I.
Whether the Due Process Clause of the Fifth Amendment —as construed
in Stop the Beach Renourishment, Inc. v. Florida Dep 't of Environmental
Protection, 560 U.S. 702 (2010), and Sheetz v. County of El Dorado, 601
U.S. 267 (2024) —forbids federal courts from issuing judicial decrees that
extinguish a litigant 's vested procedural default rights under Federal
Rules of Civil Procedure 81(c)(2)(C) and 55(a), without prior notice and
without affording an opportunity to be heard, where the opposing party
concededly never filed a responsive pleading within the mandatory
statutory deadline.

II.
Whether the Second Circuit 's affirmance —which treated a pre-motion
conference letter that the Clerk of the Eastern District of New York
expressly rejected as "not a motion " as sufficient to defeat Petitioner 's
default entitlements —is irreconcilable with that same Court 's holding in
Kowalchuck v. Metropolitan Transportation Authority, 94 F.4th 210 (2d
Cir. 2024), thereby creating an intra-circuit conflict of constitutional
dimension that only this Court can resolve.

III.
Whether a circuit judge who previously presided over and rendered a
complete, unreserved judgment in favor of one party in prior insurance
coverage litigation is disqualified under 28 U.S.C. § 455(a) from
adjudicating that same party 's appeal, and whether the judge 's unilateral
denial of her own recusal motion —without referral to the full panel —
constitutes a structural due process violation under the Fifth
Amendment independently warranting certiorari.

IV.
Whether the Contracts Clause of Article I, Section 10, and the Due
Process Clause of the Fifth Amendment are violated when federal courts
affirm the dismissal of a breach-of-contract claim arising from a
documented litigation agreement without addressing uncontroverted
documentary evidence of the contract 's formation and its material
breach, where the breaching party obtained its procedural advantages
through fraud upon the court within the meaning of United States v.
Throckmorton, 98 U.S. 61 (1878).

Whether the Due Process Clause of the Fifth Amendment forbids federal courts from issuing judicial decrees that extinguish a litigant's vested procedural default rights under Federal Rules of Civil Procedure 81(c)(2)(C) and 55(a) without prior notice and opportunity to be heard, and whether judicial recusal and breach-of-contract dismissals without addressing documentary evidence violate constitutional protections