Does this case present an important question not previously decided by the Supreme Court in which an elected member of the Arizona Legislature engaged in exposing corruption by the Executive Branch was ambushed with a sexual-harassment-allegation and summarily-expelled-without-due-process, based upon a third-party-report edited-illegitimately and containing-false-statements, instead of having a public-committee-hearing?

QUESTIONS PRESENTED 1. Does this case present an important question not previously decided by the Supreme Court in which an elected member of the Arizona Legislature engaged in exposing corruption by the Executive Branch was ambushed with a_ sexual harrassment allegation and summarily expelled without due process of law and having no private state constitutional cause of action, based upon a third party report edited illegitimately and deceptively by the proponent of expulsion to remove exculpatory material to the elected representative and containing false statements, instead of having a public Committee hearing involving, inter alia, opening statements, presentation of documents, examination and cross-examination of witnesses and confrontation of accusers? 2. Does the Ninth Circuit’s qualified immunity decision in this case, which relied upon cases involving police law enforcement, that a constitutional right is not “clearly established” for a damages action under 42 U.S.C. §1983 where there is an absence of a specific case on the facts of this case conflict with this Court’s decision in Hope v. Pelzer, 536 U.S. 730, 740-741 (2002), that in determining whether there was “reasonable warning that the conduct then at issue violated constitutional rights,” “general statements of the law are not inherently incapable of giving fair and clear warning” and “a general constitutional rule already ii identified in the decision law may apply with obvious clarity to the specific conduct in question”? 3. Does the Ninth Circuit’s decision in this case create a conflict with other Circuits which recognize a due process interest of a legislator in having a public hearing before a Committee of peers, McCarley v. Sanders, 309 F.Supp. 8 (M.D. Ala. 1970), and Monserrate v. N.Y. State Senate, 599 F.3d 148, 158 (2d Cir. 2010)? 4. Does the Ninth Circuit’s qualified immunity decision, which effectively immunizes a deliberate effort to prevent anti-corruption inquiries, raise an important federal constitutional due process question that the U.S. Supreme Court should consider and call for the exercise of this Court’s supervisory power? 5. Does the Ninth Circuit’s rationale for rejecting an equal protection claim—the intent to stop anticorruption efforts precluded finding a required intent to discriminate based on sex—constitute an important federal constitutional due process question that the U.S. Supreme Court should consider and call for the exercise of this Court’s supervisory power? 6. Does the Ninth Circuit’s departures from established principles, stated by this Court and other courts of appeal, of deciding motions to dismiss— (a) when ignoring statements of material fact and treating as true a document not attached to the Complaint but rather that is referenced in the Complaint as misconceived and erroneous and (b) iii when denying leave to amend the original an important federal constitutional due process question and an issue of appellate review that the U.S. Supreme Court should consider and call for the exercise of this Court’s supervisory power? PARTIES Donald Shooter (“Shooter”) was a Republican member of the Arizona Senate from 2010 to 2016 and was a member of the Arizona House of Representatives from 2016 until his expulsion on February 1, 2018. In the period 2010 to February 1, 2018, Shooter also was, at various times, Chairman of the Senate Appropriations Committee, Chairman of the House Appropriations Committee and Chairman of the Joint Legislative Budget Committee. (50a-51a, 54a, 57a.) For all periods relevant to the Complaint in this case, Kirk Adams (“Adams”) was Chief of Staff to the Governor of Arizona, and Javen Mesnard (“Mesnard”) was Speaker of the House. (50a.)