1. Whether the New York State Law, adopte d on or about April 3, 2020, permanently
banning high volume hydraulic fracturi ng in the State of New York is an
unconstitutional Taking of the United States Consti tution under the Fifth and
Fourteenth Amendments.

2. Alternatively, whether the New York State Law, adopted on or about April 3, 2020,
permanently banning high volume hydraulic fracturing in the State of New York is
a violation of Due Pr ocess of the United States Constitution under the Fourth and
Fourteenth Amendment.
3. Alternatively, whether the United Stat es Court of Appeals-Second Circuit
improperly applied or ignored the dict ates and reasoning of the Court in
Rosemary Knick, Petitioner v. Township of Scott, Pennsylvania, et al., 588 U.S. _
(2019), Docket No . 17-647, held on June 21, 2019.

4. Alternatively, whether the New York State Law, adopted on or about April 3, 2020,
permanently banning high volume hydraulic fracturing in the State of New York is
a violation of interstate commerce.

5. Alternatively, whether the decision by t he United States Court of Appeals-Second
Circuit was a denial of the fundamental rights of justice in that Petitioners were not
allowed to: amend their Complaint pursuant to Fed.R.Civ.P. Rule 15; the
Fed.R.Civ.P. 12(b)(6) Motion should have been denied; that pursuant to the
proposed simple amendments, the suit should not have been barred under the
Eleventh Amendment of the United States Constitution; and that Petitioners had
standing to sue Respondents.

Whether the New York State Law, adopted on or about April 3, 2020, permanently banning high volume hydraulic fracturing in the State of New York is an unconstitutional Taking of the United States Constitution under the Fifth and Fourteenth Amendments