Gina Russomanno v. Dan Dugan, et al.
DueProcess
Whether the Supreme Court will consider the merits of the decision of the U.S. Court of Appeals for the Third District, pursuant to res-judicata, barring anti-discrimination claims, when such decision contradicts with the petitioners express-allegations, and directly conflicts with relevant-precedent
QUESTIONS FOR REVIEW.) 1. Whether the Supreme Court will consider the merits of ; the decision of the U.S. Court of Appeals for the Third : District, pursuant to res judicata, barring anti-discrimination _ claims, when such decision contradicts with the petitioners “express allegations,” and directly conflicts with relevant precedent. 2. Whether a simultaneous dismissal for a “remand” . reconsideration juxtaposed as a “judgement” . reconsideration within a single ‘uniform-decision’ with a motion to dismiss can completely foreclose all rights to due process in new-evidence, and serve to later justify the barring of subsequent claim (by res judicata). ; 3. Whether proper precedent establishes that when new : and discrete evidence information arises from a prior case it . permits judicial right to proceed and provision for timely . leave to reinstate. Whether reasonable amendment would be _ futile when the court withholds leave to reinstate, quashes all due process, and completely forecloses on new evidence ; claims. . 4. Whether res judicata same-claim preclusion can bar discrimination claims in Title VII, ADEA, and Equal Pay Act and NJLAD and Diane B. Allen Equal Pay Act when the two cases do not duplicate in any discrimination statutes either ; federal or state by any (reiteration, simultaneous, — additional, or ‘same-claim’) overlap and are wholly separate in cause of action. 5. Whether “assumptions” that are “absent any elaboration” (as defined by previous courts) can still ; ’ gupport reasoning decision to determine that discrimination “must have been prior known.” Whether precedent governs ~ that the merits of “material fact” are adjudicated on ; “determinative” claim. 6. wht or precedent for ‘essential similan_'s ‘not assumptive, but relevant to ‘expressly asserted,’ material of fact. Whether same-claim preclusion is eliminated when the . nucleus of allegations in both suits is substantially different and the subject of the allegations are mutually exclusive. 7. Whether federal jurisdiction for NJ state law (NJLAD), honors precedent to hold individual defendants : liable and exclude ‘same-parties’ preclusion. Whether sameparties preclusion is justified when it extends from ‘sameclaim’ preclusion that conflicts with relevant precedent. 8. Whether precedent for same-parties establishes that . “determinative factors” for individual defendant parties must be applied by “material fact.” Whether court’s failure to apply ‘determinative factors’ can justify the preclusion of individual defendants. 9. Whether there is strong court prejudice surrounding every aspect of plaintiff's cases. Whether precedent establishes proper, just treatment and judicial fairness to pro se parties. Whether it is widely held that plaintiff parties are entitled to the court’s assumption of trust, and whether plaintiff testimony should be construed liberally especially for pro se litigants. : LiX_F PARTIES AND RELATED (_ Jes ; ¢ Gina Russomanno v. Dan Dugan, Jenna Yackish, Trevor Voltz, Erik Weeden, and Sunovion Pharmaceuticals Inc., Case No. 21-2004, United States Court of Appeals for the Third Circuit. Judgement entered Oct. 15, 2021. e Gina Russomanno v. Dan Dugan, Jenna Yackish, Trevor Voltz, Erik Weeden, and Sunovion Pharmaceuticals Inc., Case No 3:20-cv-12336, United States District Court of New Jersey. Judgement 7 entered May 4, 2021. (Origin: MON-L002421-20). © Gina Russomanno v. Sunovion Pharmaceuticals, and : IQVIA Inc. Case No 3:19-cv-05945, United States District Court of New Jersey. Judgement entered May . 18, 2020. (Origin: MON-L00017619). CORPORATE DISCLOSURE, RULE 29.6 Petitioner, Gina Russomanno, is strictly a personal entity with no such corporation or LLC established under this name or control. ; Cryrnion FOR WRIT OF cer( RARI Petitioner respectfully prays that a writ of certiorari is issued to review the judgements below and so requiring the entire record be sent up for decision of the entire matter in controversy. OPINIONS BELOW