Whether the district court error and/or abused its discretion by not affording the
Petitioner leave to amend her complaint and instead granted the Respondent
summary judgment without any consideration or regards to Petitioner 's substantive
rights under 281 U.S.C. § 2072 (b)?

Whether the district court error and/or abused its discretion by omitting the
Petitioner's former Counsel of Record, James D. Hartt, Esq., who initiated the Title
VII civil action on April 13, 2016 in the U.S. District Court on behalf of the
Petitioner who was not even Pro Se at the time, all of which was not mentioned in
the memorandum & Order [USDC/EDNY - 16-cv-1784 (MLK)(LB) - Doc. No. 104].

Whether the district court error and/or abused its discretion by stating in its
memorandum & order [USDC/EDNY - 16-cv-1784 (MLK)(LB) - Doc. No. 104]
"Plaintiff... [was] proceeding prose..." commenced the above-caption action on April
13, 2016, when Petitioner 's former Counsel of Record, commenced the action on
behalf of the Petitioner?

Whether the district court error and/or abused its discretion by not permitting
Petitioner liberal discovery.

Whether the district court error and/or abused its discretion by ignoring the
Petitioner's Affidavit of Request for Summary Judgment [USDC/EDNY- Doc. No.
59].

Whether the district court erred and/or abused its discretion