Whether the Due Process Clause, equal protection clause of the Fourteenth Amendment of the U.S. Constitution, and the litigants' right to access justice implied in the First Amendment of the U.S. Constitution were violated when the California Superior Court for the County of Alameda appointed a discovery referee for all discovery purposes in the action without follow the precedents to properly consider parties' financial hardship and economic disparity among the parties and through an unfair referee nomination and selection process.

Whether it was a violation of the Supremacy Clause of the U.S. Constitution when the procedure in the state court conflicts with Federal Rule of Civil Procedure 53 on the court must give parties an opportunity to be heard before adopting the referee's recommendations.

Whether the appointment of a discovery referee without considering financial hardship and using an unfair selection process violates due process, equal protection, and access to justice rights