1. Defendant Northam's Executive Order 55 (2020) institutes quarantine restrictions
on all Virginians without invoking Va. Code § 32.1-48.08 and without explicitly providing any
due process to citizens challenging their quarantine. Subsequently, the District Court's Order
denies Petitioner any timely procedural due process during a quarantine. The questions related to
these facts are as follows:
Can the Governor legally deprive citizens of liberty and property rights and
circumvent the statutory protections for quarantined individuals by establishing a quarantine
under emergency powers without invoking the quarantine statutes called for under those
emergency powers?
Can the State deprive citizens of liberty and property for quarantine reasons
without the due process required by O'Connor v. Donaldson, and universally treat all citizens as
infected subject to quarantine without offering individual assessments as required by Demore v.
Kim?
Does the District Court's denial of Petitioner's request for a hearing during the
period of the quarantine and the Appellate Court's denial of Petitioner's request for an
emergency injunction or stay without an expedited hearing violate the Fifth or Fourteenth
Amendments by extinguishing citizens' rights to due process when there is no other avenue for
due process provided by the State to redress ongoing injury to Petitioner's rights?
Does the quarantine imposed by Defendant Northam's Executive Orders which
applies universally to all citizens violate the requirement for the restriction of liberty to be the
least restrictive means possible as called for under Shelton v. Tucker?

2. If Defendant Northam's actions and orders under Executive Order 55 (2020)
(hereinafter, "E0-55") are not considered a quarantine, Defendant Northam's Executive Orders
issued under Va. Code § 44.146-17 are the most extensive use of executive powers by a
Governor of Virginia at least since the Civil War and for the first time in history, apply
emergency powers which restrict all citizens liberty and property rights under criminal penalty
universally on all people throughout the extent of Virginia, without any limitation or mitigation.
Also, Defendant Northam's Executive Orders and the statute cited do not explicitly provide due
process to citizens injured by the order and are in effect until June 10, 2020, at which time
Defendant Northam can summarily extend them for another year. The questions related to these
facts are as follows:
Can the Governor use emergency powers under a statute (which was not intended
by the legislature to be used without a quarantine order during a public health threat) to deprive
the entire citizenry of the state of their constitutional right to travel, assemble, worship and use
their property, without legislative action for an extended period of time?
Does the District Court's denial of Petitioner's request for a hearing during the
period of a State of Emergency and the Appellate Court's denial of Petitioner's request for an
emergency injunction or stay without an expedited hearing violate the Fifth or Fourteenth
Amendments by extinguishing citizens' rights to due process when there is no other avenue for
due process provided by the State to redress ongoing injury to Petitioner's rights?
Can Defendant Northam use his emergency powers to deprive all citizens of
Virginia their liberty and property rights without due process as required by Joint Anti-Fasc

Can the Governor legally deprive citizens of liberty and property rights and circumvent the statutory protections for quarantined individuals?