Based on the Supreme Court of the United States precedents:
Should a 'pro se litigant's" [or any litigant's] First Proposed
"Heightened" Amended Complaint with attachments be
unfairly denied by any courts of law through its
discretionary privileges based on not following the Court's
Scheduling Order,' Undue delay, futility, employee's
knowledge of information available to employee before
filing suit, etc.; in spite of court records substantiating that
the "pro se litigant" did irrefutably believed he followed the
trial court's Scheduling Order; because the trial court
approved of and did not object to the proposed deadline to
amend complaint as designated within the "pro Se"
Plaintiffs, "Joint Preliminary Report?"

Under the second and third frameworks of McDonnell Douglas v.
Green, 411 U.S. 792 (1973), and within Title VI, Title VII, §§ 1981
and 1985 claims:
Does an employer's "verbal articulation(s)" without
providing any pulpable evidence or factual support [e.g.:
warning notices, other remedial write-ups, snapshots,
salary administration policy, etc.] be sufficient alone, in
validating pivotal segments of the employer's rebuttal for
its disciplinary adverse actions against an employee within
a summary judgment motion;

and, under the Constitutional Laws of the United States and
Evidentiary Rules:
Should any "litigant's" (especially pro se) submitted
documentary evidence [e.g.: business records, employer's
handbooks, policies, appraisals, memos, personnel files,
routine practices, affidavits, etc.], be calculatingly
eradicated by judicial discretion based on authentication-
manipulation, and/or one 'possible" hearsay statement,
which then makes invalid a "litigant's" substantial rights
and legal opportunities in establishing (by a preponderance
of evidence) pretext, race and compensation discrimination,
comparators, routine practices, and delayed retaliation
claims under the "cat's paw theory" of liability when
opposing a summary judgment motion?

Should a pro se litigant's First Proposed Heightened Amended Complaint be unfairly denied by courts based on not following Scheduling Order, undue delay, futility, employee's knowledge, etc. despite substantiating belief of following Order?