Whether the posting of a deposition video to educate pro se litigants is protected by the First Amendment

QUESTIONS PRESENTED In 2010, Springs, a black, female attorney, sued her employer pro se -GMAC, now Ally Financial, the largest recipient of bailout funds in history-for retaliatory discrimination. The case was dismissed without a trial in 2012. In 2014, right after the Department of Justice ordered Ally to pay $80 million in damages for discriminating against 235,000 minority borrowers, Springs posted the corporate deposition video on a Youtube educational channel called the ProSe Advocate with the stated purpose to train others how to represent themselves. A magistrate judge issued an ultra vires order that she remove the video. In a decision that was upheld by the Fourth Circuit, Springs respectfully told the court that only a district court judge could issue that order. Now the NC State Bar is using Springs’ proper exercise of her constitutional rights in resisting the magistrate as a basis for punishment. The questions presented are: I. Whether the N.C. Court of Appeals erred in holding that Springs’ posting of a deposition video --long after the proceedings were concluded -in order to educate poor, unrepresented litigants in an entertaining manner, namely through commentary on how to identify deceit, is so unflattering to Ally Financial’s corporate representative that it is not protected by the First Amendment in conflict with 11 state courts of last resort and federal court of appeals that have addressed the issue. II. Whether the failure of the North Carolina tribunal to establish any evidence at all to support their grievance against Springs rendered the discipline unconstitutional pursuant to Thompson v Louisville, 362 US 199, 200 [1960] which found it a violation of constitutional due process to convict someone on a record completely devoid of evidence, although the punishment be only payment of a $10 fine. ii