Complaint Review: AMERIQUEST MORTGAGE COMPANY - Orange California

Hey John Where did they go, hum maybe they needed to save some of that money, So they can GIVE it to a good lawyer..... We are still watching you guys at ameriquest, amc, and argent.... you better save some of that money or hide it.... loll Are you still looking for a pony,, watch out for that Trojan horse. Now you guys will know how it feels to lose your home, hum and everything you own, Ooops, I mean use to own. HAVE A NICE DAY!!!

These search terms have been highlighted: v ameriquest tila respa Atoo Heera Sakhrani 300 Gorge Road, Suite #59 Cliffside Park, New Jersey 07010 201-840-9880 IN THE GENERAL ASSEMBLY OF THE LEGISLATURE FOR NEW JERSEY Atoo Heera Sakhrani, sui juris Petitioner ) PETITION FOR A BILL IMPEACHMENT AGAINST NEW JERSEY SUPERIOR COURT JUDGE GERALD ESCALA (BERGEN COUNTY) DUE TO ACTS OF TREASON; ) JUDICIAL / OFFICIAL vs. )MISCONDUCT; JUDICIAL TYRANNY; GOVERNMENT OPPRESSION; VIOLATION OF OATH OF OFFICE; OBSTRUCTION NEW JERSEY SUPERIOR COURT )OF JUSTICE; NEW JERSEY STATE JUDGE GERALD C. ESCALA, J.S.C. ) CONSTITUTIONAL RIGHTS Individually, and in his Official and ) VIOLATIONS; RACIAL BIAS; Corporate Capacity, R.I.C.O.1947 New Jersey State Constitution-- Respondent. ) Article VI, Section VI, Paragraphs 45; Article VII, Section III, Paragraphs 1, 2 & 3 PETITION A. New Jersey State Constitution, Article 7, Section 3, Paragraph 1: "The Governor and all other State officers, while in office and for two years thereafter, shall be liable to impeachment for misdemeanor committed during their respective continuance in office." B. New Jersey State Constitution, Article 7, Section 3, Paragraph 2: "The General Assembly shall have the sole power of impeachment by vote of a majority of all the members. All impeachments shall be tried by the Senate, and members, when sitting for that purpose, shall be on oath or affirmation "truly and impartially to try and determine the charge in question according to the evidence". No person shall be convicted without the concurrence of two- thirds of all the members of the Senate. 1. The New Jersey State Constitution of 1947 provides two (2) other concepts for impeachment: a. Article VI, Section VI, Paragraph 4: "The Justices of the Supreme Court and the Judges of the Superior Court shall be subject to impeachment, and any judicial officer impeached shall not exercise his office until acquitted. The Judges of the Superior Court shall also be subject to removal from office by the Supreme Court for such causes and in such manner as shall be provided by law. II b. Article VI, Section VI, Paragraph 5: "Whenever the Supreme Court shall certify to the Governor that it appears that any Justice of the Supreme Court or Judge of the Superior Court is so incapacitated as substantially to prevent him from performing his judicial duties, the Governor shall appoint a commission of three persons to inquire into the circumstances; and, on their recommendation, the Governor may retire the Justice or Judge from office, on pension as may be provided by law." 2. Pursuant to New Jersey Statute N.J.S.A. 41:1-1: "Every person who is or shall be required by law to give assurance of fidelity and attachment to the Government of this State shall take the following oath of allegiance: "I,. . . . . . . . , do solemnly swear (or affirm) that I will support the Constitution of the United States and the Constitution of the State of New Jersey, and that I will bear true faith and alleqiance to the same and to the Governments established in the United States and in this State, under the authority of the people. So help me God." PRELIMINARY STATEMENTS 3. Respondent, Superior Court, Bergen County Judge Gerald C. Escala, by taking the oath to support, protect, defend and uphold the Constitution of the United States and Constitution of New Jersey, also falls under the purview of the Federal Statutes, United States Code, 28 U.S.C. 372 et seq. regarding the removal of judges from office not acting in good behavior, disability, incompetence or for other reasons. 4. Article VII, Section III, Paragraph 2 of the New Jersey Constitution provides for the filing of a complaint with the General Assembly, in this instance where the above named Respondent has, and continues to engage in conduct prejudicial to the effective and expeditious administration of the business of the courts, due to mental and physical disability, and for treasonous acts against residents of New Jersey and citizens of the United States, more fully demonstrated hereinafter. 5. Furthermore, Title 28 U.S.C. 372 (c)(l) et seq., also provides for the filing of a written complaint containing a brief statement of the facts constituting such conduct aforementioned. 6. Because neither the New Jersey Constitution or New Jersey Statutes have a formal scheme for filing of written complaints involving judicial impeachment, Petitioner will rely upon the United States Code, 28 U.S.C. Sections 351 (a) and 372 (c)(l), as his source and guidance in this matter. Since Article I, Paragraph 2 of the New Jersey Constitution states that all political power is inherent in the people, and that Government is instituted for the protection, security and benefit of the people, and the people have the right at all times to alter or reform the same, whenever the public good may require it, Petitioner has the right to file this Petition for Impeachment since Petitioner has no other remedies because no public official will remove judges from office or sue them due to alleged fictional immunities. STATEMENT / HISTORY AND NATURE OF PROCEEDING FOR PETITION FOR A BILL OF IMPEACHMENT AGAINST NEW JERSEY SUPERIOR COURT JUDGE GERALD C. ESCALA 7. Petitioner, Atoo Heera Sakhrani, has been involved with the New Jersey court system involving allegedly fraudulent foreclosure matters, involving case docket numbers F-18721-03, Deutsche Bank Trust Company v. Sakhrani; F-18867-03, Washington Mutual, et al. v. Sakhrani; C-86-05, Sakhrani v. Washington Mutual, et al.; and C-87-05, Sakhrani v. Ameriquest. He has been unceremoniously deprived of his fundamentally protected due process rights, equal protection rights, rights to property and liberty, without justification, proof or substantiation by Respondent. Respondent has denied Petitioner any and all rights with which to defend himself or appoint competent, effective counsel to properly defend Petitioner in order to "even the playing field" against the depradations of the lending institutions seeking to steal Petitioner's properties through predatory lending practices schemes. Respondent, being a state judicial officer, has caused the state to improperly and unconstitutionally interfere with Petitioner's fundamentally secured rights. 8. Respondent has interjected his own personal biases and improprieties against Petitioner without justification. Respondent has discriminated against Petitioner on the basis of Petitioner's race (Asian American) and senior citizen status. Respondent will no doubt attempt to argue that Petitioner is a "disgruntled litigant" seeking to "circumvent the court process for his own needs". These are the typical comments used as a tactic by the New Jersey judiciary to hide behind when they violate the rights of litigants who come before them for relief. Respondent has usurped his judicial authority by siding with the lending institutions and their attorneys involved against Petitioner. Respondent is aiding and abetting the lending institutions and their attorneys in predatory lending practices in violation of numerous state and federal laws and regulations. 9. Respondent has made and continues to make threats against Petitioner. Respondent has screamed at Petitioner in open court. Respondent has called Petitioner names. He refers to Petitioner as being "uncivilized" and "indecent". Respondent has failed to read the pleadings submitted by Petitioner. An example of such is that Respondent failed to read Petitioner's answers, affirmative defenses and counterclaims in the cases docketed under numbers F-18721-03, Deutsche Bank Trust Company v. Sakhrani, and F-18867-03, Washington Mutual, et al. v. Sakhrani, in which each counterclaim listed over 300 points against the lender and its representatives and agents. Respondent also failed to read Petitioner's affidavits which also contained over 300 points against the lender and its representatives and agents. 10. Respondent Escala made false representations and lies on the record by purporting he read Petitioner's case and addressed the merits, yet struck and dismissed Petitioner's answers, counterclaims and affirmative defenses on summary judgment and ex parte applications. 11. This indicates incompetency and impropriety on the part of Respondent. Respondent has violated the Code of Judicial Conduct, Canons 1, 2 and 3. Respondent has failed to uphold the integrity of the Court and has not acted impartially by siding with the lending institutions and their attorneys on every motion and argument presented before him, even though the laws and the facts are totally on the side of Petitioner. 12. Respondent has not acted diligently, as he has failed to read Petitioner's pleadings. It has gotten so bad, that Respondent has had to resort to name calling and racial discrimination against Petitioner. 13. On numerous occasions, Petitioner attempted to zealously argue his case in hearings before Respondent. He was rudely cut off and screamed at by Respondent Judge, thus, intimidating Petitioner and having a chilling effect on the assertion of his rights. Respondent's authority is misplaced here because he is an appointed state official demeaning litigants in their own county courts paid for by county taxpayers' monies and not state monies. This is a blatant abuse of judicial office. 14. Respondent is siding with the lending institutions and their attorneys as a "bonus partner". This creates a significant imbalance in partiality against Petitioner. Here we see one appointed public official giving advantage and benefit to corporations against a New Jersey resident--one of the People. Petitioner has also been forced to represent himself because he can no longer afford an attorney, let alone find one competent, effective or trustworthy to challenge the attorneys of the lending institutions and to "even the playing field". The law and facts are on Petitioner's side. The judge and the lawyers for the lender are not. 15. It has been disclosed that Respondent Escala has been doing the same thing to others who have foreclosure cases and are unable to afford counsel to represent them against the depradations of the predatory lending practices of the lending institution's in question. Respondent Escala's modus operandi is to deny the litigant being foreclosed against his answers, affirmative defenses and counterclaims by siding, ex parte, with the lender's attorneys. When the litigant attempts to sue the lender and the attorneys in a second suit, Respondent denies the suit and dismisses it with prejudice under the guise of the purported entire controversy doctrine. Then, Respondent Escala issues an order prohibiting the litigant from filing any more petitions, pleadings or papers with regard to the same or similar issues. Respondent claims that the issues are repetitive and, therefore, frivolous. The only problem with this argument is that the first set of answers, affirmative defenses and counterclaims filed by the litigant were dismissed without a full and fair hearing, and without benefit of competent, effective counsel to "even the playing field". This creates a conflict of interest with the entire Superior Court of New Jersey. This has created a significant conflict of interest with Respondent, because of Respondent's pattern of biased and improper conduct against Petitioner. 16. This is not only inequitable and unconscionable, but evidences an unconstitutional denial of reciprocity and fairness in the law. 17. Respondent Escala's pattern of conduct against Petitioner presents a picture of an unfair system for litigants, especially those who are self-represented, that has irredeemably damaged public confidence in the integrity of her court and the courts in general. Respondent has shown a demonstrated pattern of willful misconduct that includes intemperate, discourteous and injudicious behavior and language during courtroom proceedings. Given Respondent's behavior and rumors heard in the courthouse, upon knowledge and belief, Petitioner is of the belief that Respondent has a psychological problem. 18. Respondent took an Oath of Office to Uphold, Defend, Support and Protect the Constitutions for the United States and New Jersey upon his swearing in as a public official-judge, and as an attorney. 19. It is the judge's obligation to see that justice is done in every case that comes before him or her. This includes not only reaching the correct legal result in the particular case, but also the exhibiting at all times of judicial demeanor, patience and understanding. People come to the court to be heard. They have a right to expect that in presenting their grievances they will be treated with respect. (In re Albano, 75 N.J. 509, 514). 20. The poorest, weakest, most hapless or illiterate Respondent standing before an American court, is entitled to exactly the same respect, rights and hearing as would be the Chief Justice of the United States standing before the court." (In re Yengo, 72 N.J. 450). 21. Respondent Escala has treated Petitioner with hostility, gender bias, disdain and loathing and has made his feelings well known in the aforementioned cases that he doesn't like Petitioner. 22. Respondent bad faith acts against Petitioner include unlawful denial of fundamental due process rights and equal protection under the law, refusal to read Petitioner's pleadings, racial and senior citizen bias. The accumulation of minor, seemingly innocuous incidents, (e.g., sarcastic comments, screaming at Petitioner, berating and denigrating Petitioner in front of the opposition empowering the opposition, threats for no reason, intimidation of Petitioner by use of Bergen County Sheriff's officers, removal from the courtroom when Petitioner challenged Respondent's authority) when considered together, demonstrate a pattern of conduct unbecoming a member of the New Jersey judiciary because of his innate hostility toward Petitioner. Respondent has made it known that he is biased and that his bias is a virulent form of disrespect for the Petitioner, and the people and citizens of New Jersey. 23. Respondent Escala's cavalier disregard of Petitioner's basic and fundamental constitutional rights exhibits an intolerable degree of judicial incompetence, and a failure to comprehend and safeguard the very basis of our constitutional structure. Respondent's remarks have been so extreme show that his decisions have been predetermined, improper bias or prejudice will be found to exist. 24. Petitioner's hearings are being conducted in what can be termed a Star-Chamber, Kangaroo Court proceeding where the Respondent judge doesn't read the papers and has predetermined the outcome of the cases. Respondent gives Petitioner short shrift at hearings and limits hearings to only what the lender's attorneys demand in their arguments. 25. Petitioner is involved in two (2) actions before Respondent Judge Gerald C. Escala regarding allegedly unlawful foreclosure matters on two of Petitioner's properties in the cases of Washington Mutual Bank vs. Atoo Heera Sakhrani, et al., Docket No. F-18867-03 and Deutsche Bank Trust Company v. Atoo Heera Sakhrani, et al., Docket No. F-18721-03. 26. In the Washington Mutual case, Petitioner filed a timely statutory Truth In Lending Act (TILA) rescission, pursuant to Title 15 U.S.C.S. 1635 and 15 U.S.C.S. Appx. 12 C.F.R. 226.15 on the Washington Mutual mortgage loan because of predatory lending practices, the agents, representative and entities have acted as an association-in-fact to defraud Petitioner through fraud in the inducement, actual extrinsic and intrinsic fraud, forgeries, constructive forgeries, falsification of state and federal lending documents, refusal to deliver certain lending documents and forms to Petitioner, failure to disclose important terms, and violation of Petitioner's Right of Rescission. 27. In the Deutsche Bank case, Petitioner filed a timely statutory Truth In Lending Act (TILA) rescission, pursuant to Title 15 U.S.C.S. 1635 and 15 U.S.C.S. Appx. 12 C.F.R. 226.15 on the Deutsche Bank mortgage loan because of predatory lending practices of the lenders, their agents, representative and entities, which have acted as an association-in-fact to defraud Petitioner through fraud in the inducement, actual extrinsic and intrinsic fraud, forgeries, constructive forgeries, falsification of state and federal lending documents, refusal to deliver certain lending documents and forms to Petitioner, failure to disclose important terms, Petitioner bank's attorneys swearing under oath and lying on the record, and violation of Petitioner's Right of Rescission. 28. It became apparent that the lending banks and their agents, representatives and entities (e.g., mortgage, title and settling companies) were the cause of the problems with the mortgages being improperly lent because they failed to forward Petitioner proper documentation, signed documentation, documentation showing terms of the lending agreements, disclosures, and fraudulently signing of federal HUD-1 settling documents. 29. In the Deutsche Bank/Ameriquest case, Petitioner has evidence and certifications that the mortgage note was altered and endorsed, contrary to the senior counsel's certification that the document was not altered. This was submitted as evidence to Respondent Judge Escala on or about April 19, 2003. 30. When both Washington Mutual and Deutsche Bank/ Ameriquest filed complaints, Petitioner responded in kind with Answers, affirmative defenses, counter-claims and Third-party complaints. Respondent Escala dismissed Petitioner's Answers, affirmative defenses, counter-claims and Third-party complaints in the alleged foreclosure matter. Respondent deprived Petitioner of fundamental due process and equal protection rights. 31. Respondent Escala ruled that the Deutsche Bank case foreclosure was not contestable, after the Trenton Foreclosure Unit, on April 30, 2004 and June 7, 2004, had determined that the matter was contestable. 32. At least 10-15 motions have been filed by Petitioner in both matters before Respondent Judge Escala. Petitioner has not won one (1) motion before Respondent. Upon knowledge and belief, Petitioner believes that the Respondent never read any of his motions. 33. Respondent Escala has sided with the corporate bank Petitioners in those cases. Respondent has awarded attorney fees to Deutsche Bank's counsel, Richard Haber, of $7,000 as against Petitioner, without any findings, other than Mr. Haber's whining to the Respondent that this matter was costing his client, the bank, a lot of money in legal fees. Respondent also ordered at least another $20,000 in attorneys' fees to the various lawfirms involved, in 13 orders he issued all at the same time in July of 2005. 34. After Respondent Escala told Petitioner that if he didn't like his rulings, he could appeal them, based on representations from the Bergen County clerks, Petitioner was told that if he appealed the matter to the Appellate Division, that Respondent has friends in the Appellate Division who he would contact to negatively influence the appeal cases against Petitioner. It is apparent that Petitioner (and his wife, who is also a Defendant in the above two (2) captioned cases) cannot get a fair trial in the Superior Court, Bergen County, Chancery, Equity Part or the Superior Court, Appellate Division. 35. The matter, as set forth in the trial court, involves a mortgage application that Petitioners and the Third-party Respondents failed to consummate, because of the two banks' failures to make disclosures pursuant to the federal Truth In Lending Act (TILA), RESPA and Regulation Z, and failed to deliver certain important forms and documents as requested. The Respondent timely submitted a rescission notice and has raised it numerous times as his affirmative defense. Through an Affidavit to Supplement the record that Respondent Escala take mandatory judicial notice, Petitioner (and his wife, who is also a Defendant in both aforementioned cases) have submitted a United States Supreme Court decision, Beach v. Ocwen Federal Bank, 523 U.S. 410, 140 L.Ed.2d 566, 118 S.Ct. 1408 (1998) supporting their position of timely filing their Truth In Lending Act (TILA) Rescission notice, which is an affirmative defense against any foreclosure proceeding, and that because of this Supreme Court ruling, res judicata and collateral estoppel applies as against the banks and their agents, representatives and entities as an association-in-fact. 36. Respondent Escala has "railroaded" this case through the Court and refuses to give latitude to Petitioner(s), who is a pro se litigant, an Asian-American minority, and who is a senior citizen. Respondent Escala dismissed Petitioner's Answers, Third-Party Complaints and Counter-claims in the Deutsche Bank case and Washington Mutual case for allegedly refusing to attend to the opposition's discovery. 37. However, Respondent Escala was supposed to rule on motions prior to any discovery and never did until after the fact. Even the oppositions' attorneys said that they would postpone discovery until the motions were ruled on. In the Deutsche Bank/Ameriquest case, the Trenton Foreclosure Unit sent a letter back to the Court on April 30, 2004 and June 7, 2004 that the Deutsche Bank matter was contestable. 38. Petitioner has made several applications for the recusal and disqualification of Respondent Judge Escala, J.S.C., because Respondent has proven to be a lapdog and bonus partner of Washington Mutual and Deutsche Bank/Ameriquest plaintiffs in their respective cases. Respondent has allowed both banks to perpetrate predatory lending practices of "packing" and "equity stripping", and as a result has allowed the banks to racially discriminate against Petitioner, who is Asian-American, as well as discriminate against him as a senior citizen. 39. Respondent has done everything the banks want him to do. He's a "runaway" judge from the inception of the case. In fact, one of the senior lawyers representing one of the banks got up and applauded Respondent for his rulings against Petitioner. Respondent willfully refuses to or cannot read any of Petitioner's motions as evidenced by his one-sided rulings against Petitioner and his wife. Respondent has ruled favorably for the lending bank plaintiffs in every motion and ruled against Petitioner and his wife on every motion. Petitioner and his wife are Asian-American minorities and Petitioner is a senior citizen. 40. Respondent Escala, by siding with Washington Mutual and Deutsche Bank/Ameriquest and their predatory lending practices of packing, flipping and ultimately the equity stripping of Petitioner's assets, has committed racial discrimination and senior citizen discrimination against Petitioner and his wife. That information is now part of the record. 41. Moreover, Washington Mutual and Ameriquest have been the subject of major class action lawsuits for predatory lending practices against minorities and senior citizens that resulted in settlements in the hundreds of millions of dollars. 42. Respondent Escala has thrust himself into the dispute rather than resolve it impartially. Petitioner tried to be professional about the whole matter, but Respondent is corrupt and lazy, in that it has become obvious he doesn't read Petitioner's papers submitted, ignores Petitioner, and rules against Petitioner on every motion and paper filed. 43. Even if Respondent Escala responds to Petitioner's court papers, he does not address any of the merits other than making unsolicited comments and personal ad hominem attacks about Petitioner attacking Respondent's credibility as a judge. Petitioner will show evidence of these personal ad hominem attacks and vicious comments coming from Respondent. This behavior by Respondent shows a lack of demeanor and lack of impartiality. 44. The facts will show that Petitioner filed a timely TILA (Truth In Lending Act) rescission notice to cancel the mortgages and notes that he was applying for on the above properties in question. The opposition admits it. Yet they proceed with the frivolous cases to unlawfully foreclosure and steal Petitioner's valuable Bergen County properties that the banks, their agents, entities and representatives, along with Respondent Escala, whose wife is a financial investment expert, will use for their own property investments. 45. Respondent Escala ruled that the Petitioner Deutsche Bank's attorney, Richard Haber, is to receive $7,000 in legal fees for having to defend against Petitioner's motions. Petitioner is a pro se litigant. This is a denial of fundamental due process and equal protection under law. This is an absolute outrage and criminal act (official misconduct) by this Judge. Respondent is obviously working with the opposition to steal Petitioner's property, then charges Petitioner for it, and then accuses Petitioner and his wife of being "disgruntled litigants" because they "dare" to challenge the Respondent's integrity as a judge. And, when all else fails, Respondent disallows Petitioner from filing claims, motions or papers with the court in order to defend himself from the depradations of the banks and their attorneys. 46. Petitioner has presented reams of unrefuted evidence to the Respondent, but the Respondent refuses to take cognizance of it. Petitioner submitted an Affidavit supporting a Motion for Summary Judgment against Washington Mutual that incorporated over 300 points of evidence and documents. Not one point has ever been rebutted by the opposition. Not one single fact or expert witness has been produced at any hearing. Whereby, this Affidavit stands as an unrefuted affirmative defense, res judicata and acts as collateral estoppel against the banks and their agents, representative and entities from moving against Petitioner's properties. Yet, Respondent never addressed it, let alone read it. 47. Petitioner also submitted an Affidavit supporting his Answer, counter-complaint and complaint against Third-party Respondents as against Deutsche Bank/Ameriquest that incorporated over 300 points of evidence and documents. Not one point has ever been rebutted by the opposition. Not one single fact or expert witness has been produced at any hearing. Whereby, this Affidavit stands as an unrefuted affirmative defense, res judicata and acts as collateral estoppel against the banks and their agents, representative and entities from moving against Petitioner's properties. Yet, Respondent never addressed it, let alone read it. 48. Respondent Escala has arbitrarily and capriciously ignored these fact documents and summarily ruled(s) in favor of the two banks. Petitioner believes because he is a pro se litigant without an attorney that he is being treated as a "third class" citizen by Respondent. Petitioner asserts that according to Corpus Juris Secundum, 7 CJS 4 "Attorney & Client" relationship, the first duty of the attorney is to the Court, his second duty is to the State, his third duty is to public policy/law, and his fourth duty his to his client. If the client conflicts with the first three duties, the client always loses. 49. Petitioner had attorneys in the case and they botched the cases for him. Now, Respondent Judge Escala wants Petitioner to appeal. Petitioner has been told by the clerks that if he appeals, Petitioner will fall into the trap since Respondent Escala has friends in the Appellate Division that he'll contact and tell them to negatively influence them against Petitioner's appeal. 50. In the January 7, 2005 Orders and attached comments, Respondent Escala accuses Petitioner of using "intimidation techniques" to achieve a desired outcome in the case. All Petitioner wants as a desired outcome is that it is a fair one. The intimidation is being brought against Petitioner by Respondent, the banks and their attorneys. 51. Respondent Escala accused Petitioner of being "uncivilized", "indecent" and not respecting the rule of law. Petitioner asserts that if the rule of law operates the way Respondent Escala wants it to operate--to steal people's property and liberty--then Petitioner will be civilly disobedient, if that is what is considered "uncivilized" to Respondent. Respondent has acted in a rude, vindictive and malicious manner against Petitioner after suggesting that Respondent is an advocate for the opposition. Respondent has turned the matter into a personal vendetta against Petitioner. 52. Respondent Escala further accused Petitioner of trying to get Respondent to (1) admit his bias, dishonesty and having committed criminal acts, or (2) succumb to the onslaught of personal and vituperative attacks in order that Petitioner force him to cede the case to the attention of another judge. If this is what it takes to get a fair judge to hear the case, then Petitioner will continue the attack. Petitioner has made at least five (5) motions for Respondent to recuse/disqualify himself from the cases 53. Upon knowledge and belief, Respondent Escala doesn't respect the rule of law, which includes due process and equal protection. He accuses Petitioner of being a "disgruntled litigant" which is the buzzword of the judiciary when they violate and deny the rights of litigants that come before them for relief and recourse, and then said litigants start to fight back. 54. Petitioner states that Respondent Escala is doing the same thing n**i judges did under Hitler when the Jews decried the treatment they received at the hands of the courts in Germany in 1935. 55. Respondent Escala complains he is slighted because Petitioner allegedly insulted and demeaned him, as well as allegedly denigrated and challenged the very integrity and dignity of the judicial system. Petitioner contends that Respondent Escala shows no integrity or dignity in a judicial system where Respondent "steamrolls" pro se litigants for his own self-aggrandizement, and in protecting corporate clients as well as their lawyers. 56. Petitioner invoked his First Amendment Right to record his displeasure with Respondent Escala because Respondent has sided in a civil and criminal conspiracy with large banks, he refuses to disclose his personal finances that may implicate him in the case as being a "bonus partner" with said banks, and sides with the banks on every motion. 57. Petitioner contends that Respondent Escala not only wants to violate Petitioner's property rights, he wants to silence Petitioner's First Amendment Rights as well. 58. Petitioner states that Respondent Escala has denied him a full and fair litigation in the matters involving the banks. 59. Respondent Escala continues to allege he will not defend or explain his actions. That's further evidence he's covering up what he is doing. Respondent Escala cannot or will not defend or explain any of his actions with respect to findings of fact or conclusions of law every time he denies or dismisses Petitioner's pleadings and petitions. Petitioner contends that the maxim that silence is an admission of guilt is playing out here. 60. In June 2004 Petitioner submitted a Motion for Summary Judgment and Affidavit and an on or around April 19, 2004 filed an Answer with Affidavits in each separate matter that included over 300 points in each Affidavit that have gone unrefuted by the opposition. Respondent Escala failed to take cognizance of these Affidavits of fact, or Petitioner's fact witnesses. Respondent passes it off as "intimidation techniques" and "uncivilized" behavior. If Respondent had read the Affidavits and then sought the opposition to explain why they've admitted that Petitioner filed the proper rescission notice but they failed to act on it, he might likely would be asking the opposition why they are now trying to steal Petitioner's property after Petitioner complied with all of the lending terms. 61. Respondent ignores the aforereferenced U.S. Supreme Court rulings as an affirmative defense, res judicata and collateral estoppel which supports Petitioner's position. Respondent Escala is bailing out the banks, not on the facts, but through his own personal biases and through technical irregularities. Respondent is a friend of the banks and corporations, and an enemy of the people. 62. Respondent Escala has treated Petitioner in a rude manner. He has castigated Petitioner in front of the opposition counsel at hearings, empowering the opposition to further violate the law in stealing Petitioner's properties. This suggests that the Respondent is an advocate for the banks against Petitioner. 63. The only one being harmed here is Petitioner and his wife. The banks and its "bonus partners" stand to make a profit off of stealing Petitioner's properties, even after Petitioner made the appropriate payments on the mortgages, and then made the timely and proper Rescission on the mortgages when he did not receive certain important documents to sign, and the lending entities failed to disclose important terms accurately. The banks lose nothing through their fraudulent mortgage practices and predatory lending scheme practices. In fact the banks have failed to provide Petitioner information as to where the mortgage notes have been sold to, thus, implicating standing of whether or not the lending institutions had the ability to sue Peititoner in the first place. 64. The hostile third-party defendants, who are acting in concert with the banks have nothing to lose. They get to cover up their mistakes and go on and do it to other unsuspecting people through their predatory lending practices. Respondent is allowing this to happen by ignoring Petitioners papers and summarily granting relief in favor of the lending institutions and their attorneys, who are racking up obscene legal fees in order to continue attacking Petitioner. 65. Respondent Escala continues to support these predatory lending practices, even after he has been notified of same by Petitioner's submissions of the New Jersey Anti-Predatory Lending Statute, N.J.S. 46:10B-22 et seq. (with amendments), a U.S. Supreme Court decision regarding the proper filing of a timely TILA rescission notice as an affirmative defense and being used as res judicata and collateral estoppel against any foreclosure proceeding, and news reports that the banks in question have been the subject of massive class action lawsuits for predatory lending practices that resulted in verdicts against the banks in the hundreds of millions of dollars. 66. Ameriquest has been involved in massive class actions for predatory lending practices. Deutsche Bank realized that Ameriquest was in trouble again with Petitioner, and jumped into the case on or about October, 2003. It has yet to be determined if Deutsche Bank had any standing to enter the case against Petitioner, but Petitioner cannot get this information, as he is being blocked and "stonewalled" by Respondent Escala. 67. Respondent Escala keeps repeating the unsubstantiated fact that Petitioner's Special Civil Part action against Ameriquest (now Deutsche Bank) for monies owed to Petitioner for overcharging of fees and shorted amounts on the original refinancing was "settled". It was never settled. The record will show that the matter was never settled. The opposition swears in their own Affidavits that the matter was never settled. Yet, Respondent Judge continues to falsely represent to the parties that the matter was "settled". 68. Respondent Escala ignores this fact and has "steamrollered" the case over Petitioner to the point that the matters have been forwarded to the Foreclosure Unit for action awaiting final judgment. 69. Respondent Escala refuses to explain his financial disclosures upon Petitioner's request to the Administrative Office of the Courts for such disclosures, which only leads to further suspicion of his actions. His refusal to explain his disclosures furthers the evidence of lack of impartiality, lack of integrity and lack of competence allegations that Petitioner levelled against him in several motions for Respondent's disqualification and/or recusal. 70. Respondent Escala arrogantly and obnoxiously feels that it is "disquieting that a litigant has gone to such lengths to seek my removal from handling this litigation". Respondent Escala believes that he is "above the law", doesn't have to answer to Petitioner's requests for financial disclosure or motions for disqualification, and doesn't want his finances brought into the picture while he is acting in conflict of interest in the civil and criminal conspiracy to aid and abet in the defrauding of Petitioner and theft of his private property through predatory lending practices schemes. 71. Respondent Escala compromised(s) the "appearance of impartiality" for thrusting himself into the dispute rather than resolving it impartially. Respondent is "casting himself in the public's eye as a participant in the case, therefore compromising the appearance of impartiality, if not demonstrating actual bias". 72. Respondent Escala accused Petitioner of "ad hominem" attacks in his January 7, 2004 attachments to his Orders. This is further obfuscation and refusal to accept reality by Respondent. Since Respondent refuses to or cannot read Petitioner's papers submitted to the Court, and they are very detailed with facts and exhibits, Petitioner (and his wife) find it incomprehensible that Respondent refuses to make any rulings in their favor, based on the evidence, yet, he has time to read and respond to Petitioner's alleged "ad hominem" attacks on him. 73. Petitioner contends he (and his wife) cannot get a fair and full litigation, or impartial, litigation in Bergen County. In July, 2004, Petitioner had filed a complaint to the Bergen County Grand Jury for an investigation into the activities of the banks' predatory lending practices, the Third-party defendants working with the banks and the two (2) judges on the case, Respondent Escala and Bergen County Superior Court Judge Robert C. Wilson. Petitioner filed the complaint with the Grand Jury during the window of opportunity during the Loigman matter. 74. When Bergen County Assignment Judge Sybil Moses found out that Petitioner had filed a complaint with the Grand Jury, she told the Clerk of the Grand Jury, Mary E. Hissin, not to proceed with the Grand Jury investigation. Judge Moses wrote Petitioner a letter that he file for judicial misconduct if he was not happy with the judges. Petitioner is aware that the Advisory Committee on Judicial Conduct is nothing more than a "rubber stamp, whitewash" committee, and chose not to file any complaints with them. Judge Moses copied her letter to Judges Escala and Wilson. This immediately prejudiced these two judges against Petitioner in his cases before these judges. 75. Petitioner shows that he cannot get a fair trial before Respondent or any other Judge in Bergen County because of the complicitous nature of Assignment Judge Moses' with the other judges in this case. 76. In his last parting shot in the January 7, 2005 attachment to the Order involving Deutsche Bank, Respondent levels a vicious personal attack on Petitioner and his wife. Respondent Escala accuses Petitioner of having "no decency". This further shows Respondent's animosity toward Petitioner that has harmed and continues harming Petitioner. The actions of Respondent against Petitioner are a direct and proximate result of Respondent Escala's commission of judicial oppression, judicial misconduct and official misconduct against Petitioner. ACTS OF TREASON 77. Petitioner, repeats, reiterates and realleges the substance of paragraphs 1-76 herein, and incorporates by reference the same by this reference as if fully restated herein. 78. Because of the violations of Petitioner's fundamentally secured due process rights and fundamentally secured rights under equal protection of the law, the pattern of official misconduct exhibited by Respondent Judge Gerald C. Escala violated and breached his Oath of Office to Uphold, Support and Protect the Constitution for the United States of America and Constitution for New Jersey, and committed the crime of Official Misconduct, in violation of N.J.S.A. 2C:30-2, committed the crime of Official Deprivation of Civil Rights, in violation of N.J.S.A. 2C:30-6, and committed the crime of Pattern of Official Misconduct in violation of N.J.S.A. 2C:30-7. 79. Judicial immunity does not exist for judges who engage in criminal activity, for judges who connive with, aid and abet the criminal activity of parties, or to a judge for damages sustained by a person who has been harmed by the judge's connivance with, aiding and abeting, another judge's criminal activity. 80. Under Federal law which is applicable to all states, the U.S. Supreme Court stated that if a court is without authority, its judgments and orders are regarded as nullities. They are not voidable, but simply void; and form no bar to a recovery sought, even prior to a reversal in opposition to them. They constitute no justification; and all persons concerned in executing such judgments or sentences, are considered, in law, as trespassers. Elliot v. Piersol, 1 Pet. 328, 340, 26 U.S. 328, 340 (1828). 81. The Respondent had no legal authority (jurisdiction) to hear or rule on certain matters before them. They acted without any jurisdiction. When judges act when they do not have jurisdiction to act, or they enforce a void order (an order issued by a judge without jurisdiction), they become trespassers of the law,and are engaged in treason. 82. When a judge acts as a trespasser of the law, when a judge does not follow the law, the judge loses subject-matter jurisdiction and the judges orders are void, of no legal force or effect. The U.S. Supreme Court, in Scheuer v. Rhodes, 416 U.S. 232, 94 S.Ct. 1683, 1687 (1974) stated that "when a state officer acts under a state law in a manner violative of the Federal Constitution, he "comes into conflict with the superior authority of that Constitution, and he is in that case stripped of his official or representative character and is subjected in his person to the consequences of his individual conduct. The State has no power to impart to him any immunity from responsibility to the supreme authority of the United States." By law, a judge is a state officer. The judge then acts not as a judge, but as a private individual (in his person). 83. The U.S. Supreme Court has stated that "No state legislator or executive or judicial officer can war against the Constitution without violating his undertaking to support it." Cooper v. Aaron, 358 U.S. 1, 78 S.Ct. 1401 (1958). Any judge who does not comply with his oath to the Constitution of the United States wars against that Constitution and engages in acts in violation of the Supreme Law of the Land. The judge is engaged in acts of treason. Having taken at least two, if not three, oaths of office to support the Constitution of the United States, and the Constitution of the State of New Jersey, any judge who has acted in violation of the Constitution is engaged in an act or acts of treason. 84. If a judge does not fully comply with the Constitution, then his orders are void, In re Sawyer, 124 U.S. 200 (1888), he/she is without jurisdiction, and he/she has engaged in an act or acts of treason. Whenever a judge acts where he/she does not have jurisdiction to act, the judge is engaged in an act or acts of treason. U.S. v. Will, 449 U.S. 200, 216, 101 S.Ct. 471, 66 L.Ed.2d 392, 406 (1980); Cohens v. Virginia, 19 U.S. (6 Wheat) 264, 404, 5 L.Ed 257 (1821). 85. Respondent Escala, as a state public official and state judge, subjected Petitioner to fundamentally unfair treatment such as oppression, harassment and egregious deprivation. These constitute acts of treason because Respondent waged war against the Constitution for the United States and Constitution for New Jersey against Petitioner. STATE CONSTITUTIONAL RIGHTS VIOLATIONS 86. Petitioner, repeats, reiterates and realleges the substance of paragraphs 1-85 herein, and incorporates by reference the same by this reference as if fully restated herein. 87. The conduct of Respondent Escala against Petitioner constituted(s) fundamentally unfair treatment such as oppression, harassment and egregious deprivation of Petitioner's fundamentally secured rights in violation of the New Jersey Constitution, Article I, Paragraph 1, whereby Respondent violated and is continuing to violate Petitioner's unalienable rights of enjoying life, liberty and property, of acquiring, possessing and protecting property, and of pursuing and obtaining safety and happiness. 88. Respondent Escala subjected Petitioner to fundamentally unfair treatment such as oppression, harassment and egregious deprivation of Petitioner's fundamentally secured rights in violation of the New Jersey Constitution,Article I, Paragraph 5, whereby Respondent perpetrated acts of racial discrimination and age (senior citizen) discrimination against Petitioner. 89. Respondent Escala subjected Petitioner to fundamentally unfair treatment such as oppression, harassment and egregious deprivation of Petitioner's fundamentally secured rights in violation of the New Jersey Constitution,Article I, Paragraph 7, whereby Respondent has the right to be secure in his property against unreasonable seizures. 90. Respondent Escala subjected Petitioner to fundamentally unfair treatment such as oppression, harassment and egregious deprivation of Petitioner's fundamentally secured rights in violation of the New Jersey Constitution,Article I, Paragraph 9, whereby Respondent has the inviolate right to a trial by jury. 91. Respondent Escala subjected Petitioner to fundamentally unfair treatment such as oppression, harassment and egregious deprivation of Petitioner's fundamentally secured rights in violation of the New Jersey Constitution,Article I, Paragraph 20, whereby Respondent has the right to protect his private property from being stolen from him by predatory lending practices of the banks in question that will later be subject to public use/sale, without affording Respondent just compensation on said property/ equity. 92. Respondent Escala subjected Petitioner to fundamentally unfair treatment such as oppression, harassment and egregious deprivation of Petitioner's fundamentally secured rights in violation of the New Jersey Constitution,Article I, Paragraph 21, whereby Petitioner's enumerated rights, privileges and immunities cannot be impaired or denied by Respondent or anyone else. 93. Respondent Escala subjected Petitioner to fundamentally unfair treatment such as oppression, harassment and egregious deprivation of Petitioner's fundamentally secured rights in violation of the New Jersey Constitution,Article I, Paragraph 22, whereby Petitioner and his wife are now victims of crimes perpetrated by Respondent and the lending institutions and their attorneys that Respondent has aided and abetted. OBSTRUCTION OF JUSTICE-- VIOLATIONS OF FEDERAL LAW AND U.S. SUPREME COURT DECISIONAL LAW 94. Petitioner, repeats, reiterates and realleges the substance of paragraphs 1-93 herein, and incorporates by reference the same by this reference as if fully restated herein. 95. The conduct of Respondent Escala as against Petitioner constituted(s) violations of Federal law, specifically violations of the Truth In Lending Act ("TILA"), pursuant to Title 15 U.S.C.S. 1635 and 15 U.S.C.S. Appx. 12 C.F.R. 226.15, and U.S. Supreme Court Decisional law, Beach v. Ocwen Federal Bank, 523 U.S. 410, 140 L.Ed.2d 566, 118 S.Ct. 1408 (1998), supporting Petitioner's (and his wife's) position of timely filing their Truth In Lending Act (TILA) Rescission notice, and that because of this Supreme Court ruling, res judicata and collateral estoppel applies as against the banks and their agents, representatives and entities as an associations-in-fact. 96. As a direct and proximate result of the violations of federal law and U.S. Supreme Court decisional law, Respondent Escala obstructed justice, violated his Oath of Office, committed Official/Judicial Misonduct, causing egregious financial and emotional damage to Petitioner. VIOLATIONS OF "NEW JERSEY HOME OWNERSHIP SECURITY ACT OF 2002 AND AMENDMENTS,P.L.2003, c.64 (C.46:10B-22 et eq.)[ANTI-PREDATORY LENDING LAWS 97. Petitioner, repeats, reiterates and realleges the substance of paragraphs 1-96 herein, and incorporates by reference the same by this reference as if fully restated herein. 98. The conduct of Respondent Escala, as against Petitioner constituted(s) violations of the "NEW JERSEY HOME OWNERSHIP SECURITY ACT OF 2002" AND AMENDMENTS,P.L.2003, c.64 (C.46:10B-22 et eq.), known as the New Jersey Anti-Predatory Lending Laws. This constituted violations of oath of office, obstruction of justice, judicial oppression, official/judicial misconduct in violation of N.J.S. 2C:30-2, committed the crime of Official Deprivation of Civil Rights, in violation of N.J.S.A. 2C:30-6, and committed the crime of Pattern of Official Misconduct in violation of N.J.S.A. 2C:30-7. CONSPIRACY WITH LENDING BANKS, AGENTS, REPRESENTATIVES AND ENTITIES AND ASSOCIATIONS-IN-FACT TO ACT AS A "BONUS PARTNER" IN THE ILLICIT THEFT OF PETITIONER'S PROPERTY 99. Petitioner, repeats, reiterates and realleges the substance of paragraphs 1-98 herein, and incorporates by reference the same by this reference as if fully restated herein. 100. The conduct of Respondent Escala constitutes(d) a civil and criminal conspiracy with the aforementioned lending banks, agents, representatives, and associations-in-fact as a "bonus partner" in the illicit theft of properties from Petitioner. 101. As a direct and proximate result of Respondent Escala acting in a civil and criminal conspiracy and as a "bonus partner" with the named banks, their agents, representatives and entities as associations-in-fact, caused Petitioner to suffer damages. The demeanor, fraudulent acts, omissions, commissions and decisions by Respondent against Petitioner demonstrate that Respondent has woefully failed to carry out the proper role of the judiciary which is to protect the public and not to protect predatory lending institutions and their mercenary attorneys. Respondent has betrayed the public trust and endangered the public welfare by letting predatory lending institutions commit grand theft of innocent New Jersey residents' properties. 102. Respondent Escala has ignored Petitioner's papers and arguments, and continues to harm and damage Petitioner's fundamentally protected rights based on mere allegations and conjecture without proof, innuendos, and a vitriolic hatred of Petitioner. Petitioner has no remedy other than this Petition for Impeachment. RESPONDENT JUDGE GERALD C. ESCALA HAS COMMITTED ABUSE OF JUDICIAL OFFICE BY CRIMES OF OFFICIAL MISCONDUCT, OFFICIAL DEPRIVATION OF CIVIL RIGHTS, AND PATTERN OF OFFICIAL MISCONDUCT, IN DENYING PETITIONER OF HIS FUNDAMENTAL, UNALIENABLE PARENTAL RIGHTS AND LIBERTIES AND THROUGH THE RACIAL BIAS HARASSMENT OF PETITIONER 103. Petitioner, repeats, reiterates and realleges the substance of paragraphs 1-102 herein, and incorporates by reference the same by this reference as if fully restated herein. 104. Petitioner has been deprived of his fundamental, unalienable rights and liberties without cause, justification, substantiation or proofs. The deprivation of his liberties by Respondent has now become punishment without any trial by jury. The Respondent refuses to read Petitioner's pleadings, refuses to allow him to speak, refuses Petitioner the right to file petitions, pleadings and papers thereby denying him access to the court, humiliates him in open court, threatens him, intimidates him, admonishes him, and deprives him of his rights, and now his properties, for no reasonable cause. Respondent has circumvented all due process rights of Petitioner. 105. This is violation of Petitioner's natural and unalienable rights of enjoying life and liberty and pursuing safety and happiness pursuant to the New Jersey Constitution, Article I, Paragraph 1. 106. Respondent Judge Gerald C. Escala, as a Superior Court Judge of the State of New Jersey (Bergen County), through government oppression and judicial tyranny, has usurped his authority and has suspended, chilled and violated Petitioner Atoo Heera Sakhrani's fundamental, unalienable rights under the Constitution for the United States of America and New Jersey State Constitution. 107. Respondent Escala has and is continuing to perpetrate official misconduct/judicial misconduct. N.J.S.A. 2C:30-2 (Official Misconduct) states: "A public servant is guilty of official misconduct when, with purpose to. . .injure or deprive another of a benefit: a. He commits an act relating to his office but constituting an unauthorized exercise of his official functions, knowing that such act is unauthorized or he is committing such act in an unauthorized manner. 108. Respondent has deprived Petitioner of the fundamentally secured, constitutional due process rights to defend himself against the corporate lending institutions by striking and denying Petitioner's claims, defenses and answers, denying Petitioner's separate claims against the lending institutions and their attorneys, and then denying Petitioner access to the court , without justification, substantiation, evidence, proofs or any evidence, therefore depriving Petitioner of his fundamental rights without a compelling state interest. Respondent is therefore liable to Petitioner for harm and damages to his rights. 109. By depriving Petitioner of his fundamentally secured rights without a compelling state interest, Respondent is in violation of N.J.S.A. 2C:30-6 (Official deprivation of civil rights): a. A public servant acting or purporting to act in an official capacity commits the crime of official deprivation of civil rights if, knowing that his conduct is unlawful, and acting with the purpose to intimidate or discriminate against an individual or group of individuals because of race, color, religion, gender, handicap, sexual orientation or ethnicity, the public servant: (2) denies or impedes another in the lawful exercise or enjoyment of any right, privilege, power or immunity. b. (1) Except as provided in paragraphs (2) and (3) of this subsection, a public servant who violates the provisions of subsection a. of this section is guilty of a crime of the third degree. c. Notwithstanding the provisions of N.J.S. 2C:1-8 or any other law, a conviction of official deprivation of civil rights under this section shall not merge with a conviction of any other criminal offense, nor shall such other conviction merge with a conviction under this section, and the court shall impose separate sentences upon each violation of this section and any other criminal offense. d. . . . . . . e. For purposes of this section, an act is unlawful if it violates the Constitution of the United States or the Constitution of this State, or if it constitutes a criminal offense under the laws of this State. 110. Respondent has intimidated and threatened Petitioner. Respondent has violated Petitioner's Constitutionally secured rights by perpetrating racial and age bias, discrimination and intimidation in violation of N.J.S.A. 2C:30-6. 111. The acts complained of against Respondent constitutes a violation of Petitioner's Constitutionally protected rights, evidencing a pattern of official misconduct. Pursuant to N.J.S.A. 2C:30-7 (Pattern of Official Misconduct): a. A person commits the crime of pattern of official misconduct if he commits two or more acts that violate the provisions of N.J.S. 2C:30-2 or section 2 of P.L. 2003, c. 31 (C.2C:30-6). It shall not be a defense that the violations were not part of a common plan or scheme, or did not have similar methods of commission. b. Pattern of official misconduct is a crime of the second degree if one of the acts committed by the Respondent is a first or second degree crime; otherwise, it is a crime of the third degree, provided, however, that the presumption of nonimprisonment set forth in subsection e. of N.J.S. 2C:44-1 for persons who have not previously been convicted of an offense shall not apply. Notwithstanding the provisions of N.J.S. 2C:1-8 or any other law, a conviction of pattern of official misconduct, official deprivation of civil rights, or any other criminal offense, nor shall such other conviction merge with a conviction under this section, and the court shall impose separate sentences upon each violation of N.J.S. 2C:30-2 and sections 2 and 3 of P.L. 2003, c. 31 (C.2C:30-6 and C.2C:30-7). 112. Petitioner has no remedy at law or equity because Respondent continually struck and denied Petitioner's papers without ever addressing the merits, and then denied Petitioner access to the court on the false representations that Petitioner's pleadings and papers were repetitive and frivolous. The Petitioner's papers, petitions and pleadings could not be repetitive or res judicata because they were never fully and fairly litigated, Petitioner is unable to afford competent, effective counsel to "even the playing field", and the court will not appoint competent, effective counsel to protect Petitioner's rights. 113. Respondent is torturing Petitioner through abuse of his authority as a Judge and acting in concert with the predatory lending institutions and their attorneys to misappropriate properties from an unsuspecting public. 114. Respondent's unconstitutional acts against Petitioner constitutes racial bias and racial harassment of Petitioner because he is Asian-American and a senior citizen that Respondent and the predatory lending institutions feel they can take advantage of. OBSTRUCTION OF JUSTICE AND VIOLATION OF THE NEW JERSEY CONSTITUTION AND CONSTITUTION FOR THE UNITED STATES OF AMERICA 115. Petitioner, repeats, reiterates and realleges the substance of paragraphs 1-114 herein, and incorporates by reference the same by this reference as if fully restated herein. 116. Respondent has violated her Oath to support the Constitution for the United States of America and New Jersey State Constitution by denying Due Process, Equal Protection of the Laws, Depriving Petitioner of his property rights, threatening him with force to intimidate him in Court, attempting to paint Petitioner in a bad light as mentally disturbed by accusing him of being "uncivilized" and "indecent" because Petitioner demands Respondent's disqualification from the cases in question. Respondent has violated Petitioner's fundamental, unalienable Freedoms and Rights under Article I, Paragraph 1 of the New Jersey State Constitution. 117. Respondent has committed racially biased crimes on the basis of Petitioner's race, color and age status, in violation of the race bias crimes against intimdation and threats, in violation of New Jersey Constitution, Article I, Paragraph 5 [Prohibition against race bias] and the New Jersey Laws Against Discrimination [LAD]. 118. Respondent Escala was and continues to be in violation of the New Jersey Code of Judicial Conduct: Canon 1--A Judge Should Uphold the Integrity and Independence of the Judiciary; Canon 2--A Judge Should Avoid Impropriety and the Appearance of Impropriety in All Activities; Canon 3--A Judge Should Perform the Duties of Judicial Office Impartially and Diligently. 119. Under Canon 1, Respondent Escala violated the Code of Judicial Conduct by violating and denying Petitioner his rights to his property without a trial or hearing to which he was entitled. Respondent has testified on the record as a litigant and adversary against Petitioner by making denigrating statements about Petitioner, alluding that Petitioner was a liar, and has circumvented Petitioner's access to justice. Respondent "stepped down" off of the bench by screaming at Petitioner in open court, and denigrating him in front of opposing counsel which has empowered opposing counsel to continue to circumvent the law to deny Petitioner his rights. 120. Under Canon 2, Respondent violated the Code of Judicial Conduct, by violating Petitioner's rights in usurping clearly established law and Constitutional prohibitions, and clearly has a special interest in violating Petitioner's rights because Respondent is acting in concert with the predatory lending institutions and their attorneys. 121. Under Canon 3, Respondent violated the Code of Judicial Conduct, and violated and denied Petitioner his rights by usurping clearly established federal and state law, U.S. Supreme Court rulings, and Constitutional prohibitions, by "discriminating against Petitioner on the basis of his race and age, in violation of the New Jersey State Constitution, Article I, Paragraph V [which prohibits discrimination on the basis of race] and Paragraphs XXI and XXII [rights of victims and rights of State inhabitants]. 122. Respondent has further violated Petitioner's rights, in violation of Canon 3 of the Judicial Conduct Code, by denying and depriving Petitioner a full right to be heard according to law. 123. In further violation of Canon 3, at the July 22, 2005 hearing, Respondent waved a copy of a notice of lis pendens that Petitioner filed against Respondent's property and screamed at Petitioner to immediately remove the lis pendens from Respondent's property. Respondent completely ignored the intent of the hearing and subsequently issued 13 orders against Petitioner, with sanctions and approximately $20,000 in legal fees against Petitioner. This is clear evidence of a personal vendetta being instituted by Respondent against Petitioner. 124. Respondent has effectively suspended Petitioner's guaranteed rights to Due Process of Law, both procedurally and substantively, that are guaranteed under the Fifth (5th) and Fourteenth (14th) Amendments of the Constitution for the United States of America. Respondent has deprived Petitioner of his liberties and right to pursuit of happiness without a compelling state interest. 125. Respondent is "blanket" denying every one of Petitioner's motions, orders to show cause or any other petitions to defend himself, and has failed to read his pleadings. Respondent is trampling Petitioner's fundamental substantive and procedural due process rights in a malicious campaign to deprive him