Whether the actions of the district and appellate courts violated due process by allowing perjury, denying motions, and covering up misconduct by a prominent law firm

QUESTION PRESENTED This is a legal-malpractice case filed against the Respondent Frost Brown Todd ("FBT") law firm and several of FBT's attorneys by their former client (Petitioner Eileen Zell), who is currently being represented by her son (the undersigned Jonathan Zell).! The question presented in this cert. petition is: Whether the following actions of the district and appellate courts below represented concrete evidence of actual bias that violates due process of law: 1. Due to Petitioner's refusal to accept the sixfigure settlement offer that the district court judge personally negotiated from Respondent FBT during the ex parte meetings the judge held with FBT and its counsel during the parties' Settlement Conference and the judge's vehemently stated disapproval on the record of the undersigned Petitioner's son's (Jonathan Zell’s) intention — unless FBT increased its settlement offer — to publicize the facts of the instant case via a website that could harm FBT’s reputation, the judge apparently gave FBT the green light to commit perjury at trial and to frame the undersigned for FBT's own legal malpractice. 1 Both Frost Brown Todd individually and all the Respondents collectively will be referred to herein as “FBT”; Petitioner Eileen Zell will be referred to as "my mother," "Petitioner," or “MRS. ZELL”; and Jonathan Zell will be referred to as "I," "me," "the undersigned," "MRS. ZELL's son," or “MR. ZELL.” MRS. ZELL's pleadings in the instant case before the 6th Circuit will be identified with the designation "6th Cir." All "Trial Exhibits" are those of MRS. ZELL. ii 2. After Respondent Jeffrey Rupert ("RUPERT"), Rupert's associate, Respondent Katherine Klingelhafer ("KLINGELHAFER"), and two other FBT attorney-witnesses, Respondent Shannah Morris ("MORRIS") and Aaron Bernay ("BERNAY"), gave blatant, obvious, and wholesale perjured testimony at trial — which testimony was directly contradicted by everything else in the almost four-year history of the case, including (according to the undisputed testimony of Petitioner's expert witness) even commonsense as well as the district court's own prior rulings (which should have constituted the law of the case) — the district court still based its findings of fact directly on those obviously-perjured testimonies. 3. The district court denied Petitioner's request to recall (only) RUPERT to the witness stand despite Petitioner's having been "sandbagged" and "ambushed" at trial by the surprise perjuries of RUPERT, KLINGELHAFER, MORRIS, and BERNAY. (See p. 94 of 6th Cir. Opening Brief.) 4. The district court denied Petitioner's Motion for a New Trial Based on FBT's Perjury without addressing any of the voluminous documentary evidence or the district court's own prior rulings (representing the law of the case) — both of which clearly demonstrated FBT's perjury. 5. The district court denied Petitioner's request for oral argument on Petitioner's Motion for a New Trial Based on FBT's Perjury — an oral argument that would have exposed both FBT's perjurious testimony and the district court's biased decision for all to see. iii 6. The Sixth Circuit denied Petitioner's appeal without addressing any of the voluminous documentary evidence demonstrating the perjurious testimony of FBT on which the district court had based its decision or even addressing the district court's own prior contradictory rulings (which should have constituted the law of the case). 7. The Sixth Circuit denied Petitioner's request for oral argument (which was opposed by FBT) — an oral argument that would have exposed both FBT's perjurious testimony and the district court's biased decision for all to see, and thus would have interfered with the Sixth Circuit's intention to cover up both FBT's and the district court's misconduct. 8. The Sixth Circuit denied Petitioner's appeal before the stated date that the panel was supposed to begin reviewing that appeal, thereby preventing Petitioner from filing a motion to challenge