Whether Mr. Perez can amend his complaint to allege that a State cannot exclude a person from the practice of medicine in a manner that contravenes the Due Process or Equal Protection Clause, whether the continued enforcement of an unconstitutional statute cannot be insulated by the statute of limitations, whether the Fifth Circuit erred in ruling that a Federal Fifth Amendment Takings Claim must be filed within the two year statute of limitations for 42 U.S.C. 1983 actions, and whether the Fifth Circuit erred in ruling that good faith reliance on Williamson County was not an exceptional circumstance justifying tolling the statute of limitations

QUESTIONS PRESENTED This Court has ruled that in the case of a pro se litigant, the courts must, sua sponte, grant leave to amend the complaint to correct curable defects and/or “ correct defective jurisdictional allegations, Scarborough v. Principi, 124 S.Ct. 1856, 541 U.S. 401, 158 L.Ed.2d 674 (U.S. 05/03/2004) citing Becker v. Montgomery, 532 U.S. 757 (2001), 28 U.S.C. § 1653 and Rule 15(c) Federal Rule Civil Procedure. Furthermore, Rule 54(c) of the Federal Rules of Civil Procedure directs trial courts to “grant the relief . : to which each party is entitled, even if the party has not demanded that relief in its pleadings, Engel v. Tele prompter Corp., 732 F.2d 1238 (5th Cir. 05/25/1984); In re Railworks Corporation, 760 F.3d 398 (4th Cir. 2014); QUESTIONS PRESENTED . 1. Whether Mr. Perez can amend his complaint pursuant to 28 U.S.C. § 1653 and 15(c) F.R.C.P., to allege that a State cannot exclude a person from the : practice of medicine in a manner or for reasons that contravene the Due Process or Equal Protection. Clause of the Fourteenth Amendment, Schware v. Board Bar Examiners New Mexico, 353 U.S. 232 (1957), Dent v. West Virginia, 129 U.S. 114 (1889). 2. Whether Mr. Perez can amend his complaint pursuant to 28 U.S.C. 1653 and 15() F.R.C_P., to allege that the continued enforcement of an unconstitutional ; statute cannot be insulated by the statute of limitations. Va. Hosp. Ass’n v. Baliles, 868 F.2d 653, 663 (4th : Cir. 1989), affd sub nom. Wilder v. Va. Hosp. Ass’n, , 496 U.S. 498 (1990). ii 3. Whether The Fifth Circuit erred when it ruled that a Federal Fifth Amendment Takings Claim must be filed within the two year statute of limitations imposed by Texas on 42 U.S.C. 1983 actions. 4, Whether the Fifth Circuit erred when it ruled that a good faith reliance on Williamson County ; Regional Planning Comm'n v. Hamilton Bank of Johnson City, 473 U.S. 172, 194 (1985) was not considered an exceptional circumstance justifying tolling the statute of limitations. iii ; °