Whether the government violates the Fifth and Fourteenth Amendments' due process and takings protections when it retains surplus proceeds from tax foreclosure sales beyond the amount of delinquent taxes owed, based on technical notice deficiencies

No question identified. : To the Honorable Brett M. Kavanaugh, Justice of the Supreme Court of the United States and Circuit Justice for the Sixth Circuit: Pursuant to Supreme Court Rule 13.5, Petitioner Johanna McGee, as personal representative of the estate of Jacqueline McGee, and Petitioner Lillian Joseph respectfully request an extension of time of 50 days to file their Petition for Writ of Certiorari in this Court up to and including August 15, 2025. JUDGMENT FOR WHICH REVIEW IS SOUGHT The judgment for which review is sought is the consolidated decision in In re Petition of Alger County Treasurer, No. 363803, and In re Petition of Iron County Treasurer, No. 363804 (attached as Exhibit 1). The Michigan Supreme Court denied Petitioners’ timely petition seeking review on March 28, 2025 (attached as Exhibit 2). This means a petition is presently due on June 26, 2025. This application for an extension of time is filed more than ten days prior to that date. JURISDICTION In response to tax foreclosure actions brought by the Treasurers for Alger County and Iron County, the Petitioners each filed motions seeking surplus proceeds from the sale of their properties, arguing that failure to refund those proceeds violates the Fifth and Fourteenth Amendments to the United States Constitution. The Michigan Court of Appeals consolidated the cases and held that the confiscations did not violate due process or take property without just compensation. This forthcoming petition will ask whether the government violated due process and took property without just compensation when it took their houses and land, sold them for far more than what was owed, and then kept the surplus proceeds because Lillian Joseph’s timely mailed notice was sent via Express Priority Mail instead of trackable certified mail and because the heirs of Jacqueline McGee missed the administrative notice deadline, even though she passed away around the time of the foreclosure—just a few months before the deadline ran. This Court has jurisdiction over a timely filed petition for writ of certiorari in this case pursuant to 28 U.S.C. § 1257. REASONS FOR GRANTING THE EXTENSION OF TIME Petitioners’ undersigned Counsel of Record requires extra time to prepare the petition in this case due to her workload, which during the relevant time period includes filing a Petition for a Writ of Certiorari in Koetter v. Manistee County Treasurer, No. 24-1095 (docketed April 21, 2025), a reply brief in support of a Writ of Certiorari in Beeman v. Muskegon County Treasurer, No. 24-858, as well as other deadlines in trial and appellate courts in multiple jurisdictions, and other obligations. CONCLUSION For the foregoing reasons, Petitioners request that this Court grant an extension of 50 days, up to and including August 15, 2025, within which they may file a petition for a writ of certiorari. DATED: May 21, 2025. fk submitted, Chui M. ina. ge Counsel of Record 4440 PGA Blvd., Suite 307 Palm Beach Gardens, FL 33414 (916) 330-4059 Counsel for Petitioners CERTIFICATE OF SERVICE A copy of this application was served via email and U.S. mail to counsel listed below in accordance with Supreme Court Rules 22.2 and 29.3: Charles A. Lawler Clark Hill PLC 215 8S. Washington Square, Suite 200 Lansing, MI 48933 (517) 318-3100 Cynthia M. Filipovich 500 Woodward Ave., Suite 3500 Detroit, MI 48226 (318) 965-8373 Attorneys for Respondent Alger County Treasurer Laurie S. Longo 220 E. Huron St., Suite 110 Ann Arbor, MI 48104 (734) 730-3936 lslongo@hotmail.com Steven J. Tinti 201 S. 5th Street P.O. Box 98 Crystal Falls, MI 49920-1508 (906) 875-7451 Attorneys for Respondent Iron County Treasurer Chudlin Mgt CHRISTINA M. MARTIN Counsel of Record 4440 PGA Blvd., Suite 307 Palm Beach Gardens, FL 33414 (916) 330-4059 DATED: May 21, 2025. Counsel for Petitioners Exhibit 1 If this opinion indicates that it is “FOR PUBLICATION, ” it is subject to revision until final publication in the Michigan Appeals Reports.