I'm Ready! To Do A Lot-A Damn Squealing
The "Godfather of Soul," James Brown said: "I can do wheeling, I can do dealing, but I don't do no damn squealing." In this instance I must digress. When injustice and corruption are exacted at the expense of concealing ten days of my freedom being taken, I must do a whole lot of damn squealing.
Basis in Fact & Law For Recusal (part II), posted previously, began to answer the question, "Why is Judge Joel L. Hillman and Karen M. Williams presiding over civil action 1:11-cv-06304. Viewer's, as you will begin to see, they had too. How else would they conceal their own ratification of the "Liar's for Hire" misconduct exacted to protect two Atlantic City Casinos from being held liable under § 1983.
On page 4 of the "28 U.S.C.A. § 1746 Declaration of Bias or Prejudice and Motion for Recusal of U.S.D.J. Noel L. Hillman and U.S.M.J. KarenM. Williams," averment  says: "Noel L. Hillman knew that Christopher C. Mauro’s Motion for Summary Judgment, submitted on behalf of his client Harrah’s was supported and couched upon said defendants answers to the “Original Complaint” and were not signed by any corporate officer of Harrah’s, yet he did couch his opinion of September 27, 2010 on this falsehood."
The above is given a basis in fact and law on pages 8 and 9 of the "BRIEF IN SUPPORT OF MOTION FOR RECUSAL OF U.S.D.J. Noel L. Hillman and U.S.M.J. Karen M.Williams," when the plaintiff's set forth the following:
Your own opinion of September 27, 2010 says that you, Judge Hillman are once again shown to lack honorability. Hickson v. Marina Associates, et al., 743 F.Supp.2d 362, 379 holds: “It is worth noting, however, that defendants filed answers in response to Hickson's complaint, which has been amended three times.” Any reasonable person armed with this fact from your own words would understand that the prevailing complaint in civil action 08-cv-02407 would be the “Third Amended Complaint.” Correct Judge Hillman?
Just by telling you that the answers that Christopher C. Mauro attached as “Exhibit D” allows you to go and attempt to correct the numerous mistakes, but try just explaining why you based your "9/27/2010 Opinion" on a document, attached as “Exhibit D,” who’s caption reads “Answers,” not “Answers to Third Amended Complaint?”
Civil action 1:11-cv-06304 addresses the same at averment #187 which states: “Harrah’s Hotel and Casino having terminated and or secured the absence of Alexander Lovas and Vance Thompson did proceed on the actions of their counsel Christopher Mauro and he [Mauro] did file a motion for summary judgment seeking dismissal of Hickson’s §1983 claims against Harrah’s, Thompson, and Haag based entirely upon the general denials within the answers to the complaint and unsupported by any affidavits, depositions, statements or other admissible evidence from a Harrah’s agent, Thompson or Haag. The answering defendants cannot deny that judge Hillmans grant of summary judgment to those defendants contradicts FRCVP 56 as the record clearly shows that reliance was made on the submission of Christopher C. Mauro’s statement of facts and answers to the prevailing complaint that were signed by Mauro on the behalf of Vance Armstrong and further exhibiting a strong inference to prevent Lovas, Thompson and Haag from presenting any admissible evidence or taking the witness stand. [See Exhibit Y @ pgs. 164-167 and Exhibit I @ pg.93].”
The above averment #187 directs the reader to Exhibit Y @ pgs. 164-167 and Exhibit I @ pg. 93, of the exhibits attached to civil action 1:11-cv-06304. Yet you plainly refer to the complaint consisting of 61 pages not the full 235 pages judge Hillman. You can’t deny that your own words once more make your statements untrue for Hickson v. Mauro, CivilAction No. 11-6304, holds: “Plaintiffs filed a 61-page complaint asserting civil rights claims pursuant to 42 U.S.C.A. §§ 1981, 1983, and 1985, claims of civil conspiracy and fraud, and a criminal claim alleging violation of 18 U.S.C.A. § 2071 (concealment, removal, or mutilation of court or public documents).” On what date do you intend to update the public that this complaint was actually 235 pages judge Hillman? The public has a right to know why you and the Clerk of the Court (bdk) are attempting to make it appear that only exhibits (A) through (C) were filed knowing that to be a lie as the exhibits extend (A) through (Z). The public also has a right to know why justia.comsays that the case was assigned to Judge Karen M. Williams and she referred the case to you, but as of 11/26/2012 the case is numbered 11-cv-06304-NLH-JS. This fact further supports the “Stealthy Hubristic Injustice Tactics exacted within this court.
You have used the “Summary Judgment Rule” in an attempt to remove all of Earl Hickson’s claims from a jury. Now you further attempt the same in civil action 1:11-cv-06304 against Earl Hickson and Markland Grant, this action of yours is contrary to the holdings of Poller v. CBS, 368 U.S. 464, 467 holding: “Summary judgment should be entered only when the pleadings, depositions, affidavits, and admissions filed in the case "show that [except as to the amount of damages] there is no genuine issue as to any material fact and that the moving party is entitled to a judgment as a matter of law." Rule 56 (c), Fed. Rules Civ. Proc. This rule authorizes summary judgment "only where the moving party is entitled to judgment as a matter of law, where it is quite clear what the truth is, . . . [and where] no genuine issue remains for trial . . . [for] the purpose of the rule is not to cut litigants off from their right of trial by jury if they really have issues to try." Sartor v. Arkansas Natural Gas Corp., 321 U. S. 620, 627 (1944).”
Not only are your acts contrary to the case law above, judge Hillman but it further supports a reasonable persons belief that you are biased and prejudiced against those that would expose your judicial misconduct which is unbecoming of a United States District Judge. If we were playing the game of “Chess” you would see “Check-Mate” coming in the next 31 moves for I have 31 more averments to this motion. There will be no “en passant” on our part, but you still have a choice judge Hillman.
Yes Judge Noel L. Hillman has a choice, but this writer doubt's that he will respond as James Brown would by saying, "I'm ready, I can dig scrapping." No, because that would mean that he has to adhere to the (JSHIT) he has floating around the "judicial toilet" he call's his courtroom.
No Judge Hillman the plaintiff's can do wheeling, yes they can turn your lies around upon you. Yes the plaintiff's can do dealing. They can lay the cards out on the table before John and Jane Q Public so that they can come to a reasonable conclusion based upon all the facts and circumstances. How? By doing a whole lot of damn squealing Judge Hillman. We're Ready!
You attempt to train Judge Williams in your corrupt ways, and she wanting to please, and continue receiving her paycheck, did conform. But "Superman" didn't land in Cuba where he would have been raised to protect the mandated of a dictator. No he is shown to grow and protect "truth and justice," the American way. So now we ask you the viewer, who should tell their story walking?
Thank You oh so much for your time, and please tell a friend or two.
The Casino Gaming Oracle!