Whether the Sixth Circuit panel's decision to affirm the District Court decision that was based on the application of the wrong legal test constituted a violation of a Supreme Court guideline, a denial of due process to Plaintiff, and a violation of the just aspect of Rule 1

QUESTIONS PRESENTED Question 1 presented is: Whether the Sixth Circuit panel’s decision to affirm the District Court decision that was based on the “application of the wrong legal test” constituted a violation of a Supreme Court guideline (“an erroneous legal conclusion deserves no deference on appeal”), a denial of due process to Plaintiff, and a violation of the “just” aspect of Rule 1; because even though the panel applied the correct law to the District Court decision, the panel and the District Court held no hearing and Plaintiff therefore did not have the opportunity to be heard. Indeed, the panel asserted as follows: “On remand, the district court denied Jaiyeola’s motion for sanctions, concluding that he had failed to meet his burden of proving by “clear and convincing evidence that Defendants’ counsel presented intentionally false material to the Court.” Obviously, Plaintiff could not have presented a “clear and convincing evidence that Defendants’ counsel presented intentionally false material to the Court.” without a hearing at the District Court or at the Sixth Circuit. A “clear and convincing evidence” burden of proof is a very high standard for a Court to ask for. In a lawsuit where credibility of the litigants are tied to the facts of the case, an . evidentiary hearing and cross-examination 1 Koon. : ii QUESTIONS PRESENTED—Continued must be allowed. Hemphill v. New York, No. 20-637, 595 U.S. _ (2022). As the Supreme ; ; Court has noted, cross-examination is the “sreatest legal engine ever invented for the discovery of truth.” California v. Green, 399 US. 149, 158, 90 S.Ct. 1930, 26 L.Ed.2d 489 (1970).” Johnson v. Bell, 605 F.3d 333 (6th Cir. ’ 2010). And if there is a video evidence that is central to the issues, the Court should admit the video into evidence. A litigant cannot overcome a “clear and convincing evidence” burden of proof without evidentiary hearing, cross-examination, and admission of evidence like a video evidence. Both the District Court and the Sixth Circuit Court of Appeals denied Plaintiff a hearing. Plaintiff was unable to overcome a “clear and convincing evidence” burden of proof at the District Court. ; Question 2 presented is: Whether a Court can correctly decide a lawsuit when the Court demands “clear and convincing evidence” burden of proof and where credibility of the litigants are tied to the facts of the case without conducting evidentiary : hearing, allowing for cross-examination, and admitting any valid video into evidence. ; . “Because a district court has no discretion not to abide by governing law, an erroneous legal conclusion , deserves no deference on appeal. See Koon v. United iii QUESTIONS PRESENTED—Continued States, 518 US. 81, 100 (1996).”? “Rule 1... emphasize that ... the court should construe and administer these rules to secure the just, ... determination of every action,” Fed. R. Civ. P. 1 (Committee Notes on Rules—2015 Amendment). The Sixth Circuit Court of Appeals violated the “just” aspect of Rule 1 and denied : Plaintiff due process when the panel affirmed a District Court decision where the District Court used the wrong legal standard and the District Court denied Plaintiff a hearing. The Sixth Circuit also denied Plaintiff a hearing. “injustice was more likely to be caused than avoided by deciding the issue without pe: titioner’s having had an opportunity to be heard.” Singleton v. Wulff, 428 U.S. 106 (1976). “Accordingly, the proceedings did not comply with [Rule 1], and neither did they comport with due process. See, e.g., Mullane v. Central Hanover Bank & Trust Co., 339 U.S. 306, 314 (1950) (‘The fundamental requisite of due process of law is the opportunity to be heard.’) (quoting Grannis v. Ordean, 234 U.S. 385, 394 (1914)).” Nelson v. Adams ~ USA, Inc., 529 U.S. 460 (2000). ; The Sixth Circuit panel asserted as follows: “In denying that motion on remand, the district court applied Sixth Circuit precedent stating that a party seeking to show a fraud on t