Tagged: Laura Taylor Swain

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?

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. 😩😂😩😂😆 

I know there’s a conspiracy taking place to deprive me of my constitutional and statutory rights under the color of law because two out of the three judges that denied my appeal are BLACK!! smdh.

Laura Taylor Swain

I’m disgusted. I just googled the third judge — district judge Laura Taylor Swain of the Southern District of New York — and found this!! I gasped when I saw her face. Smdh. Black people, our lives are in jeopardy. If you don’t wake up and start paying close attention to what’s happening, the Civil Rights Act of 1964 and other antidiscrimination laws created as a direct result of the black-led civil rights movement of the 1950s and 1960s will be entirely eviscerated. Swain needs to be IMPEACHED!

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!