Tagged: Dennis Jacobs

read my Em. Motion for Reconsideration En Banc, or in the Alternative, Motion to Recall the Mandate Pending the Filing of a Petition for a Writ of Certiorari to the Supreme Court

Scales-Of-Justice

The Second Circuit rendered its decision on March 11, 2015. I received the Order in the mail on March 17, 2014 and pursuant to Fed. R. App. P. 40, the Motion for Reconsideration was due by March 25, 2014. I actually wrote this 15-page Motion in two days after I decided to scrap the Motion I was working on.

This case was destined to reach the Supreme Court, so I wasn’t too concerned about the decisions of the lower courts because I know for a fact that as a matter of law, I have proven my claims against William Morris, Loeb & Loeb LLP, Michael P. Zweig and others beyond a reasonable doubt.

In the end, it all works out because writing this Motion helped prepare me to write my petition for a writ of certiorari. If the Second Circuit is going to issue another 2 sentence Order falsely saying my appeal “lacks an arguable basis either in law or in fact,” then I asked them to issue their decision no later than April 1, 2015. I think that’s pretty reasonable since they aren’t upholding the law or discussing the facts of the case…or even providing an ethical judicial opinion which is required of an Article III federal judge in a case of this magnitude.

To Clarence and his racist white buddies in black robes on the bench: “I been waiting on [ya’ll] at the do’!” Lmao!!! (shout out to Ms. Foxy!!)

if an appeal is basically a summary of the legal arguments raised in the lower court, is it possible for the appellate court to conclude that a party’s appeal “lacks an arguable basis either in law or in fact,” if it took the district court judge 26 pages to issue an Order that purposefully ignored the facts of the case and manifestly disregarded the prevailing law?

“The judiciary’s power comes from its words alone — judges command no army and control no purse. In a democracy, judges have legitimacy only when their words deserve respect, and their words deserve respect only when those who utter them are ethical. Opinion writing is public writing of the highest order; people are affected not only by judicial opinions but also by how they are written. Therefore, judges and the opinions they write — opinions scrutinized by litigants, attorneys, other judges, and the public — are held, and must be held, to high ethical standards. Ethics must constrain every aspect of the judicial opinion.”

The reason they can’t say anything is because I have proven each and every single one of my claims against William Morris, Loeb & Loeb LLP, Michael P. Zweig, Christian Carbone, P. Kevin Castel, Timothy K. Lewis, the American Arbitration Association, the United States of America and others beyond a reasonable doubt. The conspiracy to interfere with the human rights of people of African descent is still on-going. Can’t you see? Who the fuck do these people think they are to deny my appeal without explanation or reason or mention of my claims of “fraud upon the Court”? Jacobs, Swain & Lohier: You are not God nor are you above the law. You three, as well as Chin, Lynch, Hall, Castel, Patterson, and Preska, will be held accountable for your highly unethical and criminal conduct.

Source: Alifya V. Curtin, Gerald Lebovitz & Lisa Solomon. Ethical Judicial Opinion Writing. The Georgetown Journal of Legal Ethics. Vol. 21, 237. 2008.

Since the allegedly “IMPARTIAL” and “INDEPENDENT” three-member panel consisted of two individuals of African descent, they were in the best position to explain to me why ALL of my legal arguments, especially my Title VII claims, were not sufficient or “arguable” as a matter of law, especially since the only lawfully appointed arbitrator – David L. Gregory of the American Arbitration Association – concluded that “William Morris Endeavor Entertainment LLC discriminated against [me] in violation of pertinent federal, state, and local law prohibiting discrimination in employment on the basis of race” and awarded me the full gamut of monetary damages, including punitive damages and pro se attorneys fees.

As token minorities in America’s historically all-white judicial system, anyone who thought that those two [Laura Taylor Swain of the Southern District of New York and Raymond J. Lohier, appointed by Clinton and Obama respectively] had enough power to reverse the decision of Republican appointed federal judge P. Kevin Castel and say that William Morris’ 117 year pattern and continuing practice of excluding qualified African Americans from meaningful positions of employment violated the Civil Rights Act of 1964 & New York City Human Rights Law, that Arbitrator Gregory issued a “final” decision regarding the issue of arbitrability and liability and thus his Partial Final Award was reviewable by Castel, that Gregory’s disqualification by the AAA violated due process or that Loeb & Loeb LLP and Michael P. Zweig have engaged in a “pattern” of “fraud upon the Court” to prevent civil rights cases against William Morris from reaching an impartial jury in New York City, must be dumb or STUPID AS FUCK. 😩😂😩😂😆 

in ONE paragraph, the Second Circuit DENIES my appeal. falsely states that it “lacks an arguable basis either in law or in fact” despite the fact that the only LAWFULLY APPOINTED FINDER OF FACT in the forum chosen by William Morris admitted concealed evidence into the evidence of record in my case and concluded that WME “discriminated against [me] in violation of pertinent federal, state, and local law prohibiting discrimination in employment on the basis of race.” SMDH!l

The Improvident Order:

Here’s the Reply that I submitted to my Ex. Motion for Extraordinary Relief on December 15, 2015:

The three judges that issued this improvident order are former Chief Judge Dennis Jacobs, Raymond J. Lohier, Jr. [Af. American] and district judge Laura Taylor Swain of the Southern District of New York. [Why did they assign a district court judge who works with Castel to review my appeal???] In addition to the Robert P. Patterson, P. Kevin Castel and the three circuit judges [Denny Chin, Peter W. Hall and Gerard E. Lynch] who ignored my arguments when I sought to appeal Castel’s erroneous July 20, 2011 Stay Order which compelled my case into arbitration after ignoring my claims and legal arguments, these corrupt “judges” need to be IMPEACHED for their intentional violations of the U.S. Constitution, their Oaths of Office, as well as the prevailing law!

“If judges are not independent, they will be subject to influence that could distort the outcomes of cases, skew the development of substantive law, and detract from public confidence in the judicial system.”

The independence of American trial judges interacts in a complex way with the quality of their work product. On the one hand, independence is itself a quality enhancing policy. If judges are not independent, they will be subject to influence that could distort the outcomes of cases, skew the development of substantive law, and detract from public confidence in the judicial system. Along this dimension, independence is positively correlated with quality. On the other hand, independence also comes with a cost. Power unchecked becomes power abused. A corporate executive who performs badly can be penalized by receiving lower compensation or suffering a demotion and must be prepared to receive criticism from others in a team setting. But in a world of perfect judicial independence, such constraints would not apply to trial judges. Even if they perform badly, they would still receive deference from lawyers who appear before them, would still retain the status, salary, and perquisites of office, and would still be emperors of their small domains. Human beings in robes, judges shirk when they can get away with it.

Source: Geoffrey A. Miller. Bad Judges 83 Tex. L. Rev. 431, 457 2004.