1. “Whether Respondent’s multi-year possession, control and use of Petitioner’s property is a taking sufficient to trigger the payment of ‘just compensation’, as required by the 5th Amendment to the U.S. Constitution?”
2. “Whether the lower courts properly applied the doctrines of res judicata and claim preclusion when they ignored the two different and non-overlapping sets of transactional facts as clearly identified in Petitioner’s Amended 2025 Complaint (the first set of facts ending on September 12, 2023, and the second set of facts beginning on September 13, 2023) when determining if the lower court has subject matter jurisdiction under 28 U.S.C. 1491(a)(1)?”
3. “Whether the lower courts properly applied the doctrines of res judicata and claim preclusion when both of the lower courts failed to correctly identify Petitioner’s property interests taken by Respondent, failed to identify when Petitioner’s property interests were taken and continue to be taken by Respondent and failed to identify when Respondent continues to breach the implied contract between the parties, which are necessary predicates to the legal conclusions reached by the lower courts?”
4. “Whether the lower courts properly applied Due Process, as required by the 5th Amendment to the U.S. Constitution, when they failed to even identify the standard to be applied?”
