Whether a federal court had the authority and obligation to vacate a state court judgment obtained through perjury suborned by the prevailing party's attorney

QUESTIONS PRESENTED 1. Whether, under Fed. R. Civ. P. 60(d), a federal court had the authority, and obligation, to vacate a judgment obtained in a state court, where the documentary and trial testimony evidence unequivocally demonstrated that the prevailing party’s principal witness committed perjury during the trial on a central issue in the lawsuit, suborned by his attorneyan officer of the court-and where the defendant was not represented by an attorney during the trial, because the judge proceeded to conduct the trial even though the defendant’s attorney failed to appear for the trial, despite the fact that the court had not granted his motion to withdraw, and did the federal court abuse its discretion by refusing to apply Rule 60(d) without even addressing the defendant’s claim, or the unequivocal evidence, that the plaintiffs principal witness had committed perjury, suborned by his attorney. 2. Whether a declaratory judgment that a state judge had violated the defendant’s right to due process under the 14th Amendment was appropriate where the judge proceeded to conduct a jury trial even though the defendant’s attorney failed to appear for the trial, and the attorney’s motion to withdraw had not been granted, and where the evidence indicated that the judge’s decision to conduct the trial without the defendant’s attorney present was motivated by a retaliatory motive against the defendant because the defendant’s mother had been urging the court to adjourn the trial so that the defendant could retain new counsel, and where the court’s appointment of a receiver to enforce the judgment obtained via the ii suborned perjury continued to have ongoing and future adverse effects on the defendant. 3. Whether the Rooker-Feldman doctrine, state preclusion law, or the statute of limitations precluded applying Fed. R. Civ. P. 60(d) to vacate a judgment which had been obtained in a state court based on the principal witness’s commission of perjury, suborned by his attorney, and the perjury could not be raised as an appellate issue in the state court because the trial court had proceeded to conduct the trial without the defendant’s attorney present, and therefore no attorney was present to make an evidentiary objection to the admission of the perjurious testimony, which in turn precluded raising the issue on appeal under the state’s appellate rules and case law. 4. Whether the federal court abused its discretion by denying the plaintiff's motion for leave to file a Second Amended Complaint in which the plaintiff had corrected the court’s assertion that the plaintiff had not adequately pled the claim to vacate the state court judgment under Fed. R. Civ. P. 60(d), where the proposed Second Amended Complaint remedied the alleged pleading deficiency by clearly and specifically citing Rule 60(d) in the proposed Second Amended Complaint.