With discovery still ongoing, the district judge, facing hundreds of injured plaintiffs and unable, as in MDLs, “to send these people home,” doubted plaintiffs’ sworn answers used by a causation expert, struck the expert, disregarded the treating physicians’ causation Opinions, and granted summary judgment.

The questions presented:

When a district judge is annoyed by the number of plaintiffs, laments he is unable to send them to other districts, and, as Daubert gatekeeper, strikes an expert for relying on plaintiffs’ sworn medical history answers because the judge considers the answers unworthy of belief, is the judge subject to the inference that he abused his discretion?

As to 174 of the plaintiffs before him, does a district judge deny them jury trial and due process rights by ignoring expert treating physicians’ opinions showing that material facts on causation are genuinely disputed?

Did the Court of Appeals for the Seventh Circuit err by failing to address petitioners’ arguments seeking remand to the district court for consideration of pending issues related to the multiple treating physicians’ causation opinions as expressed in the petitioners’ Rule 26(a)(2)(C) disclosures?

(i)

The decision below ignores the central teaching of Mallory v. Norfolk Southern Ry. Co., 600 U.S. 122 (2023). That decision upheld Pennsylvania’s exercise of general jurisdiction over a foreign corporation be- cause Pennsylvania’s business-registration statute gave express notice that registration to do business constituted consent to general jurisdiction. That is uncommon. Like 36 other States, Georgia’s busi- ness-registration statute contains no comparable provision. Instead, Georgia and at least two other States infer consent to general jurisdiction based on judicial interpretations of statutes that concededly lack the notice that was central to Mallory.

The question presented is whether the Due Pro- cess Clause of the Fourteenth Amendment permits a State to assert general jurisdiction without providing notice that registration constitutes consent to gen- eral jurisdiction, particularly where, as here, the ju- dicial decisions supplying that notice were issued on- ly after the corporation first registered to do busi- ness.

1. May Congress constitutionally limit removal of members of the National Labor Relations Board to cases of “neglect of duty or malfeasance in office.” 29 U.S.C. § 153(a)?

2. To the extent that the National Labor Relations Board possesses any residual “executive functions” in its bifurcated structure, is the appropriate remedy to sever that function rather than invalidate the entirety of the for- cause removal provision?

This case presents a question of national significance regarding the role of equity in federal procedural common law. The question presented 1s: e Whether considerations of equity, such as

manifest injustice, apply to a federal court’s

preclusion, or res judicata, analysis.

1. Whether Article IIT permits federal procedural finality to attach

through dismissal, affirmance, rehearing denial, and mandate issuance before any court adjudicates a preserved Rule 60(b)(4) | challenge asserting that the judgment is void.

2. Whether Rule 60(b)(4) becomes functionally unavailable when preserved voidness challenges remain unadjudicated while | procedural finality continues to accumulate through successive Judicial stages.

, LIST OF PARTIES Petitioner: Houhe Zeng Respondents: Owner of 8020 Quartz Lane FirstKey Homes, L.L.C. | To Petitioner’s knowledge, no respondent is a publicly traded corporation requiring disclosure under this Court’s Rules. I

1. Whether this case presents a recurring question concerning the established procedural safeguard afforded to an indigent pro se litigant with PTSD by district court and sixth circuit court far departed from the accepted and usual _ course of iudicial proceedings, required to call for an exercise of this courts Supervisory power. | , | - | _

2. Whether this case presents a question of exceptional importance concerning the ability of federal employees to seek redress for intentional disparate treatment including systemic retaliation, violation of statutory mandate and - procedural abuses following work-related injuries and aggravated injuries, warranting Certiorari review to clarify the judiciary’s role in holding federal agencies accountable to their own regulations and statutory duties |

3. Whether interfering with approved or protected leave under FMLA, resulting aggravation of the condition that accepted under FMLA, caused extended | unpaid absences, constructive suspension, and constructive discharge, _ | impaired the mental ability to pursue pending litigation at federal district court and pending EEO administrative proceedings, constitutes cognizable prejudice sufficient to sustain FMLA interference and retaliation claims and whether the deprivation of job protections in civil service under such , circumstances violates the Fifth Amendment’s Due Process Clause

I. Whether a state court may exercise child custody jurisdiction consistent with the Parental Kidnapping Prevention Act, 28 U.S.C. § 1738A, after determining that no state qualifies as the child’s home state, where another state had previously asserted jurisdiction in a proceeding of which the opposing party had notice.

II. Whether the Fourteenth Amendment Due Process Clause permits a court to conclusively determine jurisdiction before valid service of process and to preclude a party from meaningfully challenging that determination after service is completed.

I. OTHER ACTS EVIDENCE CREATES A SIGNIFICANT RISK OF IMPROPER CONSIDERATIONS BY A JUROR OF A DEFENDANT’S CHARACTER INSTEAD OF THE EVIDENCE RELATED TO THE CHARGES. THE TRIAL COURT ALLOWED EVIDENCE OF A ROBBERY FOR WHICH MR. EWING WAS NOT CHARGED INTO EVIDENCE WITH FOUR OTHER ROBBERIES IN THE INDICTMENT. WHERE THE TRIAL COURT IMPROPERLY DETERMINED PROBATIVE VALUE AND FAILED TO EVALUATE UNFAIR PREJUDICE, IS MR. EWING ENTITLED TO A NEW TRIAL? I]. THE DUE PROCESS CLAUSE OF THE FIFTH AMENDMENT REQUIRES THAT A CRIMINAL PROSECUTION BE SUPPORTED BY PROOF BEYOND A REASONABLE DOUBT. WHERE NO RATIONAL JURY COULD CONCLUDE FROM THE EVIDENCE PRESENTED THAT MR. EWING POSSESED A FIREARM AS DEFINED IN LAW, MUST HIS CONVICTION FOR VIOLATING 18 U.S.C. $924(c) BE VACATED?

ii

Petitioner was charged in West Virginia with numerous counts arising from the alleged sexual abuse of his son. While the jury was deliberating on the charges, a member of the jury lied to his fellow jurors about knowing Petitioner and his family and expressed not only his fear should Petitioner not be convicted, but that his fellow jurors should share that fear. Petitioner was eventually convicted on only four of the twelve counts on which he went to trial in a nonsensical verdict.

This Petition presents the issue of whether a juror’s false statement that he knows the defendant and his family, combined with expressions of fear should the defendant be acquitted and exhortations that other jurors should feel the same, constitute an “external influence” on the jury that deprived Petitioner his right to an impartial jury as guaranteed by the Sixth Amendment.

_l-

5, Khdhes pettionsss sectence is ill! undes Stole ond Yada! low

4. Udhelher Tennessean judges showad 3 partisan interest S. Whether Tennessie judges abused theie disceetion a. Whelhee Wit of Cerkcr’ is invokad inthese. pescerding T Idhelherthis petition should be gaanted