Whether the district court's dismissal of Petitioner's case without permitting record development deprived Petitioner of a meaningful opportunity to present evidence, in violation of the Fourteenth Amendment's Due Process Clause

1. Whether the district court ’s dismissal of Petitioner ’s case without permitting the development of the record deprived Petitioner of a meaningful opportunity to present evidence, in violation of the Fourteenth Amendment ’s Due Process Clause. (See Logan v. Zimmerman Brush Co., 455 U.S. 422 (1982).) 2. Whether the lower courts erred in dismissing Petitioner ’s claims without considering newly discovered evidence that was material to the issues presented. (See United States v. Bagley, 473 U.S. 667 (1985).) 3. Whether the district court ’s denial of discovery contravened precedent requiring litigants be afforded a fair opportunity to develop the factual record before summary judgment. (See Celotex Corp. v. Catrett, 477 U.S. 317 (1986); Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986).) 4. Whether the denial of discovery to a pro se petitioner, when similarly situated litigants were allowed discovery, violates the Equal Protection Clause of the Fourteenth Amendment. (See Griffin v. Illinois, 351 U.S. 12 (1956); Flowers v. Mississippi, 588 U.S._ (2019).) 5. Whether the use of inhumane detention conditions to coerce involuntary pleas violates due process and raises systemic concerns of coercion. 2 (See Brown v. Mississippi, 297 U.S. 278 (1936); Brady v. United States, 397 U.S. 742 (1970); McMann v. Richardson, 397 U.S. 759 (1970); United States v. Ruiz, 536 U.S. 622 (2002).) 6. Whetherthe assertion of jurisdiction and imposition of parole conditions after the expirationof Petitioner ’s mandatory supervised release (MSR) violates due process and exceeds lawful authority. (See Doyle v. U.S. Parole Comm ’n, 894 F.2d 593 (D.C. Cir. 1990); Jones v. Cunningham, 371 U.S. 236 (1963).) 7. Whether the introduction and improper use of expunged and jurisdictionally barred records in sworn affidavits by high-ranking Maryland Parole Commission (MPC) officials, who were also defendants, tainted the judicial decision granting summary judgment. (See United States v. Crowell, 374 F.3d 790 (9th Cir. 2004).) 8. Whether the re construction of lost records without notice, using inaccurate or expunged materials, violated due process by depriving Petitioner of a fair chance to defend against the allegations. (See California v. Trombetta, 467 U.S. 479 (1984); California exrel. Cooper v. Mitchell Bros. ’ Santa Ana Theater, 454 U.S. 90 (1981).) 9. Whether the suppression of exculpatory evidence regarding Petitioner ’s MSR expiration date and the warrant ’s procedural defects violated due process. (See Brady v. Maryland, 373 U.S. 83 (1963).) 10. Whether the unlawful conditions of pre-revocation detention, prolonged 3 isolation, denial of prescription glasses, lack of legal resources, constituted cruel and unusual punishment, in violation of the Eighth Amendment. (See Hope v. Pelzer, 536 U.S. 730 (2002); Estelle v. Gamble, 429 U.S. 97 (1976).) 11. Whether retaliatory actions and collusion by MPC officials, directed at punishing Petitioner for asserting legal rights (including lawsuits), violated the First Amendment. (See Hartman v. Moore, 547 U.S. 250 (2006); Dennis v. Sparks, 449 U.S. 24 (1980).) 12. Whether the inclusion of expunged and erroneous records in the FBI database by MPC officials, despite prior notice, constitutes a violation of the Privacy Act. (See Doe v. FBI, 936 F.2d 1346 (D.C. Cir. 1991).) 4 (Ill)