Dmitry Kruglov v. Federal National Mortgage Association

I. Due Process and Equal Protection Questions (Fourteenth Amendment)

1. Whether the trial court violated procedural due process and equal protection A. by allowing discovery deadlines to lapse and extending discoveiy for one party without motion or notice (App. A53,54,58-62); B. by denying enforcement of discovery orders and agreements (App. A48, A53); C. by vacating the February 24, 2023 scheduling order from the bench without motion or notice, citing “directives” from higher courts, and denying motions to compel previously served discovery (App. A35, A37-41); D. by granting summary judgment without resolving the unconscionability dispute in favor of the non-movant, despite acknowledging that Defendant signed the contract ten days after Plaintiff and that Plaintiff sought reformation of commitment dates as unconscionable, contrary to Pennsylvania Commercial Code § 2302 and the rule that all factual disputes be construed in favor of the non-moving party (App. A26, A32); E. by failing to address any of the six appellate questions—each alleging discovery misconduct, bias, or due-process violations— and by applying de novo instead of “abuse of discretion” review (App. Al 1-12);

2. Whether the following actions violated the right to an impartial tribunal under Caperton v. A.T. Massey Coal Co., 556 U.S. 868 (2009), and Tumey v. Ohio, 273 U.S. 510 (1927): (a) a trial judge concealing a conflict through a spouse’s firm’s