Charlie Wilson, as Executor of the Estate of Debra Wilson v. Dallas County Hospital District, dba Parkland Health and Hospital System

Are state statutory pre-discovery deadlines tolled – either by the rules of federal appeal, rules of federal procedure, or equitable tolling principles – during a federal appeal if a defendant voluntarily removes a case from state trial court to federal court where the state deadline is inapplicable, the federal trial court dismisses some claims, and the plaintiff pursues a rightful federal appeal; especially when the federal appeal would result in the case remaining in federal trial court if successful, and in the face of the U.S. Supreme Court’s expressed desire to avoid “jurisdictional ping-pong games”?

Do state statutory pre-discovery deadlines restart anew after a state trial court has regained jurisdiction when a defendant voluntarily removed the case to federal court, and when considering that the state-imposed deadline is inapplicable in federal court?

Does the doctrine of Federal Conflict Preemption preempt a state statutory deadline that is inapplicable in federal court and thereby prevent a state court from applying that state-statutory deadline after removal to federal court while the nonremoving party is pursuing a rightful federal appeal?