NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION Jerome A. Pintaro Plaintiff v. Case No. 23-cv-02008 Gerald Granada, Catherine M. Levine, Evelyn Martinez, Nicholas Taylor, Dr. Bryan J. Cole, Dr. Richard B. Foulkes Judge: Thomas M. Durkin PLAINITFF JEROME PINTARO'S REPLY TO ATTORNEY DEFENDANT CATHERINE M. LEVINE'S REPLY IN SUPPORT OF HER MOTION TO DISMISS BACKGROUND UNCONTROVERTIBLE FACT #1 DEFENDANT CATHERINE M. LEVINE, ALLEGED PARTNER IN THE LAW FIRM OF WEIDNER & McAULLIFE HAS BEEN REMOVED AS DEFENSE ATTORNEY FOR PACE SYSTEMS, INC., IWCC WORKER'S COMPENSATION CLAIM CASE NO. 18wc032482; JEROME A. PINTARO, PLAINITIFF, v. PACE SYSTEMS, INC., DEFENDANT, DAVID L. GORE, WEIDNER & McAULIFFE, HAS ALLEGEDLY REPLACED ATTORNEY CATHERINE M. LEVINE ALTHOUGH IWCC COMPFILE INDICATES NO MOTION OR ACTION FOR SUBSTITUTION OF ATTORNEY WAS OFFICIALLY FILED TO COMPFILE AND NO ACTION WAS TAKEN BY ARBITRATOR GERALD GRANADA UNCONTROVERTIBLE FACT #2 OVER THE PAST FIVE YEARS, NO MEDICAL TEST OR PRECEDURES WERE ALLOWED OR COMPLETED ON PLAINTIFF JEROME PINTARO WITH THE EXCEPTION OF THE INTENTIONAL SABOTAGE OF PLAINTIFF JEROME PINTARO'S RIGHT ARM ROTATOR CUFF REPAIR SURGERY COMPLETED BY DR. BRIAN J. COLE, MIDWEST ORTHOPAEDICS, AT RUSH UNIVERSITY MEDICAL CENTER, THE ILLINOIS WORKER'S COMPENSATION WEBSITE DOCKET, 'LEGACY' PRIOR TO 2021 AND 'COMPFILE' AFTER 2021, CLEARLY REVEALS THAT THIS CONSPIRACY BY DUPAGE COUNTY GOVERNMENT, ATTORNEY CATHERINE M. LEVINE, AND IWCC ARBITRATOR GERALD GRANADA, INTENTIONALLY WITHHELD ALL MEDICAL TREATMENT FROM PLAINTIFF JEROME PINTARO, WHO AT THE TIME WAS REPRESENTED BY THE LAW FIRM OF HORWITZ, HORWITZ, & ASSOCIATES, NEVER FILING A SINGLE MOTION, CAPRON, AVGERINOS, & HEINLEN, FILING A SINGLE MOTION THAT WAS HEARD BY ARBITRATOR GRANADA, A SUBSITITUTION OF ATTORNEY WHEN PLAINTIFF JEROME
STRATEGICALLY AND INTENTIONALLY FAILING TO REPRESENT PLAINTIFF JEROME PINTARO'S INJURY, WORKER'S COMPENSATION CLAIM, AND MEDICAL INTERESTS, NEVER HAVING RECEIVED ANY BENEFITS FROM THE DATE OF THE INJURY, PLAINITFF JEROME PINTARO HAVING TO WAIT THREE YEARS TO RECEIVE A SINGLE FOLLOW UP MRI TO DIAGNOSE THE LOSS OF THE USE OF PLAINTIFF JEROME PINTARO RIGHT ARM AFTER THE SABOTAGED SURGERY PERFORMED BY DR. BRIAN J. COLE, MIDWEST ORTHOPAEDICS, AT RUSH UNIVERSITY MEDICAL CENTER AND THE TEAM PHYSICIAN FOR THE WHITE SOX MB Defendant attorney Catherine M. Levine presents no relevant basis pursuant to any matter of law for her reply in support of her motion to dismiss, but instead argues citing conclusory conclusions, assertions, and opinions for which defendant Levine offers no supporting evidence. For 'want of any defense' defendant Levine's 12(b)(6) motion to dismiss aimlessly consumes fifteen lines of irrelevant dialgue in the first two paragraphs 1, and 2, where defendant Levine attemps to describe what she believes to be plaintiff Pintaro's 'irrational nonsense,' accusing plaintiff Pintaro of being a 'serial filer', and 'professional litigant.' Defendant Levine then proceeds in paragraph 3 in an attempt to regain her dubious mission to defend herself against plaintiffs claims, unsurprisingly not for deprivation of plaintiff Pintaro's civil rights under plaintiff's Section 1983 claim, but rather on the basis of defendant Levine's 'absolute litigation privilege,' between defendant Levine as defense counsel, (a representatin which she has been removed from) and Pace Systems,Inc. and Nicholas Taylor, as her clients; "Plaintiff’s alleged claims against Levine should be dismissed with prejudice because as explained in Levine’s motion to dismiss (Dkt. #35, pp. 3-8), plaintiff’s claims are precluded by the attorney absolute litigation privilege because plaintiff’s allegations describe nothing more than counsel (Levine) representing her client (Pace) in the underlying workers compensation litigation" .....taken completely out of context, making absolutetly no sense, a particular unit of writing isolated with a complete and total disregard of the universal pursuit of plaintiff Pintaro's Section 1983 complaint for deprivation of rights, the central claim of what plaintiff Pintaro's response to defendant Levine's motion to dismiss purports, namely that defendant, attorney Catherine M. Levine is party to a conspiracy to deprive plaintiff Jerome Pintaro of his civil rights, and that attorney Catherine M. Levine acted in the capacity of a government 'actor' who was solicited to engage in a criminal undertaking.
from which they arise Defendant Levine attemps to intentionally abandon any reply to plaintiff's claims under 42 U.S.C. SECTION 1983 by citing unrelated, conclusory assertions, and opinions, beyond and "out of bounds" of the jurisdiction of plaintiff Pintaro's Section 1983 claim, an obvious attempt to deflect from the germane issues of law relative to plaintiff Pintaro's 42 U.S.C. SECTION 1983 claims, by litigating inappropriate matters and citing case precedence for issues which are totally irrelevant to plaintiff Pintaro's SECTION 1983 claims, citing case precedence for 'out of bounds' allegations to subject matter being or occurring beyond the designated issues, having nothing to do with the matter at hand, namely, attorney Levine's conduct pursuant to the violations of the civil rights of plaintiff Pintaro, conduct by defendant Levine which denied plaintiff Pintaro of rights, privileges, and immunities guaranteed him by the U.S. Constitution, and laws of the United States. Defendants allegations are 'out of bounds' deflective, disruptive, and totally inappropriate, and therefore not entitled to be assumed as a relevant argument of the matter at hand. To satisfy the standard under Twombly and Iqbal, “a complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.'” Id. (citing Twombly, 550 U.S. at 570). A claim has facial plausibility when the plaintiff pleads enough factual content that allows the court to draw the reasonable inference that the defendant is liable under the alleged claim. Id. (citing Twombly, 550 U.S. at 556). While a court confronted with a Rule 12(b)(6) motion must accept the truth of all factual allegations in the complaint and must draw all reasonable inferences in favor of the non-movant, Gross v. German Found Indus. Initiative, 549 F.3d 605, 610 (3d Cir. 2008), legal conclusions receive no such consideration, and the court is “not bound to accept as true a legal conclusion expressed as a factual allegation.” Papasan v. Allain,
plaintiff may use legal conclusions to provide the structure for the complaint, the pleading’s factual content must independently “permit the court to infer more than the mere possibility of misconduct.” Iqbal, 129 S.Ct. at 1950. In short, when the well pleaded complaint does not permit the court “to infer more than the mere possibility of misconduct,” the pleader is not entitled to relief. Fowler v. UPMC Shadyside, 578 F.3d 203, 2011 (3d Cir. 2009)(quoting Iqbal, 129 S.Ct. at 1949). Defendant attorney Catherine M. Levine is a 'self-proclaimed' government 'actor' as defined in U.S. Constitutional law. Catherine M. Levine is party to a DuPage County government sponsored conspiracy pursuant to the illegal, extortionate pursuits of Peter C. Powers and Rosemary Powers, solicited by DuPage County government officials, elected, appointed, and employed, and other government 'actors' also solicited and party to this conspiracy, to assist in the interference of plaintiff Pintaro's civil rights by weaponizing medical treatment, weaponizing DuPage County Government, DuPage County judges, the DuPage County 18th Judicial Circuit Court Clerk's office, DuPage County State's Attorney's office, DuPage County Sheriff's office, the DuPage County Recorder of Deeds, the DuPage County Treasurer and Tax collector, and the DuPage County Clerk. The conduct under this conspiracy has occurred and continues to occur under 'color of law' and this conduct has and continues to deprive plaintiff Jerome Pintaro of rights, privileges, and immunities guaranteed under the U.S. Constitution and laws of the United States. This conspiracy has maliciously violated plaintiff Jerome Pintaro's civil rights with the filings of numerous fraudulent complaints, both civil and criminal. The two primary fraudulent complaints filed were 2018L001177; plaintiff Powers, et al. v. defendant Pintaro, et al., and 2020CH000378; plaintiff CSMC 2018-SP3 TRUST v. defendants Jerome A. Pintaro and Marilyn Pintaro, both fraudulent complaints for which these 18th Judicial Circuit Courts lacked subject matter jurisdiction to hear the cases, lacked the delegated judicial authority to make any decision on the merits or decisions on the cases, and lacked the delegated authority to file any judgements resultant of the cases. These 18th Judicial circuit courts presided over by local 18th Judicial circuit court judges, violated state and
judgement, fraudulently granted by judges French Mallen, Bryan Chapman, Angelo Kappas, and Neal Cerne to plaintiffs Peter C. Powers and Rosemary Powers, and likewise a void judgement of foreclosure and sale, illegally and fraudulently granted to a plaintiff trust by judges James D. Orel, Robert G. Gibson, and Bryan Chapman, the CSMC 2018-SP3 TRUST, a fiduciary trust filed with no trustee, which cannot sue nor be sued pursuant to State of Illinois law and under the laws of the United States. "A Judge is not the court" - The U.S. Supreme Court has stated that: No state legislator or executive or judicial officer can war against the U.S. Constitution without violating his undertaking to support it. Cooper v. Aaron, 358 U.S. 1, 78 S Ct. 1401 (1958) Any judge who does not comply with his oath to the Constitution of the United States wars against that Constitution and engages in acts in violation of the Supreme Law of the land, the judge is engaged in acts of treason. These two complaints were illegally and fraudulently filed by attorney David A. Belofsky, and attorney Ira T. Nevel, fraudulently accepted by the 18th Judicial Clerk of the circuit court, and fraudulently litigated and prosecuted with these courts having "zero" subject matter jurisdiction over the claims of these complaints, by seven judges, five law firms, and nearly a dozen attorneys in the 18th Judicial DuPage County circuit court, without a single document having any Illinois Supreme Court required signatures by any of the filing attorneys or by any attorneys signatures from the filing attorney's law firms, without a single document having the Illinois Supreme Court required verification by certification under 735 ILCS 5/1-109, by any of the filing attorneys or other attorneys from the filing attorneys law firms. At the core of case 2018L001177 comes plaintiff Peter C. Powers and Rosemary Powers, who through their attorney, David A. Belofsky, maliciously and fraudulently filed a fraudulent complaint against Jerome Pintaro and Marilyn Pintaro in the DuPage County circuit court, a court which lacked subject matter jurisdiction over the claims affirmed in the complaint, the court fraudulently granting Peter C. Powers and Rosemary
Rosemary Powers to extort $283,000 pursuant to a fraudulent $179,000 alleged oral debt from defendant Jerome Pintaro and Marilyn Pintaro, that neither existed, that was neither due nor owing plaintiffs, that was in its best case filed two years three months beyond the statute of limitations for such filings, and in its worse case, filed seven years, three months beyond the statute of limitations, the window to file a complaint for such causes, for any and all possible violations including, 1.) for collection of an oral debt, 2.) for the fraudulent concealment of an oral debt, and 3.) for breach of fraud of an oral debt. Plaintiff Peter Powers and Rosemary Powers, vicariously sponsored a second fraudulent complaint, 2020CH000378, fraudulently filed by attorney Ira T. Nevel, for a non-human plaintiff client, a document at best, a plaintiff trust which lacked the capacity to negotiate any legal retention representation from attorney Ira T. Nevel, a non-human, plaintiff fiduciary trust, a document at best, the CSMC 2018-SP3 TRUST, filed to the court with no trustee at the time of filing, a plaintiff trust that cannot legally sue nor legally be sued under State of Illinois law and the laws of the United States, a complaint which the 18th Judicial Circuit court lacked subject matter jurisdiction over the claims of the complaint, a court which lacked the authority to render any decision on the merits of claims of the complaint or render any decisions on the complaint, in an attempt by plaintiffs' Peter C. Powers and Rosemary Powers to fraudulently steal defendants Jerome Pintaro's and Marilyn Pintaro's principal $4M residence located at 118 Saint Francis Circle, Oak Brook, IL. The above aforementioned fraudulent complaints filed with the 18th Judicial Court, a fraudulent DuPage County Sheriff's false arrest and false imprisonment of plaintiff Jerome Pintaro in the DuPage County Jail, for walking towards Dimitri A. Sayegh, the criminal who was solicited and franchised by DuPage County government to steal plaintiffs Jerome Pintaro's and Marilyn Pintaro's principal Oak Brook residence, Dimitri A. Sayegh, the criminal who stole plaintiff Pintaro's identity along with criminal Dimitri A. Sayegh's attorney Adham Alaily, both publishing plaintiff Jerome Pintaro's full Social Security number, full Illinois Driver's license number, date of birth, full vehicle license plate number, full physical description, on a fraudulent "stalking, no contact order" with a malicious and fraudulent 'warning' transmitted to law enforcement thoughout the State of
Pintaro, as being "ARMED AND DANGEROUS" distributed to all Illinois police officials and other public sources and criminal records throughout the State of Illinois, fraudulently granted and filed by DuPage County judge Jeffrey Mackay in an unannounced, unnoticed 'kangaroo court trial.' Fraudulent DuPage County Eviction Orders filed by criminal Dimitri A. Sayegh, fraudulent Eviction Orders granted criminal Dimitri A. Sayegh by DuPage County judge Bryan Chapman, and judge Craig R. Belford, fraudulent Eviction orders, fraudulently granted, by judge Bryan Chapman and judge Craig R. Belford which resulted in the search, seizure, and confiscation of plaintiff Jerome Pintaro's $4M principal Oak Brook residence, with all his personal property acquired over two generations, over one hundred years, confiscated with no court order, confiscated without being compensated, confiscated with no probable cause, and reappropriated to criminal Dimitri A. Sayegh, who was allowed to change all exterior locks by DuPage County Sergeant Eduardo Castillo, and Sheriff Deputy Kristopher Gravel, both of whom confiscated all Pintaro family member's keys, and then allowed criminal Dimitri A. Sayegh to illegally take possession of plaintiff Pintaro's Oak Brook residence, which to the date of this writing, on 8/7/2023, has been held hostage by DuPage County government for the past nine months for no legal reason other than to extort $283,000 pursuant to a void judgement and void memorandum of judgement, illegally and unofficially, without subject matter jurisdiction, unconstitutionally granted by judge Neal Cerne to Peter C. Powers and Rosemary Powers, which as of 8/3/2023, judge Neal Cerne, without official authority delegated to the court to render a decision in this complaint, judge Neal Cerne continues to refuse to vacate the void judgement, and void memorandum of judgement, unless plaintiff Jerome Pintaro makes an extortion payment of $283,000 to Peter C. Powers and Rosemary Powers. DuPage County judges continue to refuse to release the fraudulent complaints filed against plaintiff Pintaro which were illlegally filed, illegally accepted by the corrupt clerk of the 18th Judicial Circuit court's office, fraudulently accepted, and fraudulently litigated and prosecuted, unlawfully granting relief without the legal authority deletated to the court to do so, without the court having subject matter jurisdiction over the claims of the complaints, through fraudulent court proceedings which the 18th Judicial courts lacked subject matter jurisdiction over the claims stated in the fraudulent complaints.
Jerome Pintaro, verbally confirmed that he has evaded federal income taxes on $5M of skimmed retail cash revenues and cash parking lot revenues since 2005, through money skimming and money laundering, untaxed cash revenues kept in 'coffee cans' revenues collected by Peter C. Powers' and Rosemary Powers' from White Sox MB retail business, the Grandstandsox, Ltd., a retail business of primarily White Sox products, located at 600 W. 35th St, Chicago, IL and from White Sox MB, Guaranteed Rate Field parking lot revenues. Consider that Peter C. Powers and Rosemary Powers with all their real estate property holdings and alleged tax free cash, allegedly filed for federal bankruptcy protection in DuPage County. Consider that Peter C. Powers and Rosemary Powers are being aided and abetted by the entire DuPage County Government, the DuPage County State's Attorney's Office, DuPage County judges, the DuPage County 18th Judicial Circuit Court Clerk's office, DuPage County Sheriff's office, the DuPage County Recorder of Deeds, the DuPage County Treasurer and Tax collector, and the DuPage County Clerk. These two fraudulent cases filed in the DuPage County circuit court were the basis for two federal, Section 1983 complaints for deprivation of civil rights, filed by plaintiff Jerome Pintaro to the U.S. District Court of Northern Illinois, Eastern Division, case no. 23-cv-1425; plaintiff Jerome A. Pintaro v. defendants Orel et. al, presided over by Judge Thomas Durkin, and 23-cv-2008; plaintiff Jerome A. Pintaro v. defendant Granada, et. al. presided over by Judge Sharon Johnson Coleman. Judge Sharon Johnson Coleman having carefully and judicially considered the issues and evidence at hand with the allignment of plaintiff Jerome Pintaro's claims in both these federal 42 U.S.C. Section 1983 cases for deprivation of civil rights, and having also considered the nexus between the correlation of claims against defendants in both these cases, which includes defendant attorney Catherine M. Levine; Judge Sharon Johnson Coleman, sua sponte, on the court's order, reassigned case no. 23-cv-2008 which Judge Coleman was initially assigned, to Judge Thomas Durkin, who is the assigned presiding judge over case no. 23-cv-1425, providing uncontroverted evidence by the court of the plausibilty of plaintiff Jerome Pintaro's claims against defendant attorney Catherine M. Levine.
and team physician for the White Sox MB players, located at Guaranteed Rate Field. Pace Systems, Inc., Nicholas Taylor, have been a major supplier and electrical contractor and service provider to Rush University Medical Center and Rush University physicians for the past thirty years. Pace Systems, Inc. and Nicholas Taylor have been a supplier and electrical contractor and service provider to the White Sox MB and Guaranteed Rate Field. Pace Systems, Inc., Nicholas Taylor, have been a major supplier and electrical contractor and service provider to all agencies of the DuPage County Governement including the DuPage County State's Attorney, the DuPage County 18th Judicial Circuit Court, the DuPage County Jail, and DuPage County Sheriff. Pace Systems, Inc. was also a former employer of plaintiff Jerome Pintaro, and the company where plaintiff Jerome Pintaro sustained a shoulder injury in 2018. Pace Systems, Inc., Nicholas Taylor, is also the defendant in a Illinois Workers' Compensation Claim, case no. 18wc032482; Jerome Pintaro, plaintiff v. Pace Systems, Inc., defendant, and Nicholas Taylor, a named defendant in federal case no. 23-cv-2008; Pintaro v. Granada, et al. Dr. Brian Cole was the orthopedic surgeon selected by plaintiff Jerome Pintaro to diagnose and surgically repair plaintiff Pintaro's injury sustained at the Pace System, Inc. warehouse in 2018. Defendant Dr. Brian Cole was solicited to intentionally misdiagnose and sabotage the surgical repair of plaintiff Jerome Pintaro's shoulder in 2019, a surgery which resulted in immediate failure upon completion of the surgery, a surgery of which nerve damage was confirmed by Dr. Brian Cole and his phyician assistants, a result of improper use of a 'nerve block' at the time of surgery, potential vertebrae damage subsequently diagnosed subject to further testing, unbearable pain and suffering and essentially loss of plainitff Pintaro's use of his dominant right arm being right handed for the past five years, a surgery of which Dr. Brian Cole lied on his operative report of plaintiff Jerome Pintaro's rotator cuff repair surgery, a surgery of which Dr. Brian Cole refused to allow a follow-up MRI for three years, from the time of surgery in July, 2019 until May, 2022, three years after the surgery was completed by Dr. Brian Cole. The reason for denial of a post-surgery MRI which was orally conveyed to plaintiff Jerome Pintaro by Dr. Brian Cole's physician assistants, the potential of liability that Dr. Brian Cole would be exposed to as a result of a post-surgery MRI. Plaintiff Jerome Pintaro has
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