William Rupert v. Susan Bond, et al.

Should the circuit splits over the use of FRCP 12(b)(6) motions (prior to discovery or an evidentiary hearing), to rule upon a disputed issue of fact (the “sham litigation” or “fraud exception” to claimed Noerr-Pennington immunity), be resolved?; and if so, should the resolution favor judicial expediency? or fair, orderly and prudent procedures?

Whether, Post -Walden, due process permits a court to exercise personal jurisdiction over an out-ofstate defendant, who individually targets a known forum resident plaintiff, if they send knowingly false statements into the forum state, intending that reliance take place therein, if reasonable and detrimental reliance takes place in the forum state?

Whether the numerous circuit splits between the Ninth Circuit and other Circuits, concerning the RICO Statutes should be addressed and resolved? (A) Whether injunctive relief, under 18 U.S.C. § 1964(a), is available, in a private civil RICO action, brought pursuant to 18 U.S.C. § 1964(c)? (B) In a private civil RICO action, is nationwide service of process authorized only by 18 U.S.C. § 1965(b)? or can it also be alternatively authorized by 18 U.S.C. § 1965(d)? (C) Whether the “ends of justice” language in 18 U.S.C. § 1965(b) implies a single rigid test, or whether a more flexible standard should be utilized, on a case by case basis?