I. Did Michigan Ingham County and its officials Greta Wu, Kim Coleman, Bruce Bragg, Leslie M. Shanlian, Jennifer Mack violate U.S. Const. amend. V, XIV Takings Clause, Due Process and Equal Protection clauses when they removed Petitioner’s already earned 572 hours worth $22,656.92 from his personal payroll account and took it for public use without compensation, notice or hearing and while they paid for such already earned hours to other employees?

II. Did the state officials Jill Hookey, Jason Koontz, and Jennifer Fields in their’ personal capacities violate Petitioner’s constitutional due process and equal protection rights when they, contrary to their duties, refused to apply the state mandatory PTO payout guidelines to the Respondent ICMCF’s PTO policy and relieved Respondent ICMCF from paying Petitioner his already earned and unpaid PTO of $26,241.63 when other similarly situated claimants routinely received unpaid PTO and there was no rational basis not to require pay of the already earned compensation to Petitioner?

III. Did the Michigan courts violate the U.S. Const. Article I, Section 10 Contract clause when they impaired Respondent ICMCF’s obligation of the imphed/oral PTO contract with Petitioner by relieving Respondent ICMCF from paying Petitioner his already earned PTO compensation pursuant to his oral/implied agreement with County Respondents?

IV. Did the Michigan judges and the state officials Jill Hookey, Jason Koontz, and Jennifer

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Can a District Court dismiss a plaintiffs case by demanding improper discovery from him in connection with a Federal Rule of Civi Procure 17 inquiry as to his mental health competency, for purpose of the court appointing a guardian ad litem, when the plaintiff objected to the discovery, was unable to provide the discovery, and the District Court failed to appoint a guardian ad litem in connection with the competency inquiry proceedings?

Can the Court of Appeals Dismiss an Appellant’s Case without explanation for failure to file a brief on an Appellees’ motion to dismiss, where the Plaintiff had sought by motion an extension for cause and opposed the Appellee’s motion to dismiss?

1. Whether a District Court’s decision allowing a witness called by a criminal defendant to refuse to testify based on his claimed Fifth Amendment privilege is subject to “abuse of discretion” review by the Court of Appeals, because it presents merely an evidentiary issue, as the Fourth Circuit held, or 1s subject to “de novo” review, because it involves the analysis of the conflicting Constitutional rights of the witness and the defendant, as the Tenth Circuit has held?

2. If “abuse of discretion” 1s the proper standard, whether a district court abuses that discretion and thereby violates a criminal defendant’s Sixth Amendment rights, when, as here, it allows a witness called by the defendant to refuse to testify, even though the witness’s conviction was final and he would not have any legal exposure unless his sentence were first reversed by the Court of Appeals, in the absence of any plausible grounds for reversal, and, even then, it would be implausible that he could receive a lesser sentence.

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1. Whether U.S.S.G. § 4C1.1(a)(10) (Nov. 2023), which provides that a defendant is eligible for a two-level reduction if “the defendant did not receive an adjustment under § 3B1.1 (Aggravating Role) and was not engaged in a continuing criminal enterprise,” creates two independent disqualifying conditions (either of which bars relief) or requires both conditions to be present for disqualification?

2. Whether a district court violates Dillon v. United States, 560 U.S. 817 (2010), and U.S.S.G. § 1B1.10(b)(.) when it makes new factual determinations about a defendant’s conduct that were never adjudicated at the original sentencing in order to deny eligibility for a sentence reduction under 18 U.S.C. § 3582(c)(2), raising fundamental questions about the proper scope of judicial fact-finding in sentence modification proceedings.

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