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Earl D.

Hickson 719 B Kentucky Avenue Atlantic City, New Jersey, 08401 (609) xxx-xxxx Plaintiff, Pro-Se

AND

Markland K. Grant 1920 Union Street Apt. 4D Brooklyn, NY 11233 (646) xxx-xxxx Plaintiff, Pro-Se

UNITED STATES DISTRICT COURT DISRTICT OF NEW JERSEY


CIVIL ACTION NO. 1:11-cv-06304

____________________________________________________
Earl D. Hickson and Markland K. Grant, Plaintiff(s),

Vs.
Christopher C. Mauro, Kathleen M Bartus, Sharon Fedaczynsky, Russell L. Lichtenstein, Victor P. Wasilauskas, Vincent J. Rizzo, Jr., Marvin L. Freeman, Bruce Weeks, Boardwalk Regency Corp., d/b/a, Caesars Atlantic City Hotel and Casino, Marina Associates d/b/a Harrahs Casino Hotel Atlantic City, i/s/h/a Harrahs Hotel and Casino a/k/a Harrahs Atlantic City, Defendant(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

____________________________________________________

Table of Contents
Specific Facts and Reasons for Belief that Judges are Biased or Prejudiced ................................. 3 Wherefore ....................................................................................................................................... 8 CERTIFICATION .......................................................................................................................... 8 Certificate of Pro Se Plaintiffs Supporting Declaration of Bias or Prejudice ............................... 9 PROOF OF SERVICE .................................................................................................................. 10

Earl D. Hickson and Markland K. Grant, in accordance with 28 U.S.C.A. 1746, do hereby declare under penalty of perjury that: 1. Earl D. Hickson is a plaintiff in civil action 1:11-cv-06304. 2. Markland K. Grant is a plaintiff in civil action 1:11-cv-06304. 3. U.S.D.J. Noel L. Hillman and U.S.M.J. Karen M. Williams, judges of the court in which this action was commenced and is now pending, and before whom it proceeded, has a personal bias and prejudice against the above named plaintiffs and in favor of Harrahs Hotel and Casino, Caesars Atlantic City Hotel and Casino, Christopher C. Mauro, Russell L.
Lichtenstein, Kathleen M Bartus, and the other defendants named in this action.

4. The facts and reasons for belief that bias or prejudice exists on the parts of Judges Noel L. Hillman and Karen M. Williams are as follows: Specific Facts and Reasons for Belief that Judges are Biased or Prejudiced Unlike U.S.D.J. Stephen C. Robinson, who claimed not to know of five relevant facts in Levine v. Gerson, 334 F. Supp 2d 376, 377, judges Noel L. Hillman and Karen M. Williams cannot deny that they individually and collectively knew the following: 5. Noel L. Hillman and Karen M. Williams cannot deny that they individually and collectively knew of plaintiffs Earl D. Hickson and Markland K. Grant. 6. Noel L. Hillman and Karen M. Williams cannot deny that they individually and collectively knew of defendant Christopher C. Mauro. 7. Noel L. Hillman and Karen M. Williams cannot deny that they individually and collectively knew of defendant Kathleen M. Bartus. 8. Noel L. Hillman and Karen M. Williams cannot deny that they individually and collectively knew of defendant Marina Associates d/b/a Harrahs Casino Hotel Atlantic City. 9. The two judges, Noel L. Hillman and Karen M. Williams cannot deny that they individually and collectively knew of defendant Sharon Fedaczynsky. 10. U.S.D.J. Noel L. Hillman and U.S.M.J. Karen M. Williams knew that the new collective action
filled by Earl D. Hickson and Markland K. Grant would reveal facts that the above averments #5 through 9 are true, as Mauro, Bartus and Fedaczynsky would have to give testimony in and on their own behalf. 11. U.S.D.J. Noel L. Hillman and U.S.M.J. Karen M. Williams knew that the only way to prevent the knowledge of their previous acts from becoming known would be to halt the progress of civil action 1:11-cv-06304, so when it was given to U.S.M.J. Karen M. Williams she naturally referred it to U.S.D.J. Noel L. Hillman, while she (Williams) knew Hillman was referenced as a non-party conspirator.

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 3

purported deposition of Sharon Fedaczynsky, which brought into question, this documents validity, yet Noel L. Hillman couched his opinion of September 27, 2010 on this document. 13. Noel L. Hillman knew that Christopher C. Mauros Motion for Summary Judgment, submitted on behalf of his client Harrahs was supported and couched upon said defendants answers to the Original Complaint and were not signed by any corporate officer of Harrahs, yet he did couch his opinion of September 27, 2010 on this falsehood. 14. Judges Hillman and Williams knew form the documents filed within the court that upon the proceeding of 1:11-cv-06304, Christopher C. Mauro would have to reveal the truth as to him
representing to the court, by filing with the same several document signed on behalf of Vance Armstrong, who was never a party to any proceeding before the court, yet judge Hillman accepted these documents.

15. The two judges, Noel L. Hillman and Karen M. Williams cannot deny that they individually and collectively knew that the proceeding of 1:11-cv-06304 would reveal the
default on Alexander Lovas in Earl Hicksons civil action 08-cv-02407.

16. 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 D. Hickson, that were contrary to other documented facts within the record, yet judge Hillman accepted these documents. 17. The two judges, Noel L. Hillman and Karen M. Williams cannot deny that they individually and collectively knew that 08-cv-02407 was supported by Exhibits A through Z, in accordance with FRCVP 10, yet judge Hillman willfully ignored the substantial record as evidenced by the complete lack of reference to any of these documents in any of has rulings. 18. Judge Noel L. Hillman cannot deny that he was specifically requested to give judicial notice to facts that would aid in his determination that the Atlantic City Casinos are exacting an unlawful machination of evicting casino patrons and violating said patrons civil and constitutional rights. 19. Judges Hillman and Williams knew form the courts own docket of 08-cv-02407 that docket item [11] was removed from the docket and said removal could be construed as a cover for the fact that George Morton submitted to the jurisdiction of the court on 12/17/2008, and that said order was written and signed by Magistrate Joel Schneider. 20. Judges Hillman and Williams knew from the above averment #19, that U.S.M.J. Schneiders knowledge of the Atlantic City Casinos machination could not be denied as he had previously sat on the civil action of Earl D. Hickson and he was privy to Hicksons Exhibit M which is a transcript of a purported eviction trial of Markland K. Grant, and Mr. Grant has a pending matter under judge Schneider, civil action 1:10-cv05653-RBK-JS. 21. The two judges, Noel L. Hillman and Karen M. Williams cannot deny that they individually and collectively knew that the United States Third Circuit Court of Appeal misrepresented the fact that Earl Hickson had filed a complaint against several state 4

employees, and that court name Vance Thompson and Anna Haag as being amongst said state employees when their records clearly should have prevented such a false statement, which further could be considered favoritism towards the NJ casinos by placing their employees under the protection of the States 11 Amendment immunity. 22. The two judges, Noel L. Hillman and Karen M. Williams cannot deny that they individually and collectively knew that there is a practice within the Clerk of the Courts office where by Summons were not issued properly and lacked the courts seal, which could be construed as bias towards pro se litigants. 23. The two judges, Noel L. Hillman and Karen M. Williams cannot deny that they individually and collectively knew or should have known that their presiding on civil action 1:11-cv-06304 could be construed as their use of their positions as judges to prevent disclosure of the Continuing Objects and or Goals of This Civil Conspiracy, as detailed on pages 8 through 10 of the complaint. 24. U.S.D.J. Noel L. Hillman and U.S.M.J. Karen M. Williams, by way of response to this motion, must show that but for their absolute immunity as judges they would be held as participants in the scheme to exact the following: A. The prevention of an Atlantic City, New Jersey casino from being held liable for the violation of its patrons civil and constitutional rights as protected by the Civil Rights Act of the United States of America and the Constitutions of the United States and the State of New Jersey. B. Concealment of the unlawful scheme whereby the Atlantic City Municipal Court is used as an arm of the New Jersey Casino Control Commission, whereby it [A.C. Municipal Court] abrogates its authority to Atlantic City casinos and issues documents that state that a patron is barred from the sending casino, amounting to an eviction of said patron in violation of New Jerseys Casino Control Act, its Administrative Codes and decisional law from the Supreme Court of the State of New Jersey, in Knight v. Margate, which establishes that no Municipal Court, especially those of Southern New Jersey, should have any dealings in the matters of a New Jersey casino. C. The hiring of law firms that staff liars for hire, willing to aid and abet the Atlantic City Casinos in the concealment and avoidance from liability of A and B above, all while taking the opportunity to exhibit their prowess at deception, fraud, evidence tampering, willful ignorance, and acceptance of fees in exchange for their prostitution of their oaths as judicial officers and violations of the Rules of Professional Conduct, plus Federal and State criminal statutes.

D. Utilization of attorneys, hired for purposes of C above, specialized knowledge, as lawyers, to circumvent and violate the law, take unfair advantage of those unrepresented by lawyers so trained and or subscribing to the ways and means of deception used to stir favors from the courts judges and judicial officers. Said favors made to appear as mistakes or accidents. Most importantly, as exhibited in this action, the hiring and or using lawyers that will not object to and do take full advantage of a known indigent pro se litigants lack of financial resources needed to secure depositions, travel to make effective investigations, or simply sustain the cost of litigation, cause frustrations whereby they just give up, fade away, or abandon their God given blessings, tasks and or assignments. E. The presentation of misleading documents to Courts of law that can pass as legitimate to the un-trained or those willing to practice willful ignorance. F. Acceptance of what is made to appear as accidents or mistakes by judicial officers purporting to be trained in their ministerial duties, yet upon close inspection of the facts, acts, and physical evidence it is plain to any reasonable person that said acts are not the product of mistake or accident as most reasonable persons accept the fact that the odds of lighting striking in the same place twice and in the exact same manner are very high and almost impossible. So too, are the odds that a machine such as the Courts PACER SYSTEM computer being able to pick out, set itself to overexpose, specific pages containing valid judicially noticeable laws, accurate photographic snapshots from surveillance video that a jury would be able to authenticate and see, and further specifically train itself to retroactively give page ID numbers to certain and not all documents entered on said system to a specific case. Computers do what the human hand tells it to do, it is connected to the human brain by the hand and said hand is controlled by intent of the brain giving it the impulses to press the proper keys to exact said brains desire. G. The issuance of decisional case law that counteracts that of other Circuits of the United States that hold casinos within their jurisdiction liable when they violate a patrons civil rights.

H. The issuance of decisional case law that initiates and perpetuates a trend that those of African heritage are not afforded the same rights as white patrons of American casinos. I. Utilization of Judge Noel L. Hillmans and Robert B. Kuglers positions whereby they [the judges] can willfully ignore applicable New Jersey laws and regulations that regulate New Jersey casinos, find phrases within written case law to support their purported administration of justice, all the while knowing that said citings are not made using the full context of said decisional case law. Yet the judges being able to conceal their affinities for New Jersey casinos and the State itself , would bear the cross of allowing misconduct within their courts, accept forged documents, ignore clear issue of facts, ignore relevant and controlling facts such as the formation of aleatory contracts, abandonment and judicial notice of persuasive decisional law and relevant statutes of New Jerseys Casino Control Act and New Jerseys Administrative Code (Title 19) relating to the regulation of New Jersey casinos. J. All of the above A through I are carried out knowing that the lawyers would not be checked by the respective judge, the judge would be protected by absolute immunity, and a misguided prayer that the victims, Hickson and Grant, would lack the wherewithal to see through this shocking scheme. But God All Mighty has His hand in this matter and the two are blessed with understanding, courage and devoid of fear. 25. Noel L. Hillman and Karen M. Williams should admit that the attempted dismissal of civil action 1:11-cv-06304 appears to be their last unethical effort prevent a jury from hearing the truth and allowing Christopher C. Mauro, Kathleen M. Bartus, Sharon Fedaczynsky, Russell L. Lichtenstein, Victor P. Wasilauskas, Vincent J. Rizzo, Jr., Marvin L. Freeman, Bruce F. Weeks, Boardwalk Regency Corp., d/b/a Caesars Atlantic City Hotel and Casino, and Marina Associates d/b/a Harrahs Casino Hotel Atlantic City, to have a means to avoid answering civil action 1:11-cv-06304 as they are aware of the action and were sent and all did receive Requests for Waiver of Summons dated Nov. 4, 2011 and Hillmans purported opinion of Nov. 30, 2011 could be construed as a means to suppress his favored parties having to comply with said request in accordance with the law as evidence by not one defendant so complying. 26. Judge Hillman and Williams must admit that the failure of any named defendant to respond after being given notice by way of a Request for Waiver of Summons supports an inference that they all knew that judge Hillman would come to their aide, and the evidence further supports that the plaintiffs were either given an incorrect address for Ms. Fedaczynsky by Christopher C. Mauro and or the cohorts have persuaded and reached her as well. Tell the truth judge Hillman or recuse yourself. 7

27. Noel L. Hillman and Karen M. Williams cannot deny that the above averments #5 through #26 unless supported by substantial evidence to the contrary, support and offer valid grounds for their recusal from civil actions 1:11-cv-06304 and 1:08-cv-02407. 28. Lastly, Noel L. Hillman and Karen M. Williams must admit that this matter has been put into the interest of the public as it relates to the integrity of a United States District Court and John and Jane Q Public following these events via Earl Hicksons truth revealing venue @ thecasinogamingoracle.blogspot.com deserve to know and await the truth.

Wherefore
Plaintiffs Earl Hickson and Markland Grant pray that U.S.D.J. Noel L. Hillman and U.S.M.J. Karen M. Williams proceed no further in the cause of 1:11-cv-06304 and that another judge be designated in this cause. The plaintiffs further pray that their IFP status from their previous actions satisfy the immediate issuance of Summons properly signed by the clerk of the court, and stamped with the seal of the court, so that these plaintiffs may have Christopher C. Mauro, Kathleen M. Bartus, Sharon Fedaczynsky, Russell L. Lichtenstein, Victor P. Wasilauskas, Vincent J. Rizzo, Jr., Marvin L. Freeman, Bruce F. Weeks, Boardwalk Regency Corp., d/b/a Caesars Atlantic City Hotel and Casino, and Marina Associates d/b/a Harrahs Casino Hotel Atlantic City served by the U.S. Marshall. The plaintiffs lastly pray that U.S.D.J. Noel L. Hillman and U.S.M.J. Karen M. Williams repent and issue the attached Order Designating Another Judge, or one similar in form and substance.

CERTIFICATION
Plaintiffs Earl Hickson and Markland Grant, based upon their collective first-hand knowledge of the facts, hereby certify that we have investigated and satisfied ourselves that all statements are based on fact and based on prevailing law and all copies of exhibits are accurate and true copies of said documents.

Dated: _____________________

________________________________ Earl Hickson, Plaintiff Pro Se

Dated: _____________________

________________________________ Markland K. Grant, Plaintiff Pro se

Certificate of Pro Se Plaintiffs Supporting Declaration of Bias or Prejudice

I, Earl D. Hickson, the undersigned plaintiff pro se in this cause, hereby certify that the above declaration, in lieu of affidavit pursuant to 28 U.S.C. 1746, made by me and upon the knowledge I possess is made in good faith and continues my efforts to make injustice known.

Dated: _________________________

__________________________________ Earl D. Hickson, Plaintiff, Pro Se

I, Markland K. Grant, the undersigned also a plaintiff pro se in this cause, hereby certify that the above declaration, in lieu of affidavit pursuant to 28 U.S.C. 1746, made by me and upon the knowledge I possess is made in good faith and continues my efforts to make injustice known.

Dated: _________________________

__________________________________ Markland K. Grant, Plaintiff, Pro Se

PROOF OF SERVICE
Earl D. Hickson and Markland K. Grant, at the risk of perjury do hereby certify that on January 18, 2010, an accurate and true copy of this 10 page Motion for Recusal, and 24 page Brief in support was served upon the individuals listed below.

TO:
________________________________________ ________________________________________ ________________________________________ ________________________________________ ________________________________________ ________________________________________

TO:
________________________________________ ________________________________________ ________________________________________ ________________________________________ ________________________________________ ________________________________________

Dated: _____________________

________________________________
Earl Hickson, Plaintiff Pro Se

Dated: _____________________

________________________________
Markland K. Grant, Plaintiff Pro se

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