1. Whether a state court violates the Parental Kidnapping Prevention Act. (PKPA), 28 U.S.C. § 1738A, by exercising child custody jurisdiction over a non-resident parent after the Clerk of Court had officially closed the docket, and while a federal lawsuit for injunctive relief was pending and in default against state court Petitioners.

2. Whether the Fourteenth Amendment's "Due Process" Clause and the American Disability Act (ADA) are violated when a state court:

(a) Seizes a child from a non-resident without a warrant or predeprivation hearing,

(b) Denies a Rule 60.02(8) motion to vacate a void judgment as "untimely" in direct contradiction of established state Supreme Court precedent, and

(c) Refuses to allow a disabled, out of state parent to participate in hearings via remote technology (Zoom/Phone), effectively barring access to the court.

3. Whether a federal court violates the Due Process Clause and FRCP 55 by denying a default judgment where service was effective and unchallenged by the defendants, thereby allowing a state court to bypass the PKPA and seize a child during the federal delay.

Whether a state court violates the Parental Kidnapping Prevention Act by exercising child custody jurisdiction over a non-resident parent after the docket has been officially closed and while a federal lawsuit for injunctive relief is pending, and whether such exercise of jurisdiction violates the Due Process Clause and the Americans with Disabilities Act when the court seizes a child without a warrant or predeprivation hearing, denies relief from void judgments as untimely contrary to established precedent, and refuses to accommodate a disabled out-of-state parent's request for remote participation in hearings