Whether prisoners' constitutional rights are violated by court procedural technicalities that impede access to justice during COVID-19 pandemic

QUESTIONS PRESENTED Mr. Metcalf petitions this Honorable Court, alleging that his civil action was improperly dismissed by the lower courts primarily based on the courts' opinions that his pro se complaint and submissions in opposition to summary judgment were not technically sound in his attempttto verify and or notarize his documents. Although pbFisoner pro se filings are to be liberally construdesand held to less stringent standards, this "technicality" created the lack of an adversary presentation in opposition to each of the three seperate motions for summary judgment, Thus this case presents the folhowing questions: QUESTION ONE Are prisoners' Constitutional Rights to access the Courts violated when the institutional law library is closed in response to COVID-19 protocols, leaving the prisoners without any meaningful: means to research or prepare any filings for extended periods of time? QUESTION TWO Should Courts be more favorable and compéiled to grant pro se prisoners' motions for appointment of counsel when unprecedented events, such as COVID-19, causes the institutional law library to be closed for extended periods of time as presented in question one? : i QUESTION. THREE Are prisoners' Constitutional Rights under the Eighth Amendment violated when prisoners are diagnosed by a specialist and prescribed treatment, and the medical staff at the prison ignores the diagnosis andctreatmentiof the specialist, leaving the diaghosed mediéAltcondition untreated? QUESTION FOUR Are prisoners' rights under Titie II of the Americans with Disabilities Act, 42 U.S.C. §§ 12102 and 12131 violated when diagnosed with a disability and the prison medical staff ignores the disability and refuses to provide the disabled prisoner reasonable accommodations? ‘ QUESTION FIVE Is it proper for the District Court for the Eastern District of Virginia to reject a prisoner's pro se complaint as a "verified" document based on the wording or muddled draftmanship in the verification statement under the liberal construction rule? QUESTION SIX Is it proper for the District Court for the Eastern District : of Virginia and the United States Court of Appeals for the Fourth Circuit not to consider "unrebutted legally significant evidence" when deciding material issues of fact at summary judgment? ii