Does Fed. R. Civ. P. Rule 26(a)(1)(B)(iv) deny Initial Disclosure to incarcerated, pro se litigants, thereby rendering the Confrontation and Equal Protection clauses of the Fourteenth Amendment unavailable to them?

1. ) Does Fed. R. Civ. P. Rule 26 (a)(1)( B)(iv.) deny Initial Disclosure to incarcerated, pro se litigants, simply because they are not represented by counsel; thereby rendering the Confrontation and Equal Protection clauses found in the Fourteenth Amendment to the United States Constitution, unavailable to them? 2. ) Applying the response for Question No. 1, when •jchallenging the veracity of an affidavit , before summary judgment, did the deprivation caused by Rule 26 (a)(1)( B)(iv.) infringe upon the petitioner's right to petition the courts, for the redress of grievances, guaranteed by the First Amendment to the United States Constitution? 3.) Did the United States Court of Appeals, for the Sixth Circuit, err when it stated that the petitioner failed to argue the case of Reed-Bey v. Prams taller ^,in the district court? ^An affidavit written by Richard D. Russell, the Grievance Section Manager for the Michigan Dep't of Corrections, signed 14, 2022 was taken in "Good Faith" by the attorney for the defend ants, Joseph Y. Ho. The district court cited "Authentication Language" as the basis for it's acceptance of this document. Cited by the petitioner in a Reply brief, filed on Dec. 5, 2022, as ECF No. 50(See