Whether the government's repeated intentional flooding of private property constitutes a regulatory taking under the Fifth Amendment's Takings Clause requiring just compensation

No question identified. : To the Honorable Elena Kagan, Associate Justice of the Supreme Court of the United States Petitioner, Carolyn J. Florimonte, respectfully requests an order to extend the time to file a Petition for a Writ of Certiorari in this matter for sixty (60) days, concerning an issue relating to a Major Question Doctrine, which will doubly affect Petitioner directly, as well as all others similarly afflicted singularly. The Supreme Court of Pennsylvania, in direct conflict with lower court decisions rendered by the Commonwealth Court of Pennsylvania, regarding a continuing trespass in Graybill v. Providence Township, 140 Pa. Commw. 505, at 512 (Pa. Commw. Ct. 1991), and Lake v. The Hankin Group, et al, No. 278 C.D. (2013) at 13, denied request by Petitioner for Permission to Appeal for Extraordinary Relief on November 6, 2023. Ninety (90) days from that date would be February 4, 2024. Therefore, an extension of sixty days would fall on April 4, 2024, as a final date for filing of Petition for a Writ of Certiorari. (Both Graybill and Lake Opinions ruled that continuing trespass on private property permits filing of a succession of lawsuits until the continuing trespass is ended as all injuries occurring over a period of 2 years cannot be claimed in one lawsuit). Petitioner is of an advanced age — the last twenty-four (24) of those years have been consumed by anguish and despair after repeated events of ravaging of her property, by flooding, multiple times a year, year after year. Warned of the danger to Petitioner caused by the severe flooding, Respondent knew or should have known, but ignored, the repercussions of the illegal flooding. Petitioner’s request for extension is a direct result of ongoing personal injuries suffered during the September, 2023, event of supersaturation flooding, of her home and property, intentionally caused by Respondent, Borough of Dalton, in a disturbing example of government overreach, thus resulting in delay of her ability to meet the standard ninety (90) days for filing a Petition for Writ of Certiorari. This Court has jurisdiction under 28 U.S.C. Section 1257 and the Constitution of the United States, Fifth Amendment. BACKGROUND In support of this application, Petitioner avers as follows: 1. For the last twenty-four (24) years, Petitioner has suffered overwhelming, illegal flooding of her home and property by the Borough of Dalton, Respondent. 2. Petitioner has never, at any time, had control of the property which she owns. The first thirteen (13) years involved her attempts to legally end Respondent’s unconstitutional occupation of her property. 3. On May 5, 2000, Petitioner purchased the property located at 219 Third Street, Dalton, PA (hereinafter known as the Property). 4. Sellers falsely signed a disclosure statement that no flooding occurred on the Property. 5. The Property consists of three surveyed lots which were conveyed as one parcel when purchased in May, 2000. 6. One third of the Property was impassable heavily overgrown with vines, downed trees and debris which Petitioner intended to clear in anticipation of a possible future lot sale, after obtaining a variance. 7. Hidden from view on that portion of the Property were two enormous pipes, which the Borough of Dalton had illegally installed and hidden on the Property, sometime after 1986. (This was confirmed by previous owners during Injunction Hearings in May, 2009). 8. During Trial in August, 2011, Respondent’s Engineer testified that the excessive amounts of water artificially directed by pipe to the Property were originating not from only all other properties on Third Street but also the sixteen (16) acres uphill from Third Street. 9. Those sixteen acres contain a newly developing community now known as Huntington Woods, Dalton, PA. (New homes are still being constructed). 10. The lawsuit filed by her counsel in 2003, before Petitioner became pro-se in 2009, was dismissed by a Judge in Lackawanna County Civil