1. Due Process and Access to Courts
Whether the combined effect of emergency tolling restrictions, denial of disability
accommodations, and additional procedural barriers violated the Due Process
Clause by depriving pro se litigants with disabilities of meaningful access to the
courts and extinguishing otherwise timely claims.

2. Equal Protection in Application of Tolling Orders
Whether limiting tolling relief only to claims expiring strictly within the emergency
period, while denying relief to similarly situated litigants whose claims expired
immediately thereafter, violates the Equal Protection Clause.

3. Conflict with Federal Precedent on Tolling Principles
Whether the District of Columbia courts ' narrow interpretation of emergency tolling
Orders conflicts with federal precedent requiring broader tolling to protect litigants '
rights during extraordinary circumstances.

4. Delayed Discovery Doctrine and Disability Rights
Whether refusal to apply the delayed discovery doctrine, despite
physician-documented cognitive impairments and DC. Code § 12-302, violated
federal law and Title II of the ADA by denying equal access to justice.

5. Impact of Hostile Work Environment and Retaliation on Disability
Progression
Whether courts must consider the cumulative impact of unresolved hostile work
environment and retaliation claims —where the record shows progression from one
disability to multiple impairments —when applying tolling doctrines and
access-to-justice protections.

6. National Importance of Uniform Standards for Pro Se Litigants with
Cognitive Impairments
Whether inconsistent application of emergency tolling, disability-based tolling, and
delayed discovery doctrines among jurisdictions raises a question of national
importance warranting this Court 's intervention to ensure uniform access to justice
for pro se litigants with cognitive impairments.

Whether the combined effect of emergency tolling restrictions, denial of disability accommodations, and procedural barriers violated Due Process and Equal Protection by depriving pro se litigants with disabilities of meaningful court access