1. Whether the district court violated the Seventh Amendment and Federal Rule of Civil Procedure 39(b) by denying petitioners' timely motion for a jury trial based solely on an inadvertent omission in the original complaint, notwithstanding this Court's instruction that such motions should be liberally granted absent compelling prejudice.

2. Whether the district court erred, and the Eighth Circuit compounded the error, by holding that petitioners failed properly to assign their rights and claims to a sister entity—contradicting common-law principles of assignment and undermining settled expectations in commercial surety contracts.

3. Whether the courts below misapplied Federal Rules 26 and 37 by excluding petitioners' supplemental expert opinion as "untimely" even though the opinion was disclosed within weeks of an amended complaint that first alleged fraud in the inducement, and despite the absence of any prejudice to respondent.

Whether the district court violated the Seventh Amendment and Federal Rule of Civil Procedure 39(b) by denying petitioners' timely motion for a jury trial based solely on an inadvertent omission in the original complaint