[This Court and circuits have agreed: plaintiffs demonstrated triable issues for a
jury on review of similar facts and issues under Title IX, See Davis v. Monroe
County Board of Education, 526 U.S. 629 (1999); Doe v. Fairfax Cnty. Sch. Bd., 1
F.4th 257, 263 (4th Cir. 2021); and Papelino v. Albany College of Pharmacy of Union
University, 633 F.3d 81 (2d. Cir. 2011).]

1. Whether the underlying case presents one of more Questions of Fact for a jury;
and, if no, Whether the case presents one or more cognizable claims that, should the
plaintiffs application for pro bono court-appointed counsel have been granted, an
attorney presenting such claims could have avoided the pleading and procedural
errors charged by the lower courts in deciding the case against the pro so, IFP
plaintiff?

2. Whether the court 's denial of an indigent Title IX plaintiffs application for pro
bono counsel, and subsequent judgment that she could not meet pleading standards,
imposes a higher burden on an indigent claimant seeking relief under Title IX in a
private action?

3. Whether the record demonstrates misconduct or discrimination sufficient to
support the plaintiffs position that the court 's judgment cannot stand due to
impermissible discrimination and hostility adverse to her rights during the
adjudication, and involving the state; and, if no, whether the record demonstrates a
departure from proceedings sufficient to impact the judgment, or to require the
judgment to be set aside?

Whether the underlying case presents one or more Questions of Fact for a jury; and, if no, Whether the case presents one or more cognizable claims that, should the plaintiffs application for pro bono court-appointed counsel have been granted, an attorney presenting such claims could have avoided the pleading and procedural errors charged by the lower courts in deciding the case against the pro so, IFP plaintiff?