Whether the Full Faith and Credit Clause requires a state court to enforce a sister-state judgment when the judgment was allegedly obtained in violation of the defendant's constitutional right to due process, including through denial of adequate notice, opportunity to be heard, and fair proceedings

No question identified. : Rota is unable to appeal. The jurisdiction is contested, the Utah trial Court did not let her address jurisdiction that can be raised at any time. Moreover, HMS admitted in the final order that it had a policy that there is no agreement without a fully signed copy. No signed copy was provided to Appellant prior to revocation of both agreements or either agreement. HMS did not send her a fully signed copy. (Exhibit 1) notes that there was a dispute on the contracts at the inception of the dispute so the Court of Appeals in D084575 gets it wrong. INTRODUCTION This case presents significant and unsettled questions of federal law regarding the enforcement of state court judgments under the Full Faith and Credit Clause when those judgments may have been obtained in violation of due process. Petitioner seeks review of the California Court of Appeal's decision affirming the denial of her motion to vacate a California judgment that was based on a Utah judgment. Petitioner contends that the Utah judgment was obtained through proceedings that violated her constitutional rights to due process. Without a stay of the trial court proceedings, Petitioner will suffer irreparable harm as enforcement actions may proceed before this Court has an opportunity to consider her forthcoming petition. BACKGROUND 1. On October 18, 2023, the First Judicial District Court of the State of Utah entered a judgment against Petitioner in the amount of $8,859,175 in favor of Respondent Howell Management Services, LLC. This judgment was entered after the Utah court struck Petitioner's pleadings as a discovery sanction, that is erroneous as she is the producing party of the documents. HMS had to file an SODI first and did not. The Court defaulted Rota for privileged statements. Despite Petitioner's contention that she was unable to appear in person and was denied the opportunity to appear remotely for critical hearings. There was a standing order for her to appear by phone. 2. In February 2024, Respondent obtained a California judgment based on the Utah judgment pursuant to the Sister State Money Judgments Act (Cal. Code Civ. Proc., § 1710.10 et seq.) in the amount of $9,034,805.27, which included accrued interest. 8. Petitioner moved to vacate the California judgment on several grounds, including that the Utah court had denied her due process of law and a fair trial, that the Utah court lacked jurisdiction under California Labor Code § 925, and that the Utah judgment was not entitled to full faith and credit. 4, On July 12, 2024, the Superior Court of San Diego County denied Petitioner's motion to vacate, indicating that it would only consider the first 15 pages of Petitioner's 49-page memorandum due to page limit violations, despite the complex constitutional issues involved. 5. On February 5, 2025, the California Court of Appeal, Fourth Appellate District, affirmed the trial court's order denying Petitioner's motion to vacate. 6. On February 7, 2025, the Court of Appeal denied Petitioner's petition for rehearing. 7. On March 7, 2025, the Superior Court denied Petitioner's motion to stay enforcement proceedings pending appeal, as evidenced by the attached Notice of Ruling. 8. Petitioner has a Motion for Satisfaction of Judgment scheduled for May 9, 2025, and enforcement actions are imminent. 9. Petitioner is preparing to file a Petition for Writ of Certiorari with this Court within the time allowed by Rule 13. ARGUMENT I. A Stay Is Necessary to Preserve This Court's Jurisdiction and Prevent Irreparable Harm This Court has authority to issue a stay under the All Writs Act, 28 U.S.C. § 1651(a), which provides that federal courts "may issue all writs necessary or appropriate in aid of their respective jurisdictions and agreeable to the usages and principles of law." This power extends to the authority to issue stays of lower court proceedings to preserve this Court's jurisdiction to review cases properly before it. See Nken v. Holder,