1. Whether the Ninth Circuit has been
denying Due Process by applying a
purportedly categorical rule, Ramirez-
Alejandre u. Ashcroft, 320 F.3d 858, 875
(9th Cir. 2003) (en banc), allegedly
supported by Padgett u. Wright, 587 F.3d
983, 985 n. 2 (9th Cir. 2009) to thousands
of pro se appeals, a-la secret policy in
Schexnayder v. Vannoy, 140 S. Ct. 354
(U.S. 2019) (Sotomayor, J.), when this
Court's and the circuit's actual waiver /
forfeiture law has discretion, e.g. In re
Apple Inc. Device Performance Litigation,
50 F. 4th 769, 782 n. 9 (9th Cir. 2022)?

2. Whether the Ninth Circuit retaliated
against Lukashin for repeatedly bringing
the "Padgett fraud" to that court's
attention via Circuit Rule 36-4 requests
for publication and motions to intervene,
e.g. California River Watch v. City of
Vacaville, 14 F.4th 1076, 1079 (9th Cir.
2021), intervention denied by amended
opinion, 39 F.4th 624 (9th Cir. 2022)
("CRW'), via a pre-filing review order and
denying reconsideration, all without
following requirements of binding circuit
precedent (Molski / DeLong / Ringgold) or
engaging with Lukashin's arguments.

3. Whether the entered pre-filing review
order is a de-facto filing ban and violates
Due Process for failing to follow circuit
precedent, Johnson v. Missouri, No.
22A463, p. 1 (U.S. Nov. 30, 2022)
(Jackson, J.) ("Kevin Johnson"), lack of a
reasoned explanation, Jonhson u. Ryan,
No. 20-15293, pp. 5760 (9th Cir. Dec. 15,
2022) ("Richard Johnson"), and effective
ultra vires suspension of Circuit Rule 2710 by the clerk's office?

Whether the Ninth Circuit has been denying Due Process by applying a purportedly categorical rule