This case concerns the Fourth Amendment limits on warrants to search a home and seize all of its digital contents based on a single, months-old image of child pornography attributed to an email account. The lower courts are openly divided on each of the following recurring questions:

1. Staleness. Whether a single, isolated transmission of child pornography — here, one image sent roughly eight months before the warrant issued — becomes categorically “not stale” for purposes of probable cause simply because digital files are capable of indefinite storage, even where the affidavit contains no evidence that the suspect 1s a “collector” who retains such material.

2. Nexus to the residence. Whether evidence that an online child-pornography offense was

Whether, in a _ hostile-work-environment case involving facially racist and sexist harassment by students, an employee satisfies Title VII’s notice require- ment by repeatedly reporting the conduct to school officials who already know of it, or whether, as the courts below held, she must also use prescribed reporting channels, expressly state that she and others were subjectively offended, and tolerate a heightened level of harassment because she teaches at an alternative school.

l. Whether sheriff deputies are entitled to summary judgment based on qualified immunity in a federal § 1983 civil rights action despite evidence that the deputies investigated whether the plaintiff was loitering without seeking any relevant information; induced the plaintiff to leave the scene by threatening him with arrest and refusing to explain why he was instructed to exit from his parked vehicle; then aimed firearms at the plaintiff’s head before he drove away from the parking lot.

2. Whether sheriff deputies are entitled to summary judgment based on qualified immunity in a federal § 1983 civil rights action despite evidence that the deputies initiated an unauthorized vehicle chase of the plaintiff and immobilized his vehicle by performing a dangerous, unjustified, and unauthorized “precision immobilization technique” or “pursuit intervention tactic” (PIT maneuver).

3. Whether sheriff deputies are entitled to summary judgment based on qualified immunity in a federal § 1983 civil rights action despite evidence that the deputies used deadly force to shoot the plaintiff in the head without giving him a feasible advance warning or any opportunity to turn off his engine while he was sitting in an immobilized vehicle without posing a threat to anyone.

4, Whether a sheriff deputy is entitled to summary judgment based on qualified immunity in a federal § 1983 civil rights action despite evidence that he used excessive, unnecessary force on the critically wounded, helpless plaintiff.

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A 12-year-old girl alleged that Petitioner sexually abused her. Weeks later, she fully recanted the allegation: “Everything was a lie. I made it all up.” Months after that, Petitioner, who was on supervised release for a prior sex offense, was arrested for violating the conditions of that release. He was later charged with enticement of a minor, although the grand jury was never told about the girl’s recantation. A later indictment dropped the enticement count, but charged Petitioner with obstruction, witness tampering, and conspiring (with his wife) to tamper with a witness, allegedly to ensure that the girl stuck by her recantation.

Petitioner went to trial on those charges. The Government’s case was made up largely of portions of recorded conversations between Petitioner and his wife, one of which ended with his wife stating that if the girl did not tell the truth “it’s gonna’ get ugly.” Petitioner’s counsel sought to ask the Government’s witness what came next, to show that “it’s gonna’ get ugly” referred to how diligently defense counsel would treat the matter. After losing an objection to that question, the Government argued that if defense counsel asked the question, it would “open the door” to evidence that defense counsel had previously cross-examined the girl in a prior case, leaving her in tears. The district court agreed and counsel decided not to ask the question. Petitioner was convicted on all counts.

At sentencing, the driving issue was whether Petitioner had, in fact, sexually abused the girl. The girl never testified in court or otherwise under oath. Instead, the district court reviewed videos of two forensic interviews with the girl — one from

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Whether Petitioner was deprived of his right, under the Sixth and Fourteenth Amendments, to a trial by a 12-person jury when the defendant is charged with a serious felony?

In Kian v. Florida, No. 25-6623, the Court has granted certiorari on the identical question. This case should at least be held pending resolution of that case.

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a) MISUSE OF MEDICARE FOUR STEP APPEAL PROCESS 42 CFR §422.564(b)(!) . et Seq WHICH REQUIRES DEFENDANT UPMC TO BE LIABLE FOR ITS OWN NEGLIGENCE,FRAUD AND MALPRACTICE.

b) Defendant UPMC is the Medicare Advantage organization (MAO) , is required by Center for Medicare Services (CMS) to operate a meaningful grievance and appeal process of its own

ANSWER: YES SEE PAGE 7 FOR SUPPORTING ARGUMENTS QUESTION 3: Wether the District Court lacked subject-matter jurisdiction because Appellant’s claims are common-law negligence and breach of contract actions, rather than appealable administrative “Medicare claims.”? ANSWER: YES SEE PAGE 7 FOR SUPPORTING ARGUMENTS 14) QUESTION 4: Whether the District Court erred by denying petitioner’s Motion to Remand despite fatal, waiver and untimely procedural defects in the Defendants’ Notice of Removal.? 16) QUESTION 5_ Whether the District Court erred by covering up and engaging in wilful indifference to the defective removal of complaint made by the defendants, from the state of Pa court.? QUESTION 6) Whether, the 3rd circuit court of Appeal and district court of Western Pennsylvania, erred by Arbitrary, Capricious abuse of discretion by deliberate indifference ( Wilful Blindness ) of the collateral order doctrine pursuant to 28 USC §1292 et seq, by summarily denying appellant’s appeal at No. 24-1208. See Ca3 docket ECF # 42, 43, 74. 75 & 76, inter alia.? ANSWER: YES SEE PAGE 7 FOR SUPPORTING ARGUMENTS QUESTION 7) Whether, the 3rd circuit court of Appeal and district court of Western Pennsylvania, erred by Arbitrary, Capricious abuse of discretion by deliberate indifference ( Wilful Blindness ) of the lack of standing of the defendants/appellees/respondents to remove the plaintiff/appellant/petitioner’s complaint GD23-12632 filed on October 31, 2023 at State of Pa Allegheny County Court of Common Pleas (ACCPC). For reasons that include but not limited to the following:? ANSWER: YES SEE PAGE 7 FOR SUPPORTING ARGUMENTS QUESTION 8 Whether, the 3rd circuit court of Appeal and district court of Western Pennsylvania, erred by Arbitrary, Capricious abuse of discretion by deliberate indifference ( Wilful Blindness ) and violated the separation of powers ( between Judiciary and DOJ) and acted as “ servants” of the DOJ . Corruption of the Judiciary is prejudicial and violates the petitioner’s constitutional rights of an independent Judiciary and “ Equal Protection clause”under the 14th Amendment of the US Constitution. . See Ca3 docket ECF # 42, 43. & 75 , inter alia. ? ANSWER: YES SEE PAGE 7 FOR SUPPORTING ARGUMENTS

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Petitioner was convicted at trial of being a felon in possession of a firearm and witness tampering. In the lead up to sentencing, he made several pro se arguments about the calculation of his advisory Guideline range and ultimate sentence, none of which his counsel adopted. One of those objections was to the classification of a prior conviction as a “controlled substance offense.” The district court classified the offense as such and calculated the advisory Guidelines range accordingly. On appeal, Petitioner restated his argument that the conviction was not a controlled substance offense, but on a different theory and buttressed by documentation that had not been presented to the district court.

The question presented in this Petition is, in such circumstances, whether the Court of Appeals should review the question of whether a Petitioner’s prior conviction is a controlled substance offense de novo or only for plain error.

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