I. Due Process and Equal Protection Questions
(Fourteenth Amendment)
1. Whether the trial court violated procedural due process and
equal protection
A. by allowing discovery deadlines to lapse and extending
discoveiy for one party without motion or notice (App.
A53, 54,58-62);
B. by denying enforcement of discovery orders and agreements
(App. A48, A53);
C. by vacating the February 24, 2023 scheduling order from the
bench without motion or notice, citing "directives " from higher
courts, and denying motions to compel previously served
discovery (App. A35, A37-41);
D. by granting summary judgment without resolving the
unconscionability dispute in favor of the non-movant, despite
acknowledging that Defendant signed the contract ten days after
Plaintiff and that Plaintiff sought reformation of commitment
dates as unconscionable, contrary to Pennsylvania Commercial
Code § 2302 and the rule that all factual disputes be construed
in favor of the non-moving party (App. A26, A32);
E. by failing to address any of the six appellate questions —each
alleging discovery misconduct, bias, or due-process violations —
and by applying de novo instead of "abuse of discretion " review
(App. Al 1-12);
2. Whether the following actions violated the right to an impartial
tribunal under Caperton v. A.T. Massey Coal Co., 556 U.S. 868
(2009), and Tumey v. Ohio, 273 U.S. 510 (1927):
(a) a trial judge concealing a conflict through a spouse 's firm 's
business ties with Fannie Mae (App. A43);
(b) a judge relying on "marching orders " from the Supreme
Court and President Judge (App. A35,A37); and
(c) a President Judge self-adjudicating disclosure of her own
directives (App. A 14-Al 9).

II. Questions of First Impression and Public Importance
(Due Process, Life, Liberty, and Property)
3. Whether access to justice for pro se litigant was denied
A. by the Pennsylvania Supreme Court 's per curiam denial of a
nunc pro tunc petition filed 20 minutes past deadline due to
documented court-website malfunction, after five months of
inaction (App. A1-A4); and
B. by denying pro se motions without reasons, including the
refusal to explain non-enforcement of a discovery order,
hindering appealability and error correction (App. A47-A48).
4. Whether a "time-of-the-essence " clause in Fannie Mae 's
standard adhesion contract is waived or breached when Fannie
Mae, as drafter, fails to execute the agreement within one
business day after the buyer 's signature and signs a contract
without completing mandatory pre-listing tasks, such as paying
outstanding utilities and "critical Equator tasks " (REO Guide
App. A71-A73), thereby creating unconscionable terms
contrary to § 2302 and established UCC principles.
5. Whether the REO Guide 's provisions for third-party complaints
and ethical conduct in negotiations exist independently of any
executed contract (App. A71-

Whether the trial court violated procedural due process and equal protection by allowing discovery deadlines to lapse without notice, granting summary judgment without resolving unconscionability disputes, and whether the Pennsylvania Supreme Court denied access to justice by denying a nunc pro tunc petition and failing to review judicial bias claims