For the last three months, I have had the psychologically daunting task of addressing the Second Circuit’s error in denying my appeal without reason. After extensive research, this motion asks the Court to recall its mandate and either: (1) vacate its improvident order and articulate en banc’s decision or (2) articulate en banc’s decision and stay the mandate for 90 days, pending the filing and disposition of a petition for a writ of certiorari. Read my arguments discussing why the Second Circuit erred by denying my appeal as “moot,” why the Court is guilty of violating many of its ethical Canons under the Judicial Code of Conduct and why this is part of a larger conspiracy over the last thirty two years by the majority conservative judiciary to eviscerate many of the gains made during the civil rights movement, which may create a cause of action for reparations if the Court can’t remain impartial.