1. Absent unfair delay or futility, does fundamental due process require that a Plaintiff be allowed to amend a complaint at least once before a Court's ruling on Summary Judgment?

2. Should a Defendant who caused a lengthy delay in litigation be prevented from prevailing on opposing a first motion to amend?

3. Does a school teacher have an obligation to file a lawsuit pursuant to her job as a teacher that makes her first amendment retaliation claim for filing a lawsuit futile?

4. Is a First Amendment Claim of retaliation for an employee petitioning the courts such a fundmental due process issue that denial of Plaintiff's first motion to amend to add this claim was abuse of discretion?

Absent unfair delay or futility, does fundamental due process require that a Plaintiff be allowed to amend a complaint at least once before a Court's ruling on Summary Judgment?