1. Whether a district court may categorically stay all
discovery at the pleading stage and dismiss a civil
action on a closed record where adjudication of the
claims turns on facts uniquely within defendants '
possession.

2. Whether a court of appeals may apply a prudential
waiver doctrine to foreclose appellate review of a
dismissal entered after discovery was categorically
denied, where the asserted waiver arises from the
procedural posture created by the discovery stay
itself.

3. Whether the interaction of categorical discovery stays
and rigid application of prudential waiver doctrines
permits district court dismissals to be effectively
insulated from meaningful appellate review on the
merits, in a manner capable of repetition yet evading
review.

Whether a district court may categorically stay all discovery at the pleading stage and dismiss a civil action on a closed record where adjudication of the claims turns on facts uniquely within defendants' possession, and whether such procedural mechanisms effectively insulate dismissals from meaningful appellate review