Does the Appellate Division's ruling regarding standing remain valid if both of the status terms the Court relied upon were held factually inaccurate?

QUESTIONS PRESENTED On June 16, 2019 Superior Court Judge Lynott reversed AmeriCare’s license suspension after findings of provable due process and civil rights violations and reinstated Americares’s license/ property rights and standing. The Appellate Division cited the sole basis of their ruling on two (2) key status terms regarding licensure, being “Expired” or “Revoked”. They claimed that once a license was “expired” or “revoked this negated standing. AmeriCare’s license was Never “revoked” or “expired” at any time during these proceedings. 1. Does the Appellate Division’s ruling regarding standing remain valid if both of the status terms the Court relied upon were held factually inaccurate, which would have given AmeriCare legal standing to challenge a constitution due process violation by a State Agency of a taking of property (a license)? 2. Do the determinations of State agencies that deprive African Americans and communities of color the specialized emergency and critical healthcare services afforded other communities in the state violate the Equal Protection clause of the 14th Amendment as well as the State Constitution’s due process and equal protection requirements? 38. Does the State Appellate Division opinion violate the United States Constitution’s Equal Protection Clause requirements when it declines to consider or examine evidence found by the Trial Court that disclose acts of State Agencies constituting a “taking” of property (a license) without complying with constitutionally due process procedures? ii 4. Does a state agency’s violation of the 14th Amendment’s due process requirement impact the rights of African Americans and other minorities when it ignores the state’s constitutional due process protections? iii PARTIES AND CORPORATE DISCLOSURE Petitioner e AmeriCare Emergency Medical Services, Inc. AmeriCare has no parent corporation and no public company owns greater than 10% of its stock. Respondents e State of New Jersey e Department of Health e Office of Emergency Medical Services e James Sweeney e Scott Phelps e = Eric Hicken e Bell Medical Transportation iv LIST OF PROCEEDINGS Supreme Court of New Jersey Case No: 084600 AmeriCare Emergency Medical Service, Inc., Plaintiff Petitioner, v. The City of Orange Township, Bell Medical Transportation, Township of Irvington, and Township of South Orange, Defendants, and State of New Jersey Department of Health Office of Emergency Medical Services, James Sweeney, Scott Phelps, and Eric Hicken, Date of Final Order: December 8, 2020 Superior Court of New Jersey Appellate Division Docket No: A-0117-19T4 AmeriCare Emergency Medical Service, Inc., Plaintiff Respondent, v. The City of Orange Township, Bell Medical Transportation, Township of Irvington, and Township of South Orange, Defendants, and State of New Jersey Department of Health Office of Emergency Medical Services, James Sweeney, Scott Phelps, and Eric Hicken, Date of Final Opinion: May 27, 2020 v Superior Court of New Jersey Law Division—Essex County Docket No. ESX-L-2397-19 Americare Emergency Medical Service, Inc., Plainuff, v. The City of Orange Township, State of New Jersey Department of Health Office of Emergency Medical Services, James Sweeney, Scott Phelps and Eric Hicken, Defendants. Date of Bench Ruling: June 2, 2019