Gina Russomanno v. Sumitomo Pharma America, Inc., et al.
Environmental SocialSecurity Securities Immigration
Whether the district court's judgment is void due to abuse of discretion and miscarriage of justice,
QUESTIONS FOR REVIEW J. Whether the related-case, OPINION-decision, DCNJ [3:19-cv05945), [DKT. 61], which is boldly “absent adequate remedy of law,” per judicial law requirement is extraordinary circumstance in abuse of discretion, and grave miscarriage of justice; and whether, : that judgement is thereby, void as a matter of law. To Note: . (Wherein, (no form of) “curative amendment remedy was ever provided on a Motion to Dismiss, Rule 12(6)(6) dismissal in failure to state a claim,” (starting page 10 of a uniform-Opinion, with a remand reconsideration), per : related-case, [3:19-cv-05945}). a 2. Whether, the Rule 60(d)(1), independent-action, no-time limitation, savings-clause provision, can be jurisdictionally brought to the trial court, as specially enjoined by law, for due-relief to “cure” a Judgement “absent adequate remedy of (judicial) law,”(per it’s related-case, [3:19-ev-05945]); whereby, discovery to the Opinion-Omission, was after-timelines in Matter of Right Rule . 4a, and Permission to Appeal Rule 5a; and whereby, adequate relief cannot be obtained in any other form or any other court. : 3. Whether, the U.S. Court of Appeals for the Third Circuit will , “certify” questions of law to the U.S. Supreme Court; whereto: “A district court must provide curative amendment, leave to amend, or Opinion-statements in reasons amendment . would be futile, upon ANY, Motion to Dismiss, Rule 12(b)(6) dismissal in failure to state a claim; [Phillips v. County of Allegheny], et. al; And whether, the courts omission to provide that judicial : requirement is extraordinary circumstance in abuse of discretion and grave miscarriage of justice; wherein, : : thereby, the judgement is void as matter of law. [Barrett]; [Wright& Miller); [Allcock); [Jaffe]; [Beggarly]; [Mitchell . . 4. Whether, DCNJ Freda L. Wolfson, now Partner Lowenstein Sandler, LLP, will comply to enter amicus curiae brief, in , ‘considerable help to this Court,’ in support of the plaintiff per : granting certiorari. i, 5. Whether, the Deference (by the Judges and Courts) to ‘Cure’ this has gone too far toward this Pro Se Plaintiff, her cases, and her earnest attempts toward appropriate, adequate due-relief. To Note: (Whereby, for example, the Court of Appeals for the Third Circuit denied plaintiffs appeal [24-1080], in a final summary sentence, that stated: ; “Accordingly, the District Court did not ‘abuse its discretion’ in declining to grant relief on Russomannos Rule 60(d) motion”). : (The Third Circuit Appeals Court could easily construe, that plaintiffs ‘appeal petition statements’ were not pertaining to any “abuse of discretion” upon the District Courts “denial by Jurisdiction” for plaintiffs Rule 60(d)(1) action, but rather, for: the “abuse of discretion” upon the related-case, ' [3:19-cv-05945], for its Judgment-Opinion, [Dkt ; 61}, in being boldly, “absent adequate remedy of Gudicial) law,” requirements; when by Rule 4a, and Rule 5a) Memorandum Citations: [Phillips v. Cnty. of Allegheny], 515 F.3d 224, 234 (3d Cir. 2008) [Barrett], 840 F.2d at 1263 [Wright & A. Miller], Fed. Practice and Procedure § 2868 at 238 (1973) [Allcock v. Allcock], 437 N.E. 2d 392 (Ii App. 3 Dist. 1982) [Beggarly], 524 U.S. at 47 (1998) . [Mitchell v. Rees}, (6™ Cir., 2011) ii.