Was the layman's intelligence gravely discounted in this medical malpractice case without determining the base of that common knowledge of a Virginia jury? Did spoliation occur by the nonmoving party and was Summary Judgement granted legally with that knowledge? Did the lower courts abuse their discretion by precluding the Plaintiff from calling his providers, who are government employees, to serve as expert witnesses and the Plaintiff treating physicians?

Spoliation by the non-moving party: Spoliation refers to the destruction or significant alteration of evidence, or the failure to preserve property for another's use as evidence in pending or reasonably foreseeable litigation. If spoliation occurred by the non-moving party, could it impact the summary judgment decision? Preclusion of expert witnesses: Courts have discretion in managing the admission of expert testimony. If the lower court precluded the plaintiff from calling government employees or treating physicians as expert witnesses, would it be reviewed under an "abuse of discretion" standards? Discounting layman ’s intelligence: In medical malpractice cases, courts must ensure that the jury can understand the issues without unduly discounting their intelligence. If the base of common knowledge for a Virginia jury wasn't determined, it could be a point of contention. Conflict with other appellate courts: If the Fourth Circuit Court of Appeals' decision conflicts with other appellate courts on the same issue, it could indicate an important federal question that the Supreme Court hasn't settled. Was the layman ’s intelligence gravely discounted in this medical malpractice case without determining the base of that common knowledge of a Virginia jury? Did spoliation occur by the nonmoving party and was Summary a Judgement granted legally with that knowledge? Did the lower courts abuse their discretion by precluding the Plaintiff from calling his providers, who are government employees, to serve as expert witnesses and the Plaintiff treating physicians? Page 10 of 35 Reginald Mack v United States THE SUPREME COURT OF VIRGINIA Petition for a Writ of Certiorari Email; mack.reggic7 18@gmail.com