1. whether there is a federal common law standard to determine the existence of a property interest in city employment, without applying state laws, requiring that such interest exists only when there is a procedural right to appeal a for cause removal decision, in contradiction of Board of Regents v. Roth, 408 U.S. 564 (1972), and Cleveland Board of Education v. Loudermill, 470 U.S. 532, (1985).

2. whether a classified service probationary employee appointed from a certified reemployment list states a claim upon removal without any hearings with decision maker, without proper notice, when the employer created a public record stigmatizing such disputed removal and concealed the charter rights.

Whether there is a federal common law standard to determine the existence of a property interest in city employment, without applying state laws, requiring that such interest exists only when there is a procedural right to appeal a for cause removal decision, in contradiction of Board of Regents v. Roth and Cleveland Board of Education v. Loudermill