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Showing posts with label Brief supporting Recusal. Show all posts
Showing posts with label Brief supporting Recusal. Show all posts

Monday, February 6, 2012

Details of A Non-Existing Warrant Tells All


My previous post titled "A Non-Existing Warrant Tells All" delved into the question of what Judge Noel L. Hillman and Karen M. Williams knew, and are now attempting to conceal by presiding on a civil action that would have the defendants answer issues revealing a concerted effort to deny Earl Hickson and Markland Grant equal protection of the laws and meaningful access to the courts as afforded by the Constitution of the United States of America.
 Let's take a closer look at one of the six paragraphs of averment [16], as set forth within the plaintiff's "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. Karen M. Williams," and it's supporting "Brief."

The first question asked of Judge Hillman was, "Judge Hillman did you accept Kathleen Bartus’ submissions to the court?"  If I had my own daytime T.V. show, this would be the segment where I reach for the envelope, and announce, "When it comes to accepting the submissions of Kathleen Bartus, the evidence says, Judge Noel L. Hillman, you are the father."
 Judge Noel L. Hillman, fathered this "(JSHIT) progeny" by giving birth to this fact within his submission to the world, in the form of his Sept. 27, 2010 Opinion.  Said opinion is now held out to the world as  Hickson v. Marina Associates, et al., 743 F.Supp.2d 362. The proofs that this Judge relied upon the submissions of Deputy Attorney General for the State of New Jersey, Kathleen Bartus are as follows:
  1. @ 366 to 367 the judge says: "Soon thereafter, Kosko informed Hickson that there was a warrant for his arrest for violation of probation. Hickson denied that he was ever on probation or that a 367*367 valid warrant was issued for his arrest." [Click link and scroll to last sentence of page 366, of Hickson v Marina Associates, et al.]
  • The Proofs Support- (a) On 3/10/2008 Earl Hickson took a photo of the New Jersey Promis/Gavel, showing that I was charged with a violation of probation on 5/15/2008, jailed on the same date and not discharged until 5/25/2008. (b) The same NJ Promis/Gavel shows that I was arrested and charged by "NJ STATE POLICE." (C)  On 7/17/2009 I took a photo of the report sent to me by Kathleen Bartus that stated in box #33 that I was charged with "bail jumping, 2C:29-7" contrary to the NJ Promis/Gavel charge of VOP 2C: 45-3. [Scroll to pg 2 after clicking]  (d) On 3/19/2003 Earl Hickson initialed the document stating at item #13 that: "Time Served, No Probation... (e)The so-called warrant manufactured by Kathleen Bartus, and or someone under her direction has not been signed by Mark Kosko, nor does the name of the judge match that given in Kosko's report that Noel L. Hillman say he could rely on in good faith.   
  1. @ 371 the judge says: "According to his investigation report, Kosko observed video footage depicting Hickson's removal of a voucher from the slot machine at issue and, thereafter, a conversation between Hickson and Fedaczynsky."
  1. @ 371 the judge further states: "Kosko had learned and reasonably relied on the belief that Hickson had an outstanding warrant. Although Hickson challenges the validity of the warrant, Kosko was entitled to rely on it in good faith. See Berg v. County of Allegheny, 219 F.3d 261, 273 (3d Cir.2000) ("[W]e have generally extended immunity to an officer who makes an arrest based on an objectively reasonable belief that there is a valid warrant.")"
  2. Judge Noel L. Hillman hangs himself out to dry within his second to last sentence on page 371 where he say's: "Hickson does not raise a genuine issue of material fact on any of these points, including the reasonableness of Kosko's reliance on the warrant."
  • Judge Noel L. Hillman is a Liar and unfit to sit on the bench as the following contradicts his statement. I, Earl Hickson raised the following genuine issues of material fact that this liar ignored and now attempts to continue concealing as follows:
  1. Within the prevailing "Third Amended Complaint" averments, #44, 46, 49,133, 134, 178 and #189 make specific reference to the issue of the warrant. 
  2. As established within 4(c) of "Aiding and Abetting From the Bench (part II)" Judge Noel L. Hillman has acknowledged by his own hand that I filed a "Renewed/Supplemental Motion For Summary Judgment. That document also specifically argues the issue of the warrant at averments, #44, 46, 49, 133, 177, and #188.
  3. The above at (b) was supported by a "Brief" wherein I stated at "Point 2 (F)" the following:
"I was raised to respect my elders and to always give a woman respect but I am taken aback by the presentation of Kathleen Bartus when she mailed me an unsigned copy of a purported warrant for my arrest that supposedly served as the basis for Mark Kosko taking me to the Atlantic County Justice Facility, where I was held against my will for 11 days as the cohorts sorted out their plan.  Any warrant that has been executed on May 15, 2006 should have the executing Officer’s signature in the area validating the warrants return to the court.

Mark Kosko stated within his report that Judge Conner issued the warrant of November 22, 2003, (See Exhibit X box 37), yet the presentation of March 2010 say that it was issued by Judge Garofolo.  (See Photo of Warrant I and Photo of Warrant II)."  [Click this link to see accurate copies of the cited exhibits attached as Details of A Non-Existing Warrant]
Now that you have both sides of the story and not just those of a Judge failing to uphold the Constitution of the United States by denying those within the jurisdiction of a United States District Court the equal protection of the laws and meaningful access to his court, do you agree that the clock is ticking for these judges to remove themselves from this matter?

With 14 days left in the "Count Down to a Recusal" why not tell a friend or two about this site?
Thank you, The Casino Gaming Oracle!

A Non-Existing Warrant Tells All


"Judges Hillman and Williams knew that civil action 11-cv-06304 would require that Kathleen Bartus reveal the truth as to the documents she submitted to the court purporting to be warrants for the arrest of Earl  Hickson, that were contrary to other documented facts within the record, yet judge Hillman accepted these documents." The afore recites the allegation made within averment #16 of Earl Hickson and Markland Grant's "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. Karen M. Williams."

The above allegation is given a basis in fact and law on pages 10 to 11 of the plaintiff's "Brief in Support of Motion for Recusal of U.S.D.J. Noel L. Hillman and U.S.M.J. Karen M. Williams."  Said  basis in fact and law is argued as follows:

Averment [16]
Well Judge Hillman did you accept Kathleen Bartus’ submissions to the court, which she would now have to stand own her own, and answer in civil action 1:11-cv-06304?   Your own words at Hickson v. Marina  Associates, et al., 743 F.Supp.2d 362, 371 holding: “Kosko had learned and reasonably relied on the belief that Hickson had an outstanding warrant.  Although Hickson challenges the validity of the warrant, Kosko was entitled to rely on it in good faith.

You further state at Hickson v. Marina Associates, et al.,743 F.Supp.2d 362, footnote [11], that: “The Court may consider Kosko's investigation report as part of the record. See Clark v. Clabaugh, 20 F.3d 1290, 1294 (3d Cir.1994) (holding that "the district court exercised sound discretion in admitting for consideration" an unsworn police report). Although Hickson disagrees with the conclusions drawn therein, the report essentially repeats facts already alleged or established in the case, i.e., Fedaczynsky's allegations and Hickson's outstanding warrant, and serves principally to show Kosko's awareness of those facts—regardless of their ultimate veracity— at the time when the events of this case were still unfolding.” No other words other than “Bullshit” can fully explain a reasonable person’s reaction to the true facts.

Civil action 1:11-cv-06304 would require that Kathleen Bartus answers as to why she, a Deputy Attorney General for the State of New Jersey, could not come up with the warrant purportedly issued by Judge Connors, in box #37 of the same report that you said the court accepted above.  [After clicking link scroll to page 2]  You know that Ms. Bartus cannot explain away that her presentation to the court of a warrant for the arrest of Earl Hickson is signed by Judge Garofolo is contrary to the police report your court says it accepts judge Hillman.

Truth told you are covering for them because you can see that the warrant could never have existed, like I told Kosko on [FN] May 15, 2006.  But when it comes time for her to stand on her own, answer and refute 1:11-cv-06304 exhibit attachments (S) through (T) at pages 129 through 144 showing the lie, what do you do judge Hillman, but cosign the (JSHIT). You are running out of room with which to leave your dignity in tact judge Hillman.  Just Stop!
Let’s put the icing on the cake, Earl Hickson will do this, you Judge Noel L. Hillman get a copy of the so called proceedings held before Judge Isman on any day in May of 2006, with a verifiable representation of my voice conducting my presentation before this judge and I will bow-out gracefully. NOT!  This can't happen, I was just [FN] with you, cause you and I both know that I never went before Judge Isman, and my constitutional rights were violated, right?  OH, my bad you wanna keep that on the DL. (That down low)  What you know as concealed, and or what a reasonable jury could find, but for your “bent of mind” for Mauro and Bartus huh, judge Hillman.

According to State v. Brown, NJ: Supreme Court 2011, 14 A.3d 26, 32  “The warrant requirement provides citizens with protection from unreasonable arrests by having a neutral magistrate determine probable cause before an arrest is made.  State v. Henry, 133N.J. 104, 110, cert. denied, 510 U.S. 984, 114 S. Ct. 486, 126 L. Ed. 2d 436 (1993); see also Johnson v. United States, 333 U.S.10, 14, 68 S. Ct. 367, 369, 92 L. Ed. 436, 440 (1948).  Without a warrant, the State has the burden of proving the overall reasonableness of an arrest. See Payton v. New York, 445 U.S. 573, 585, 100 S. Ct. 1371, 1379, 63 L. Ed. 2d 639, 650 (1980); State v. Mann, 203 N.J. 328, 337-38 (2010).  I could not find an exception that stated “Without a warrant the State has the burden of proving the overall reasonableness of an arrest, unless the state has favoritism from the Federal Bench.”

Until said exception above is produced the reasonable people must presume that you are evidencing bias or prejudice Judge Hillman.
 The above is yet another key averment that deserves further detailed analysis so that you the viewer can have a full grasp of the facts.  After gaining said facts you will be in a much better position to make you own reasonable conclusions, so I will provide said detail within the next posting. To be continued…

Until next time and as always, thank you for your time, and please tell a friend or two.
The Casino Gaming Oracle!

Thursday, February 2, 2012

Basis in Fact & Law For Recusal (part II)


When I was growing up you would always hear the daytime soap opera's open with a line saying, "previously on As The World Turns or  today on, All My Children."  Well folks if you take a passive approach to the facts being revealed herein, courts will continue their daytime soap opera of performing the appearance of justice.

But, who am I to break tradition so, previously on "The Countdown To a Recusal" as held within the post titled "Blogging, A Reversal of Power" you were brought up to speed as to the unconscionable scheme being attempted by U.S.D.J. Noel L. Hillman and his merry band of unethical cohorts.

Today we answer the question, " Why is Judge Noel L. Hillman presiding over civil action 11-cv-06304 when the complaint cites him as an non-party co-conspirator," which was asked within the post titled "A Judge Should be Placed Before 3 Cannons for Ignoring Canon 3."  The answer to this question is found within the plaintiffs "Brief" of averment [12], and said answer is further given a basis in law as the case law defines and reveals what a "fraud upon the court is.   But now that a U.S. District Judge has joined in the scheme, it has become "fraud upon and by the court, has it not?

I am just the messenger, you be the judge for averment [12] of the "Motion" says: "12. The two judges, Noel L. Hillman and Karen M. Williams cannot deny that they individually and collectively knew of the misrepresentations evidenced within the purported deposition of Sharon Fedaczynsky, which brought into question, this document’s validity, yet Noel L. Hillman couched his opinion of September 27, 2010 on this document."  On page 7 and 8 of the "BRIEF IN SUPPORT OFMOTION FOR RECUSAL OF U.S.D.J. Noel L. Hillman and U.S.M.J. Karen M. Williams," you will find the following:
Averment [12]
The facts show that the purported deposition of Ms. Fedaczynsky is very, very questionable, yet you ignored the fact that the deposition is addressed to the “Superior Court of New Jersey, Camden,” you further ignored that the deposition referred to the plaintiff as “Eric Hickman” you judge Hillman also embraced the fact that a “Mr. Fedaczynsky” is listed as being a witness at said deposition.  As we say socially “It’s all Good,” yes it was all good as long as you could keep these facts hidden but now that John and Jane Q. Public know of the same and have access via: https://docs.google.com/viewer?a=v&pid=explorer&chrome=true&srcid=0B1nZXLmzKrmnOWVhYWY2OTktNzIzNy00OGEzLWFkMGQtMzkwMzYzNDg3OWVl&hl=en_US, they await your response to this motion, they await to see if you have an ounce of integrity left.

Your continued involvement in 1:11-cv06304 moves the acts of Mauro and Bartus beyond “fraud upon the court,” to active fraud by the court.  Knowing that truthful testimony will destroy your credibility and expose your unethical behavior you have walked the path of aiding Christopher C. Mauro and Kathleen Bartus, for reason only you know of judge Hillman.  Fraud upon the court is given basis in law by Triffin v. ADP, 986 A. 2d 8, 11, holding: “We explained that a fraud on the court occurs "where it can be demonstrated, clearly and convincingly, that a party has sentiently set in motion some unconscionable scheme calculated to interfere with the judicial system's ability impartially to adjudicate a matter by improperly influencing the trier or unfairly hampering the presentation of the opposing party's claim or defense." Ibid. (quoting Aoude v. Mobil Oil Corp., 892 F.2d 1115, 1118 (1st Cir.1989); Perna v. Elec. Data Sys. Corp., 916 F.Supp. 388, 397 (D.N.J.1995)). We further noted that unlike common law fraud on a party, fraud on a court does not require reliance. Ibid. We noted that "[s]eparate and distinct from court rules and statutes, courts possess an inherent power to sanction an individual for committing a fraud on the court." Ibid. Consequently, we remanded the matter to the trial court for further proceedings. We held that, "[f]ollowing a hearing, the trial court may impose sanctions on plaintiff on its own motion or on the application of defendant, or both."”

Armed with the above facts a reasonable person can decide if he or she believes that Judge Noel L. Hillman has  "bent of mind" to prevent his fellow cohorts from having to answer a well pleaded complaint wherein the cohorts might break down and tell the truth about him.  You be the judge.  Click the links to see the copy of the purported deposition, doesn't it say as I claim.

Those that are trained in the law know that a lawyer has a duty to inspect the accuracy of all documents he or she files with a Federal Court of Law.  If said lawyer ignores FRCVP 11, he or she must be prepared to face the sanction's that will be imposed for such ignorance.  The plaintiff's as pro se litigant's are subject to the same sanctions, and do you think that a judge would hesitate to exact such a sanction on the pro se party.  Well if I turned this laptop over to Markland Grant right now he would be able to tell you a story or two.
 The facts reveal themselves and the band of wrongdoer's acts give support to their guilt.  Case in point, while reviewing my "blogger stats" I found that there were two views of this blog from "Referring URL" http://www.google.coin/imgres?q=district+court&hl=e.  Now I ask you, do you think that two members from a district court are watching me telling you the truth?  But now that we know that they know that you know the truth, lets let them know that we know that they are viewing by saying: "Hello Judge Hillman, welcome to the party pal, the clock is ticking and you have 19 days left to show your true colors and or unbend your mind."

As always I thank you for your time and ask that you tell a friend or two.
Thank You, The Casino Gaming Oracle!

Black History Month 2012 reigns in and all still do not have equal protection of the laws and meaningful access to the Courts of these United States of America. But now the Judges peek at and or view the redeeming effect of the internet, which this writer predicts will change the tides of injustice.

Wednesday, February 1, 2012

Blogging, A Reversal of Power


Judge Caught Flip-Flopping the Truth

Within the post "Absolute Immunity via Recusal" you were introduced to the fact that Earl Hickson and Markland Grant filed a timely "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. Karen M. Williams."  This ten page motion is supported by a 24 page "BRIEF IN SUPPORT OF MOTION FOR RECUSAL OF U.S.D.J. Noel L. Hillman and U.S.M.J. Karen M. Williams." With 20 days left in the "Count Down to A Recusal," let's look further into the basis in fact and law for these two judges recusal.

This is not a complicated process folks, but as the standard for the review of a motion of this sort, is that of a reasonable person armed with all the facts surrounding the circumstances, I want to make sure that we are all on the same page.  For those just joining this cause, please refer back to the parts you've missed by clicking the titled links to those postings.  You may start with the one above.

The "Introduction" to the 24 page "BRIEF IN SUPPORT OF MOTION FOR RECUSAL OF U.S.D.J. Noel L. Hillman and U.S.M.J. Karen M. Williams" was covered within the posting titled "Absolute Immunity via Recusal (part one)."  After this introduction the plaintiff's proceed to give a basis in fact and law to the twenty eight "Specific Facts and Reasons for Belief that Judges are Biased or Prejudiced" that are required to be stated in good faith for such a motion.

The first five averments of the motion covers all the preliminary stuff, you know, who's who, you can't just start running off at the mouth folks, this is not an argument with your spouse or your best friend.  Averments [5] through [10] begin on page 5 of the Brief, and this section was covered in the post proceeding this one, and said posting is titled "Basis in Fact & Law For Recusal (part I)."

This post covers the fact that Judge Noel L. Hillman is caught attempting to conceal the truth, which actually folks, amounts to nothing more than his attempt to cover his own ass.  TO LATE! Caught by his own hand, and as you will see, these to litigants confront him  on it directly.

On page 7 of the "Brief" the plaintiff's set forth that averment [11] is given basis in fact and law as follows:
Averment [11]
At http://thecasinogamingoracle.blogspot.com/2011/12/judge-should-be-placed-before-3-cannons.html I ask John and Jane Q. Public, Why is Judge Noel L. Hillman presiding over civil action 11-cv-06304 when the complaint cites him as a non-party coconspirator?  The days when you alone have access to impose the appearance of justice are gone judge Hillman.  Through the power of the internet I have the same power to share all the facts you wish to conceal.  W.E.B. DuBois, said “Awful as race prejudice, lawlessness and ignorance are, we can fight time if we frankly face them and dare name them and tell the truth; but if we continually dodge and  cloud the issue, and say the half -truth because the whole stings and shames; if we do this, we invite catastrophe.    Let us then in all charity but unflinching firmness set our faces against all statesmanship that looks in such directions.”

A person a having copy of civil action 1:11-cv-06304 on a computer capable of searching the document will find that the name “Hillman” appears some 46 times.  This same reasonable person would further find that the name “Williams” appears some 17 times.  The names of these two judges do not appear just because they were judges in the matters before the court but a close examination of the context with which these names were referenced would reveal that they are spoken of as non-party co-conspirators.  In that context even judges are not allowed to adjudicate matters they have an interest in.

The above is given a basis in law by Liteky v. United States, 510 U.S. 540, 546, holding: “Before 1974, § 455 was nothing more than the then-current version of the 1821 prohibition against a judge's presiding who has an interest in the case or a relationship to a party. It read, quite simply: "Any justice or judge of the United States shall disqualify himself in any case in which he has a substantial interest, has been of counsel, is or has been a material witness, or is so related to or connected with any party or his attorney as to render it improper, in his opinion, for him to sit on the trial, appeal, or other proceeding therein." 28 U. S. C. § 455 (1970 ed.).”

Judge Hillman, you can no longer continue to hide the truth, your interest in civil action 1:11-cv-06304 is personal as you continue to attempt to conceal your misconduct.  But your own hand has revealed the same and published it to the world via the internet broadcast of  Hickson v. Marina Associates, et al., 743 F.Supp.2d 362.  I am just telling the whole truth and nothing but the truth.
Judge Hillman operates on an "Appearance of Justice" when in reality he is concealing, and ignoring the facts holding the truth. My turn to blow up the spot folks, but those of you familiar with this writer know that I tend to get a little long winded.  I will follow the rules of blogging today by closing here.  I will trust that "inquiring minds" wanting to investigate the 46 and 17 allegations against the judges will click on the link to the complaint filed in civil action 11-cv-06304, as found within the posting titled "Got Proofs--Need Judges."

As always, I thank you for your time and support, and kindly ask that you tell a friend or two.
The Casino Gaming Oracle!

Black History Month 2012 reigns in and all still do not have equal protection of the laws and meaningful access to the Courts of these United States of America.

Tuesday, January 31, 2012

Basis in Fact & Law For Recusal (part I)


The basis in fact and law for the recusal of Noel L. Hillman and Karen M. Williams is set forth within Earl Hickson and Markland Grant's "BRIEF IN SUPPORT OF MOTION FOR RECUSAL OF U.S.D.J. Noel L. Hillman and U.S.M.J. Karen M.Williams."

The plaintiff's legal arguments as to "Specific Facts and Reasons for Belief that Judges are Biased or Prejudiced" for "Averments [5] through [10]" begin on page 5 of the Brief.  Those versed and trained in the law will know how to read each averment and then turn to the brief for it argument and basis in law.  For those not as well versed please allow these two pro se litigant's some license and you will be writing your own brief's in no time.  [Click link above and scroll to page 5 to confirm accuracy]

Averments [5] through [10] of the "Motion for Recusal" are supported by the following arguments and presentations of laws when the plaintiff's state:
"Averments [5] through [10]
The plaintiff’s anticipate that judge’s Hillman and Williams will feigned that their disqualifications are misplaced and Earl Hickson is not pleased with the rulings of Judge Hillman and that the same applies to Mr. Grant, when as we will show herein, such an outcry by them would be misplaced as their “bent of mind” will be evidenced by their inability to dispel the 28 averments of this motion and support each denial or failure to admit with documentary proof’s or  evidence supporting their denial or failure to admit.

Judge’s Hillman and Williams knew or should have known that their combined and concerted acts support a display of a deep-seated favoritism for Atlantic City Casinos’ and or a deep-seated antagonism that would deny fair judgment in favor of Hickson and Grant.  They knew and attempt to conceal the fact that truthful testimony and or answers to civil action 1:11-cv-06304 would show the lies of Christopher C. Mauro, Kathleen Bartus, Russell Lichtenstein, Victor P. Wasilauskas, made on behalf of their respective Atlantic City Casino clients, specifically, Harrah’s and Caesars Hotel and Casinos.

The above is given support in law by Liteky v. United States, 510 U.S. 540, 540 holding: “First, judicial rulings alone almost never constitute a valid basis for a bias or partiality motion.  In and of themselves (i.e., apart from surrounding comments or accompanying opinion), they cannot possibly show reliance upon an extrajudicial source: and can only in the rarest circumstances evidence the degree of favoritism or antagonism required…when no extrajudicial source is involved.  Almost invariably, they are proper grounds for appeal, not for recusal.  Second, opinions formed by the judge on the basis of facts introduced or events occurring in the course of the current proceedings, or of prior proceedings, do not constitute a basis for a bias or partiality motion unless they display a deep-seated favoritism or antagonism that would make fair judgment impossible.”

There is a maxim that “even a dog knows the difference between being kicked and tripped over.”  Plaintiff Earl Hickson has surely evidenced a proclivity to know the difference between being prejudiced and antagonized.  Now-a-days when a court wants to disallow testimony or a presentation all it has to say is the affiant lacks personal knowledge of the subject matter.  Yes context matters and the context with which judge Hillman states four times that I lacked personal knowledge to make my claims, as evidenced by the holdings of Hickson v.Marina Associates, et al., 743 F.Supp.2d 362, holding:
•  @pg.373- “At this stage of litigation, Hickson has not demonstrated the malignant action or intent necessary to sustain this claim. Again, he relies entirely on speculation and self-conceived conclusions, and not personal knowledge of facts or events.”

•  @pg.375- “As articulated above, Hickson presents no evidence, other than broad accusations devoid of personal knowledge, to demonstrate the requisite intent or action to sustain that cause of action under Section 1983.”

•  @pg.377- “The Court further stresses that, even accepting Hickson's averments as if they were set forth in an affidavit, only those facts to which Hickson has personal knowledge may be considered as true. See Fed.R.Civ.P. 56(e)(1) ("A supporting or opposing affidavit must be made on personal knowledge, set out facts that would be admissible in evidence, and show that the affiant is competent to testify on the matters stated.")”

•  @ Footnote[4]- “The Court further stresses that, even accepting Hickson's averments as if they were set forth in an affidavit, only those facts to which Hickson has personal knowledge may be considered as true.”

Now that Earl Hickson has personal knowledge and can substantiate judge Hillmans affinity to protect the Atlantic City Casinos’ continued interest in concealing how they violate their patrons civil and constitutional rights judge Hillman reveal his “bent of mind” in favor of the Atlantic City Casinos’ and against African-American pro se litigants as evidenced by his willingness to cite the New Jersey Casino Control Act while rendering an opinion in a case where a non-African-American was kidnapped from the Borgata.  This man could afford an attorney and Hillman granted him protection of the laws and further stated in Friedman v. Borgata, 2009 U.S.  Dist. LEXIS 29084 at [*19]: “First, the Casino Control Act, N.J.S.A. 5:12-1 to -210, is the codification of the "common law right [of a casino licensee] to exclude or eject permanently from its casino hotel any person who disrupts the operations of its premises, threatens the security of its premises or its occupants, or is disorderly or intoxicated.”  This law is for the casino, and it does not provide permission for a city police department, otherwise acting unreasonably, to drive an intoxicated patron to the bus station and leave him there.

The above citation from Friedman v. Borgata was set before judge Hillman within Earl Hickson’s “Letter Brief in Lieu of Formal Brief, In Support of Motion for Revision of Courts 9/27/2010 Order & Opinion,”  which is docket item [67].  Is there any wonder that the Clerk of the Court has given this docket item a “Text Description” of: “MOTION for Reconsideration of 65 Order on Motion for Summary Judgment, 64 Opinion by EARL D. HICKSON. (js) (Entered: 10/12/2010).”  This fact is just one of many that support’s your proclivity to conceal document’s judge Hillman.   The a-fore mentioned text description conceals the filing of the Letter Brief from the public. Who knows how many pro se litigants, or other African-American’s you have denied equal protection of the laws to or for how many years you have practiced what I have labeled Judicial Stealthy Hubristic Injustice Tactics (JSHIT)."

Now you, the public at large have access to the same legal arguments and basis in decisional case law that Judge Noel L. Hillman and Karen M. Williams must consider on or before February 21, 2012.  Now Earl Hickson and Markland Grant ask that you keep in mind the holding of the Federal Statutory law cited in the introduction of the motion which says: "When a party seeks to disqualify a judge for personal bias or prejudice under 28 U.S.C.A. § 144, the judge must examine the affidavit or declaration and accompanying certificate to determine whether they are timely and legally sufficient.  Only if the documents meet strict scrutiny does disqualification become mandatory.  If the affidavit or declaration is presented in time and in proper form, the court must take as true the facts set out in the affidavit or declaration.  Only questions of law are presented and there can be no dispute about the truth or falsity of the allegations of the affidavit or declaration."

Reasonable people, now that you are armed with the above facts, and if neither judge can present evidence to the contrary should these two judges be recused based upon averments [5] through [10].

Thank you, for viewing this accurate and true copy of the documents filed in this action.  Earl Hickson and Markland Grant ask that you continue to follow this walk through these documents, and we pray that you will comment as to your confidence in the impartiality and integrity of these judges and their band of cohorts.

The Casino Gaming Oracle!

Black History Month 2012 reigns in and all still do not have equal protection of the laws and meaningful access to the Courts of these United States of America.