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

QUESTIONS PRESENTED 1. Whether the Ninth Circuit has been denying Due Process by applying a purportedly categorical rule, RamirezAlejandre v. Ashcroft, 320 F.3d 858, 875 (9th Cir. 2003) (en banc), allegedly supported by Padgett v. 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. Jn re Apple Inc. Device Performance Litigation, 50 F. 4th 769, 782 n. 9 (8th 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. iff 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. : . . : 224463, p. 1 (U.S. Nov. 30, 2022) (Jackson, J.) (‘Kevin Johnson”), lack of a ; : reasoned explanation, Jonhson v. Ryan, os No. 20-152938, pp. 57-60 (9th Cir. Dec. 15, 2022) (“Richard Johnson”), and effective ultra vires suspension of Circuit Rule 27; 10 by the clerk’s office? :