NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION Jerome A. Pintaro, et al. Plaintiff v. James D. Orel, et al. Defendants Case No. 23-cv-01425 Judge Thomas M. Durkin PLAINTIFF JEROME PINTARO'S REPLY TO CERTAIN DEFENDANTS' REPLY IN SUPPORT OF THEIR MOTION TO DIMSIS COMPLAINT CERTAIN DEFENDANTS’ REPLY IN SUPPORT OF THEIR MOTION TO DISMISS COMPLAINT Now Comes DIMITRI A. SAYEGH (AS A DEFENDANT) MAJD G. KHOURY (AN ILLEGAL SCAM 'STRAW BUYER' WITH THE DELIBERATE INTENT TO DISGUISE THE TRUE NATUE OF THE TRANSACTION, THE USE OF A FRAUDULENT, FICTICIOUS, AND FABRICATED BUYER'S NAME TO COMMIT MORTGAGE AND FORECLOSURE FRAUD BY THE CORRUPT DUPAGE COUNTY GOVERNMENT, AND CERTAIN CORRUPT 18th JUDICIAL CIRCUIT COURT JUDGES, DUPAGE COUNTY SHERIFF, AND DUPAGE COUNTY RECORDER OF DEEDS) ADHAM ALAILY (AS A NAMED DEFENDANT IN 23-cv-1425, PINTARO, et, al., v. OREL, et, al.) (AS AN ILLINOIS LICENSED ATTORNEY PARTY TO CONSPIRACY TO COMMIT FRAUD) (AS AN ILLINOIS LICENSED ATTORNEY PARTY TO A CONSPIRACY TO COMMIT FRAUD, ALLEGEDLY REPRESENTING DEFENDANTS DIMITRI A. SAYEGH AND A 'STRAW BUYER' MAJD G. KHOURY) collectively referred to as the Defendants by and through their attorney Adham Alaily, Egan & Alaily, LLC, and for "THEIR REPLY" in support of their request to be dismissed from this proceeding pursuant to Fed R. Civ. Pro. 12(b)(1) and 12(b)(6)
ATTORNEY ADHAM ALAILY CANNOT BE BOTH DEFENDANT ADHAM ALAILY SIGNS THE REPLY AS AN ATTORNEY AND NOT AS A DEFENDANT BUT THEN TRANSGRESSES BACK TO A DEFENDANT IN HIS CLOSING STATEMENT: "For the reasons stated in Defendants’ motion to dismiss, Defendants Sayegh, Khoury, and Alaily, should be dismissed from this case." UNCONTROVERTIBLE FACT #1 MAJD G. KHOURY, AN ILLEGAL, FRAUDULENT, FICTICIOUS, FABRICATED NAME, AN ILLEGAL 'STRAW BUYER' WITH A DELIBERATE ATTEMPT TO COMMIT MORTGAGE AND FORECLOSURE FRAUD BY DISGUISING THE TRUE NATURE OF THE FRAUDULENT ORDER OF JUDGEMENT OF FORECLOSURE AND ORDER OF SALE, 18th JUDICIAL CIRCUIT COURT CASE NO. 2020CH000378, TITLED "CSMC 2018-SP3 TRUST (PLAINTIFF) v. JEROME A. PINTARO AND MARILYN PINTARO (DEFENDANTS) OF PLAINTIFF JEROME PINTARO'S AND MARILYN PINTARO'S PRINCIPAL OAK BROOK RESIDENCE LOCATED AT 118 SAINT FRANCIS CIRCLE, OAK BROOK, ILLINOIS, BY THE CORRUPT DUPAGE COUNTY GOVERNMENT, AND CERTAIN CORRUPT 18th JUDICIAL CIRCUIT COURT JUDGES, DUPAGE COUNTY SHERIFF, AND DUPAGE COUNTY RECORDER OF DEEDS) UNCONTROVERTIBLE FACT #2 DEFENDANT ADHAM ALAILY AND DIMITRI A. SAYEGH HAVE VIOLATED 18 U.S. CODE SECTION 1512 TITLE 18 PART 1 CHAPTER 73 1512, TAMPERING WITH A WITNESS, VICTIM OR AN INFORMANT DEFENDANT ADHAM ALAILY AND DIMITRI A. SAYEGH HAVE COMMITTED IDENTITY THEFT DEFENDANT ADHAM ALAILY AND DIMITRI A. SAYEGH HAVE COMMITTED FRAUD, EXTORTION, AND OBSTRUCTION OF JUSTICE, BEING PARTY TO A CONSPIRACY WITH THE CORRUPT DUPAGE COUNTY GOVERNMENT, AS WELL AS OTHER CORRUPT SOLICITED GOVERNMENT 'ACTORS' HAVING FILED FRAUDULENT, FALSE DUPAGE COUNTY SHERIFF'S CRIMINAL REPORTS, FRAUDULENT 'ORDERS OF PROTECTION' FRAUDULENT 'NO CONTACT ORDERS' AND FILED PAPERS TO THE DUPAGE COUNTY 18th JUDICIAL CIRCUIT COURT TO OBTAIN FRAUDULENT COURT ORDERS FROM CERTAIN CORRUP 18th JUDICIAL COURT JUDGES ALSO PARTY TO THIS CONSPRIRACY TO DEPRIVE PLAINTIFFS JEROME PINTARO AND MARILYN PINTARO OF PROCEDURAL DUE PROCESS, AND CIVIL RIGHTS, PRIVILEGES, AND IMMUNITIES, GUARANTEED BY THE U.S. CONSTITUTION AND LAWS OF THE UNITED STATES
THE FRAUDULENT JUDGEMENT OF FORECLOSURE AND FRAUDULENT ORDERS OF SALES OF PLAINTIFF JEROME PINTARO'S PRINCIPAL OAK BROOK RESIDENCE WERE GRANTED BY VOID ORDERS PURSUANT TO THE CORRUPT 18TH JUDICIAL CIRCUIT COURT WHICH LACKED SUBJECT MATTER JURISDICTION OVER THE CLAIMS OF A NON-HUMAN, A NON-ENTITY, PLAINTIFF CSMC 2018-SP3 TRUST DOCUMENT FILED AND ACCEPTED WITH NO TRUSTEE, TO THE CORRUPT 18th JUDICIAL CIRCUIT COURT CLERK, THE COURT NOT HAVING BEEN DELEGATED AS A MATTER OF LAW THE AUTHORITY TO MAKE ANY DECISION OR GRANT ANY ORDER PURSUANT TO THE COURT'S LACK OF SUBJECT MATTER JURISDICTION RULE 3.7 ATTORNEY-WITNESS RULE STATES THAT THE COURT HAS PROPER OBJECTION WHEN THE TRIER OF FACT MAY BE CONFUSED OR MISLED BY A LAWYER SERVING AS BOTH ADVOCATE AND WITNESS. The opposing party has proper objection where the combination of roles may prejudice that party's rights in the litigation. A witness is required to testify on the basis of personal knowledge, while an advocate is expected to explain and comment on evidence given by others. It may not be clear whether a statement by an advocate-witness should be taken as proof or as an analysis of the proof. A lawyer should not act as advocate at a trial in which a lawyer is likely to be a necessary witness. Combining the roles of advocate and witness can prejudice the tribunal and the opposing party and can also involve a conflict of interest between the lawyer and the client. An attorney's inability to testify isn’t by accident. There is an inherent presumption that lawyers will lie if given the chance. If the lawyer doesn’t have evidence to support what they’re saying, everything they’ve said should be stricken from the record. Lawyers are prohibited from asserting facts in court. Even in cross-examination, which is where the lawyer’s conduct is closest to testimony, lawyers have to ask the witness to confirm or deny everything the lawyer says. Then it’s not
events. the words lawyers use to characterize facts are often unfair and misleading, and that’s why evidence is required. One of the easiest ways to win a case is to prove that the other side is lying. The lawyer just describes what everyone else is saying, and then he has to prove it. Attorneys have a special obligation to protect a court against criminal or fraudulent conduct that undermines the integrity of the adjudicative process, such as bribing, intimidating or otherwise unlawfully communicating with a witness, juror, court official or other participant in the proceeding, unlawfully destroying or concealing documents or other evidence or failing to disclose information to the court when required by law to do so. Defendants, Adham Alaily, Dimitri A. Sayegh, excluding Madj G. Khoury, a 'straw buyer' nonperson, non-entity, a ficticious name, false and fabricated, present no relevant basis pursuant to any matter of law for their reply in support of their motion to dismiss, but instead argue citing conclusory conclusions, assertions, and opinions for which defendants provide no supporting evidence. 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,
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, 478 U.S. 265, 286 (1886)(cited with approval in Twombly, 550 U.S. at 555 (citations omitted)). Although a 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 Adham Alaily is a solicited government 'actor' as defined in U.S. Constitutional law. Attorney Adham Alialy 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 the corrupt 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, and this conduct under this conspiracy has occurred and continues to occur under 'color of law' and this conduct has and continues to deprive plaintiffs Jerome Pintaro and Marilyn 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 and Marilyn Pintaro's civil rights with the filings of numerous fraudulent complaints, both civil and criminal.
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 of which these 18th Judicial Circuit Courts lacked subject matter jurisdiction to hear the claims and merits of these complaints, lacking 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 pursuant to these complaints. These 18th Judicial circuit courts presided over by corrupt 18th Judicial circuit court judges, violated state and federal law by fraudulently granting void money judgements, and fraudulent, void memorandum of money judgement, fraudulently prosecuted by party judges Dorothy 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 filed with no trustee, 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
and fraudulently litigated and prosecuted with these courts having no subject matter jurisdiction over the claims of these complaints, fraudulently prosecuted by seven judges, five law firms, and nearly a dozen attorneys in the corrupt 18th Judicial DuPage County circuit court, without a single document filed to the corrupt 18th Judicial clerk of the circuit court, and to the 18th Judicial Circuit courts, no documents filed 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 upreme 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 corrupt 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 Powers, a void money judgement and void memorandum of judgement, in an attempt by plaintiff Peter C. Powers and 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 fraudulent breach of an oral debt. Plaintiff Peter Powers and Rosemary Powers, vicariously sponsored a second fraudulent
a document at best, a plaintiff trust which lacked the capacity to even negotiate any legal representation from attorney Ira T. Nevel, a non-human, plaintiff fiduciary trust, a document at best, the CSMC 2018-SP3 TRUST, fraudulently 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 the 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 Jerome 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 Illinois, fraudulently identifying to State of Illinios law enforcement officals that described plaintiff Jerome 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
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 immediately reappropriated to criminal Dimitri A. Sayegh, who was allowed to change all exterior door 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 8/9/2023, 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 engaged in extortion, continued 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
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