1. Whether the lower courts misapplied important principles of federal removal law and erred in concluding there had been a failure of discovery in this case because by operation of federal law, pre-removal discovery requests, which have not yet become due, are nullified upon removal of a case from state court to federal court, since they (i) do not travel to the federal court, as they are not "proceedings" within the definition of 28 U.S.C. § 1450, and (ii) cannot remain in the state court either because removal of a case leaves nothing behind in the state court.

2. Whether the Maryland courts violated the Petitioner's due process rights, as guaranteed by the 5th and 14th Amendments to the U.S. Constitution, by denying him reasonable notice and opportunity to defend the "unalleged contentions."

Whether pre-removal discovery requests are nullified upon removal to federal court