1. “Whether attorney withdrawal that violates modern ethical standards—specifically the duties articulated in ABA Formal Opinion 516—can constitute an ‘extraordinary circumstance’ warranting equitable tolling under Irwin v. Department of Veterans Affairs, 498 U.S. 89 (1990), and Holland v. Florida, 560 U.S. 631 (2010).” 2. “Whether the Federal Circuit erred by affirming the MSPB’s refusal to apply equitable tolling based on a factual premise contradicted by the record, where the petitioner worked continuously and diligently after counsel’s last-minute withdrawal.” 3. “Whether the longstanding rule that ‘clients are responsible for their attorneys’ errors’ should apply when the attorney’s withdrawal is professionally improper under contemporary ethical standards and occurs at the eve of a jurisdictional deadline.”
