1. Whether the Ninth Circuit has been denying Due Process by applying a purportedly categorical rule, Ramirez-Alejandre v. Ashcroft, 320 F.3d 858, 875 (9th Cir. 2003) (en banc), allegedly supported by Padgeti v. Wright, 587 F.3d 983, 985 n. 2 (9th Cir. 2009) to thousands of pro se appeals, a-la secret policy in Schexnayder v. Vannoy, 140 S. Ct. 354 (U.S. 2019) (Sotomayor, J.), including post-Brown v. Arizona, 82 F.4th 863, 873-74 (9th Cir. 2023) (en banc).

2. Whether the Ninth Circuit retaliated against Lukashin for repeatedly bringing the "Padgett fraud" to that court's attention via Circuit Rule 36-4 requests for publication and motions to intervene, e.g. California River Waich v. City of Vacaville, 14 F.4th 1076, 1079 (8th Cir. 2021), intervention denied by amended opinion, 39 F.4th 624 (9th Cir. 2022) ("CRW"), via the suasponte-amended pre-filing review order, all without following requirements of binding circuit precedent or engaging with Lukashin's detailed arguments.

3. Whether the sua-sponte amended pre-filing review order is a de-facto filing ban for lack of a Due Process-required notice of intent to amend and an opportunity to be heard in opposition, as well as reasoned explanation; and the new language.

Whether the Ninth Circuit violated due process by imposing a pre-filing review order without notice or opportunity to be heard, effectively creating an unconstitutional filing ban