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 [13] 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:
Averment [13]
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!
No comments:
Post a Comment