Bruce Ellis, et al. v. City of Clarksdale, Mississippi, et al.
Environmental Takings DueProcess HabeasCorpus
whether-federal-rule-civil-procedure-5.1(b)-requires-court-certification-of-unconstitutional-act
QUESTIONS PRESENTED 1. This Petition presents a Federal Question that could have and harmonize conflicting decisions in the Federal Circuit Courts and could establish precedential value whether Federal Rule Civil Procedure 5.1(b) requires the Court under 28 U.S.C. § 2408(a) to certify to the appropriate attorney general that an Act of congress (AEDPA) the Antiterrorism Effective Death Penalty Act has been called into question and presents an unconstitutional taking under the Fifth and Fourteenth Amendment, violations of the vagueness Doctrine, and shall be served on the Solicitor General of the United States, Room 5616, Department of Justice, 950 Pennsylvania Ave., N.W., Washington, DC 20530-0001? 2. This Petition presents a Federal Question and could have precedential value in the Court determining whether the Fifth and Fourteenth Amendments impose “Equivalent Due Process Limits” on Court Jurisdiction? 3. This Petition also presents a Federal Question whether Federal Rule Civil Procedure 5.1(b) requires the Court under 28 U.S.C. § 2403(a) to certify to the appropriate attorney general that an Act of congress the Fifth and Fourteenth has been called into question whether the Fifth and Fourteenth Amendments guarantee equivalent Due process of law and shall be served on the Solicitor General of the United States, Room 5616, Department of Justice, 950 Pennsylvania Ave., N.W., Washington, DC 20530-0001? 4. This Petition presents a Federal Question and wish to be more fully informed whether a Trial Court Judge’s ‘mistake’ is reviewable ii : through a Writ of Certiorari pursuant to F.R.C.P. 60(b)(1)? 5. This Petition presents a Federal Question where another Appellate Court could reach a different conclusion on the same issue where the Trial Court Judge’s ‘mistake’ of requiring to establish “Elements of Monell v. Department of Soc. Sucs., 436 U.S. 658 (1978) liability regarding a policy violation, a policy maker, and violation of constitutional amendment creates a genuine issue of material fact legally relevant to Court GRANTING F.R.C.P. 56(c) Motions for Summary Judgment in favor without consideration of F.R.C.P. Subdivision 56(e)(3), F.R.C.P. 56(b), and Inverse Condemnation Claim “Strict Liability provisions of,” 33 U.S.C. § 1251 et seq. The ACT, 86 Stat. 816, (1982) ed. and Supp.II? 6. Whether a question presenting an important public interest involving violations of the Federal (EPA) Environmental Protection Agency Clean Water Act by the City of Clarksdale / Clarksdale Public Works; and Clarksdale Public Utilities at the time of the filing as alleged in Plaintiffs complaint Doc. [1] qualify for Court GRANTING a Writ of Certiorari to prohibit further health exposures to the Plaintiffs and the general public? , 7. Whether another Appellate Court could reach . a different conclusion on the same issue where the Trial Court GRANTED City of Clarksdale / Clarksdale Public Works “Untimely Surreply Dispositive” F.R.C.P. 56(c) Doc. [187] motion for summary judgment filed on July 13, 2021 without Respondent’s seeking leave of court was mistakenly GRANTED by the Trial Court Judge in “Error”? : iii 8. Whether another Appellate Court could reach a different conclusion on the same issue where the Trial Court Judge Granted “Untimely Surreply Dispositive Motion” in violation of provisions of F.R.C.P. 56(b), which provides, “a party may file a motion for summary judgment at any time until 30 days after the close of all discovery?” ; 9. Whether another Appellate Court could reach a different conclusion on the same issue where Trial Court Judge mistakenly stated, Plaintiffs failed to rebut defendant’s claims regarding their “Surreply Dispositive Docs. [153] and [187]” when a party fails ’ to support an assertion of fact or fails to properly address another party’s assertion of fact as required by Rule 56(c) or when an attempted response fails to comply with Rule 56(c), a Motion for Summary Judgment is improper? 10. Whether another Appellate Co