GRANADA

Case: 1:23-cv-02008 Document #: 50 Filed: 08/07/23 Page 1 of 17 PageID #:419




Case: 1:23-cv-02008 Document #: 50 Filed: 08/07/23 Page 1 of 17 PageID #:419

ED FIL023 /2 8/7 EW BRUTON THOMAS G.TRICT COURT . DIS CLERK, U.S UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION Jerome A. Pintaro Plaintiff v. Gerald Granada, Catherine M. Levine, Evelyn Martinez, Nicholas Taylor, Dr. Bryan J. Cole, Dr. Richard B. Foulkes Defendants Case No. 23-cv-02008 Judge: Thomas M. Durkin PLAINTIFF JEROME PINTARO'S REPLY TO DEFENDANT GRANADA'S REPLY IN SUPPORT OF HIS MOTION TO DISMISS Plaintiff Jerome Pintaro filed his response to defendant Granada's Motion to Dismiss on July 21, 2023 as titled: : "PLAINTIFF JEROME PINTARO'S RESPONSE TO DEFENDANT GRANADA'S MEMORANDUM IN SUPPORT OF HIS MOTION TO DISMISS BY HIS ATTORNEY HAL B. DWORKIN" Plaintiff Jerome Pintaro relies on his previous response a copy (See Attachment) of which he has attached to this reply and further adds the following to his previously filed response on a single subject matter as follows: The use of precedent court decisions has been justified as providing predictability, stability, fairness, and efficiency in the law. Reliance upon precedent contributes predictability to the law

Case: 1:23-cv-02008 Document #: 50 Filed: 08/07/23 Page 1 of 17 PageID #:419

Case: 1:23-cv-02008 Document #: 50 Filed: 08/07/23 Page 2 of 17 PageID #:420

because it provides notice of what a person's rights and obligations are in particular circumstances. Judges are obligated to make their rulings as consistent as possible with previous judicial decisions on the same subject matter. Each case decided by a common law court becomes a precedent, or guideline, for subsequent decisions involving similar disputes. Supreme Court past cases are most important because they have been decided on by the highest court in the land, it is the court of last resort for those looking for justice. Due to its power of judicial review, it plays an essential role in ensuring that each branch of government recognizes the limits of its own power. CERTIFICATION AND CLOSING UNDER FEDERAL RULE OF CIVIL PROCEDURE 11, BY SIGNING BELOW, I CERTIFY TO THE BEST OF MY KNOWLEDGE, INFORMATION, AND BELIEF THAT THIS MOTION: (1) IS NOT BEING PRESENTED FOR AN IMPROPER PURPOSE, SUCH AS TO HARASS, CAUSE UNNECESSARY DELAY, OR NEEDLESSLY INCREASE THE COST OF LITIGATION; (2) IS SUPPORTED BY EXISTING LAW OR BY A NON FRIVOLOUS ARGUMENT FOR EXTENDING, MODIFYING, OR REVERSING EXISTING LAW; (3) THE FACTUAL CONTENTIONS HAVE EVIDENTIARY SUPPORT OR, IF SPECIFICALLY SO IDENTIFIED, WILL LIKELY HAVE EVIDENTIARY SUPPORT AFTER A REASONABLE OPPORTUNITY FOR FURTHER INVESTIGATION OR DISCOVERY; AND (4) THE COMPLAINT OTHERWISE COMPLIES WITH THE REQUIREMENTS OF RULE 11. DATE: August 7, 2023 JEROME A. PINTARO____________________________________________________ P.O. BOX 3441 OAK BROOK, IL 60522 630-280-9300 japintaro@protonmail.com

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Case: 1:23-cv-02008 Document #: 43 Filed: 07/21/23 Page 1 of 12 PageID #:362

50 08/07/23 4 17 #:422 E FIL1/2D3 02 7/2 JB BRUTON THOMAS G.TRICT COURT . DIS CLERK, U.S

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