1. To avoid erroneous deprivation of constitutional rights, including right of access to
the court; should this Court determine that pro se plaintiff 's with severe limitations of disability
and/or stigma of self representation prejudicing compliance with court processes, receive
accommodations appropriate to his/her limitations of disability and/or appointment of counsel to
assist in addressing the demands of court processes rather than suffer a dismissal with prejudice
to avoid such accommodations/leave to amend and/or to avoid indicia of discriminatory bias.

2. Should the Ninth Circuit have decided the motion for appointment of counsel timely
filed by petitioner with severe acute medical conditions and permanent limitations of disability
seeking assistance with the pre-filing process and appeal, prior to issue of an Order dismissing
the appeal for allegedly stating "insubstantial " issues on appeal.

3. Whether a review of petitioner 's submission of district court orders on appeal and
statement of facts or law which are relied upon for purposes of the appeal are in good faith,
"merit further review, " and should have been filed pursuant to 28 U.S.C. 1915.

4. Did the Ninth Circuit err in alleging pursuant to a 20 year old pre-filing order, that the
issues on appeal are "insubstantial denying further review; thereby, sustaining a wrongful
dismissal with prejudice without leave to amend where the facts/law on the merits of any cause
in the FIRST amended complaint were NOT considered, where petitioner 's motion for
appointment of counsel to accommodate limitations of disability for timely compliance with
medically impossible demands of the court was denied, where the complaint stated a claim upon
which relief could be granted and/or amended to state a claim was denied and where a dismissal
with prejudice without leave to amend was not proper pursuant to 28 U.S.C. 1915.

Whether pro-se-plaintiffs-with-disabilities-should-receive-accommodations-or-counsel