Did the District Court violate the Due Process Clause by barring Defendant-Petitioner from presenting any evidence in his defense at trial

QUESTIONS PRESENTED 1. Did the District Court violate the Due Process Clause by barring from presenting any evidence in his defense at trial, a sanction that was imposed for his failing to produce an individual over whom he had no legal control for a deposition, despite the absence of articulable prejudice to the other side? 2. Does the Due Process Clause require an assessment of a defendant’s nationwide business activities before a court may find that it has general personal jurisdiction over the individual on the basis of a few, scattered business contacts with the state? | | ii STATEMENT OF RELATED CASES The underlying District Court case was the subject of a prior writ petition docketed as Westbourne Capital, LLC v. Dist. Ct. (Redwood Recovery Services, LLC), Supreme Court Case No. 73576—notice in lieu of remittitur filed on February 6, 2017 A separate Eighth Judicial District Court case involving some of the same parties, Redwood Recovery Services, LLC v. Jeffrey Kirsch, Case No. A-11-652803F, was the subject of a prior writ petition docketed as Rock Bay, LLC v. Dist. Ct. (Redwood Recovery Services, LLC), Supreme Court Case No. 66728—Remittitur filed April 29, 2013. This separate case was also the subject of a prior appeal docketed as Kirsch v. Redwood Recovery Services, LLC, Sup eme Court Case No. 61646—remittitur filed on February 23, 2017. The underlying case currently has two motions pending: e Statebridge Company’s Rule 59 Motion to Amend the Judgment, or, in the Alternative Rule 60 Relief from Judgment (filed 07/14/17) (Exhibit 3); and e Westbourne, Rock Bay, Sloane Park, Vizcaya, and OppsREO’s Motion for of Judgment and Findings of Facts or, Alternatively, Motion to Alter or Amend Findings of Facts and Conclusions of Law (filed 07/14/17) (Exhibit 4). The separate Eighth Judicial District Court case referenced above, Redwood Recovery Services, LLC iii STATEMENT OF RELATED CASES—Continued v. Jeffrey Kirsch, Case No. A-11-652803-F remains pending with an inactive status. The decision by the Nevada Supreme Court deny) ing Jeffery Kirsch’s (“Mr. Kirsch”) appeal is reported at Kirsch v. Redwood Recovery Servs., LLC, 2019 Nev. Unpub. LEXIS 1260. The Nevada Supreme Court issued that decision on November 15, 2019. The Order is attached at