1. Whether the 11th Circuit Court erred when it did not consider Horace's medical records and expert witness statements raised in argument to the District Court, and whether Horace stated a plausible claim of medical battery pursuant to Ashcroft v. Iqbal, 556 U.S. 662 (2009) and Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007). To avoid dismissal under Rule 12(b)(6), the court to consider Horace's medical records and expert witness statements to determine if Horace plausibly stated a claim of medical battery.

2. Whether the 11th Circuit Court erred in affirming the District Court's Motion to dismiss Horace.

3. Pursuant 28 USC App. Fed General (j)(a)(b)2, whether Defendant forfeited its argument by not denying Horace plausible claim of medical battery at its pleading stage?

4. Pursuant Rule 90.402 Evid., whether Horace abandoned his pleading of medical battery Per Pretrial Scheduling Order?

6. Whether Horace claim of medical battery is unpreserved, despite the Joint Agreement per Court order?

7. Whether The District Court recognized the psychotherapist-patient privilege in federal common law?

Whether Horace forfeited his argument in the District Court's error in granting MD Now's motion to dismiss without considering medical records and expert witness statements