1. Claim Preclusion and Due Process:
Whether the Ninth Circuit erred in affirming the dismissal of
petitioner's claims on the grounds of claim preclusion when the petitioner
was denied a full and fair opportunity to litigate those claims in the prior
state court action, in violation of Kremer v. Chemical Construction Corp.,
456 U.S. 461 (1982).

2. Judicial Misconduct and Due Process:
Whether the Ninth Circuit violated the petitioner's constitutional due
process rights and engaged in judicial misconduct by dismissing the
appeal without considering the petitioner's evidence of corporate fraud,
in retaliation for the petitioner's anti-corruption advocacy, contrary to
the Fifth and Fourteenth Amendments, and 28 U.S.C. §§ 453 and 455.

3. Fraud and Claim Preclusion:
Whether allegations of fraud and fraudulent concealment by the
petitioner against the defendant preclude the application of claim
preclusion under Federal Rule of Civil Procedure 60(b)(3), and how the
four-year statute of limitations for civil RICO claims impacts the claim
preclusion analysis.

4. First Amendment Retaliation:
Whether the Ninth Circuit violated the petitioner's First Amendment
rights by imposing sanctions or legal consequences in retaliation for the
petitioner's political expression and advocacy efforts, as protected by
NAACPv. Button, 371 U.S. 415 (1963).

5. Consistency in Judicial Process and Due Process:
Whether the issuance of conflicting orders by the Ninth Circuit, where
an original panel found the petitioner's appeal to be non-frivolous but a
later panel dismissed the appeal in retaliation for whistleblowing on
state government corruption, constitutes a violation of the petitioner's
due process rights to a consistent and fair judicial process, as articulated
in Caperton v. A.T. Massey Coal Co., 556 U.S. 868 (2009), and related
cases.

6. Fraud Upon the Court and Due Process:
Whether the California state court's approval of State Farm's Motion
for Evidence Sanctions, based on deliberate misrepresentations and
deceit, constitutes fraud upon the court, and whether the Ninth Circuit's
failure to address these allegations in the petitioner's opening brief
warrants Supreme Court review to uphold fundamental due process
rights under the Fourteenth Amendment, as supported by Hazel-Atlas
Glass Co. v. Hartford-Empire Co., 322 U.S. 238 (1944), and United States
v. Throckmorton, 98 U.S. 61 (1878).

7. Legally Binding Orders and Procedural Rules:
Whether the Ninth Circuit's memorandum issued on April 2, 2024, not
constituting a legally binding order under applicable procedural rules,
and the premature and prejudicial denial of the appeal En Banc, while
the related California Supreme Court case for claim preclusion is still
pending, justify reopening the appeal based on errors and constitutional
violations.

8. Jurisdiction and Res Judicata:
Whether the Ninth Circuit's memorandum fails the two-part test for
res judicata as outlined in Commissioner of Internal Revenue v. Sunnen,
333 U.S. 591 (1948), because there was no final judgment from the
California Supreme Court and the court lacked jurisdiction

Claim Preclusion and Due Process