Firstly, did the Ninth Circuit err in affirming
summary judgment on the Petitioner's battery and
aiding-and-abetting battery claims by holding that
consent to a regulated mixed martial arts (MMA) bout
under Nevada law extends to fighting an opponent
using performance-enhancing drugs (PEDs), contrary
to Kuchta v. Heller, 466 P.3d 534 (Nev. 2020), and
implicating national concerns about athlete safety in
regulated sports?

Secondly, did the Ninth Circuit's affirmance of
summary judgment on the Petitioner's fraud and civil
conspiracy claims, requiring more definitive evidence
than Nevada's typical "slight" evidentiary standard,
create a circuit split with the First, Third, Fifth, Sixth,
Seventh, and Eighth Circuits' lenient standards for
surviving summary judgment and violate the
Petitioner's Seventh Amendment right to a jury trial?
Further, substantial documentary evidence exists and
exceeds the lenient standards, had been referred to in
the ninth circuit (9th, Cir. Nov. 20, 2025) and
stipulated as indeed existing (9th. Cir. Apr, 2025).

Thirdly, does the enforcement of the
Promotional and Ancillary Rights Agreement's (PARA)
prevailing-party fee provision, imposing $390,605.00
in attorneys' fees and $56,751.05 in costs, violate
public policy under Nevada law by chilling meritorious
litigation, raising a question of national importance
about access to justice in adhesion contracts?

Whether the Ninth Circuit erred in affirming summary judgment on battery and fraud claims involving performance-enhancing drugs in mixed martial arts, and whether the enforcement of a prevailing-party fee provision violates public policy