1. Were the Workers ' Compensation Board (WCB) rulings denying my Article 8-A claim
and RB-89 rehearing request, arbitrary, capricious and an abuse of discretion?
Answer: Yes.

2. Does the 96 year old Workers' Compensation Law (WCL) § 123 law with its 7 year limit
from the "date of accident ", conflict with the intent of the New York State Legislature
for the new Article 8-A laws because the "date of accident " for claimants is 2001-2002,
which is 17 years ago? Does this violate Equal Protection and Due Process
rights of all Article 8-A claimants because it prevents RB-89 rehearing approvals
even before any Article 8-A claims are filed? Answer: Yes.

3. Is it a violation of the US Constitution, Separation of Powers, for the WCB to
change the Article 8-A law (and intent of the Legislature) by adding "Ground Zero " and
"affiliated with an authorized entity or agency " restrictions? Answer: Yes.

4. Did the WCB court violate the clear wording and intent of the Article 8-A law by
adding "Ground Zero " and "affiliated with an authorized entity or agency "
requirements to make it very restrictive for some 9-11 rescue/recovery/cleanup
workers? Answer: Yes.

5. Did the WCB violate Stare Decisis by ignoring violations of the Constitution in their
ruling to deny my Article 8-A claim and my RB-89 rehearing request? Answer: Yes.

6. Did the WCB ruling denying my RB-89 rehearing request ignore violations of the
Constitution in their prior rulings for my court case? Is this similar to the legal concept
of using "Fruit of the Poisonous Tree "? Answer: Yes.

7. Did the WCB abuse their discretion and violate my Equal Protection and Due
Process rights when they prevented me from submitting additional evidence and
documentation for my RB-89 request for a rehearing? Answer: Yes.

8. Did the WCB violate my Equal Protection and Due Process rights by refusing
to process and give judicial review for my Article 8-A Volunteer work and my WTCvol-3
form? Answer: Yes.

9. Did the WCB violate my Equal Protection and Due Process rights when they
ignored WCL § 165 when ruling to deny my RB-89 request? Answer: Yes.

10. Did the WCB decision denying my RB-89 request forget to state any date of
disablement as required by WCL § 164? Does this violate my Equal Protection
and Due Process rights? Answer: Yes.

11. Does WCL § 1 et seq. require that presumptions of laws operate in favor of the
claimant? Did the WCB not do this for my claim which then violates my Equal
Protection and Due Process rights? Answer: Yes.

12. Did the WCB violate the NY Supreme Court rulings that state the Board is obligated
to assess the "prejudice to the claimant " which would have inured if the case were
"closed "? Answer: Yes.

13. Did the WCB violate "Intelligent & Meaningful Judicial Review " in their ruling
to deny

Were the Workers' Compensation Board (WCB) rulings denying my Article 8-A claim and RB-89 rehearing request arbitrary, capricious and an abuse of discretion?