Whether a federal court may extinguish property rights under a federal land patent and compel an heir to execute a deed based on disputed conveyances and adverse possession claims, in potential violation of the Supremacy and Contract Clauses

No question identified. : RELIEF REQUESTED Pursuant to 28 U.S.C. § 2101(f) and Supreme Court Rule 23, Petitioner Jennine Labuzan-Delane respectfully applies to Justice Alito for an emergency stay of the enforcement orders entered by the U.S. District Court for the Northern District of Mississippi in Labuzan-Delane v. Cochran & Cochran et al, No. pending resolution of her petition for a writ of certiorari (No. __). Petitioner seeks to stay: 1. Enforcement of attorney fee awards totaling over $25,000; 2, Execution and delivery of quitclaim deeds relinquishing her title in land held under a federal land patent; 3. Any threat of contempt or sanctions tied to enforcement efforts during the certiorari period. JURISDICTION AND PROCEDURAL BACKGROUND The final judgment of the U.S. Court of Appeals for the Fifth Circuit was entered on February 21, 2025, and its mandate issued on March 21, 2025. Petitioner timely filed a motion to stay the mandate pending certiorari, which the Fifth Circuit denied. Petitioner's petition for a writ of certiorari is being filed concurrently with this application. Petitioner also timely opposed respondents’ motions seeking: e Attorney’s fees ($19,435.25 from Cochran Defendants; $5,851.06 from Greenlee Family LLC); EEE EMERGENCY STAY 2 e Compelled execution of quitclaim deeds. While her Fifth Circuit appeal was still pending, Respondents mailed Petitioner deeds for signature. Petitioner refused based on the district court's lack of jurisdiction at that time. On March 6, 2024, the district court denied the motion to compel for lack of jurisdiction—a ruling that now underscores the procedural irregularity of respondents’ coercive tactics. Following issuance of the mandate, those motions were refiled and are now pending. The district court has not ruled on Petitioner’s renewed opposition, which explicitly asks the court to defer enforcement pending Supreme Court review. STATEMENT PURSUANT TO RULE 23 Petitioner respectfully submits that the relief sought—i.e., a stay of post-mandate enforcement—is not otherwise available from any other court. The Fifth Circuit has denied her stay motion, and the district court has failed to rule on the renewed motions for fees and forced deed execution. Only this Court may now intervene to prevent irreparable injury. REASONS FOR GRANTING THE STAY I. Petitioner Has Presented Serious Questions Likely to Warrant Certiorari Petitioner’s certiorari petition raises substantial constitutional and procedural questions, including: rr EMERGENCY STAY 3 1, Whether summary judgment may be granted before any discovery, where the district court misapplied Rule 56(d) and the Fifth Circuit misapplied Rule 37—ignoring Rule 26(£)’s requirement to initiate discovery. See Celotex Corp. v. Catrett, 477 U.S. 317 (1986). 2. Whether federal courts may extinguish property rights under a federal land patent—protected by the Supremacy and Contract Clauses—and order an heir to execute a deed, based on disputed conveyances and adverse possession, contrary to precedents like: o Fletcher v. Peck, 10 U.S. (6 Cranch) 87 (1810), o Wilcox v. Jackson, 38 U.S. (13 Pet.) 498 (1839), o Redfield v. Parks, 132 U.S. 239 (1889), o Hoofnagle v. Anderson, 20 U.S. 212 (1822), 3. Whether a federal court may threaten contempt or sanctions for pursuing an appeal to the Supreme Court, chilling First Amendment and due process rights. See: o NAACP v. Button, 371 U.S. 415 (1963), o Bill Johnson's Restaurants v. NLRB, 461 U.S. 731 (19883), o BE&K Constr. Co. v. NLRB, 536 U.S. 516 (2002). The Supreme Court has granted certiorari in similar unreported decisions (e.g., Martin v. United States, No. 23-10062), signaling that the lack of a recorded opinion does not preclude review of substantial federal questions. I. Petitioner Faces Irreparable Harm Without a Stay If a stay is not granted, Petitioner will be: SS re EMERGENCY STAY 4 e Compelled to execute quitclaim deeds, extinguishing title to her family’s patented land; ¢ Subjected