please the court my name is frank yes john my representative tenants the department of central management services in the state of illinois this court should reverse the circuit court's order granting a pulmonary junction in this case because plaintiff has not demonstrated that any of the four are satisfied in this case because each of the four requirements must be established in order for an injunction to issue the failure to satisfy even one of the or fireman surrenders the injunction improper most clearly plaintiff has not demonstrated that he enjoys the likelihood of success on the merits of his underlying claim or that he lacks an adequate remedy at law in the absence of an injunction the first player cannot succeed on because he is attempting to exert control over a discretionary decision by a public official by seeking a an order that would mandate a specific outcome with regard to that discretionary decision mandamus may only be issued compel a public official to perform a ministerial duty that is not required the exercise of any discretion the decision of whether to adjust and employees to downwardly just an employee's salary is left to the discretion of the director of c m s and is based upon  consideration of the number of factors set forth in the ministry of code and his complaint plentiful edges of procedural error by claiming that the director did not take those factors into account when he decided to adjust plan of salary but then rather than oh rather than seeking a remedy that would regress that procedural error by requiring the director to reconsider his decision in life of those factors in the administrative code he is seeking an order requiring  point pulmonary injunction was granted and while planes it is alleging in his complaint that that the director did not comply with the procedures for making the underlying decision to adjust his salary is not seeking a procedural remedy that would repress that error by for example requiring the director to reconsider that decision in life those factors instead he's asking for an order that would mandate a specific outcome with regard to that discretionary  issue of whether or not an adjustment was warranted under the facts of this case by by asking for more requiring c m s and the state to pay him at that period just in the salary because mandamus cannot be used to compel i and costs and fees while the title of his complaint indicates that he is also seeking a permanent injunction he does not require or a legit claim that would support that so any such relief in the body of his complaint but even if he had that fault in the officer sued exception to sovereign immunity because the plaintiff was seeking an injunction requiring individual state agents to engage in are prohibited and will stay agents from engaging in certain conduct threats here plaintiff is not seeking in order requiring any injunction improper but in addition plaintiff has not demonstrated that he lacks an adequate remedy at law in the absence of an injunction preliminary injunctions are nic this is an extraordinary remedy that is only issued in  this case the plaintiff is challenging the decision to adjust his salary and therefore the injury he has suffered as a result of that action is the loss of wages in between his pretty high or pretty just in salary and his lower post because there's no dispute that that amount could be calculated with relative ease and certainty any injury that player might suffer during the course of litigation could if you prevails on the merits of this claim could be compensated by an easily  examination in terms of determining whether there was an adequate remedy law and then he back on to that and that's kind of where i was going as well about the damage to his credit or how do you quantify that and here is damage because you can't pay your honor i would say that that's both your honour's offered actually i can say that that that's not the correct framework to look at this issue because that would expand the scope of what constitutes an adequate remedy at law it's one that not only compensates a party for any injuries that he may suffer as a result of the defined its conduct but would also have to take into account any developments that subsequently occur as an indirect result of the injury that directly flows from the defendant's conduct and for that reason but there's there's we cited a number of cases in our brief say pointing out how when an injury can be compensated by money damages a certain court not just airs but abused by granting a preliminary injunction and plaintiff in his response has not addressed any of those cases or cited any cases of his own to support his theory an additional problem or an additional issue is that even if plaintiff definition of what constitutes an adequate remedy at law was correct he has not alleged sufficient backs in his complaint to establish that this is such a case plaintiff bears the because play a very of the burden of  post adjustment salary but he has not alleged any provable facts that could be proven to support that conclusion for example he has not allege any facts about what types of that obligations he's facing while you know the extent of his inability to pay them  i'm i'm going to refer to what i did the last time i'm going to deviate from more arguments and i hope because of what i'm going to say that you'll give me some indulgence to say what i want to say but there's a reference that i want to make i think it's relevant to this case tom i didn't bring it up here because as young man i memorize the new testament and i'm i'm very familiar with it which will become clear  client was treated i am docket for fourteen three fifty two i'm not going to do that because i no longer believe in the system and personally i don't believe and i don't believe consciously faith i can do so and order to justify that i think if you give me the opportunity and want to before i have three questions that counsel raise i want to at least give you a little background of who i am and what i am so that there is no equivocation of my sincerely and my respect for this court and that what i say is done in good conscience i'm a product of probert poverty i i grew up in poverty my my mother raised us almost completely alone it was five of us under the age of six and i remember eating sugar sandwiches for a week at a time except to still piece the bread with regular sugar in them i remember not having the ability to have transportation money or buy tires i was employed at seventeen because i wanted to earn extra spending money because i needed a roof over my head and food on my table and i when i'm in matriculated one thing i think needs to be made so it's very clear on the religionist instead of studying the books in high school why undergraduate school or even while school life i studied religion and i came to the law through religion not vice versa so my perspective on this case is a little different i understand i believe what a maintenance worker who has his minimum wages cut by one fourth and then the state comes along and says that's the correct thing to do and then questions representing you she a mouse but then reneged on after i went on vacation of the country and when i came back i was promised that we would get worked out and then when finally it was clear that they the reason i'm not coming back here is because of that case that i had here before and i filed an appeal with the end of my supreme court and whatever they do with it whatever wit i don't want to be flippant about this but he asked me in in the judges in illinois to get a mandamus when they got it and they got united their cost of living increase and the money wasn't appropriated and i do explain to him that yeah that that happened but that country it's t r o course because i filed for two euro and asked for an immediate hearing i got a hearing thirty days after because the court was too crowded couldn't give me a hearing so they had thirty days  tough ok so it's a tear up with notice now they say it's blooming or injunction what is it but that's you know there's no jurisdiction here but my individual client can sign a contract he not a party to the contract as we noted in the last year he has an individual right to detrimental lines so there are other reasons why this case is just wrong salim unity i want to make sure i explain now real quickly  my argument the sovereign immunity mirrors the only supreme court's majority decision and we tara decided about a month ago two thousand fifteen years  in thirty eight years i ever waved an argument likelihood of prevailing i'm not here you know i i put my arguments in my preplan i'm not going to do it so if you have any questions fine but i just want to dan do one thing and again i don't mention  but i want to say it questions of law are reviewed de novo and here the basis for the poor injunction were the allegations in the complaint and therefore whether or not plaintiff is entitled to a pulmonary injunction is a question of law based on the allegations