Question 1
Whether the circuit court improperly determined that
a subsequent pleading rather than the initial complaint, is
the operative bar date for claim preclusion in conflict with
Lawlor v. National Screen Service Corp. , 349 U.S. 322
(1955), Lucky Brand Dungarees, Inc. v. Marcel Fashions
Group, Inc. , 590 U.S. 405 (2020), and the Third Circuit's
own precedent in Morgan v. Covington Township , 648
F.3d 172 (3d Cir. 2011) .

Question 2
Whether the Due Process Clause is violated when a
court dismisses a legal-malpractice claim with prejudice
at the pleading stage by resolving a disputed factual issue
concerning the existence of an attorney–client relationship
against the plaintiff, notwithstanding documentary
evidence submitted in opposition to dismissal, without
leave to amend.

Question 3
Whether, under Semtek International Inc. v.
Lockheed Martin Corp. , 531 U.S. 497 (2001), federal
courts must apply the forum state's claim-preclusion and
accrual rules when evaluating state-law professionalmalpractice claims, rather than federal common-law
preclusion principles.

Whether the circuit court improperly determined the operative bar date for claim preclusion in conflict with prior Supreme Court and Third Circuit precedents