Whether the district court erred and/or abused its discretion

QUESTIONS PRESENTED 1. Whether the district court error and/or abused its discretion by not affording the Petitioner leave to amend her complaint and instead granted the Respondent summary judgment without any consideration or regards to Petitioner's substantive rights under 281 U.S.C. § 2072 (b)? 2. Whether the district court error and/or abused its discretion by omitting the Petitioner's former Counsel of Record, James D. Hartt, Esq., who initiated the Title VIE civil action on April 13, 2016 in the U.S. District Court on behalf of the Petitioner who was not even Pro Se at the time, all of which was not mentioned in the memorandum & Order [USDC/EDNY 16-cv-1784 (MLK)(LB) Doc. No. 104]. 3. Whether the district court error and/or abused its discretion by stating in its memorandum & order [USDC/EDNY 16-cv-1784 (MLK)(LB) Doc. No. 104] "Plaintiff ... [was] proceeding prose..." commenced the above-caption action on April 13, 2016, when Petitioner’s former Counsel of Record, commenced the action on behalf of the Petitioner? 4. Whether the district court error and/or abused its discretion by not permitting Petitioner liberal discovery. 5. Whether the district court error and/or abused its discretion by ignoring the | Petitioner's Affidavit of Request for Summary Judgment [USDC/EDNYDoc. No. 59]. LISTED OF PARTIES All parties appear in the caption of the case on the cover page. NEW YORK-PRESBYTERIAN QUEENS i