Category 1: Procedural Default and Compliance
1. Is the defense still in default because they failed to physically
serve the Plaintiff in compliance with the Rules of Civil
Procedure? If the Defendants have no proof of service, what
prevents any court from issuing a default judgment on this
basis?
2. Did the Defendants intentionally mislead the court and
Plaintiff by submitting conflicting certificates of service to
create the appearance of compliance with procedural
deadlines?
3. Should the court consider the Defendants ' failure to file or
serve in compliance with Rule 12(a) as sufficient grounds to
uphold a default judgment against them?
4. How has the Defendants ' submission of conflicting certificates
of service prejudiced the Plaintiff 's ability to obtain timely
relief, both emotionally and financially?

5. Is it within the judge 's discretion under Rule 6(b) to grant an
extension without a specified deadline, or does this omission
constitute judicial oversight or negligence?
6. Does the failure of the court to retroactively apply the
extension order to cure the Defendants' default status under
Rule 12(a) render the Defendants' filings procedurally invalid,
and should this oversight result in the reinstatement of the
Plaintiff 's default judgment motion?
Category 3: Extrinsic Fraud
7. Did the conflicting dates on two certificates of service —one
dated June 23, 2023, and another dated June 26,
2023 —constitute extrinsic fraud by the Defendants, as they
imply misrepresentation of compliance with filing and service
deadlines?
8. Should the submission of conflicting certificates of service be
viewed as obstruction of justice, given its impact on the
Plaintiff 's ability to obtain a fair hearing?
9. Does the lack of a specific deadline in the extension order
create an environment that facilitates extrinsic fraud by
allowing the Defendants to delay filings indefinitely without
accountability?
Category 4: Ethical and Legal Violations
10. Did the Defendants ' actions violate Federal Rule of Civil
Procedure 11(b) by submitting certificates of service that
misrepresented compliance with procedural requirements?
11. Does the submission of knowingly false certificates of service
by the Defendants ' counsel constitute perjury?
12. Did the Defendants ' counsel violate their ethical obligation to
act with candor toward the tribunal by submitting conflicting
procedural filings?
13. Should the court impose sanctions on the Defendants or their
counsel for engaging in bad faith conduct and procedural
abuse?
14. Does the judge 's omission of a deadline in the extension order
deviate from the procedural requirements of Rule 6(b), and
does this deviation undermine the fairness and efficiency of
judicial proceedings?
Category 5: Broader Impact on Judicial Integrity
15. How does the submission of fraudulent procedural documents
undermine trust in the judicial process and the fair
administration of justice?
16. Should the court establish stricter consequences for
procedural fraud to prevent erosion of procedural standards
and ensure equitable treatment of all litigants?
17. Was the submission of conflicting certificates of service a
deliberate strategy by the Defendants to buy time and delay
resolution of the case?
18. Were the conflicting certificates submitted to confuse the
record and obstruct the Plaintiff 's ability to effectively
challenge the Defendants ' procedural failures?
19. Does granting an extension without a deadline create a
prece

Is the defense still in default because they failed to physically serve the Plaintiff in compliance with the Rules of Civil Procedure?