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?

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
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)?

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