Tagged: motion

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!!)

with ONLY 5 days left to submit Motion to the 2nd Cir., i’ve decided to start new again. just finishing new draft at 5:45am.

IMG_7085

With absolutely no help, I feel like I’m working four full-time jobs right now without any pay while Loeb & Loeb LLP have been paid millions by William Morris to ensure that legitimate claims of racial discrimination and human rights violations are never allowed to reach and/or be decided by an impartial jury.

Please donate to my legal fund, so I can afford the costs of filing my appeal with the appellate court should they also refuse to restore my in forma pauperis status. Click here: www.gofundme.com/campaign2endracism.

“The United States of America has had 50 years to get its shit together, yet, our nation continues to maintain its racial caste system and engage in crimes against humanity — all in the name of ‘democracy.'”

Source: Plaintiff’s October 3, 2014 Fraud Upon the Court Motion, 52.

“Under section 12 of the Federal Arbitration Act (9 U.S.C. § 12), a notice of motion to vacate a final award must be served within 90 days of issuance of the Award. Case law in this Circuit supports the proposition, that unless the parties had agreed to a bifurcated award (which agreement does not exist in this case), a partial award as to liability is not a ‘final award’ for the purposes of a motion to confirm, modify or vacate.” — Loeb & Loeb LLP attorney Christian Carbone

There are so many misrepresentations made in this short statement. Bifurcated proceedings are typical in employment discrimination cases and I did request for Arbitrator Gregory to bifurcate the proceeding. Actually, the proceeding had to be bifurcated, because William Morris and Loeb & Loeb LLP refused to comply with my discovery requests, which also sought various financial statements so my economic expert could help me compute my damages in full.  Additionally, § 12 states nothing about the Award being “final” in order to seek to have it confirmed, modified or vacated [by the federal court]. Arbitrator Gregory issued a “Partial Final Award” and he did not only decide the issue of liability, he awarded me back pay, front pay, compensatory & punitive damages, “reasonable fees and costs, as a pro se non-attorney prevailing party on statutory claims in a case of considerable procedural and substantive complexity,” and more. Although Carbone’s statement is inaccurate, federal judge P. Kevin Castel told me not to submit my Fraud Upon the Court Motion after giving me permission to do so and told me to continue arbitrating in “good faith.” Smh.

Source: March 7, 2014 Letter to P. Kevin Castel

i’m so excited about this motion i’m currently writing. after two and a half years, i finally get to give this Bush appointed, REPUBLICAN judge who erroneously put me into arbitration a piece of my black LEGAL mind.