1. Whether a civil defendant invoking the privilege against self-incrimination in his pleadings and discovery responses, is unconstitutionally penalized by denial of his pre-trial request for leave to amend his answer and participate in discovery; and whether the civil defendant's due process rights are also infringed by effectively being forced to choose one Constitutional right (Fifth Amendment privilege) over another (due process right to full and fair trial on the merits).

2. Whether a civil contempt order based on a finding that a defendant violated a temporary restraining order freezing funds traceable to the victims of his alleged acts, violates a civil litigant's right to counsel, where he is precluded from arguing the subject funds, used to retain counsel, were untainted under this Court's decision in Luis v. United States, 136 S.Ct. 1083 (2016), because the Luis case applies only to defendants in criminal proceedings.

3. Whether a civil defendant's due process rights are violated, where the wrong standard was employed in affirming summary judgment; and further where no weight was ever considered as to Petitioner's declaration in opposition, despite the court of appeals holding that the district court erred in disregarding said declaration because it was self-serving.

Whether a civil defendant invoking the privilege against self-incrimination in his pleadings and discovery responses is unconstitutionally penalized