1. Should the Supreme Court adopt, as a
national standar d, Chapman v. Pier 1 Imports (U.S.)
Inc., 631 F.3d 939, 944 (9th Cir. 2011), to balance the
need to deter abusive serial ADA filings with the need
to afford relief to legitimate ADA claimants, by
requiring the ADA plaintiff to plead and prove
standing for each ADA non-compliance item alleged, as
a condition for recovery of attorney's fees and costs?

2. Does a ADA defendant's stipulation to fix
certain ADA non-co mpliance items preclude it from
seeking Rule 11 sanctions against a serial ADA
plaintiff for false assertions pleaded on her complaint?

3. Does the Court of Appeals lose jurisdiction to
entertain a post-mandate motion for attorney's fees
brought under Ninth Circuit Court of Appeals, Circuit
Rule 39-1.6?

4. Is Ninth Circuit Court of Appeals, Circuit
Rule 39-1.6, unconstitutional because it authorizes the
Court of Appeals to decide post-appe al fee motions,
thereby depriving parties of their right to appellate
review?

Should the Supreme Court adopt Chapman v. Pier 1 Imports as a national standard to balance the need to deter abusive serial ADA filings with the need to afford relief to legitimate ADA claimants?