The Fourteenth Amendment guarantees that no State shall deprive any person of property without due process of law. Central to the guarantee is a meaningful opportunity to be heard and to present evidence before judgment is entered.

This case presents the following questions:

1. Whether a State Court may enter judgment based upon deemed admissions or procedural default where the record shows the party timely served and filed the required admission responses, and opposing Counsel, on appeal, and the California Appellate Court, (District Four, Division Two), acknowledged that opposing Counsel received responses to request for admissions on behalf of his client, the propunding Party, ten (10) weeks before they were deemed admitted. (See Appendix - ■ F )

2. Whether due process permits a Court to exclude defenses witnesses and documentary evidence central to ownership of property, thereby preventing adjudication on the merits of the case.

3. Whether appellate affirmation resting on factual misstatements of the record denies "meaningful opportunity to be heard" required by the Due Process Clause.

4. Whether extinguishing substantive property rights through hyper-technical procedural rulings, rather than merits adjudication, constitutes an arbitrary deprivation of property under the Fourteenth Amendment.

Question not identified.