Whether the summary judgment be reversed due to it was granted adversely, improperly, and unconstitutional

QUESTION PRESENTED Federal Jaw strictly prohibits false declaration and misleading conduct in Court against Rehabilitation Act binding in potential Agency that discharged well qualified employee with disability, and is necessary to secure and maintain uniformity of decisions in this court. Whether the summary judgement be reverse due to it was granted adversely, improperly, and unconstitutional because Clancy was not given an opportunity to file any admissible evidence that was attached to her opposition to defendant motion for summary judgement. The evidence rejected is crucial to prove for disability discrimination, disability harassment, retaliation, and post-employment retaliation. Court ordered that defendant recover cost from petitioner Clancy. Clancy recover nothing. The case should be dismissed. Clancy right to petition & litigate is protected Under the First Amendment of the U.S. Constitution. Whether Clancy Surreply should be granted due to defendant raised matters (evidence and declaration) for the first time in their reply (ECF No. 133-4, 133-5). Whether an aggrieved petitioner motion to amend a complaint to add claim under (Title Vi) should be granted to seek justice for the disability harassment, retaliation & post-employment retaliation Clancy suffered from her immediate supervisor Groves, under [Federal Rule 15 (a) (2)], the amendment should be freely allowed “when justice so requires.” Foman v, Davis, 371 U.S. 178, 182 (1962). Whether the numerous misleading conducts (22 items) filed by the defendant DeCA in a motion for summary judgement such as: a) Immediate supervisor Groves false declaration that petitioner Clancy was performing poorly but personnel records showed Clancy received six year of consistent satisfactory evaluation & four promotions; b) False declaration that Groves did not know petitioner has disability but submitted “list of employees onboard” and “list of employees earned overtime & compensatory time” that showed petitioner has disability code; c) False declaration that Groves never see the documents before; d) DeCA modified Clancy deposition, added the word “unfairly” and filed it in the defendant summary judgement as “uncontroverted facts;” e) Misleading conduct that the unemployment insurance never contacted DeCA about Clancy claim for unemployment but the Unemployment Insurance Employer Handbook showed in conflict to defendant declaration, should be ignored by the court. (i) ‘