¶2 In this dissolution of marriage action, petitioner, Danielle E. Nitsche, filed a petition for a declaratory judgment regarding the validity and enforceability of a premarital agreement between her and respondent, John A. Bosch, Jr. Following an evidentiary hearing, the circuit court of Kane County ruled that the premarital agreement was valid, enforceable, and admissible. Respondent appeals, contending that the trial court erred in granting declaratory relief in petitioner’s favor. Respondent argues that because petitioner produced only a copy of the agreement signed by him,

the agreement did not satisfy the execution requirements of section 3 of the Illinois Uniform Premarital Agreement Act (Act) (750 ILCS 10/3 (West 2022)) and was therefore invalid and unenforceable. We affirm. ¶3 I. BACKGROUND ¶4 Petitioner and respondent married in California on November 14, 2015. At the time of the wedding, both parties were employed by PepsiCo. They later relocated to Illinois. On September 15, 2023, petitioner initiated dissolution proceedings by filing a two-count petition. Count I, labeled “Verified Petition for Dissolution of Marriage,” sought entry of a judgment of dissolution of marriage. Paragraph seven of the petition alleged that in September 2015, “[the parties] entered into a Prenuptial Agreement.” Count II, labeled “Verified Petition for Declaratory Judgment,” sought a declaration that the premarital agreement was valid and enforceable and that its terms and provisions be incorporated into a judgment for dissolution of marriage. Petitioner attached to her petition an affidavit stating that the premarital agreement was “not accessible to [her] at this time” despite diligent efforts to locate it. ¶5 On October 30, 2023, respondent filed a counter-petition for dissolution of marriage and a response to petitioner’s petition. In his response, respondent admitted petitioner’s allegation that the parties “entered into” a premarital agreement but disputed its enforceability. On November 16, 2023, petitioner filed a response to the counter-petition, asserting the premarital agreement’s validity as an affirmative defense. In May 2024, respondent filed a motion for leave to amend his response, asserting that it contained a “mistake of fact.” Specifically, respondent stated that he and petitioner did not enter into a premarital agreement “as [petitioner] did not execute a prenuptial agreement—as neither party can produce a fully executed original or copy of a prenuptial agreement.” Over petitioner’s objection, the trial court granted respondent leave to amend his

response. Respondent thereafter filed an amended response denying the allegations in paragraph seven of petitioner’s verified petition and asserting that petitioner did not execute the alleged premarital agreement. ¶6 On September 9, 2024, the trial court heard argument on count II of petitioner’s verified petition. Petitioner contended respondent’s original response to paragraph seven constituted a judicial admission. Respondent countered that the Act requires a premarital agreement to be signed by both parties. The court determined an evidentiary hearing was necessary. ¶7 At the hearing, petitioner called respondent to testify. Respondent recounted that the parties had been in a relationship for six years before becoming engaged early in 2015. After petitioner raised the issue of a premarital agreement, both parties retained counsel. Petitioner’s attorney prepared the first draft of the agreement. The attorneys thereafter engaged in five or six “exchanges back and forth.” Respondent signed the agreement on the last exchange and “never got anything back.” Respondent noted the parties maintained a joint OneDrive account and an external hard drive for storing important documents. Respondent testified that the external hard drive was accidentally discarded during a house remodel and the OneDrive contained only a copy of the premarital agreement bearing his signature. Respondent believed that petitioner did not sign the agreement and learned months before the hearing that no fully executed copy existed. ¶8 Petitioner testified she sought a premarital agreement because of respondent’s prior marriages and her established career. Each party retained separate counsel, and petitioner’s attorney drafted the first version of the agreement. Multiple exchanges followed. Around October 15, 2015, respondent informed petitioner that he had signed the agreement. At that time, petitioner was going back and forth between her home in California and her job in Illinois. She returned to California the weekend of October 26. Respondent offered to retrieve the premarital agreement

from the attorney’s office and bring it to the house for petitioner to sign. After signing the agreement, petitioner brought it with her to Chicago and scanned it at her office. She later returned to California with the hard copy, placed it in a file folder labeled “Prenup,” and stored the folder in a drawer in the office the parties shared at their California home. The next time she saw the folder with the document in it was in 2016 or 2017, when the couple moved from California to Illinois. ¶9 At some point, the parties acquired a gun safe. Petitioner placed the original premarital agreement in the safe and kept a copy in the file folder. She next searched for the agreement in January 2019, when she was contemplating a divorce because respondent was drinking heavily. Unable to locate it, petitioner stopped searching after respondent entered a treatment program. Petitioner searched again in July 2023, but was unable to locate the agreement. After respondent vacated the couple’s Illinois home in mid-to-late July 2023, petitioner discovered that the gun safe was unlocked and the premarital agreement was missing. The copy that Petitioner had scanned at PepsiCo had been transferred to a shared hard drive, but petitioner inadvertently discarded the hard drive while the parties were remodeling the house. ¶ 10 Petitioner testified that when she filed for divorce, she attached an affidavit to her petition. The affidavit was identified and introduced into evidence as Petitioner’s Exhibit #2. The affidavit summarizes petitioner’s efforts to locate a fully executed copy of the premarital agreement before filing the petition for dissolution of marriage. Petitioner identified Petitioner’s Exhibit #1 as the premarital agreement about which she had testified. She identified respondent’s signatures and the notary acknowledgment on the exhibit. Petitioner testified that she signed the same document and would not have married respondent without a signed agreement.

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