Ronda Melnychuk-Beselt v. Waldorf=Astoria Management LLC, a Foreign Limited Liability Company, et al.

A. Novel Questions

1. Whether the Court violated foreign Petitioner’s Fourteenth Amendment rights of the United States Constitution during an attorney only telephone status conference call, instructed in its minute order that Petitioner sign Respondent’s blank medical and employment authorizations which violated her foreign country’s health information laws requiring providers to redact third party information instead of requesting she obtain the discovery and provide it to Respondent as per established law?

2. Whether under the 14th Amendment the Court violated due process when it unfairly and severely sanctioned foreign Petitioner and arbitrarily “cut off’ her ability to produce her medical and employment records six months before the discovery deadline making it effectively impossible to prove her damages, without prior notice or an opportunity to be heard, or any warning of sanctions, based only upon a minute order directing Petitioner to violate her country’s laws, but not obtain her own records, and the subsequent medical records produced directly to Respondent by the foreign providers had redacted third party information in compliance with said country’s health information laws?

3. Whether under the 14th Amendment the Court erred when it granted her counsel’s withdrawal on the eve of trial then failed to allow disabled pro se Petitioner, a Canadian resident, ADA accommodations and guardian ad litem, further denying her verbal and written requests for time to obtain counsel, when the Court had been provided several of Petitioner’s medical expert reports and a medical letter that opined Petitioner suffered from significant psychological and physical injuries, and could not represent herself thus resulting in Respondent fraudulently and unduly influencing and coercing an extremely unfair alleged