Case No. 2020 OP 78015  ·  Cook County, Illinois
Appellate Case No. 1-22-1236  ·  Illinois Supreme Court No. 130468
Chicago Stars
RECORD
November 2020 · COVID lockdown · Day 100+
Your former roommate forwards you a packet from a law firm. Inside is a petition for order of protection and an emergency order already granted at a hearing you weren't invited to. You recognize the petitioner as someone you never got to know — but who has previously distorted your connection and made damaging statements about you. You log into Zoom Court during the pandemic. This is what that looked like.
Point of view — the respondent · First zoom appearance · Emergency order already entered
⚠ Contains discussion of suicide & false accusations — resources inside
Personal account  ·  Mark Lenington  ·  Chicago, Illinois

I'm sorry,
did we
date?

I joked about violence on social media in poor taste
An acquaintance and her family law attorney twisted it into a statute meant for intimate partners, violating my rights in the process, and continuing an ongoing effort to ruin my reputation.

A published appellate court opinion bearing my name appears near the top of search results. This site presents my account of the case alongside specific citations to the public court record — so you can verify every factual claim I make against the documents themselves.

Key numbers from the recordBujdoso v. Lenington
Dates
Lenington
claimed
0
Bujdoso's
affidavit
1
Court's
finding
3
I claimed zero. Her sworn affidavit specified "one (1) date" by word and number. The trial court found three — a number neither party ever claimed. She also stated under oath she "would not have called him her boyfriend."
Documented
Years of zero contact before petition was filed
4.5
No contact of any kind — direct or through third parties — for over four years before November 2020.
Agreed by both parties
Weeks between conflicting rulings — identical panel
5
The same three judges reversed a nearly identical case five weeks after affirming mine — on materially stronger relationship facts.
Same judges
Tangible documentary evidence in the entire case
1
One screenshot of one Facebook message asking if she wanted to get dinner. The date, the car ride, the arm-grab, the daily communication — all rest on testimony alone with no corroborating document.
Petitioner's Exhibit 4
Times petitioner's attorney said his client knew respondent's birthday — after claiming serious courtship
0
At the conclusion of the final hearing Lincoln stated: "I don't think my client knew at the time, the birthday of the respondent." Lenington provided his date of birth to the court for the first time that day.
Lincoln's own words · Final hearing
Times Lenington changed his core account
0
From the first motion to vacate through the Illinois Supreme Court petition: zero dates, business/social context only, no physical contact beyond a handshake. Unchanged.
Consistent throughout
Illinois Domestic Violence Act  ·  750 ILCS 60/103(6)
"For purposes of this paragraph, neither a casual acquaintanceship nor ordinary fraternization between 2 individuals in business or social contexts shall be deemed to constitute a dating relationship."
750 ILCS 60/103(6) — Illinois Domestic Violence Act of 1986, as amended 1993

Every in-person interaction between Mark Lenington and Allyssa Bujdoso took place either at a comedy open mic where he was performing, or at a bar where she was working as a bartender and he was a paying patron. Both parties agreed on this. The statute's own language addresses this directly. The trial court's finding was never reconciled with it.

Understanding the Stakes
No Relationship.
No Fear.
One Order of Protection.

The Illinois Domestic Violence Act requires a qualifying relationship between the parties and conduct constituting abuse. Illinois also offers civil remedies that require neither — and carry none of the federal consequences the IDVA triggers automatically. The remedy used in this case was the one with the most serious consequences and the highest threshold of prerequisites. The record shows those prerequisites were not met.

Three Illinois Civil Protective Remedies Compared
Order of Protection
750 ILCS 60 — IDVA · Used in this case
Civil No Contact Order
740 ILCS 22 — CNCO
Stalking No Contact Order
740 ILCS 21 — SNCO
Relationship requiredYes. Petitioner must establish "family or household member" status — including through a qualifying dating relationship. This threshold is contested in this case.No. Available to victims of sexual assault or sexual abuse regardless of relationship.No. Available to victims of stalking regardless of relationship.
Federal firearms disabilityYes — automatic. 18 U.S.C. 922(g)(8) attaches immediately upon entry of a qualifying civil protective order. Active for the full duration of the order.No. Civil No Contact Orders do not trigger the federal firearms disability.No. Stalking No Contact Orders do not trigger the federal firearms disability.
LEADS database entryYes — entered into Illinois Law Enforcement Agencies Data System. Appears in law enforcement background checks.Yes — entered in LEADS.Yes — entered in LEADS.
Basis for petitionAbuse (physical, harassment, intimidation, interference with personal liberty) by a family or household member.Sexual assault or sexual abuse by any person. No relationship requirement.Stalking as defined under 720 ILCS 5/12-7.3 by any person. No relationship requirement.
Duration (plenary)Up to 2 years. Renewable.Up to 2 years. Renewable.Up to 2 years. Renewable.
Standard of proofPreponderance of the evidence.Preponderance of the evidence.Preponderance of the evidence.
Ex parte emergency orderAvailable. Granted same day on petitioner's sworn testimony alone.Available. Same process.Available. Same process.
Why it matters hereThis remedy requires establishing a dating relationship. If no qualifying relationship existed, this order should not have been available. The federal firearms disability — imposed for two years — flows directly from this choice of remedy.If the concern was harassment or threatening online content, this remedy does not require a dating relationship. No federal firearms disability would have attached.If the concern was stalking behavior through online videos and posts, this remedy addresses that directly — without a relationship requirement and without triggering a federal firearms disability.
The remedy chosen — and what it required The Illinois Domestic Violence Act was used in this case. That choice required establishing a qualifying dating relationship between the parties. It also automatically triggered a two-year federal firearms disability under 18 U.S.C. 922(g)(8). Two other civil remedies were available and would have addressed any genuine safety concern about online videos and harassing content. Neither requires a dating relationship. Neither triggers a federal firearms disability. The choice to use the IDVA specifically made establishing that relationship legally necessary. The relationship was contested throughout. The consequences were not discretionary.
Within the IDVA — The Three Order Stages
Emergency Order
Up to 21 days  ·  750 ILCS 60/217
Granted ex parte — respondent not present. One party's sworn averments sufficient to indicate abuse. No cross-examination. Respondent learns of it upon service. Triggers federal firearms disability immediately.
Interim Order
Up to 30 days  ·  750 ILCS 60/218
Bridges the gap between emergency order and plenary hearing. Respondent has been notified but full hearing has not yet occurred. Maintains emergency protections while proceedings are scheduled.
Plenary Order
Up to 2 years  ·  750 ILCS 60/219  ·  This case
Full evidentiary hearing required. Both parties present. Witnesses. Cross-examination. Preponderance standard. Must establish family or household member status. Federal firearms disability continues for full duration. LEADS database. Permanent public court record. Entered against Lenington July 19, 2022. Expired July 19, 2024.
What the Plenary Order meant in this case A two-year Plenary Order entered July 19, 2022 prohibited Lenington from owning or possessing a firearm under federal law until July 19, 2024. It was entered into LEADS. It generated a published appellate opinion that appears permanently in search results. The factual basis was bar visits during a bartending shift, an unanswered dinner invitation, and uncorroborated testimony — in a case where the petitioner said she "would not have called him her boyfriend" and where the statute explicitly excludes fraternization in business and social contexts from the definition of a dating relationship. A Plenary Order is Illinois's most serious civil domestic protection remedy. The record in this case invites the question of whether it was the appropriate one.
Why It's Legally Easy
To Get a Restraining Order
Standards of Proof — Civil vs. Criminal

The legal system uses different standards of proof for different situations — and the gap between them is enormous. Where a proceeding falls on this spectrum determines how easy or difficult it is to win, and how much protection the accused has. Orders of protection sit at the lowest end of the civil spectrum. Understanding why matters.

Lowest burdenHighest burden
Level 1 — Lowest
Reasonable Suspicion
"Specific articulable facts" suggesting possible criminal activity
Requires only that an officer have a particularized, objective basis for suspicion — not proof, not probability, just specific facts they can explain. Enough to briefly stop and question someone.
Used for: Brief police stops · Terry stops · Investigative detentions
Level 2
Probable Cause
"Fair probability" or "reasonable grounds to believe"
More than suspicion but still well below a majority probability. Required to make an arrest, obtain a search warrant, or for a grand jury to issue an indictment. Courts have described it as roughly 30–40% likelihood.
Used for: Arrests · Search warrants · Grand jury indictments
Level 3 — This Case
Preponderance of the Evidence
"More likely than not" — anything above 50%
If the fact-finder believes the petitioner's account is slightly more credible than the respondent's, the petitioner wins. One person's credible testimony with no corroboration satisfies this standard completely. A judge is not required to find physical evidence, witnesses, or documentation.
Used for: Civil lawsuits · Orders of protection · Most family law matters
Standard used in Bujdoso v. Lenington
Level 4
Clear and Convincing Evidence
"Firm belief or conviction" — substantially more likely than not
A meaningfully higher bar than preponderance. The evidence must produce a genuine conviction in the fact-finder's mind that the allegation is true — not just a slight probability tipping over 50%.
Used for: Civil fraud · Termination of parental rights · Civil commitment
Level 5 — Highest
Beyond a Reasonable Doubt
Absence of any doubt for which a reason can be given
The highest standard in the legal system. Not absolute certainty — but the near-elimination of reasonable doubt. Twelve jurors must each individually reach this standard before a criminal defendant can be convicted. A single juror's reasonable doubt requires acquittal.
Used for: All criminal prosecutions · Required before any conviction
Standard required to convict of any crime
Criminal Domestic Violence Conviction
Beyond a Reasonable Doubt
12 jurors must each individually find guilt proven beyond any reasonable doubt.
The government bears the entire burden. The defendant proves nothing.
Full trial with rules of evidence, right to confront witnesses, right to counsel, right to jury.
Physical evidence, corroboration, and witness testimony typically required to sustain a conviction.
A single juror's reasonable doubt is sufficient to prevent conviction.
Requires the most rigorous proof standard in the legal system
Civil Plenary Order of Protection
Preponderance of the Evidence
1 judge decides whether the petitioner's account is slightly more credible than the respondent's.
No jury. No requirement for physical evidence. No requirement for corroboration.
One person's testimony, found credible by one judge, satisfies the standard completely.
Emergency order granted ex parte — without the respondent present — on even less: whether averments "indicate abuse."
Credibility finding by the trial court is virtually unreviewable on appeal under the manifest weight standard.
Requires only a slight preponderance — more likely than not
The consequence that is identical in both cases Federal Firearms Rights — Automatic Consequences Federal firearms disability under 18 U.S.C. 922(g)(8). A person convicted of criminal domestic violence after a jury trial proving guilt beyond a reasonable doubt loses the right to own a firearm. A person subject to a civil order of protection entered by one judge under the preponderance standard also loses the right to own a firearm — for the duration of the order. The federal law makes no distinction between the two. The consequence is identical. The standard of proof required to trigger it is not. In this case, a two-year federal firearms disability was imposed based on one person's uncorroborated testimony about events from four and a half years earlier, in a civil proceeding with no jury, no physical evidence, and no corroborating witnesses.
The ex parte emergency order — an even lower threshold Ex Parte Hearing — One-Sided Testimony Before the plenary hearing — before any cross-examination, any evidence, any opportunity to respond — an Emergency Order of Protection can be granted the same day a petition is filed. The statutory standard under 750 ILCS 60/214(c)(4) requires only that the court examine the petitioner under oath and find that the petition's averments are "sufficient to indicate abuse." No respondent present. No evidence tested. No cross-examination. No opportunity to deny. In this case the emergency order was granted on November 6, 2020, based on a brief hearing in which Bujdoso testified alone. That order triggered a federal firearms disability the same day. It remained in effect, extended repeatedly, for nearly two years before the plenary hearing concluded. By the time Lenington had his first opportunity to present his full account before a court, the emergency order had already been in place for eighteen months.
My Account
What Actually Happened
My Account / Factual Records

Everything below is drawn from the public court record. Opinions are clearly labeled as such. Citations are provided so anyone can verify.

The Story — What Lenington Says Happened · In Sequence
First Encounter — March 2016 · Comedy Open Mic
1 · First Encounter — March 2016 · Comedy open mic · Business and social context · Both parties performing
Three encounters · All in the record
Every interaction occurred at a comedy open mic or a bar where she was working and he was a paying patron.

750 ILCS 60/103(6) explicitly excludes ordinary fraternization in business or social contexts from the definition of a dating relationship. Both parties agreed on what each encounter consisted of.

The court found 3 "dates." Neither party described any of these as a date. The third — May 23 — resulted in her asking him to leave. The appellate opinion characterizes it as constituting a dating relationship.
April 2016 — North Bar Scope Out
2 · April 2016 · North Bar · Unscheduled patron visit · She was working her bartending shift · He paid for drinks and left
Last Encounter — May 23, 2016 · North Bar Closing
3 · May 23, 2016 · North Bar · 1:05am – 2:03am · She was bartending · Asked to leave at close · The last time he laid eyes on her
⚠ Heavily Disputed The Alleged Coffee Shop Incident — "Did This Actually Happen?"
Respondent denies this event in every filing at every level · Five sworn denials under direct questioning at trial (R-192–R-193) · No police report filed in 2016 · No witnesses named · Not mentioned in Bujdoso's own texts to Stassen · First appeared in petition filed 4.5 years after last contact
The Alleged Arm Grab — Heavily Disputed Extensive, Consistent Denials in the Record
0 Dates / 1 Date / 3 Dates
The core numerical inconsistency: Lenington claimed zero dates throughout every filing. Bujdoso's own sworn affidavit specified one date by word and number. The trial court independently found three — a number neither party ever claimed — characterizing bar visits during her working shift as evidence of a dating relationship.
Lenington's position — consistent throughout
0
No date ever took place. A dinner invitation was discussed and never acted on. Every interaction occurred in a business or social context — the exact category the statute excludes.
C-191 · Motion to Vacate Jan 2021 · Appellate Brief · IL Supreme Court Petition
Bujdoso's original sworn affidavit
1
"In or around May 2016, your Affiant went on one (1) date with the Respondent." Specified by word and number. Filed November 20, 2020.
Common Law Record C-34 — original affidavit
Trial court finding — July 19, 2022
3
The court found three dates — two more than the petitioner ever claimed. Two of the three were bar visits where she was working as a bartender and I was a paying patron or performer. Neither party described these as dates. The court did so independently.
Report of Proceedings R-293 — Judge Rosenberg's ruling

"Was he your boyfriend?"    "I would not have called him my boyfriend."

Exchange between Judge Bertucci Smith and Bujdoso at the ex parte hearing, November 6, 2020 — Transcript R-4. Her own sworn words before the claim was upgraded. The second judge left the "Boyfriend/Girlfriend Dating Relationship" box on the order form blank.
The 2016 Interactions
The 2016 interactions
Three encounters. All in business and social contexts. The statute explicitly excludes both.
Business and Social Context — 750 ILCS 60/103(6) March 2016: I was emcee at an open mic where she was one of approximately fifty performers. April 2016: I visited her bar as a patron to assess it as a performance venue. May 2016: I performed at her bar's open mic and stayed as a paying customer until she asked me to leave at closing. That was the entirety of our in-person contact. Every occasion involved me performing comedy, her bartending, or both. The Illinois Domestic Violence Act explicitly states that "ordinary fraternization between 2 individuals in business or social contexts shall not be deemed to constitute a dating relationship." Neither party disputed what those interactions consisted of. The trial court characterized both bar visits as "dates" constituting a serious courtship. Bujdoso's own contemporaneous text to Abby Stassen — written the night of or shortly after May 23, 2016 — describes what she told Lenington that night: his opinion was "uninformed and unnecessary at best, considering tonight was the second ever time you've been here, and first time for the mic." In her own real-time words: the May 23 visit was his second visit to the bar and his first ever visit to an open mic there. The court called it a date. She called it his second time at the establishment. Both statements are in the record.
DocumentedBoth parties agree on context750 ILCS 60/103(6)
Trial testimony — Lincoln's direct examination of Lenington · R-77 and R-78 Two facts established under Lincoln's own direct examination cut against the dating relationship narrative. First, on her phone number — Lincoln asked whether she provided it. Lenington: "She did. I didn't ask her for it. She provided it for me in our first full conversation." She volunteered her number. He did not ask. Second, on the April bar visit — Lincoln asked whether Lenington knew she would be there: "Since she invited me in and she introduced me to the venue itself, yes. It couldn't have been any other way." The visit Lincoln characterized as him "going there to see Allyssa" was a visit to a venue she had invited him to check out and personally introduced him to. Both facts came out under opposing counsel's own questioning.
C-190 — Why he messaged her the following day In his written response (C-190), Lenington described the context for the follow-up message the day after being asked to leave: "After being asked to leave her bar abruptly without explanation, I messaged her the following day asking for one. I had sensed an unrelated agenda and it explained the petition that she witnessed a conversation with me and another person on the internet. The conversation involved two parties debating polarizing topics such as modern feminism. I believe this was a turning point for Allyssa and that I had fallen out of her good graces — she had witnessed somebody that she looked up to deeply criticize me — so then she was emboldened to exaggerate the story of me being asked to leave and my response as me harassing her." This was confirmed under oath at trial. Under Lincoln's own direct examination (R-83 through R-84), Lenington testified: "I know now that she had witnessed me in a political Facebook argument with somebody she looked up to and she did not like that. And she treated me different after she witnessed that. She expressed that in messages with me and with Abby Stassen." Lincoln's follow-up: "So it's your testimony that Allyssa Bujdoso's decision to continue communicating with you had nothing to do with your personal interactions? It's based on what she saw online?" Lenington: "Correct. We don't agree on politics or social and I'm a bad guy after that. It had nothing to do with our interactions personally or any pursuit of intimacy, relationship." The follow-up message — offered by the petition as evidence of harassment — was a request for an explanation after an abrupt removal triggered by a political disagreement, not romantic pursuit.
The Claim and How It Changed
The claim that grew — three documented stages, precisely dated
From "one date, not my boyfriend" to "dates and courtship" to "we were romantic — multiple dates and consistent communication for three months, with mutual romantic interest" — each upgrade followed Lenington presenting his argument, not a new memory.
The Three Versions — Story Upgrade ChartThe description of the relationship between Lenington and Bujdoso changed three times across filed documents. Each change is precisely dated. None was accompanied by an explanation of why recollection suddenly improved. Stage 1 — November 6, 2020 (original affidavit, C-34): "went on one (1) date." Written by word and by number. At the ex parte hearing the same day, Bujdoso testified she "would not have called him my boyfriend." The first judge hearing the case said: "I'm not sure you even have a dating relationship with him." Stage 2 — February 25, 2021 (Lincoln's Written Objections, paragraph 2): "The parties enjoyed a brief dating relationship in 2016, during which MARK courted ALLYSSA." This is the first documented appearance of the word "courted" anywhere in the record. It appears in a filing dated February 25, 2021 — within weeks of Lenington's January 2021 Motion to Vacate, which cited Alison v. Westcott. The legal standard was disclosed. Within weeks, the language shifted to match it. Stage 3 — May 28, 2021 (Lincoln's Motion in Limine, paragraph 1): "the parties communicated on a consistent basis for almost three (3) months and the parties went out on dates." Plural dates. Consistent communication for three months. This filing was made after Lincoln's own Exhibit B — the full Facebook Messenger conversation — was already in the record. That exhibit shows scattered messages over 63 days on comedy industry topics. It describes no dates, no intimate content, no consistent communication. The characterization in the Motion in Limine contradicts Lincoln's own submitted evidence. There is also a documented timeline discrepancy. At the ex parte hearing on November 6, 2020, Bujdoso testified the bar incident occurred "that summer, it was around July." The trial testimony, the judge's ruling, and every other document establish the bar incident as May 23, 2016 — two months earlier. That is a two-month discrepancy in the central incident of the case, between the first sworn account and the later one.
Three stages — November 2020 · February 2021 · May 2021Each upgrade followed a legal developmentC-34 · Written Objections Feb 25 · Motion in Limine May 28Stage 3 contradicts Lincoln's own Exhibit BEx parte says July · Trial says May · Two-month discrepancyThree-stage upgrade documented in C-227 — Opposition to Motion in Limine
C-186 — Bujdoso's interrogatory response · "Admitted. ALLYSSA affirmatively states she and MARK met for drinks." In response to Question 12 of Lenington's reformatted interrogatories — "We never met for dinner" — Bujdoso's sworn response was: "Admitted. ALLYSSA affirmatively states she and MARK met for drinks." This admission is critical in three ways. First, she admits they never met for dinner — the dinner invitation in the March 2016 Messenger exchange was never fulfilled, exactly as Lenington stated throughout. Second, she describes the alleged meeting as "drinks" — not a "date," not "dinner," not "Flat Iron" — just drinks, with no location, no date, no method of scheduling. Third, this is the only sworn pre-trial description of any meeting, and it directly contradicts what she testified to at trial (Flat Iron, drinks, May 2016). Her own interrogatory counsel filed this response. It is in the public court record at C-186.
C-227 — Opposition to the Motion in Limine (June 1, 2021) · the three-stage upgrade documented in one filing In Lenington's Opposition to the Motion in Limine (C-227, filed June 1, 2021), he documented the three-stage narrative upgrade in one place: "In the original petition, in two separate areas, her claim was that the parties went on one (1) singular date. In the Background section of 'Written Objections,' filed by Steve Lincoln, the Petitioner changed the story to 'Mark courted Allyssa,' and they 'went on At Least 1 date.' Finally with this Motion in Limine, Mr. Lincoln assists the Petitioner in changing her claim to that the parties went on multiple dates." He added: "If there are unclean hands in this matter, they belong to Allyssa who continues to mislead the court with the assistance and knowledge of attorney Steve Lincoln. Mark has continuously pleaded with Lincoln that no dating activity occurred, and the Petitioner is gradually trying to adjust her claim in bad faith." This document is the primary source for the three-stage narrative analysis on this site. It was written contemporaneously — before trial — with each stage precisely dated and identified by filing.
What her own attorney admitted on the record
At the end of a two-year hearing about their courtship, Lincoln told the court his client did not know Lenington's birthday. He provided it to them for the first time that day.
The Birthday Admission
During the July 19, 2022 final hearing, as the court was completing the plenary order paperwork, Lincoln noted on the record: "I don't think my client knew at the time, the birthday of the respondent." The court then asked Lenington for his date of birth — November 24, 1986 — and he provided it for the first time in the proceedings. This was at the conclusion of a case in which Bujdoso had testified to multiple dates, daily communication, mutual romantic feelings, and a serious courtship substantial enough to constitute a qualifying dating relationship under Illinois law. If any of that testimony were accurate, his birthday would have been known long before a two-year legal proceeding concluded. It was not. Lincoln acknowledged this himself, on the record, in passing — apparently unaware of what that acknowledgment confirmed. It is in the certified transcript. It is not Lenington's characterization. It is opposing counsel's own statement.
Lincoln's admission — on the recordReport of Proceedings — final hearing July 19, 2022Not Lenington's characterization — opposing counsel's words
Physical Contact Claims
A provably false claim — the car ride
She testified I drove her home. Under cross-examination she could not recall the make, model, color, transmission, date, or whether I walked her to the door. Her strongest statement: "I remember sitting beside you in a car."
The Car Ride Cross-ExaminationHer testimony supported the claim that I knew where she lived by stating I had driven her home on one occasion. I stated throughout these proceedings — beginning with my written response at C-191 — that I have never owned or operated a vehicle in Illinois and have never held an Illinois driver's license. This is verifiable through state DMV records. I cross-examined her on this claim directly.
Q. What type of vehicle was I driving?
A. I don't recall.
Q. Was it a two-door or a four-door?
A. I do not recall.
Q. Was I driving a stick shift or an automatic transmission?
THE COURT: The objection is overruled. You can answer the question.
A. Couldn't tell you. I don't remember that.
Q. What color was the car I was driving?
A. I don't remember.
Q. But I dropped you off and drove away, which is why I remember where you live; is that correct?
A. I remember sitting beside you in a car.
Q. Do you remember about which day in May this occurred?
A. I don't — I don't remember the specific day.
What the cross-examination shows She cannot identify the make, model, number of doors, color, or transmission type of the vehicle. The court overruled two objections from Lincoln attempting to stop this line of questioning. After all of that, her most definitive statement about the car ride is: "I remember sitting beside you in a car." That is the evidentiary foundation for the claim that Lenington knew where she lived. He has never held an Illinois driver's license. Illinois DMV records would resolve this in one lookup. Lincoln's own Request for Admission to Lenington (#30) asked him to admit driving-related offenses. Lenington's response: "None of these matters involved the state of Illinois." Lincoln's own pleading is the documentary source confirming Lenington's driving history is entirely out-of-state.
C-194 — Respondent's written response · April 30, 2021 In his written response to the Second Amended Petition — filed April 30, 2021 and part of the public court record — Lenington stated: "We did not interact the next day in person, only in messenger. I did not attend an open mic let alone at a coffee shop and I did not see her the following day. Therefore, I did not grab her arm and I was not pursuing any affection or intimacy with her — and I had not ever before. The last time I laid eyes on Allyssa Bujdoso was when she asked me to leave the bar." That is the most direct statement of the timeline anywhere in the record. He also noted: "She did not discuss the coffee shop open mic allegation with Abby Stassen, because the event never transpired. In the provided text messages in the petition, the two only discuss my messaging her after she asked me to leave the bar." The Stassen texts — submitted by the petitioner in her own petition — do not contain any mention of a coffee shop encounter or physical contact. They discuss the bar incident and the follow-up message. If the coffee shop encounter had occurred the following day, it would have been the most significant event in that exchange. It is not mentioned once.
Verifiable — DMV recordsRequest for Admission Response #28: driving charges out-of-state only — formal court filingLincoln's own Request for Admission #30 confirms driving charges were not in IllinoisC-191 · R-244, R-252 cross-examination transcriptTwo Lincoln objections — both overruled
The address — who knew what, and when
She filed the petition to his old address. His former roommate received the packet. She only learned where he actually lived through his appeal filings. Meanwhile she told the court he already knew where she lived — because of the car ride. The judge left her address in on that basis. Lenington has never held an Illinois driver's license.
When Bujdoso filed the original petition on November 6, 2020, she listed Lenington's address as 3950 N. Lake Shore Dr., #1829, Chicago — his former residence. He had not lived there for years. His former roommate received the petition packet from Frumm & Frumm and informed Lenington of it. She did not know where he lived when she filed. He had moved — specifically because people in the comedy community knew his old address and he no longer felt safe there. At the ex parte hearing, Judge Bertucci Smith offered to delete her address from every document. Bujdoso said: "He already knows." The judge left 2047 W. Walton St. in the record on that basis. The sole foundation for "He already knows" is the car ride claim. If the car ride did not happen, the sworn statement "He already knows" was false. Her address remained in the public court record because of a false sworn statement made directly to the judge at the ex parte hearing. He did not have her address. She did not have his. She learned his current address only when he was required to include it in his appeal filings — years into the proceeding.
Documented — transcript, email chain, court recordReport of Proceedings — final argumentsEmail chain August 26, 2022C-191 — written response
Primary documents — the address record in sequence
Public record + correspondence
The ex parte hearing — November 6, 2020 · Judge Bertucci Smith
THE COURT: I have a question. Does he know where you live?
THE WITNESS: Yes. He's dropped me off before at my house.
THE COURT: Well, you've already written it everywhere on the petition and the order. So if you don't want him to have this address, it needs to be deleted from every piece of document that you've already written. But if you say he already knows it —
THE WITNESS: He already knows.
THE COURT: — and you want that on there that he can't go there, I'll leave it the way you have it.
THE WITNESS: Okay.
What this exchange shows The first judge offered to delete Bujdoso's address from every document — expressly, on the record. Bujdoso waived that protection by telling the judge Lenington already knew where she lived. The judge accepted that representation and left the address in. The sole basis for "He already knows" is the car ride claim. Lenington has never held an Illinois driver's license. If the car ride did not happen, the sworn statement that caused the address to stay in the record was false.
The judge also noted at the ex parte hearing: "I'm not sure you even have a dating relationship with him, a dating or engagement relationship. You went out on one date." She granted the order despite this expressed doubt. Her own characterization: "it sounds like you didn't want to date him in 2016 and you tried to break up with him." — R-4 through R-5, ex parte transcript.
MR. LINCOLN: It looks like the emergency that — I don't think my client knew at the time, the birthday of the respondent.
THE COURT: Mr. Lenington, what is your date of birth?
THE RESPONDENT: 11-24-86.
THE COURT: For the record, the respondent has no right to prevent his address from being on the plenary order. The only protected party under the Illinois Domestic Violence Act is the petitioner.
Lincoln's admission — his own words, on the record At the conclusion of a two-year hearing in which Bujdoso testified to a serious romantic courtship, her attorney told the court his client had not known the respondent's birthday. Mark Lenington provided his date of birth to the court for the first time at this hearing. If the parties had been engaged in the serious ongoing courtship Bujdoso testified to, his birthday is the kind of basic personal information that is known within weeks. It was not known after two years of proceedings.
The email chain — August 26, 2022 · Ten days after the appeal filing
The non-denial Lenington called out the comment directly and in writing within twelve minutes of receiving it. Lincoln's response did not deny the taunt, did not clarify the intent, and did not explain the reference to the building and its management. He pivoted to the court ruling. A genuinely innocent comment, misread as a taunt, typically produces a denial or clarification. This produced neither.
What she wrote in real time — and what those texts actually show
"All of this because I would not go on a date with him." But read those texts in full: the incident was triggered by a disagreement about comedy scene opinions. She submitted these texts in her own petition. The same documents contain her admission that no date occurred, that it was his second visit to the bar, and the "shoots people" language — all in her own words.
Bujdoso submitted text messages to Abby Stassen as part of her petition — offered as evidence of Lenington's threatening nature. The same documents, read in full, tell a different story. The incident that ended contact was a comedy scene opinion dispute — he argued about a post, she didn't want to hear it, he wouldn't drop it. She removed him. That is her own account of what happened, written in real time to her friend. What she wrote at the end of that account: "Part of this is because I wouldn't go on a date with him." She acknowledged in the same text that no date had occurred. She also wrote: "He's like the kind of guy that shoots people because he doesn't get his way." She submitted documents as evidence of danger that simultaneously contain her contemporaneous admission that no date took place, that his bar visits were not dates, and that the "shooting" characterization arose from a comedy scene argument — not from any romantic incident.
She submitted these texts in her own petitionIncident triggered by comedy scene opinion dispute — Amanda's North Bar post — not romance"I wouldn't go on a date with him" — her own admission · same text"Second ever time / first time for the mic" — her own words · same text"Shoots people" language — comedy argument context · same text · submitted by petitionerNo mention of coffee shop encounter in texts — because it never happened · C-194Common Law Record C-49/50/51Written 4.5 years before filing
C-195 — The "lol" in her follow-up messages In his written response (C-195), Lenington noted that in the follow-up conversation after she asked him to leave — the conversation offered as evidence of harassment — she was laughing. She wrote "lol" and statements such as "keep harassing me, you're digging yourself deeper." His response: "The petitioner was not disturbed or in fear of me at that point — she rather enjoyed the negative attention and was setting me up so that she could tell people I harassed her." Someone who is genuinely afraid does not respond to the interaction with "lol" and taunts about digging deeper. That language is in the same messages the petition offered as evidence of fear.
The only tangible evidence — one screenshot of a dinner invitation
One message asking if she wanted to get dinner. That is the only tangible document in this entire case. Asking someone to dinner is not evidence of a romantic relationship — it is evidence that someone asked someone to dinner.
The March 21 Exchange — The Romantically Adjacent MomentThere is one screenshot of a Facebook Messenger exchange in which I asked whether she wanted to get dinner sometime and whether she was single. She said yes to both. The dinner was never arranged. It never happened. In the same conversation both parties expressed they were not looking for anything serious. That one screenshot is what the petitioner built an entire case on. Everything else — the claimed date at Flat Iron, the claimed daily communication, the claimed courtship, the claimed car ride home, the claimed arm-grab at the coffee shop — rests on testimony alone. No corroborating document. No witness. No police report. No contemporaneous mention to anyone. One unremarkable social invitation surrounded by sworn statements that the record itself contradicts. That is the evidentiary foundation of a two-year order of protection and a permanent published appellate opinion.
Core argumentPetitioner's Exhibit 4No corroborating documentary evidence for remaining claims
Lincoln's direct examination of Lenington · R-74 through R-75
Q. You were initiating communication with her in an attempt to pursue a possible romantic relationship; correct?
A. That's false.
Q. But you just testified that you asked her to dinner to see where things may go?
A. No, I testified that I asked if she wanted to meet for dinner but that wasn't the sole purpose of asking her or striking up a conversation. When we had first met she said I bartend at a place that does an open mic that I had never been to. So I wanted to check that place out and maybe perform.
Q. Asking Ms. Bujdoso out to dinner was at least somewhat driven by you seeking to establish some sort of romantic or dating relationship?
A. No. That's false. I would say that asking someone out for drinks or a dinner would be — if we actually did go out, that's the point where you assess is this an acquaintanceship? Could this be something more? Are we just friends? Let's do a shot of tequila and just be friends. Or hey let the door open for anything. That's what that meant.
A. I wasn't expressing like affection or an expectation. I go to dinner with friends and acquaintances.
The Context
Before any of this — what was actually happening in October 2020
Five weeks before Bujdoso filed anything, Lenington was the one seeking legal help. He had been publicly called a racist and a rapist. He moved apartments. He tried to retain a defamation attorney. He was told it wasn't worth pursuing.
On September 29, 2020, Lenington was publicly called a rapist on social media. Within 48 hours he was searching for defamation attorneys in Chicago. On October 1, 2020, he emailed a law firm seeking defamation representation. He was referred to Daliah Saper and advised that going after social media defamation "is expensive and would likely not yield positive results." That advice closed the legal route. The Halloween video was made after that door shut. He had also moved apartments in October 2020 specifically because people in the comedy community knew where he lived. Five weeks later, a petition was filed describing him as a safety threat to Bujdoso. In the same email seeking legal help, he wrote: "Also I never dated within these circles." This was written on October 2, 2020 — to a private attorney, before any legal proceeding existed, with no incentive to characterize anything strategically.
October 1–2, 2020 — five weeks before the petition"I never dated within these circles" — pre-litigation, private correspondenceHe moved; he felt unsafe; he was the one seeking legal relief
A third contemporaneous 2016 document — and she still doesn't claim they dated
In a July 26, 2016 public Facebook thread, Bujdoso characterizes Lenington as someone who harasses women who reject him — not as a former romantic partner. The word "dated" does not appear. No relationship is described.
Two months after the May 23 bar incident, Bujdoso commented publicly on a Facebook thread where Lenington had disagreed with the political framing. Bujdoso wrote: "Mark's a psycho path who threatens women to try and get them to give him a reason on why they don't want to date him or even be his friend." "I don't think enough women are aware of how crazy he can be if you reject him." She is describing a rejected pursuer — not a former partner. She is not describing a relationship that ended badly. This is the opposite of a dating relationship claim. It is a rejection claim. This is the third contemporaneous 2016 document in which the nature of the situation is characterized without claiming any dating relationship existed. In all three, the dynamic is described as a rejection, not a breakup.
July 26, 2016 — she describes rejection, not a relationship"How crazy he can be if you reject him" — pursuer framing, not partner framingThird 2016 document: no dating relationship claimed by Bujdoso herself
June 7, 2020 — five months before the petition — she publicly claims credit for the cancellation
On Bob Keen's June 2020 Facebook post celebrating Lenington's cancellation, Bujdoso commented asking for a share of the credit. Five months later she filed a legal petition.
On June 7, 2020, Bob Keen posted publicly about Lenington's cancellation in the Chicago comedy community. Bujdoso commented: "I would appreciate a cut of that after the airport incident." She is not describing a fear of ongoing danger. She is asking for credit — a share of the reputational harm caused by the cancellation campaign. She believes she is owed something for her contribution to it. Five months later, on November 6, 2020, she filed an emergency petition for order of protection. Someone who is genuinely afraid of a person does not, in the same year they file for legal protection, publicly ask for a share of the credit for that person's reputational destruction.
June 7, 2020 — five months before the petition"I would appreciate a cut of that" — claiming credit for the cancellation
What She Couldn't Answer
The Flat Iron inconsistency — where the "date" location comes from
At trial, Bujdoso testified for the first time that the claimed date occurred at Flat Iron. Her own May 23, 2016 Facebook Messenger message places her at Flat Iron that night with David — not Lenington — describing the visit as a business conversation. The location was asked in discovery three times and never answered.
The Location Question — Discovery EvasionIn her May 23, 2016 Facebook Messenger exchange with Lenington — submitted by Lincoln as Exhibit B to his own filings — Bujdoso writes: "We went out after to flat iron to talk business." The "we" refers to her and David, the other person present at North Bar that night. This is the only contemporaneous mention of Flat Iron in any document connected to this case. It describes a visit to Flat Iron that does not involve Lenington and characterizes it as a business conversation. At trial, Bujdoso testified that her date with Lenington took place at Flat Iron in May 2016 (SUP R-39). This was the first time "Flat Iron" appeared in any court filing as the claimed date location — not in the original affidavit, not in any pre-trial sworn filing. In every round of discovery — February 2021, the reformatted version, the final request in April 2021 — Lenington's first question was: "Which location were you referring to in your claim that we went on one (1) date?" The question was asked three times. It was never answered.
May 23 messenger: Bujdoso goes to Flat Iron with David "to talk business"Flat Iron first named at trial (SUP R-39) — never in any pre-trial documentDate location asked in three rounds of discovery — never answeredLincoln's own Exhibit B is the source of the Flat Iron reference
Trial testimony — R-192 · Under direct questioning
Q. The petitioner alleges that she went to Flat Iron for drinks with you. Did you go to Flat Iron with the petitioner for a drink?
A. No, that never occurred.
Q. It's your testimony the only three times that you saw her in person were the three times we've discussed now, the initial meeting and the two interactions at North Bar?
A. Correct. The first time was when I was a performer and she also was a performer. The second time she was bartending and I was a patron. The third time I was both a patron and a performer and she was bartending. Beyond that we did not interact in person.
The exact questions asked — never answered Lenington submitted multiple rounds of interrogatories asking the petitioner to identify the date location and coffee shop location. Two Motions to Compel were filed — April 22, 2021 (C 158-C 170) and April 29, 2021 (C 171-C 187) — after the petitioner repeatedly failed to answer. Lincoln's Written Objections (C 102-C 111) were the only formal response. The specific questions that were never answered include:
Final Request for Admission — served April 24, 2021 · Questions directly about the date and coffee shop
Q1. "In your petition for order of protection case no. 2020-OP-78015 you alleged that you and I went on 'one (1) date' — which location did this event transpire?"
Q2. "More specifically than 'on or around May,' when did our '1 date' that you claimed we went on take place?"
Q3. "By which method of communication did you and I schedule this date that you alleged in your petition?"
Q4. "By which method of communication did we confirm this scheduled date during the time leading up to the date that you alleged we went on?"
Q6. "You alleged that I put unwanted physical contact onto you — what location are you alleging we interacted 'the following day' as you described?"
Q7. "When you used the phrase 'the following day' did you mean the daytime following the early morning hours that I left North Bar at closing time on May 23rd or did you mean the next numeric date meaning May 24th?"
Q12. "We never met for dinner." [Request to admit or deny]
Q14. "Do you agree that we've never visited each other's place of residence."
Q15. "Do you agree that we've never introduced each other to our families?"
Q18. "Do you agree that we've exchanged no more than 15 cellular phone SMS text messages."
None of these questions received a substantive answer. The location of the alleged date was asked in three separate rounds of discovery — original interrogatories, reformatted interrogatories, and the Final Request — and never answered in any formal filing. Flat Iron first appeared at trial.
Bujdoso's actual interrogatory responses — C-185 through C-187 When Bujdoso's counsel finally responded to the reformatted interrogatories (included as Exhibit H in the Motion to Compel, C-185), the responses are as follows: Questions 1 through 7 — every location and logistics question: All objected to on identical grounds: "ALLYSSA objects to the Request on the basis of a lack of foundation and, therefore, cannot respond to same." The location of the alleged date, the date it occurred, the method used to schedule it, the method used to confirm it, the location of the alleged coffee shop encounter, and the meaning of "the following day" — all refused with the same boilerplate objection. No location was ever provided in any sworn pre-trial document. Question 12 — "We never met for dinner": "Admitted. ALLYSSA affirmatively states she and MARK met for drinks." This is the only sworn pre-trial statement where Bujdoso describes any meeting at all. She admits they never met for dinner — the dinner invitation from the March 2016 Messenger exchange was never fulfilled. She claims instead that they met for drinks. No location is specified. No date. No method of scheduling. At trial she testified this drinks encounter occurred at Flat Iron. Her sworn interrogatory response — the only pre-trial sworn document describing the meeting — names no location at all. Question 18 — "No more than 15 SMS text messages": "Denied. ALLYSSA affirmatively states she and MARK communicated through both text messaging and Facebook (including Facebook messenger). In totality, all communication likely exceeded 100 messages." "Likely" — not a firm number. Includes all Facebook communication, not SMS only. The appellate court's reliance on the volume of communication to establish a dating relationship was based on Bujdoso's testimony of "daily communications." Her own sworn interrogatory response uses the word "likely" and combines all platforms to reach 100.
What the Facebook Messenger conversation actually shows
The complete messenger exchange — submitted by Lincoln as his own evidence — runs 63 days, contains scattered messages, covers comedy industry topics almost exclusively, and describes no dates, no intimacy, and no consistent communication. Lincoln's Motion in Limine characterized it as "almost three months of consistent communication." His own exhibit contradicts that characterization.
The full Facebook Messenger exchange between Lenington and Bujdoso is visible in the court record as Exhibit B to Lincoln's own filings. It runs from March 21 to May 23, 2016. The gaps between messages are large — they are not daily communications. They are scattered messages over two months, largely initiated around comedy open mic schedules and work shifts. The content is almost entirely comedy industry and restaurant industry discussion. The only romantically adjacent moment is the March 21 exchange where Lenington asks if she is single and wants to get dinner. She responds affirmatively but qualifies it immediately: "I'm kind of in student mode so not looking for anything too serious or hectic anyway." The dinner was never arranged. They never went out. Lincoln's May 2021 Motion in Limine described this exchange as "the parties communicated on a consistent basis for almost three months." His own Exhibit B shows what that characterization is worth.
63 days · scattered messages · comedy industry content · no intimacyLincoln's Motion in Limine contradicted by his own Exhibit BDinner invited but never arranged — both parties expressed not looking for anything serious
The agreed order — offered five times, declined five times
Lincoln called me before each hearing offering to make this go away with an Agreed Order. I declined every time. Most people would have signed. I understood exactly why I wouldn't.
On approximately five occasions before scheduled hearings, Steve Lincoln called me and offered what is known as an Agreed Order. An Agreed Order in this context does not fully mature into a Plenary Order of Protection. The matter is resolved by agreement and does not go to a full hearing. On its face it can look like the case disappears. I declined every time. An Agreed Order still places an order in the court system with my name next to hers. It still gives the other side leverage — a signed order they can reference, a concession in the record, documentation of an agreement I would never have otherwise made. I was not willing to waive or compromise any right I had, however inconvenient that made my situation. What most respondents would accept as a way out I refused. Not because I was reckless. Because I understood precisely what I would be giving away and I was not willing to give it. That refusal made the proceedings longer, more costly, and ultimately more damaging in terms of the public record. I stand by it.
Documented — multiple pre-hearing callsDeclined to protect rightsRefused to create any agreed record
Exploitation of a vulnerability — the forum post
Bujdoso and Lincoln submitted a forum post in which I had sought help for ADHD as evidence of mental instability. The judge excluded it. It is still in the record.
Among the exhibits submitted by the petitioner was a screenshot of an online forum post in which I had sought guidance or assistance related to ADHD treatment. This post was submitted, apparently, to suggest mental instability or unpredictability on my part. The judge declined to admit it as evidence of any psychiatric condition, stating on the record that neither party nor their representatives were professionals qualified to speak to anyone's psychiatric state. The ruling was correct. What it does not undo is the fact that someone — in a legal proceeding — found a moment where I was seeking help for a medical condition and attempted to use it against me. That is in the record. Exhibit E in the original affidavit references my online forum post from February 18, 2020 under the alias "mrcakebread." Seeking treatment or information about a medical condition is not evidence of danger. Submitting it as though it were is a choice that reflects on the judgment of whoever made it.
Documented — Exhibit E, original affidavitJudge excluded — neither party qualified to speak to psychiatric stateStill in the record
Procedural Disadvantages
The motion filed the Friday before the Tuesday hearing — seeking to win without a hearing
Lincoln filed a motion to bar all witnesses, all evidence, and deem all facts admitted — on a holiday weekend — with the wrong attachment. The opposition had to be filed the night before the hearing.
On Friday, May 28, 2021, at 9:24 AM — four days before the June 1 hearing, with a holiday weekend in between — Lincoln filed a Motion in Limine seeking: bar Lenington from testifying himself; bar all of Lenington's witnesses; bar Lenington from presenting any evidence; and deem all allegations admitted as true without a hearing. The motion was filed with the wrong attachment. Lincoln sent the Notice of Motion twice — not the actual motion. Lenington spotted the error at 5:15 PM and contacted Lincoln to flag it. Lincoln corrected it at 6:03 PM. One observation: Lenington caught the error and asked for the correct document. The corrected motion — the one properly filed — is the one that was partially granted, resulting in the exclusion of all of Lenington's witnesses. By catching and escalating the error, Lenington may have inadvertently helped Lincoln properly file the motion that cost him his witnesses. Lenington's opposition was filed Monday, May 31 at 6:09 PM — the night before the hearing. He had one business day to respond to a motion seeking to eliminate his entire defense. The motion was partially granted: Lenington's witnesses were barred. His own testimony was allowed.
Filed Friday May 28 before Tuesday June 1 hearingWrong attachment sent to judge and respondent — corrected only after Lenington flagged itCatching the error may have helped Lincoln properly file the motion that cost him his witnessesOpposition filed night before hearing — one business day to respondWitnesses barred · "facts admitted" denied
The discovery asymmetry — one standard applied to Lenington, another to Lincoln
Lincoln argued Lenington violated the February 26 discovery deadline. Lincoln's own emails show he continued serving subpoenas and scheduling depositions through May.
The January 15, 2021 Disposition Order stated discovery would close February 26, 2021. Lincoln's Motion in Limine relied on that deadline to argue Lenington should be barred from presenting any witnesses or evidence. Lincoln's own emails contradict how he applied that same deadline to himself. On April 30, 2021 — two months after the alleged closure — Lincoln served Lenington's witnesses with deposition subpoenas and followed up on May 6 threatening contempt if they did not comply. He participated in scheduling discussions through May. He made no acknowledgment that his own deposition activity violated the February 26 deadline. His position, in practice, was that the deadline bound Lenington's witness disclosure while leaving Lincoln free to depose Lenington's witnesses months later. Only when the judge ruled on May 10 that the closure date stood did Lincoln stop pursuing depositions — after which he immediately filed the Motion in Limine arguing the same deadline should be used to bar Lenington's witnesses entirely. Lincoln's post-deadline discovery emails are in the record as exhibits to Lenington's Motion to Compel.
Lincoln served subpoenas April 30 — two months after closureScheduled depositions through MaySame deadline: strict for Lenington, ignored for Lincoln's own activityCover letter deliberately removed from objections filing — court could not see reasonable prior attempt · Motion to CompelDocumented in emails attached to Motion to Compel
The addendum that never made it into the record
Lincoln asked for the addendum on January 21, 2021. Lenington emailed it on January 22. It was never filed with the court. Lincoln received it. The court file did not. It contains the first Westcott citation in the proceedings.
The Motion to Vacate was filed on a standard Illinois court form (MN-M 703.3 from IllinoisLegalAid.org) — a generic one-page motion form, not a properly formatted legal brief. When Lincoln received it, he asked: "Did you file a Motion like the one I did?" The motion referenced an addendum. Lincoln then asked for it specifically. Lenington emailed the addendum to Lincoln on January 22, 2021. He did not file it separately with the court as a formal supplement to the motion. The distinction — emailing a document to opposing counsel versus formally tendering it to the court so it becomes a docketed entry in the record — is the kind of procedural knowledge a represented party never lacks. Lincoln received the addendum. The court file did not contain it. The appellate court reviewing the case did not have it. What the addendum contained: the first citation of Alison v. Westcott by name and case number — January 22, 2021. Lincoln's written objections used the word "courted" for the first time on February 25, 2021. The addendum also contained: a correction of the gun caption misquote ("I wonder WHAT this is for" — not "WHO"); the Stassen text flagged as a contradiction of the dating relationship claim; and a reference to Google Timeline location data and bank records available as corroborating evidence.
January 22, 2021 — first Westcott citation; Lincoln received it, court file did notEmailed to Lincoln at his request — never formally filed with the courtMotion filed on generic court form (MN-M 703.3)E-filing inaccessible — case not found in any tool; navigated alone over holiday weekendGun caption correction: "WHAT" not "WHO" — identified January 2021
The Formal Record — Sworn Denials
The Request for Admission — formal denials on the record
Bujdoso's attorney filed a Request for Admission of Facts requiring Lenington to formally admit or deny each core allegation. His denials are not characterizations — they are sworn court filings. They document his position in the exact legal format Illinois courts recognize.
In response to Lincoln's Request for Admission of Facts and/or Genuineness of Documents pursuant to Illinois Supreme Court Rule 216, Lenington responded to each allegation individually and under oath. The document is part of the public court record. On the dating relationship (Request #4): "This is 100% false. We never went anywhere together or met anywhere together for any reason. During our first conversation, we agreed that going to dinner sometime might be a good idea but we never planned, arranged, or executed such an idea. We both independently realized that we would not be a match for dating shortly after. Allyssa Bujdoso knows we never went on a date and none of our online chats were intimate as we only discussed comedy and working in bars/restaurants. We were acquaintances and nothing more." This is the zero-date position stated in its most direct form, in a formal court filing, in response to a specific legal demand to admit or deny. On the physical grab (Request #7): "This is 100% false. There was no encounter at an open mic coffeeshop between us as claimed in the petition. This is an outright fabrication and I'll be showing that. Allyssa Bujdoso knows that this is simply not true." On the gun caption (Request #11): The petition characterized a Facebook post caption as "I wonder WHO this is for?" — implying the gun was directed at a specific person. Lenington responded that the claim was "False and manipulative in two areas." The caption in the actual post reads "I wonder WHAT this is for" — not WHO. That one-word difference is the difference between a targeted threat and an ambiguous prop caption. The correction was identified in the January 22, 2021 addendum emailed to Lincoln and was never formally in the appellate record. On sending Bujdoso certified mail (Requests #26 and #27): Lenington mailed court documents directly to Bujdoso on two occasions. His response to both requests: "I asked the clerk if sending a copy would be a violation of the EOP and she said No. I trusted the court staff and the next person representing themselves will too." The full picture is stronger than this. In his Opposition to the Motion in Limine (C-228), Lenington documented: "The clerk at 555 W. Harrison instructed and guided Mark specifically to send Allyssa Bujdoso a copy of the court filings and required Mark to provide information as to which Post Office he was sending it from. The clerk would not file the motion otherwise and her handwriting is found on the form. Mark contacted the General Manager of the court house and she confirmed that the petitioner always gets a copy of all motions and filings directly." This is not a case of a respondent misunderstanding an instruction. The clerk's physical handwriting is on the document. The courthouse's own General Manager confirmed the practice. A pro se litigant following explicit direction from two court staff members, with that direction evidenced by the clerk's own writing on the filing, should not be penalized for conduct the court itself instructed. On the driving charges (Request #28): Lincoln asked Lenington to admit prior driving-related offenses. His response: "None of these matters involved the state of Illinois and also occurred over 9 years ago." This is the formal court-filing source for the claim that Lenington's driving history is entirely out-of-state — directly relevant to the car ride allegation.
Response #4: zero dates — formal sworn denial Response #7: no coffee shop encounter — formal sworn denial Response #11: caption reads "WHAT" not "WHO" — two areas of falsity Responses #26/#27: clerk instructed him to mail copies — not a deliberate violation Response #28: driving charges out-of-state only — formal court filing Illinois Supreme Court Rule 216 — Request for Admission of Facts Public court record
The judge admitted she hadn't read the written responses — right before trial
Judge Rosenberg acknowledged on the record, immediately before the trial hearing began, that she had not read Lenington's written responses to the petition. His written defense had been in the court file for over a year.
Lenington filed his written response to the petition — C-191 — in January 2021. It contained his full factual defense: zero dates, business and social context only, denial of the car ride, denial of the coffee shop incident, the first citation of Alison v. Westcott, and the Stassen text as a contradiction of the dating relationship claim. The response was in the court file for over a year before the trial hearing. Right before the hearing began, Judge Rosenberg acknowledged on the record that she had not read it. One would think that in any civil proceeding a respondent has the basic right to have his written responses considered before a judge rules on the merits of the case against him. A judge who has not read the written defense is hearing it for the first time from someone who has not prepared to address it. Every advantage in that dynamic flows to the party whose version was read — and away from the party whose version was not. This also provides context for the appellate opinion's misattribution of Lenington's position. The opinion treats "even if one date took place" — conditional legal argument, acknowledging petitioner's claim hypothetically for the sake of argument — as his factual concession that one date occurred. His actual stated position, in every document including C-191, was zero dates. If the trial court did not read C-191, and the appellate court misread the conditional language in the brief as a factual admission, then Lenington's actual defense was never squarely before either court on the merits. He was litigating a defense that neither court had fully read. A respondent arguing "even if one date took place, it still doesn't meet the Westcott standard" is making a stronger defense than one conceding one date occurred. The appellate opinion evaluated the weaker version of his argument — the version he never made.
Judge Rosenberg admitted pre-trial she had not read respondent's written responses Written response C-191 in court file for over a year before trial Appellate opinion misattributes one-date position — actual position was zero dates throughout "Even if one date took place" — conditional argument, not factual admission Basic right to have written responses read before hearing on the merits Both courts may have ruled without fully engaging with his actual stated defense
The catfishing testimony — what the opinion records, and the denial on the record
A mutual acquaintance testified that Lenington admitted "catfishing" Bujdoso. Lenington denied it under oath, testifying that the "catfishing" reference and the message mentioning Bujdoso were two separate conversation threads. Both are in the record.
The appellate opinion records testimony from Adam Kwaselow, a mutual acquaintance from the Chicago comedy community, about an October 2020 message exchange with Lenington. The opinion states at ¶¶17–18 that Kwaselow testified Lenington admitted "catfishing" Bujdoso — communicating through a false persona — "because she embarrassed me and then started hating on me." This is recorded testimony, and it is squarely denied. At ¶25 the opinion records that Lenington denied writing that he catfished Bujdoso, maintaining that the message referring to "catfishing" and his next message mentioning Bujdoso were two different threads of conversation — the second not a response to the first. There is also a direct factual dispute about who raised her name first: Kwaselow testified Lenington brought her up (¶18); Lenington testified he mentioned her only after Kwaselow did (¶25). Two details from that same testimony cut against the picture it was offered to support. Kwaselow testified that Bujdoso's reputation in the community was "not considered untrustworthy or disreputable to any notable degree" (¶17), and on cross-examination he did not recall any "feud" in 2016 between the parties (¶18) — the period the petition characterizes as a serious courtship.
Kwaselow testimony — opinion ¶¶17–18 Catfishing denied under oath — ¶25 — "two different threads" Who named Bujdoso first — disputed: ¶18 vs ¶25 No 2016 "feud" recalled on cross — ¶18
The structural disadvantage — what I was up against
I was not in a position to have known better. That is not an excuse. It is an accurate description of what pro se respondents face in civil domestic violence proceedings.
In Illinois civil proceedings there is no right to a court-appointed attorney. That right exists only in criminal cases. I had no money and could not afford private counsel. I was not introduced to AI legal assistants — they were not widely available or prominent in 2020, and I had no access to any tool that might have helped me understand appellate procedure, briefing rules, or the standard of review. When Lenington told Lincoln "we will be looking at the law and how the court system has previously decided," Lincoln replied by email: "Who is 'we'? Did you hire a lawyer?" He was checking immediately. When Lenington clarified it was just him, Lincoln had confirmed his opponent was still unrepresented. Lincoln knew the proceeding from that point on would be him, a licensed attorney with years of family law practice, against someone navigating it alone. That is not a level proceeding. The e-filing system itself was inaccessible. When Lenington tried to file his Motion to Vacate electronically in January 2021, the case could not be found in any e-filing tool. He sent the motion to a wrong email address first. He navigated all of this alone over a holiday weekend. A represented party does not encounter any of this. Throughout the proceedings Lenington referenced evidence he had: Google Timeline location data, bank records, phone carrier records, authenticated Facebook messages. In his closing argument, Lincoln correctly stated: "He offered nothing into evidence, period." That statement is factually accurate as a description of the record. It is not accurate as a description of what existed. The distinction is procedural. His Google Timeline, bank records, and phone carrier records — all of which he stated he had — were never in evidence because he did not know how to get them there. The court's own clerks provide procedural guidance to petitioners navigating the filing process. That assistance is not extended to respondents in the same way. I was not told what Rule 341 required. I was not told what manifest weight of the evidence meant. I was not told that arguments not cited to the record are forfeited. I learned all of these things after they had already cost me the case. The tone of my briefs reflects someone who was angry, frightened, and alone in a legal system he did not understand. I am stating these facts because anyone reading this site who is in a similar position deserves to know that the playing field in civil domestic violence proceedings is not level — and that the consequences of navigating it without resources are real and permanent.
Pro se respondent · no right to counsel in civil proceedings Lincoln: "Who is 'we'? Did you hire a lawyer?" — confirmed unrepresented opponent immediately E-filing inaccessible — case not found in any tool; navigated alone over holiday weekend Evidence existed — Google Timeline, bank records, phone records — never admitted; process unknown Lincoln: "He offered nothing into evidence, period" — technically correct, procedurally explained Did not know hearing was at 2pm — believed it was 9am — never informed of correct time · C-225 Addendum emailed to Lincoln January 22 — not filed with court; appellate panel never had it No AI tools available 2020 · clerical assistance asymmetry
C-225 — He did not know the correct time of his own hearing Zoom Court / Virtual Appearance In his Opposition to the Motion in Limine (C-225), Lenington documented: "Mark was also unaware that the hearing was set for 2pm and was under the assumption that it would be held at 9am. Mark requested the disposition sheet but the court failed to provide it to him although the Petitioner's attorney was provided with it." A represented party does not walk into their own hearing not knowing what time it starts. The disposition sheet — the document specifying the hearing time — was provided to Lincoln but not to Lenington. He called the courthouse in May and still was not told the correct time for the June 1st hearing. This is the asymmetry in practice: Lincoln knew when the hearing was. Lenington had to guess.
What I Actually Said — And Why It Mattered
The Language That
Hurt My Case.
And Why I Meant It.

My legal filings contained language that the courts — and anyone reading them — could reasonably characterize as intemperate, accusatory, and personal. The appellate court noted the violations. The briefs are now permanently published online as part of the public record.

I am not retracting any of it. What I said reflects what I genuinely believe happened and what I believe is likely true based on everything the record shows. But there is a critical difference between what is true and what is legally useful. In a courtroom, only the second one matters.

I also want to be precise about something: I was not in a position to have known the difference. There is no right to counsel in civil domestic violence proceedings. I had no money for a private attorney. AI legal assistants were not widely available in 2020. Court clerks provide procedural guidance to petitioners — not respondents. This section exists to be the guide I did not have.

⚠ A note before reading

The language below was written in the context of years of legal proceedings in which I believed — and continue to believe — that I was wrongly accused. It reflects genuine conviction, not performative anger. It is quoted here from public court documents.

The purpose of this section is not to re-litigate the case or to attack anyone. It is to show pro se litigants what emotional language looks like in a legal context, why courts respond to it the way they do, and what it costs the person writing it — even when the underlying belief is accurate.

Everything quoted here is from certified court transcripts and filed documents. These are public records.

What I said — and what I meant
"Allyssa Bujdoso is an exploiter and a manipulator. In this matter, Judge, Allyssa Bujdoso is the abuser."
I meant this. She filed a petition containing claims the record contradicts. She upgraded her account from "one date, not my boyfriend" to "serious courtship" after receiving my legal research — not because new facts emerged. She used a process designed to protect victims of intimate partner violence to address a social media dispute between two people who had not spoken in four and a half years. From where I stood, "exploiter" and "manipulator" felt like the most honest words available.
Said in closing argument · July 19, 2022 · Appellate reply brief
Closing argument transcript R-272 · Reply brief on record
Why saying it this way destroyed its effectiveness
An appellate court reads briefs to find legal error in the trial court's ruling — not to adjudicate character. The moment a brief calls someone an exploiter and a manipulator, the court stops evaluating the legal argument and starts evaluating the person making it.
Courts do not have the authority to rule that someone is an exploiter. They have the authority to rule that 750 ILCS 60/103(6)'s business and social context exclusion was not correctly applied. One of those arguments was available to me. I used the other one instead.
What to write instead: "The trial court's finding exceeded the evidence presented by either party and was not reconciled with the statute's own exclusion language at 750 ILCS 60/103(6)."
What I said — and what I meant
"She calls herself a feminist but then she lied to two female judges about domestic violence."
What I was pointing to is real. Someone who positions themselves as an advocate for women's safety using a domestic violence statute — in my view — to silence a social media dispute and address a feud between acquaintances who had not spoken in years represents a form of irony that I believe is genuinely harmful to actual victims. The system was designed for people in imminent danger from intimate partners. I believe she knew that and used it anyway.
Closing argument transcript R-283
Why saying it this way destroyed its effectiveness
Calling someone a hypocrite is an opinion. Calling someone a liar is an unproven assertion. Neither advances a legal argument about whether the IDVA's dating relationship standard was correctly applied.
The observation about misuse of the IDVA process is a legitimate policy argument. It belongs in an op-ed or on a website — not in a closing argument where it crowds out the legal point.
What to write instead: "The petition was filed four and a half years after last contact — a period with zero evidence of ongoing danger — which does not reflect the immediate safety situations the IDVA's ex parte provisions were designed to address."
What I said — and what I meant
"She lied with finesse. She has developed a skill for misleading and lying to people. I watched her do it over the course of many years."
The record shows her account changed in ways that track the legal standard rather than new memories. Her 2016 text said no date had occurred. Her affidavit said one. Her trial testimony said several. Each upgrade followed a legal disclosure. The car ride she described cannot have happened — I have never driven in Illinois. These are not the mistakes of a nervous witness. They are a pattern. I called it what I believed it was.
Closing argument transcript R-275
Why saying it this way destroyed its effectiveness
The trial court made a credibility finding. It found Bujdoso credible and Lenington not credible. Appellate courts give that finding enormous deference under the manifest weight standard — they will reverse it only if the opposite conclusion is clearly evident.
Arguing in an appellate brief that the petitioner "lied with finesse" is arguing against the credibility finding in the most inflammatory possible way. The court reads it as the complaint of someone who lost on credibility — which confirms the finding rather than challenging it.
What to write instead: Document the timeline. Let the dates speak. "Her affidavit said one date. Lincoln's May 2021 motion said courtship. The intervening event was my legal research." No characterization needed.
What I said — and what I meant
"Judge Rosenberg was not paying attention, plain and simple. She's overseeing the case and is in charge of the hearing, but she really has no interest in paying attention."
She found three dates when the petitioner claimed one. She characterized bar visits where one party was working as a bartender and the other was a paying patron as a "serious courtship" — conduct the statute's own language directly excludes. The outcome exceeded the evidence. I said what I observed. There is also specific context that does not appear in the brief. During the proceedings, the court watched an hour-long video — part of the "Exploiters and Manipulators" series — as evidence. During its playing, it genuinely appeared to Lenington that the judge was not watching. That is the specific observation behind the comment.
Reply brief — published online as part of appellate record
Why saying it this way destroyed its effectiveness
This is the single most damaging passage in the entire filing record. Appellate justices are colleagues of trial judges. They work in the same system. They do not find that colleagues were not paying attention. They find legal error — or they do not.
Calling a sitting judge inattentive in a brief filed to the court sitting above her is the fastest possible way to lose the credibility of the reviewing court before they reach any substantive argument.
What to write instead: "The trial court found three dates. The petitioner testified to one. The respondent testified to zero. The additional two characterizations were the court's own — unsupported by any party's account and inconsistent with 750 ILCS 60/103(6)."
What I said — and what I meant
"ALLYSSA BUJDOSO and STEVE LINCOLN of Frumm and Frumm are a perfect match for a false restraining order submission. LINCOLN studied for many years to be ready for this moment."
Lincoln is a skilled attorney who understood how to present his client's case in the most favorable legal framing. He upgraded the factual claims after I shared the legal standard. He used procedural objections to prevent the most damaging evidence from being heard. He presented a well-structured case to a sympathetic judge. From where I stood, his skill was being applied in service of a false narrative.
Reply brief — published online as part of appellate record
Why saying it this way destroyed its effectiveness
Attacking opposing counsel by name in an appellate brief is an ethical violation that courts take seriously. The appellate court sustained an objection to this very passage during closing argument. It signals that the author cannot distinguish between the opponent and the opponent's attorney — a basic legal literacy failure.
More practically: Lincoln did nothing improper. He zealously advocated for his client within the rules. That is his job. The appropriate response to skilled opposing counsel is to develop a better legal argument — not to attack them in a published document.
What to write instead: Nothing. Opposing counsel does not appear in an appellate brief except when citing their arguments to rebut them. Full stop.
The Rule
If you are representing yourself and you feel the way I felt, write the angry version first. Then put it away. Then write the version that only contains things a court can actually rule on. The angry version will feel more true. The legal version will perform better. You need the legal version. I did not know this. I had no one to tell me. No lawyer. No AI assistant. No guide. The clerks helped the other side fill out their forms. Nobody helped me fill out mine. This site is the guide I did not have. Every quote in this section reflects what I believed then and believe now. None of it belongs in a legal document. If you are reading this before you file anything — you are already further ahead than I was.
The Videos
What They Were. What They Weren't.

Two videos were made in October and November 2020 — both played in court. The appellate opinion describes the Halloween video in detail near its opening. Less discussed is the first video, which predated it, references it, and contains a pre-litigation on-camera account of the May 23 bar incident that matches Lenington's sworn testimony exactly throughout proceedings.

🎬
"Women in Chicago Comedy — A False Accusation Halloween Special"
Posted October/November 2020
What it was
A Halloween-themed fictional sketch video made during COVID-19 pandemic lockdown when I was home alone with nothing to do.
A learning exercise in video production — specifically Adobe Premiere editing software, green screen technique, lighting, and camera work.
A creative response to being called a predator, a rapist, and a potential mass shooter — the exact accusations the Exploiters and Manipulators flowchart documents reaching the endpoint: "You're gonna shoot up a movie theater, aren't you?" The video depicts, in horror-comedy form, the false accusations being leveled at me. The title says it plainly: A False Accusation Halloween Special.
Inspired by the Annoyance Theatre's annual "Splatter Theatre" — a Chicago comedy institution featuring graphic violence, axes, guns, and blood, released virtually that same year.
Something I made in approximately twelve hours to amuse myself. I was the only real actor. Other characters wore wigs and masks.
Content I deeply regret making in the form I made it, regardless of intent. It was a mistake. I own that completely.
Made before Lenington knew Bujdoso had contributed to the accusations against him. His written response (C-192) states: "It wasn't until I read Allyssa's petition that I discovered she had also contributed to such disparagement of me. Though I had my suspicions, I was not sure who said what or heard what from who." The video was not a response to her specifically — because he did not know she was specifically involved.
What it wasn't
Sent to Bujdoso. She had been blocked from my social media for years. I never sent it to anyone with instructions to show her.
Tagged with her name or any name. No individual was named, tagged, or directly identified anywhere in the video.
Made with her specifically in mind as a target. I stated consistently that I was thinking about a group of people, not any one individual.
A threat. No threat was made, stated, or implied. I had not been in contact with or near Bujdoso for over four years when it was posted.
Uniquely identifiable to any one person. The character name "Clarissa" rhymes with many names. I stated it was inspired by multiple people's behaviors, not one individual.
Something I watched being viewed by Bujdoso during proceedings without requesting any accommodation — despite testifying it caused nightmares and panic attacks.
The Videos — Context MattersThe honest accounting: The video was graphically violent, in poor taste, and created a context that was easy to weaponize against me legally. I should not have made it the way I did. That said — it was fiction, publicly posted, inspired by Chicago's own horror-comedy tradition, and made by someone who had been subjected to years of false accusations online with no recourse. The pandemic, the isolation, the pile-on of people calling me things I was not — that was the context. Context does not excuse the content. But context is part of the truth, and the truth is what this site is for.
The connection the petition never acknowledged: The video was made in direct response to being called a predator, a rapist, and a potential mass shooter. He called it A False Accusation Halloween Special. The title is not incidental. It is the point. Bujdoso's petition then used that video to claim Lenington was "liable to shoot someone in the head." The shooting language did not begin with the petition. In May 2016 — four years before the Halloween video was made — Bujdoso wrote to Abby Stassen: "He's like the kind of guy that shoots people because he doesn't get his way." She wrote this in the same text exchange that contains "Part of this is because I wouldn't go on a date with him." The video made in response to being called a potential mass shooter was offered as evidence that he was a potential mass shooter. The accusation produced the response. The response confirmed the accusation. That is the loop. One further documented fact: the petition characterized a gun prop caption in the video as "I wonder WHO this is for" — implying the gun was directed at a specific person. The caption in the video reads "I wonder WHAT this is for." Lenington's written response to the petition (C-192) noted that the post itself made clear it was a TOY gun — a prop used in a fictional production — and that the petition had omitted that context entirely while still using the image to ask the court to remove his firearms. Lenington corrected the WHO/WHAT misquote in his January 22, 2021 addendum — emailed to Lincoln at Lincoln's request, never formally filed, never in the appellate record. The one-word change — WHO to WHAT — is the difference between a targeted threat and an ambiguous prop caption. The petition used the wrong word. The correction was never in the record.
The documented sequence:
Sep 29, 2020
Publicly called a rapist on social media. Begins searching for defamation attorneys within 48 hours.
Oct 1–2, 2020
Emails law firm seeking defamation rep. Referred to Daliah Saper. Zoom consultation scheduled. Advised defamation litigation not viable. Legal route closes.
Oct 23–29, 2020
Google search history documents searches for "green screen ghost effect adobe premiere pro," "add blood splatter to adobe premiere pro," and Splatter Theatre research — corroborating the stated learning exercise.
Nov 1, 2020
Visited Splatter Theatre Wikipedia page at 4:14 PM. Searched "halloween video submission contest" at 7:15 PM. Video posted.
Nov 6, 2020
Bujdoso files emergency petition. Ex parte order granted same day. Lenington learns of the order when served.

"The video was not meant as a threat, and he did not post it with the goal of Bujdoso viewing it."

Lenington's testimony — Report of Proceedings, October 2021 hearing. Stated consistently from the first motion through the final petition.
🎬
A Second Video — "Exploiters and Manipulators" Series — Also Played in Court
Made October/November 2020 · Before the petition was filed
What this video was: Part of a video series Lenington was making called "Exploiters and Manipulators" — episode one in that series covered Michael Avenatti's misconduct. This episode documented his personal experience with the cancellation campaign against him. It was made after his defamation consultation closed the legal route and after he had already moved apartments because people knew where he lived. The Halloween video was a separate Halloween special. Both were played in court.
What the first video also contained — the pre-litigation account: In its closing segment, Lenington addressed several individuals without naming them. One of those addresses describes the May 23, 2016 bar incident — in his own words, on camera, before any legal proceeding existed:
On camera · October/November 2020 · Before the petition was filed:
"To the chick who I think started all these rumors, um, I was at your bar close to closing time, but I was saying nice things about the venue and a show. I was saying nice things. You took offense to that, kicked me out, embarrassed me, and when I asked you about it the next day politely, you immediately turned it into me harassing you because you're a woman."
This on-camera account was made before the petition existed. The sequence he describes — visiting the bar, being asked to leave, contacting her the next day, her characterizing it as harassment — matches his C-191 written response, his Motion to Vacate, his trial testimony, his appellate brief, and his Illinois Supreme Court petition without variation. It is the same account from the pre-litigation video to the final court filing. When the same account appears in a video made before any legal incentive existed and in sworn testimony years later, that consistency is evidence of something.
The apology in the first video — and what it shows: The same closing segment of the first video — not the Halloween video — also contained what Lenington described in his formal Response to Request for Admission (#10) as a good-faith attempt to de-escalate: "In a good faith effort to end what seemed to be the impact of Allyssa's feud against me, I apologized to her without mentioning her name. I apologized for perhaps reminding her of her college abuser…but she was not identifiable and I did not ask or expect anybody to contact her on my behalf."
This is significant for two reasons. First, it places the apology in the first video — not the Halloween video — clarifying that the Halloween video was a creative piece, not a message directed at anyone. Second, it shows that in the same video that contained his factual account of the bar incident, he was also attempting to extend an olive branch. Someone making a targeted threat does not simultaneously attempt to de-escalate. The apology and the account coexist in the same video. The petition used neither — it relied entirely on the Halloween video made separately.
Source: Lenington's Response to Request for Admission #10 — Illinois Supreme Court Rule 216 — public court record
The December 2020 TikTok — alleged order violation, never submitted as evidence: In December 2020, after the emergency order was entered, Lenington posted a TikTok in which he wore a wig and used a similar prop to the Halloween video. The content was entirely different — a joke on an unrelated subject. The other side alleged this constituted a violation of the emergency order then in effect. It was never submitted as evidence in the proceedings. An allegation that was raised but never evidenced is not a finding.
What Constitutes Contact
The Video Was Public.
She Was Blocked.
Nobody Sent It To Her.

Orders of protection restrict contact with the protected person. What counts as "contact" has evolved as courts have addressed social media. The cases that found social media activity to constitute contact share a common element: each involved a deliberate act directed specifically at the protected person. Publicly posting content to your own account — with the protected person blocked — is a different category entirely. The distinction matters.

✗ Clearly prohibited
Direct communication to the protected person
Any message, call, or communication deliberately sent to or directed at the protected person. The core of what a no-contact order prohibits. Unambiguous in every jurisdiction.
Texting or calling directly
Sending a private/direct message on any platform
Emailing directly
Approaching them in person
✗ Courts have found: prohibited
Directed social media acts that reach the protected person
Courts have found these constitute contact because each requires deliberately selecting the protected person and performing an action that reaches them directly — the same deliberate-direction principle as a phone call or text.
Tagging the person in a post — sends a notification directly to them
Poking the person on Facebook — deliberate act selecting that person
Posting on their page — activity on their profile
Asking third parties to deliver messages on your behalf
△ Contested — jurisdiction dependent
Mentioning the person in your own public posts
Courts are divided on whether naming or referencing a protected person in a public post — without tagging or directing — constitutes contact. The key question is whether the content reaches the person through the respondent's deliberate action.
Naming someone in a public post they are not tagged in
Posting content that references shared events
Fictional characters that resemble real people
Raises significant First Amendment questions
→ This case — the specific facts
Publicly posted content — protected person blocked — learned through voluntary third parties
The video was posted publicly. Bujdoso had been blocked from Lenington's social media for years. He never tagged her. He never sent it to anyone with instructions to show her. She learned of it when Palm and Stockwell — acting voluntarily on their own — told her about it.
Posted to public accounts — not sent to her
She was blocked — could not see it herself
Third parties acted voluntarily — not at his direction
Made before any order existed
Contact — directed at the protected person
Every case that found social media activity to be a violation involved an act deliberately aimed at the protected person
Tagging requires selecting that specific person. The notification goes to them because you chose to send it to them. Indistinguishable from a text message in its directness.
Poking requires selecting that specific person and clicking a button directed at them. The same deliberate-direction element is present.
Posting on their wall places content on their property. The act is directed at their space.
Asking third parties to deliver messages — using someone as a conduit to communicate with the protected person is contact through a third party in every meaningful sense.
Expression — public content on your own account
Publicly posting content to your own account, where the protected person is blocked, involves no deliberate act directed at them
No notification is sent to the protected person. The content exists publicly but is not delivered to them by any mechanism the poster controls.
The protected person is blocked — she cannot see the content through any direct path. The barrier between the poster and the protected person is intact.
Third parties act independently. When a mutual acquaintance voluntarily decides to show the content to the protected person, that is the third party's act — not the poster's.
This is public expression — the same category as a published article or public speech. Prohibiting all such expression raises serious First Amendment questions.
The specific facts of this case — what happened and what did not
She was blocked from his social media before the video was posted and had been for years. This is undisputed in the record.
The video was posted publicly — not sent to Bujdoso, not shared with her, not transmitted to her by any mechanism Lenington controlled.
She was not tagged in any post. Her name does not appear in the video. No notification was sent to her by any platform.
Palm and Stockwell told her about the video. They did so voluntarily. The record contains no evidence Lenington asked or directed anyone to inform Bujdoso.
The video was made before any order existed. The emergency order was entered November 6, 2020. The video was posted November 1, 2020. No order was in effect when the video was posted.
The December 2020 video — posted after the emergency order existed — is a different question. The order at that point restricted social media contact.
The document mailings — Lenington mailed court documents directly to Bujdoso. He stated court staff told him this was permissible service of process. This is direct contact and is legally distinguishable from the video question.
On cross-examination Lenington confirmed she "had been blocked from my social media for years" — his exact testimony, affirmed in the appellate opinion at ¶29.
After "do not contact me," she contacted him. In his Denials and Admissions (C-223), Lenington noted: "Allyssa then contacted Mark 2 months later via social media." The final communication in the sequence was initiated by her. "Allyssa telling Mark 'do not contact me' is not an Order of Protection in and of itself, contrary to popular belief." — C-223
The 3rd video allegation — used to amend, then dropped. In a January 15, 2021 pre-hearing, Lincoln alleged a 3rd video violated the EOP. That allegation was the stated reason the court granted leave to file a Second Amended Petition. When the Second Amended Petition was filed, the 3rd video allegation did not appear in it. The claim that justified amending the petition was abandoned in the amendment itself. Lenington's Opposition (C-228) noted this explicitly: "The claim was frivolous and was made in an attempt to pressure Mark into settling for an Agreed Order."
The First Amendment question that was never argued The plenary order prohibited Lenington from any contact with Bujdoso "including through third parties and social media." An order interpreted broadly enough to prohibit all public posts that any third party might voluntarily show to the protected person would effectively be a prior restraint on public expression — one of the most disfavored doctrines in First Amendment law. This argument was never raised in the state court proceedings because it was never properly preserved. Arguments not raised at the trial court level cannot be raised for the first time on appeal. The First Amendment question exists in the record as an argument that was available and never made — another consequence of proceeding without counsel in a proceeding with no right to one.
The Inconsistency
Same Panel. Same Statute.
Opposite Result.
Inconsistency — overlapping appellate panel

Five weeks after Justice Hyman authored the order affirming the protective order against me, he and Justice C.A. Walker — two of my three judges — sat on a published decision that reversed an order of protection on facts far stronger for finding a dating relationship than mine. Same division of the First District. Same statute. Opposite outcome.

Bujdoso v. Lenington — Order Affirmed
Online contact~75 days of messages
In-person meetings3 — open mic & her bar
Meeting contextShe bartended; I was a patron/performer
Sexual contactNone
Romantic relationship?She denied he was her boyfriend
Statute applied?Court said yes
Plenary order affirmed — Nov. 17, 2023 (unpublished, Rule 23)
McClellan v. Hull — Order Reversed
Online contactWeeks of texts, calls, FaceTime
In-person meetings2 — actual dates
Meeting contextSocial dates
Sexual contactOral sex and intercourse
Romantic relationship?Petitioner said not boyfriend-girlfriend
Statute applied?Court said no
Plenary order reversed — Dec. 22, 2023 (published precedent)

Read those columns again. The party with two real dates and sexual intimacy was held not to be in a dating relationship. I — with no dates outside a bar where one of us was working, contact a neutral observer would call ordinary social fraternization — was. If the stronger facts failed, the weaker ones cannot logically succeed.

The statute decides this. The Domestic Violence Act says that "neither a casual acquaintanceship nor ordinary fraternization between 2 individuals in business or social contexts shall be deemed to constitute a dating relationship." 750 ILCS 60/103(6). Two of the three encounters were visits to the bar where the petitioner worked as a bartender — the textbook business/social context the statute carves out. Remove them, as the statute requires, and one meeting remains. And the appellate court itself accepted the rule from Alison C. v. Westcott that a single date cannot establish a dating relationship. The affirmance survives only by counting, as "dates," the very encounters the legislature excluded.

This is not a quarrel with the facts. Whether I was at the bar was never disputed. Whether being at a bar where the other person is working counts as a "date" is not a fact at all — it is the application of a statutory term to undisputed conduct, a question of law. Calling it a "date" does not make it one when the statute says contact in that setting is not a dating relationship.

"When you talk about a dating relationship, that is a subjective concept. The intent of the parties matters... There had to be an intent on both sides to enter into such a relationship in the first place."

Opposing counsel's closing argument — July 19, 2022 · R-262. The reasoning the court accepted here.

"The 'intent' to have one is not the same as having one."

McClellan v. Hull, 2023 IL App (1st) 220465, ¶ 74 — Justices Hyman and C.A. Walker concurring, five weeks after affirming the order against me, rejecting the reasoning used in my case.

My case is an unpublished Rule 23 order — not precedent. The decision that contradicts it is published, citable law. And mine is not the mainstream Illinois rule: a family-law commentary describes Bujdoso as a Rule 23 case "leading us in New Jersey's direction," while noting that Alison C. "is still the law of the land in Illinois." My panel reached its result by importing another state's broader standard — from a statute that contains no business-or-social-fraternization exclusion — to override Illinois's narrower text. If the conduct warranted any civil remedy, the legislature provided one that requires no dating relationship at all: a Stalking No Contact Order, 740 ILCS 21/15, available precisely "when relief is not available under the Domestic Violence Act."

The Opinion
What the Court Said.
What the Record Shows.

The appellate court issued an unpublished order in November 2023 affirming the trial court's ruling. Unpublished orders are not citable as precedent under Illinois Supreme Court Rule 23, but they are public documents. For a condensed, transcript-anchored breakdown, see the full Bujdoso v. Lenington case summary and record-based rebuttal.

Below is a paragraph-by-paragraph analysis. Items are categorized as factual contradictions, omissions, reasoning problems, and correct rulings. Every record citation is verifiable. Every quotation from the opinion is exact.

This is my personal account and assessment. My opinions are labeled as opinions. Every factual claim is cited to a specific document in the public record. Readers are encouraged to read the opinion and the cited documents and reach their own conclusions.

Citation: 2023 IL App (1st) 221236-U, filed November 17, 2023, Sixth Division. Rule 23 order — non-precedential.

Legend — item types
Internal contradiction: The opinion states something that conflicts with another part of the record, including documents the court itself cited.
Material omission: Relevant contrary evidence or argument that was available in the record and not addressed.
Reasoning problem: A legal inference or analytical step that doesn't follow from the cited authority or stated facts.
Correct ruling: An analysis or conclusion I believe the court got right, or a ruling against me that was procedurally appropriate given how the case was litigated.
¶3 · Holding summary
"going on three dates and communicating via the Internet for nearly three months in a romantic relationship"
Internal contradiction
The court's own summary contradicts the petitioner's cross-examination testimony recorded four paragraphs later
The opinion opens by summarizing the holding as involving "three dates." Paragraph 39 records Bujdoso's cross-examination testimony: "Bujdoso reiterated that the parties went on one date before their 'final interaction' in May 2016." The petitioner testified to one date on cross-examination. The respondent testified to zero dates throughout. The opinion upholds a finding of three without reconciling its own paragraph 39 with its paragraph 57, which upholds the three-date finding.
RecordBujdoso cross-examination: one date — ¶39 of the opinion itself. Lenington throughout: zero dates — C-191, Motion to Vacate Jan 2021, trial testimony, appellate brief, IL Supreme Court petition. Neither party's sworn testimony supports three dates.
¶5 · Ex parte hearing
"she had a date with Lenington and they 'spent time' together in 2016, though she denied he was her boyfriend"
Internal contradiction
The opinion records her own denial of a boyfriend-level relationship at the ex parte hearing — then concludes a serious courtship existed
Paragraph 5 documents Bujdoso's sworn statement at the November 2020 ex parte hearing: she "denied he was her boyfriend." The first judge at that same hearing said on the record: "I'm not sure you even have a dating relationship with him." The boyfriend/girlfriend relationship checkbox on the emergency order form was left blank. The opinion records this denial in its own background section and then reaches a conclusion of serious courtship without explaining how both can be true.
RecordEx parte transcript R-4: "Would not have called him my boyfriend." Emergency order form: boyfriend/girlfriend box blank. First judge on record: "I'm not sure you even have a dating relationship with him."
¶46 · Trial court's three-date finding
"Bujdoso and Lenington went on two additional dates when he went to her workplace and stayed past the time for regular customers"
Statutory omission
The two "additional dates" are bar visits where she was working as a bartender and he was a paying patron — the exact factual pattern 750 ILCS 60/103(6) addresses
750 ILCS 60/103(6) states: "neither a casual acquaintanceship nor ordinary fraternization between 2 individuals in business or social contexts shall be deemed to constitute a dating relationship." The April 2016 encounter: Bujdoso was working her bartending shift. Lenington was a patron assessing a comedy venue. The May 2016 encounter: Bujdoso was working until close. Lenington performed at the open mic and ordered drinks as a customer. Both were in a business context. Neither the trial court's order nor the appellate opinion's analysis section ever applies the statutory exclusion language to these precise facts.
RecordBoth parties agreed: she was working as a bartender in both bar encounters. He was a patron and performer. 750 ILCS 60/103(6) analysis section: ¶55 quotes the exclusion language. ¶56–62 analysis: the exclusion is never applied to the bar visits characterized as dates.
¶44 vs ¶61–62 · Reciprocal interest
"her reciprocal interest constitutes a 'serious courtship'"
Internal contradiction
The "reciprocal interest" finding is contradicted by Bujdoso's own testimony recorded in the same opinion, her 2016 text, and her ex parte denial
Paragraph 62 finds "her reciprocal interest" as part of the basis for serious courtship. Paragraph 44 records her own trial testimony: she "was focusing on her career." Her 2016 text to Abby Stassen — written four and a half years before any litigation — states: "All of this because I would not go on a date with him." That sentence, written in real time with no legal incentive, describes a situation in which no date had occurred. Her ex parte testimony: she would not have called him her boyfriend. The reciprocal romantic interest the opinion finds is contradicted by the petitioner's own contemporaneous document, her own ex parte testimony, and her own trial testimony.
RecordBujdoso to Abby Stassen, May 2016 — C-49: "all of this because I would not go on a date with him." Trial testimony ¶44: "focusing on her career." Ex parte transcript R-4: "would not have called him my boyfriend."
¶57–58 · Alison C. v. Westcott
"Alison C. was decided more than 20 years ago before Facebook or its Messenger application existed"
Reasoning problem
Updating a precedent because technology changed is a legislative function — the statute has not been amended, and the court's modernization argument substitutes judicial policy for statutory text
The court says Alison C. v. Westcott is outdated because it predates Facebook. This may be true as a factual observation about technology. It is not a basis for a court to expand a statutory definition. The Illinois Domestic Violence Act has not been amended to change the dating relationship definition since Alison C. was decided in 2003. The legislature has had more than twenty years to update the statute if it wished to. Statutory interpretation does not permit a court to expand a definition because circumstances have changed — that is precisely the legislature's function.
Record750 ILCS 60/103(6): unchanged since Alison C. was decided. No legislative amendment to the dating relationship definition in the intervening 20 years. The casual acquaintance exclusion remains in the statute exactly as written.
¶59 · C.C. v. J.A.H. (NJ)
"C.C. v. J.A.H., 463 N.J. Super. 419 (2020), where the New Jersey appellate court found a 'dating relationship'... who exchanged hundreds of texts messages"
Reasoning problem
The NJ case involved hundreds of texts in a neutral social setting — this case involved approximately fifteen texts in a workplace context. The court applied NJ reasoning without acknowledging the factual disparity.
C.C. v. J.A.H. is a New Jersey case interpreting a different statute. The NJ court found a dating relationship where the parties exchanged hundreds of text messages and met in a neutral social setting that neither party worked at. Here, Lenington testified to approximately fifteen messages total. The in-person encounters were exclusively at Bujdoso's workplace during her working hours. The opinion applies the NJ case's reasoning about volume and nature of online communication without noting that the factual basis — hundreds of texts versus approximately fifteen — is materially different.
RecordLenington trial testimony ¶23: "exchanged about 15 texts messages." C.C. v. J.A.H.: parties "exchanged hundreds of texts messages" — quoted in ¶59 of this opinion.
¶60 · Public policy argument
"courts must also view the facts through the prism of the State's strong public policy against domestic violence"
Reasoning problem
Using the policy the statute serves to expand the jurisdictional threshold that governs access to the statute is circular — and directly contradicts the legislature's deliberate inclusion of the casual acquaintance exclusion
The "dating relationship" requirement is jurisdictional — it determines whether the Act applies at all. The court uses the policy against domestic violence to interpret that threshold expansively. But the legislature deliberately included the casual acquaintance exclusion alongside the dating relationship requirement. That exclusion is itself a policy choice — the legislature decided that not every dispute between people who know each other qualifies for the Act's protections. Using the Act's general policy to override its specific exclusion language substitutes the court's policy preference for the legislature's own balance. Five weeks later in McClellan, the same panel reversed a case on stronger facts — suggesting the policy argument does not produce consistent outcomes even within the same panel.
Record750 ILCS 60/103(6): the casual acquaintance exclusion is in the same sentence as the dating relationship provision — a deliberate legislative balance. McClellan v. Hull, Dec. 22, 2023: same panel, stronger facts, policy argument not sufficient to sustain the order.
¶61 · Volume of communication
"Bujdoso testified she had daily communications with Lenington, denoting a dating relationship"
Internal contradiction
The court treats Bujdoso's testimony about daily communication as establishing the dating relationship — but the opinion itself records Lenington's uncontradicted testimony about the actual volume of messages
Paragraph 61 treats Bujdoso's claim of daily communication as establishing a dating relationship. Paragraph 23 of the same opinion records Lenington's testimony: "the parties never spoke on the phone, exchanged about 15 texts messages, and communicated mostly through Facebook Messenger." No documentary evidence of daily communication volume was presented. Petitioner's Exhibit 4, the Facebook Messenger screenshot in evidence, is a single substantive exchange. The court resolved the volume dispute in Bujdoso's favor without explaining why her testimony about daily communication was credited over his testimony about fifteen total messages or why no documentary evidence of the claimed volume was required. The birthday admission — Lincoln stating his client did not know Lenington's birthday — is also inconsistent with months of daily intimate communication.
RecordLenington testimony ¶23: "about 15 texts messages." Petitioner's Exhibit 4: one Facebook Messenger exchange. No message logs admitted in evidence as noted in the opinion. Lincoln birthday admission: inconsistent with months of daily intimate communication.
¶49–52 · Rule 341 violations
"Lenington's brief violates Illinois Supreme Court Rule 341(h)(7)... Nonetheless, the deficiencies are not so flagrant to hinder our review"
Correct ruling
The Rule 341 finding is accurate. The brief did not comply with citation requirements. The court's decision to reach the merits anyway was generous — and is not disputed here.
This finding is correct. Lenington's appellate brief did not include proper citations to the common law record or sufficient legal authority. Rule 341(h)(7) requires both. The brief was written by someone who was not in a position to have known these requirements — no attorney, no AI tools available in 2022, no court assistance for respondents comparable to what petitioners receive. The court chose to reach the merits anyway. That decision was generous and is acknowledged here. The procedural deficiency is real. It does not change what the underlying documents show about the facts.
ContextNo right to counsel in civil proceedings. No AI legal assistance widely available in 2022. Court clerical staff assist petitioners navigating filings — that assistance does not extend to respondents in the same way. The procedural violation was the product of circumstances, not indifference.
¶45 · Discretionary remedies
"The court did not order Lenington to undergo counseling or surrender firearms nor assess Lenington attorney's fees or costs."
Correct ruling
The trial court correctly declined to impose discretionary remedies including firearms surrender — these decisions are not disputed here
The trial court exercised sound discretion in not ordering counseling, firearms surrender, or attorney's fees. These are discretionary remedies under the Act. The court's restraint on these discretionary remedies is appropriate given the facts as found and is not part of this critique. The critique is limited to the jurisdictional question — whether a dating relationship existed — and the legal reasoning used to answer it. Note that the federal firearms disability under 18 U.S.C. 922(g)(8) attached automatically to the plenary order regardless of the court's discretionary decisions — it is a federal statutory consequence, not a separate discretionary remedy.
NoteThe federal firearms disability under 18 U.S.C. 922(g)(8) is a federal statutory consequence of any qualifying civil order of protection, not a discretionary remedy within the court's control.
R-292 · Trial court's ruling · The "third date"
"A common patron would not be allowed to stay after hours. A common patron would leave when the bar closes. This also constitutes a dating relationship."
Internal contradiction
The court characterizes the incident that ended contact — in which she asked him to leave and escorted him out — as evidence of a dating relationship
The May 23rd bar incident is the event that directly led to Bujdoso sending the "Do not contact me" message. Both parties agree she told Lenington to leave and he was escorted out. The court characterizes his staying until closing — the behavior she objected to — as evidence of a dating relationship rather than as an ordinary dispute between a bartender and a patron. Neither party described this as a date. The court invented that characterization based solely on the fact that he stayed past closing. The court does not address why this reasoning does not conflict directly with 750 ILCS 60/103(6).
RecordR-292 — Judge Rosenberg's ruling. Both parties agreed Bujdoso told Lenington to leave and escorted him out. The "Do not contact me" message followed this incident directly. The incident that ended contact is characterized as constituting the relationship.
R-290 · Trial court's ruling
"I am well versed on what the case law is and spent time reading the cases in advance of the hearing to be well versed in the law."
Statutory omission
The trial court states it is well versed in the applicable law — then delivers its entire ruling without mentioning the statutory exclusion that directly applies to every encounter it characterizes as a date
Judge Rosenberg tells the parties she has spent time reading the cases and is well versed in the law. She then characterizes three encounters as dates — two of which occurred while Bujdoso was bartending and Lenington was a patron or performer. She does not mention 750 ILCS 60/103(6)'s exclusion of "ordinary fraternization between 2 individuals in business or social contexts" anywhere in her ruling. A court that has read the applicable law would have addressed the exclusion language before characterizing bar visits during a work shift as dating relationship evidence. The exclusion is in the same statutory provision as the dating relationship requirement she does address. It applies directly. It is not mentioned.
RecordR-290 — Judge Rosenberg's statement. 750 ILCS 60/103(6): the exclusion is in the same sentence as the dating relationship provision. The trial court ruling: no mention of the exclusion. The appellate opinion: the exclusion is quoted at ¶55 and then never applied to any specific encounter in the analysis that follows.
¶23 · Lenington's attributed position
"The opinion attributes a one-date position to Lenington — based on a misreading of conditional language as a factual admission"
Internal contradiction
The appellate court misread "even if one date took place" — a conditional legal argument — as Lenington's admission that one date occurred. His stated position throughout every filing was zero dates.
Lenington's position from C-191 through his Illinois Supreme Court petition was zero dates. The appellate opinion incorrectly characterizes his position as conceding that one date occurred. The source of the error: somewhere in the record Lenington wrote conditional language — "even if one date took place" — as a hypothetical legal argument. This is a standard legal construct: accepting the other side's best case for the sake of argument, then showing that even under that assumption the legal standard isn't met. The court read the conditional as a factual concession. It was not. This error matters for what it reveals about how the court engaged with the record. Lenington's written response — C-191 — states his zero-date position plainly. The court's misattribution of a one-date position is consistent with the pre-trial admission: Judge Rosenberg acknowledged on the record immediately before the hearing that she had not read Lenington's written responses to the petition. If the trial court did not read C-191, and the appellate court misread the conditional language in the brief, then Lenington's actual defense — zero dates, business and social context only, statutory exclusion directly applicable — was never squarely before either court. A respondent arguing "even if one date took place, it still doesn't meet the Westcott standard" is making a stronger defense than one conceding one date occurred. The opinion evaluated the weaker version of his argument — the version he never made.
RecordC-191 — written response: zero dates, stated explicitly. Every subsequent filing through IL Supreme Court petition: zero dates, consistent. "Even if one date took place" language: conditional/hypothetical legal argument, not a factual admission. Judge Rosenberg pre-trial: acknowledged on the record she had not read respondent's written responses. Appellate opinion: attributes one-date position to Lenington in its characterization of his defense.
Problems identified — 13 items
Three-date finding exceeds both parties' testimony. Petitioner said one on cross. Respondent said zero throughout. The court invented the characterization of bar visits as dates.
Statutory exclusion never applied. 750 ILCS 60/103(6) is quoted in ¶55 and then never applied — despite directly governing every in-person encounter characterized as a date.
Reciprocal interest contradicted by record. The finding is contradicted by the petitioner's 2016 text, her ex parte denial, and her trial testimony — all recorded in the opinion itself.
NJ case misapplied on facts. C.C. v. J.A.H. involved hundreds of texts in a neutral setting. This case: approximately fifteen texts in a workplace context.
Modernization argument is judicial legislation. The statute hasn't changed. Updating a definition because technology changed is the legislature's function, not the court's.
Public policy bootstrapping. Using the Act's policy to expand the threshold that governs access to the Act overrides the legislature's deliberate casual acquaintance exclusion.
Daily communication claim accepted without documentary evidence. Lincoln's birthday admission — his client didn't know Lenington's DOB — directly contradicts the claimed daily intimate communication for months.
The ending-contact incident characterized as a date. The May 23rd encounter — which both parties agree resulted in her removing him — is characterized as a date because he stayed past closing. Neither party described it as a date.
"Well versed" but no 103(6) analysis. The trial court stated it had read the cases — then ruled on bar visits as dates without mentioning the business and social context exclusion that directly applies.
McClellan inconsistency. Same panel, stronger facts, opposite result five weeks later. ¶74 of McClellan directly contradicts the reasoning Lincoln used in this case — and which the trial court accepted.
Ex parte denial unreconciled. The opinion documents her ex parte denial of a boyfriend-level relationship, then reaches a conclusion of serious courtship without explaining the contradiction.
Birthday admission not addressed. Lincoln's on-the-record statement that his client didn't know Lenington's birthday — at the conclusion of a case about a serious courtship — is not mentioned anywhere in the opinion.
Lenington's position misattributed. The opinion attributes a one-date position to him based on a misreading of conditional "even if" language as a factual admission. His actual stated position throughout was zero dates — a significantly stronger defense than the court evaluated.
Correct rulings — 3 items
Rule 341 findings accurate. The appellate brief did not comply with citation requirements. The court's decision to reach the merits anyway was more generous than required.
Discretionary remedies correctly declined. No counseling order, no firearms surrender, no attorney's fees — appropriate given the facts as found.
Prosecution referral correctly declined. Not within an appellate court's jurisdiction. The ruling was procedurally correct.
A note on what this analysis is and isn't: This is my personal assessment of a published legal document about my own case. I am not an attorney. These observations are not legal advice and are not a substitute for the actual opinion, which is publicly available. Readers are encouraged to read both and reach their own conclusions. I stand behind every factual claim above and have cited each one to a specific document in the public record.
The Fifty-State Standard
How Illinois Defines
"Dating Relationship"
Compared to Every Other State
American Flag — Illinois among the fifty states
The Fifty-State Standard — How Other States Would Have Treated This Case

The National Conference of State Legislatures maintains an authoritative survey of how every state defines domestic violence and the relationships that trigger protection order jurisdiction. Reading Illinois's definition against the other forty-nine states reveals something important: Illinois has one of the least specific positive definitions of "dating relationship" among states that include a casual acquaintance exclusion.

Most states that exclude casual acquaintances also define what a dating relationship actually requires — frequent interaction, expectation of affection or sexual involvement, romantic or intimate nature, continuity over time, or declarations of romantic interest. Illinois excludes certain things but provides almost no positive definition of what is required. That gap is what allowed a trial court to characterize three bar visits — two of which occurred while one party was working as a bartender — as constituting a serious courtship.

Several states have provisions that would have barred this petition entirely — or required a substantially higher factual showing — under their definitions of dating relationship. Illinois is an outlier not in having a casual acquaintance exclusion, but in failing to pair that exclusion with a meaningful positive standard.

Source: National Conference of State Legislatures, "Domestic Violence/Domestic Abuse Definitions and Relationships." All statutory text reproduced for educational and comparative purposes from public government records.

Illinois — The Definition At Issue
"For purposes of this paragraph, neither a casual acquaintanceship nor ordinary fraternization between 2 individuals in business or social contexts shall be deemed to constitute a dating relationship."
750 ILCS 60/103(6) — Illinois Domestic Violence Act
The gap: Illinois tells courts what a dating relationship is not. It does not tell courts what one is. No positive definition. No required elements. No minimum duration, frequency, or nature of contact. The statute relies entirely on case law — including Alison v. Westcott's "serious courtship" standard — to fill a definition the legislature never wrote. Most other states wrote it.
12
Month limit — Alabama
Alabama explicitly requires that the dating relationship "did not occur further than 12 months prior to the filing of the petition." The interactions in this case occurred in 2016. The petition was filed in 2020 — four and a half years later. Under Alabama's definition, this petition could not have been filed at all.
38+
States with more specific positive definitions
The overwhelming majority of states define what a dating relationship requires — not just what it excludes. Frequent interaction. Expectation of affection or sexual involvement. Romantic or intimate nature. Continuity over time. Illinois requires none of these elements explicitly.
0
Positive elements Illinois requires
Illinois law states what a dating relationship is not. It states no minimum duration, no required frequency of contact, no requirement of romantic or intimate nature, no time limit since last contact. Zero affirmative requirements. The determination rests entirely on judicial interpretation of "serious courtship" — a standard the legislature never enacted.
Alabama
Ala. Code §30-5-2
"A significant relationship of a romantic or intimate nature characterized by the expectation of affectionate or sexual involvement over a period of time and on a continuing basis during the course of the relationship... A dating relationship does not include a casual or business relationship or a relationship that ended more than 12 months prior to the filing of the petition."
Requires: romantic or intimate nature, expectation of affection or sexual involvement, ongoing basis, and filing within 12 months of relationship end. The petition in this case was filed 4.5 years after last contact.
12-month rule would bar this petition
California
Cal. Fam. Code §6210
"'Dating relationship' means frequent, intimate associations primarily characterized by the expectation of affection or sexual involvement independent of financial considerations."
Requires: frequent associations, intimate nature, and expectation of affection or sexual involvement. Three bar visits over three months — two while one party was working — would not constitute "frequent intimate associations." No intimacy, affection, or sexual involvement existed or was claimed.
Higher standard than Illinois applied
Iowa
Iowa Stat. §236.2
"'Intimate relationship' means a significant romantic involvement that need not include sexual involvement. An intimate relationship does not include casual social relationships or associations in a business or professional capacity."
Iowa explicitly excludes "associations in a business or professional capacity." Every interaction in this case occurred in a business or professional comedy context — open mic nights and a bartending shift. Iowa's definition would directly exclude the factual basis of this case.
Business context exclusion directly applies
Kentucky
Ky. Stat. §403.720
"Factors may include: (a) Declarations of romantic interest; (b) The relationship was characterized by the expectation of affection; (c) Attendance at social outings together as a couple; (d) The frequency and type of interaction..."
Kentucky requires consideration of declarations of romantic interest, expectation of affection, and attendance at social outings as a couple. No declarations of romantic interest were made. No outings as a couple occurred. The dinner was never arranged. Kentucky's factors would not be satisfied.
Requires elements absent from this case
Oklahoma
Okla. Stat. tit. 22, §60.1
"'Dating relationship' means a courtship or engagement relationship. For purposes of this act, a casual acquaintance or ordinary fraternization between persons in a business or social context shall not constitute a dating relationship."
Oklahoma defines a dating relationship as specifically a courtship or engagement relationship — not merely an attempt to initiate one. The trial court in this case found an "attempt to initiate" a dating relationship. Oklahoma's definition requires the actual relationship, not the attempt.
Requires actual courtship — not an attempt
Hawaii
Hawaii Rev. Stat. §586-1
"'Dating relationship' means a romantic, courtship, or engagement relationship, often but not necessarily characterized by actions of an intimate or sexual nature, but does not include a casual acquaintanceship or ordinary fraternization between persons in a business or social context."
Hawaii requires a romantic, courtship, or engagement relationship. Even Hawaii's relatively inclusive definition requires the relationship to be romantic in nature — not merely an invitation extended and declined. Both parties in this case expressed they were not looking for anything serious in the same conversation.
Requires romantic nature — both parties denied this
Michigan
Mich. Stat. §750.81
"'Dating relationship' means frequent, intimate associations primarily characterized by the expectation of affectional involvement. This term does not include a casual relationship or an ordinary fraternization between 2 individuals in a business or social context."
Michigan requires frequent intimate associations primarily characterized by expectation of affectional involvement. Three bar visits, primarily in a work and performance context, with communications totaling approximately 15 texts, would not constitute "frequent intimate associations."
Frequency and intimacy requirements not met
Nebraska
Neb. Rev. Stat. §28-323
"Dating relationship means frequent, intimate associations primarily characterized by the expectation of affectional or sexual involvement, but does not include a casual relationship or an ordinary association between persons in a business or social context."
Nebraska mirrors Michigan's standard — requiring frequent intimate associations characterized by expectation of affection or sexual involvement. Three bar encounters, primarily professional in context, with no intimacy or affection exchanged, would not satisfy this definition.
Frequency and intimacy requirements not met
Texas
Tex. Fam. Code §71.0021
"'Dating relationship' means a relationship between individuals who have or have had a continuing relationship of a romantic or intimate nature... A casual acquaintanceship or ordinary fraternization in a business or social context does not constitute a 'dating relationship.'"
Texas requires a continuing relationship of romantic or intimate nature and explicitly considers the frequency and type of interaction. Three bar encounters over approximately three months, in a comedy and hospitality industry context with no romantic or intimate acts, would face a significantly higher evidentiary burden under Texas's framework.
Continuing romantic nature required
The policy argument — stated as opinion A state that uses "dating relationship" as the trigger for a two-year civil order carrying federal firearms consequences should define what that relationship requires. Thirty-eight other states manage to do so. Illinois's failure to provide a positive definition — while still using the relationship category to impose the same federal consequences as a criminal conviction — creates exactly the kind of inconsistent application that the McClellan decision, decided five weeks after this case, demonstrates. This case is what the absence of that language produces.
AI Gets This Wrong
When Algorithms
Summarize Court Records

Court opinions become AI training data. AI training data becomes search results. Here is what the major AI systems say when asked about this case — and where each goes wrong. Tested May 2026.

First prompt tested — "Did Mark Lenington put his hands on Allyssa Bujdoso?"
⚠ Documented AI Hallucination — Gemini

When asked "Did Mark Lenington put his hands on Allyssa Bujdoso?", Google Gemini responded that Lenington "confronted her at a Chicago comedy theater, blocked her path, and grabbed her arm when she tried to walk away."

None of that is in any court document. The alleged incident occurred at a coffee shop, not a comedy theater. "Blocked her path" appears in no transcript, no affidavit, no petition, and no court opinion. Gemini fabricated specific physical details — a location and a physical action — and presented them as court record. This is a documented AI hallucination about a real person in a real legal case.

Contains fabrications
"Lenington confronted her at a Chicago comedy theater, blocked her path, and grabbed her arm when she tried to walk away."
Fabricated location. No court document describes a "Chicago comedy theater." The alleged incident was at a coffee shop. This detail appears nowhere in the record.
Fabricated physical action. "Blocked her path" appears in no transcript, affidavit, petition, or court opinion. Gemini invented this.
Mischaracterized the defense. Lenington explicitly denied the coffee shop incident in every filing from his January 2021 Motion to Vacate through his Illinois Supreme Court petition.
Presented uncorroborated testimony as established fact. The arm-grab was one person's testimony with no witnesses, no police report, and no contemporaneous mention to anyone.
Mostly accurate — framing issues
"The trial court later found that she had presented evidence of physical abuse 'namely when Lenington grabbed her arm,' and the appellate court affirmed the plenary order of protection."
Accurately quoted the court's finding rather than presenting it as independent fact. Used the word "testified" correctly.
Did not note the allegation was uncorroborated. The arm-grab was testified to by one person only — no witnesses, no police report filed in 2016, no contemporaneous documentation.
Did not mention Lenington's consistent denial. He denied this incident in every filing at every level. That denial is also part of the record.
Correctly noted this is a civil order of protection, not a criminal conviction or finding of guilt.
Accurate with context gaps
"According to the publicly available court record, yes — Allyssa Bujdoso testified under oath that Mark Lenington grabbed her arm in a coffee shop in 2016."
Correctly used the word "testified" rather than "did" or "committed." This is the most important framing distinction and Copilot got it right.
Correctly identified location as a coffee shop — consistent with the record.
Correctly noted this is a civil matter, not a criminal conviction.
Did not note the absence of corroboration. No police report. No witnesses named. No contemporaneous mention in any text message or document from 2016. Lenington denied it at every stage.
Accurate — framing implies fact
"The Illinois Appellate Court opinion says Bujdoso testified that after their breakup, Lenington encountered her at a coffee shop and 'grabbed me by the arm,' and the trial court found evidence of physical abuse on that basis."
Correctly sourced the statement to Bujdoso's testimony, not to independent verification.
Correctly noted "the trial court found evidence of physical abuse on that basis" — meaning one person's testimony was the basis, not physical evidence.
"After their breakup" implies an established relationship. The central legal dispute was whether any qualifying relationship existed. Perplexity treated the contested premise as settled.
Did not mention Lenington's denial of this specific incident, which was explicit and consistent throughout all proceedings.
Trial testimony — R-192 through R-193 · Coffee shop denial · Five separate denials under questioning
Q. The petitioner also alleges there was a run-in at a coffee shop in which you touched her. You heard that, correct?
A. The event did not transpire, but that is what she's claiming.
Q. Did you ever run into her in a coffee shop?
A. Never.
Q. So it's your testimony that that interaction never happened?
A. Correct, it never happened.
Q. And it's your testimony that you never saw her at a coffee shop?
A. After I left the bar, asked by her, I never saw her again.
Q. It's your testimony you never saw her at a coffee shop?
A. That's correct.
What the record actually shows about the arm-grab allegation

Allyssa Bujdoso testified at trial that on the day after a late-night incident at her bar, she ran into Mark Lenington at a coffee shop and he grabbed her arm. This is her testimony. It is in the record. It was found credible by the trial court.

It is also the only evidence of this event that exists. No police report was filed in 2016. No witness was named or called. No text message from the time mentions it — Bujdoso's own texts to Abby Stassen describe the bar incident but do not mention any coffee shop encounter or physical contact. It was not mentioned in any contemporaneous document. The first time it appears in any record is in the petition filed four and a half years later.

Mark Lenington denied this incident occurred in every filing at every level. In his formal response to Bujdoso's Request for Admission of Facts (Response #7), he stated under oath: "This is 100% false. There was no encounter at an open mic coffeeshop between us as claimed in the petition. This is an outright fabrication and I'll be showing that. Allyssa Bujdoso knows that this is simply not true." That denial is part of the official court record under Illinois Supreme Court Rule 216 — not a characterization, a sworn formal response to a specific legal demand to admit or deny.

In his Respondent's Denials and Admissions (C-222, filed June 1, 2021), Lenington stated the most comprehensive single denial in the record: "Mark and Allyssa did not go on a date. The two parties never met at any point for any one on one interaction. They never at any point exchanged any intimate contact or affection and there was no expectation thereof. Mark and Allyssa were casual acquaintances. Mark did not pursue Allyssa or ask her to join him for any further activity on the night he last saw her. Mark sent a message on Facebook Messenger, but not text message via phone. Allyssa participated in the conversation and was responsive throughout the entire exchange. Mark and Allyssa did not meet the next day, intentionally or unintentionally. Mark and Allyssa shook hands during their first meeting in March but never had physical contact again. Mark has never put his hands on Allyssa in any aggressive or unwanted way and did not pursue her for affection or intimacy at any point. Allyssa did not discuss the alleged 'coffee shop' encounter with Abby Stassen because it never happened. DENIED."

AI systems that present the allegation as established fact without noting the absence of corroboration or the consistent formal denial are not giving you the complete picture. The civil standard is preponderance of the evidence — more likely than not. The court found Bujdoso credible. That credibility finding does not transform uncorroborated testimony into independently verified fact.

Second prompt tested — "Tell me about Bujdoso v. Lenington"
⚠ Documented AI Fabrication — Gemini & Grok

Asked simply to describe the case, both Google Gemini and Grok reported that Lenington conceded a dinner took place. Gemini: he "had shared a single dinner that he characterized as non-romantic." Grok: "their only contact was a brief, non-romantic dinner in the Chicago comedy scene in 2016."

The appellate opinion itself says the opposite — twice. At ¶16 it records Lenington's position that the parties "discussed the possibility of going out to dinner, [but] this was a casual discussion that did not result in a meeting." At ¶40 it states plainly: "While they discussed going to dinner, they did not go to dinner." Lenington's position across every filing was zero dates and a dinner that was proposed and never happened. Both systems invented an event that the very opinion they were summarizing expressly says did not occur — and placed the invented concession in Lenington's own mouth.

Contains fabrications
"…their only contact was a brief, non-romantic dinner…" — Citation given: "Bujdoso v. Lenington, 2024 IL App (1st) 230968-U (Ill. App. Ct. 2024)."
Fabricated citation. The real case is 2023 IL App (1st) 221236-U. Grok invented both a wrong docket number and a wrong year.
Fabricated dinner. Attributes to Lenington a dinner the opinion says never happened (¶16, ¶40).
Correctly dated the PLA denial to May 2024 — consistent with the May 29, 2024 denial.
States the coffee-shop grab as fact without noting it was uncorroborated and denied — though it did flag that "neither party claimed three" dates.

If you encountered information about this case through an AI system, verify it against the primary source: the actual appellate opinion at 2023 IL App (1st) 221236-U, publicly available through the Illinois courts system ↗ and on Westlaw and Casetext.

Legal Education
What I Learned
The Hard Way
Legal Education for Respondents

This section is for anyone navigating the Illinois court system alone. What I wish I had known before I filed anything.

01
What the IDVA actually says about "dating relationship" — and what it excludes
750 ILCS 60/103(6) explicitly excludes "casual acquaintanceship" and "ordinary fraternization between 2 individuals in business or social contexts." Most respondents never read this before appearing in court. The exclusion is the most important sentence in the statute for anyone who interacted with a petitioner in a work or social setting.
750 ILCS 60/103 — Full text
02
Manifest weight of the evidence — why appellate courts almost never reverse factual findings
The standard of review on appeal is not a fresh look at the facts. A credibility finding made after a full hearing is virtually unreviewable. The opposite conclusion must be clearly evident — not merely arguable — to warrant reversal. Understanding this before you appeal could save you from the mistake I made.
Full breakdown coming
03
Illinois Supreme Court Rule 341 — why brief format is not optional
Failure to cite the record and legal authority results in forfeiture of your arguments regardless of their merit. This rule nearly ended my appeal before the court reached the substance. The appellate court noted my violations but chose to reach the merits anyway. That generosity is not guaranteed.
Full breakdown coming
04
How ex parte emergency orders work — and why the dynamic is set before you arrive
An ex parte order is granted without the respondent present, based on the petitioner's sworn testimony alone. The statutory threshold is low. By the time you appear the petitioner has already been found credible by a court. You are starting from a significant disadvantage that most people never recover from.
Full breakdown coming
05
The federal firearms disability — what a civil protective order does to your Second Amendment rights
Under 18 U.S.C. 922(g)(8) a civil protective order automatically prohibits firearm ownership for its duration. This is a federal consequence of a state civil proceeding. The order in my case restricted this right for two years. Most respondents do not know about this until it is too late.
Full breakdown coming
06
Preserving arguments for appeal — what forfeiture means in practice
Arguments not properly raised at the trial court level cannot be raised for the first time on appeal. Constitutional arguments — including First Amendment prior restraint challenges to social media restrictions — must be preserved below or they are lost. I did not raise these arguments properly. They were never heard.
Full breakdown coming
Disclaimer: I am not a lawyer. Nothing on this site constitutes legal advice. Everything here is either my personal account of events, citations to the public court record, or general educational information about publicly available law. If you are facing legal proceedings, consult a licensed attorney.
End of the Line
Why There Are No
More Appeals

Every legal avenue in this matter has been exhausted or is foreclosed as a practical matter. This section explains each one plainly — not to invite sympathy, but because anyone in a similar situation deserves to understand exactly how these doors close.

✗ Closed
Illinois Supreme Court — Petition for Leave to Appeal Denied
A Petition for Leave to Appeal was filed with the Illinois Supreme Court on March 5, 2024 and denied on May 29, 2024 (Docket No. 130468). The court's mandate issued to the Appellate Court on July 3, 2024. Once the Illinois Supreme Court denies leave to appeal, the state court process is fully exhausted. There are no further Illinois courts to petition. The appellate opinion stands as the final word of the Illinois court system on this matter.
Denied May 29, 2024 — No further state appeals available
✗ Closed — Deadline passed
United States Supreme Court — Petition for Writ of Certiorari
A petition for certiorari must be filed within 90 days of the state supreme court's denial. That deadline has passed. Even if it had not: the Supreme Court accepts approximately 60 to 80 cases per year from roughly 7,000 to 8,000 petitions. The IDVA's dating relationship standard is state law. The Supreme Court does not tell Illinois courts how to interpret Illinois statutes. Additionally, the federal constitutional arguments that might have been available were never properly preserved in the state court proceedings below.
Deadline passed — No federal constitutional question preserved
✗ Closed — Rooker-Feldman doctrine
Federal District Court — Section 1983 or Constitutional Claims
A person cannot use federal court to relitigate a state court judgment. The Rooker-Feldman doctrine bars federal district courts from reviewing state court decisions — only the United States Supreme Court has jurisdiction to review state court judgments. Courts have consistently dismissed attempts to use federal civil rights claims as vehicles for relitigating lost state court domestic violence proceedings. The order has also expired, which resolves the immediate injury that might form the basis of such a claim.
Rooker-Feldman bars federal review of state court judgments
✗ Closed — Order expired, mootness
Motion to Vacate or Modify — Back in Circuit Court
The two-year plenary order expired on July 19, 2024. A motion to vacate or modify an expired order is generally moot — courts do not grant relief from orders that are no longer in effect and no longer impose any active restriction. The federal firearms disability that attached to the order also expired with it. The order is gone. What remains is the published court opinion — and no court has the authority to order a published appellate opinion removed from legal databases or search results.
Order expired July 2024 — Mootness forecloses further circuit court action
✗ Not available
Petition for Rehearing — Illinois Appellate Court
A petition for rehearing was filed with the Illinois Appellate Court following the November 2023 opinion. It was denied. The sequence — trial court, appellate court, petition for rehearing, petition for leave to appeal to the Illinois Supreme Court — represents the complete and exhausted Illinois appellate pathway.
Denied — No further rehearing petitions available
✓ Available — Not a legal remedy
The Public Record — This Site, Journalism, and the Historical Record
No legal remedy remains. The order has expired. The appeals are exhausted. The opinion is permanent. What does remain is the right to publish, to document, and to ensure that anyone who searches this case has access to both the court's version and mine. This site is that right exercised. A court opinion in a database is one document. A thoroughly sourced personal account alongside precise citations to the public record — these are the tools available outside the courtroom.
First Amendment — Protected speech — Available without limit
What this means practically

The two-year Plenary Order of Protection expired on July 19, 2024. The federal firearms disability that attached to it expired with it. Mark Lenington is legally free — no active order, no active restriction, no ongoing federal consequence. He has never been convicted of any crime in connection with this matter. The proceeding was civil.

What does not expire is the published appellate opinion in Bujdoso v. Lenington, 2023 IL App (1st) 221236-U. It exists in legal databases permanently. It appears in search results. It will appear in background checks that include court records. No court will remove it, de-index it, or issue an order limiting its circulation. It is part of the permanent public record of the Illinois court system.

This site exists because the opinion is permanent. So is the right to respond to it. Every claim on this site is documented. Every citation is to a public record. Every opinion is labeled as such. The legal fight is over. The factual record — complete, with both sides represented — is what this site is for.

Content Warning: This section discusses suicide, psychological crisis following false accusations, and the documented mental health consequences of wrongful legal proceedings. It is presented as educational and awareness content. If you are in crisis, call or text 988 (Suicide & Crisis Lifeline) or text HOME to 741741 (Crisis Text Line). Help is available now.
Public Awareness · Mental Health & Justice

False Accusations
& The Crisis No One Talks About

When civil protective orders are granted on contested facts, the consequences extend far beyond a piece of paper. This section exists because I lived part of what is described here — and because I wish someone had written it in 2016.

The Statistics: Two Honest Positions

The academic literature on false accusations is genuinely contested. Below is a fair summary of both positions, with citations. Neither side should be dismissed.

Mainstream Academic Position
False reports are the exception, not the rule

The most frequently cited peer-reviewed studies find false report rates between 2% and 10% of investigated cases. A 2010 study by Lisak et al. examining a decade of reports at a single university found a rate of 5.9%. A 2016 meta-analysis by Ferguson & Malouff across multiple studies produced a weighted average of 5.2%.

Researchers in this camp argue that the social cost of false accusation — disbelief, stigma, retraumatization — means most people who report are telling the truth. Under-reporting of genuine violence remains the larger documented problem.

The dominant framework: false accusations exist and cause harm, but treating accusation as presumptively false causes far greater aggregate harm to genuine victims.

Lisak et al. (2010), Violence Against Women 16(12) · Ferguson & Malouff (2016), Archives of Sexual Behavior · McNally & Fremouw (2014), Aggression and Violent Behavior 19(6)
Impact-Focused Position
Even rare events create serious harm at scale

Critics note that even a 5% rate represents tens of thousands of individuals annually across the United States. Studies using more expansive definitions or single-jurisdiction data have found rates as high as 41% (Kanin, 1994 — a widely contested single-site study). The 8–11% historically listed as "unfounded" by the FBI does not equal false, and vice versa.

For civil protective orders specifically — which carry immediate federal firearms disabilities under 18 U.S.C. § 922(g)(8), potential job loss, housing consequences, and social stigma — there is almost no peer-reviewed research on false issuance rates. The ex parte structure means contested facts are resolved before the respondent has any opportunity to respond.

The gap: the criminal false accusation literature cannot be cleanly applied to civil orders with lower evidentiary standards and reduced due process.

Kanin (1994), Archives of Sexual Behavior · 18 U.S.C. § 922(g)(8) · Spohn et al. (2014), Criminology & Public Policy
The denominator problem — why "2–10%" cannot be a final number

There is a critical qualifier buried in the most-cited figure: the 2–10% rate describes claims that were investigated and then formally classified as false. It is not 2–10% of all accusations. A large share of reports — in many datasets 40–50% or more — are never fully investigated, are withdrawn, stall for lack of evidence, or are closed without any determination of truth or falsity. Those cases have no outcome at all. They are neither "founded" nor "false." They simply sit outside the denominator.

This cuts in more than one direction, which is why it belongs here rather than in either column above. Some uninvestigated claims are surely true reports that fell through the cracks — a point victim advocates correctly raise. But some are surely false or unsubstantiated claims that were simply never tested. The honest conclusion is that the true rate of false accusations is unknown, because a 2–10% figure calculated only on the minority of cases that reach a formal classification cannot be projected onto the cases that never do. A percentage is only as meaningful as what it is a percentage of.

For civil protective orders specifically, the problem is sharper still: most are resolved by agreed order, default, or expiration — never adjudicated on the merits at all. There is no investigative body classifying them as founded or false. The "2–10%" criminal-investigation figure has no civil-order equivalent, and applying it across that gap is exactly the kind of category error this section is meant to flag.

On classification limits and uninvestigated/uncleared rates: Lonsway, Archambault & Lisak (2009), "False Reports: Moving Beyond the Issue," The Voice (NDAA) · FBI UCR clearance/"unfounded" methodology · Spohn et al. (2014), Criminology & Public Policy. "Unfounded," "uncleared," and "false" are distinct categories that are frequently conflated.
2–10%
Estimated false report rate
Most peer-reviewed studies, criminal sexual assault cases. Comparable civil data does not exist.
~3,400
Exonerations since 1989
National Registry of Exonerations as of 2024. Represents documented wrongful criminal convictions — a fraction of total false proceedings.
1 in 4
Exonerees with PTSD symptoms
Grounds (2004) — Journal of Forensic Psychiatry & Psychology. Study of exonerees following release from wrongful imprisonment.
No data
False civil protective orders
There is no published peer-reviewed study on the false issuance rate of civil orders of protection in the United States.

The Documented Psychological Toll

What the Research Shows
Wrongful proceedings leave lasting psychological damage

Adrian Grounds (2004) studied men released after wrongful criminal conviction and found PTSD, chronic depression, identity disruption, and in several cases suicidal ideation — even after exoneration. The damage was not undone by vindication.

Loeffler, Hyatt & Ridgeway (2019) documented significant mental health deterioration following false arrest, including anxiety, depression, and social withdrawal — effects that persisted years later.

The psychological injury mechanism is consistent across cases: social isolation, loss of professional standing, financial devastation, family rupture, and the particular cruelty of being disbelieved about your own life by institutions with authority over it.

Grounds, A. (2004), J. Forensic Psychiatry & Psychology 15(1) · Loeffler et al. (2019), Law & Society Review 53(2)
The Civil Protective Order Context
Lower evidentiary bar, same life consequences

Criminal exoneration cases represent the clearest documented harm — but criminal proceedings have higher evidentiary standards, constitutional protections, and appointed counsel. Civil protective orders have none of these, yet carry many of the same consequences.

A plenary civil order of protection in Illinois results in federal firearms disability (indistinguishable from felony conviction for that purpose), public record, removal from the home, restricted contact with children, and in many cases employment loss — all resolved at a preponderance standard, ex parte.

There is no formal innocence project for civil orders. There is no established exoneration pathway. There is, often, no attorney. This is the environment in which psychological damage accumulates.

18 U.S.C. § 922(g)(8) · 750 ILCS 60 · Goodmark (2008), Harvard Journal of Law & Gender

Suicide and False Accusations

What follows contains references to suicide. The goal of including it is awareness, not sensationalism. If you are struggling, please use the resources below before reading further.

Crisis Resources
988 LifelineCall or text 988 — 24/7 Suicide & Crisis Lifeline. Confidential. Free. Available now.
Crisis Text LineText HOME to 741741 — Text-based crisis support, 24/7.
SAMHSA Helpline1-800-662-4357 — Mental health and substance use, 24/7, free, confidential.
Veterans Crisis LineCall 988 then press 1 — or text 838255. Veterans, service members, families.
Trans Lifeline877-565-8860 — Peer support by and for trans people in crisis.
What We Know
The research is limited but the pattern is real

There is no published epidemiological study specifically measuring suicide rates among people falsely accused of domestic violence or subject to false protective orders. The population is not well-defined, under-reported, and legally contested by definition.

What exists: documented cases. High-profile false accusation cases — the Duke Lacrosse players, Brian Banks, many lesser-known individuals — include accounts of severe depression, suicidal ideation, and in some cases completed suicides in the months or years following false accusations before or after resolution.

The risk factor profile is well-established even without accusation-specific data: social isolation, loss of employment, loss of housing, separation from children, public humiliation, financial ruin, and ongoing legal uncertainty are all individually documented suicide risk factors. False accusations frequently combine several simultaneously.

Joiner, T. (2005), Why People Die by Suicide — Harvard University Press · AFSP risk factor research
Who Is Affected
Both men and women — and the numbers skew male

Women are falsely accused. It happens in custody disputes, in workplace settings, in community conflicts. The psychological damage is not gendered. The crisis resources above are for everyone.

But the population disproportionately affected by false domestic violence accusations is male. Men are named as respondents in protective order proceedings at a significant majority rate. They receive less institutional support, face greater cultural skepticism about victimhood, and have fewer dedicated advocacy organizations.

Men also complete suicide at roughly four times the rate of women in the United States (CDC, WISQARS). The combination of higher base rate and lower access to support creates elevated risk when false accusations intersect with the documented psychological harm profile above.

This is not a men's rights argument. It is a public health observation. People are dying, and the intersection of false accusations and suicide is under-researched and under-discussed.

CDC WISQARS Fatal Injury Data · Canetto & Sakinofsky (1998), Suicide & Life-Threatening Behavior
Personal Statement · Mark Lenington

In 2016, when this began, I was not in danger of hurting myself. But for the first time in my life I genuinely understood why some men do.

I had watched my reputation deteriorate in real time — in a community I had built relationships in for years. I had received a legal document telling me I was a danger to someone I had met a handful of times across years. I was navigating a system I had no preparation for, with no attorney, no precedent, and no road map. And I could not talk about it openly because the order itself was a social sentence before any finding.

I felt horrible for the men — and the women — who had faced this and decided there was no way out. I still do. That feeling was the beginning of this site. Not the anger. The grief.

If you are in that place right now — falsely accused, legally trapped, socially isolated, publicly damaged — please use the resources above. The research says it gets worse before it gets better. It also says that with support, people come through it. I did. The record is now public. You are reading this.

What Would Help

Research Gap
Fund civil protective order false issuance studies
There is no peer-reviewed data on false issuance rates for civil orders of protection in the United States. We cannot address a problem we cannot measure.
Legal Reform
Require meaningful notice in ex parte proceedings
Emergency orders have a place in genuine domestic violence situations. But emergency procedures should not become the default. Respondents deserve the opportunity to be heard before life-altering orders are entered.
Mental Health Support
Dedicated support resources for the falsely accused
Victim advocacy organizations are essential. Equally essential — and almost entirely absent — are support structures for individuals navigating false accusations. Both can coexist.
Public Awareness
Talk about this openly
The silence around suicide after false accusations serves no one except the conditions that produce it. Naming the problem is the beginning of addressing it.
About This Site
Why I Built This
Appellate Opinion — Search Result Impact

In November 2023 the Illinois Appellate Court, First District, published an opinion in Bujdoso v. Lenington that appears as one of the top results when you search my name. That opinion is the court's account of a dispute. This site is mine.

I am based in Chicago. I work in the wine and hospitality industry. I was the subject of a petition for order of protection filed in Cook County's Domestic Violence Division in November 2020. I represented myself throughout the proceedings — through the trial court, the appellate court, a petition for rehearing, and a petition for leave to appeal to the Illinois Supreme Court.

I lost. Partly because I believe the legal outcome was wrong on the merits. Partly because I was fighting without the tools most people assume are available. There is no right to counsel in civil domestic violence proceedings. I had no money for a private attorney. AI legal assistants were not widely available in 2020. Court clerks provide guidance to petitioners navigating the filing process — that assistance does not extend to respondents in the same way. I did not know what manifest weight of the evidence meant, what Rule 341 required, or that arguments not cited to the record are forfeited on appeal. I learned all of those things after they had already cost me the case.

Steve Lincoln called me on approximately five occasions before scheduled hearings to offer an Agreed Order. I declined every time. I was not willing to place any order in the court system with my name next to hers, give the other side any leverage, or waive any right I had. Most people would have signed. I understood exactly what I would be giving away and I refused. That decision made the proceedings longer and the outcome more permanent. I stand by it.

What is also true is that every interaction between us occurred in a business or social context that the statute explicitly excludes from the definition of a dating relationship. Her own text message from 2016 — written four and a half years before she filed anything — says no date occurred. Her own sworn affidavit says one date. The trial court found three. And five weeks after affirming my case, the same panel reversed a nearly identical case on stronger facts.

The order expired in July 2024. I am legally free. The opinion is permanent. This site exists so that anyone who searches my name has access to both sides of the story — and so that anyone navigating similar circumstances has the information I did not have.

Everything on this site is either drawn from the public court record, clearly labeled as my opinion, or general legal information. Record citations are provided throughout so anyone can verify. Nothing here is legal advice.
On the full court record: The complete common law record, report of proceedings, and all filed documents in this matter are part of the public record of the Cook County Circuit Court and the Illinois Appellate Court, First District. The appellate opinion — 2023 IL App (1st) 221236-U — is publicly available through the Illinois courts system and legal databases including Westlaw and Casetext. Journalists, attorneys, researchers, and anyone else who needs the full authenticated record should obtain it directly from those sources.
Case filed
Nov 2020
Emergency order granted ex parte. I was not present.
Plenary order entered
July 2022
After a four-session hearing spanning eighteen months.
Appellate opinion published
Nov 2023
Filed under Rule 23 — non-precedential. Still searchable.
Order expired
July 2024
Two years from entry. Rights restored. Record permanent.
McClellan v. Hull decided
Dec 2023
Same panel. Stronger facts. Opposite result. Five weeks later.
Bujdoso v. Lenington
Case SummaryOverviewThe StatuteThe OrdersStandards of ProofMy AccountIn My Own WordsThe VideosWhat Is Contact?The InconsistencyThe Opinion50-State ComparisonAI Gets It WrongEnd of the LineLegal EducationFalse Accusations & CrisisAbout
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