Should certiorari be granted as an important question of federal law that should be settled by this Court exists as the petitioner Mario Alberto Recinos' due process rights were violated

QUESTIONS PRESENTED The questions presented are: 1) Should certiorari be granted as an important question of federal law that should be settled by this Court exists as the petitioner Mario Alberto Recinos’ due process rights were violated by the State of New Jersey, Department of the Treasury, Division of Pension and Benefits, as he was not required to re-enroll in the Police and Fireman’s Retirement System (PFRS) nor required to pay back retirement benefits he has received (and payments into the pension system) and the PFRS Board’s decision is arbitrary, capricious, unreasonable and incorrect and at the very least, petitioner should have been granted an evidentiary hearing? 2) Should certiorari be granted as an important federal question exists as petitioner’s due process rights were violated since the decisions of the New Jersey state courts were arbitrary, capricious and unreasonable (with petitioner denied an evidentiary hearing)? 3) Should certiorari be granted as an important federal question exists as petitioner’s due process rights were violated since the PFRS Board erred in finding as a factor that the petitioner did not contact the Division? 4) Should certiorari be granted as an important federal question exists as petitioner’s due process rights were violated as the petitioner has the requisite breaks in service which were greater than 30 and 180 days as to any law enforcement position? li QUESTIONS PRESENTED — Continued 5) Should certiorari be granted as an important federal question exists as petitioner’s due process rights were violated as the item of full police powers is not a question of pensionability and should not prevent the petitioner from receiving his pension while serving as Undersheriff? 6) Should certiorari be granted as an important federal question exists as petitioner’s due process rights were violated since the position of Undersheriff is not listed on any documents issued by the Pension Board regarding pensionable positions? 7) Should certiorari be granted as an important federal question exists as the Board erred by finding that the expert report of Mr. Meyers was not entitled to any weight (without an evidentiary hearing)? 8) Should certiorari be granted as an important question exists as petitioner’s due process rights were violated as the retirement plan provided by the State of New Jersey to police officers and fire fighters who are vested in the plan creates rights that are protected by the United States and New Jersey Constitutions? 9) Should certiorari be granted as an important question exists as petitioner’s due process rights were violated as the positions of the Director of the Bureau of Narcotics and Undersheriff are not PFRS-eligible positions because the titles do not appear on the Division’s website as an eligible title nor are they permanent positions under the Rules ili QUESTIONS PRESENTED — Continued of Civil Service which prohibit re-enrollment of petitioner into the PFRS? 10) Should certiorari be granted as an important question exists as petitioner’s due process rights were violated as the ever-changing theories presented by the Division and the Board made it impossible for the petitioner to defend and present his case? 11) Should certiorari be granted as an important question exists as petitioner’s due process rights were violated as the Board denied petitioner’s request for an evidentiary hearing (particularly in light of the confusion in the record surrounding petitioners positions)?