Whether the Ninth Circuit's procedural actions, including deferring motions to correct the record and permitting premature briefing, constitute a violation of due process and fundamental appellate rights

No question identified. : EMERGENCY MOTION FOR INJUNCTIVE RELIEF, STAY OF PROCEEDINGS AND REMAND FOR CORRECTION OF THE RECORD PENDING REVIEW To the Honorable Chief Justice and Associate Justices of the United States Supreme Court: Pursuant to Rule 23 and the Court’s supervisory authority under 28 U.S.C. § 2101), Petitioners respectfully move for an emergency stay of all proceedings currently pending before the United States Court of Appeals for the Ninth Circuit in the above-captioned matter and request that the case be remanded to the district court—transferred to a new venue—for correcting the record to include omitted motions and filings essential to appellate review. (Dkt. 4, 5, 6, 7) Petitioners also request correction of the record prior to the imposition of briefing deadlines, due to significant procedural defects, jurisdictional concerns, and violations of due process. I. BACKGROUND On July 16, 2025, the Ninth Circuit (Judges Silverman and VanDyke) denied Petitioners’ motion for reconsideration of the Court’s April 15, 2025 order (Dkt. 34), and further denied all pending motions for injunctive relief (Dkt. 32, 34, 36), including those supported by newly discovered evidence of judicial bias, improper venue, fraud on the court, unlawful omission of timely filed motions, and unlawful retaliation, and failed to rule on the pending Motion for Reconsideration of Injunctive Relief. (Dkt. 59.1) The Court held that these motions would not be considered until the panel addressing the merits of the appeal is assigned. That order also denied Petitioners’ motions to strike appellees’ answering briefs (Dkt. 53), despite the premature and improper filing of those briefs before the opening brief was submitted, and denied motions to strike responses to the injunction request (Dkt. 50, 51). The Court further stated it would not entertain any further motions for a stay of appellate proceedings based on pending motions referred to the merits panel, effectively precluding resolution of foundational disputes prior to briefing. On July 28, 2025, the Ninth Circuit issued a subsequent order (Dkt. 57), granting in part and denying in part Petitioners’ motion to clarify the July 16 order. The court reaffirmed that all pending motions—including those to correct or supplement the record, for judicial notice, and for recusal—would remain unresolved until the merits panel is assigned. All other requests for clarification were denied, and the court expressly stated it will not entertain any further motions for clarification or reconsideration of the July 16 order. The motion for expedited ruling (Dkt. 58) was denied as moot. The opening brief remains due on August 20, 2025, with answering briefs due September 19, 2025, and an optional reply brief due 21 days after service of the last answering brief. II. GROUNDS FOR EMERGENCY STAY Petitioners respectfully submit that this procedural posture creates manifest due process violations and threatens irreparable harm. The record on appeal is materially inaccurate and incomplete, and Petitioners’ multiple motions to correct the record and vacate prior orders—based on newly discovered evidence and serious constitutional defects—have been deferred indefinitely. A. Due Process and Jurisdictional Concerns Proceeding to merits briefing without resolving disputes over the accuracy of the record and the validity of underlying court actions violates Petitioners’ fundamental rights. Appellees were permitted to file premature answering briefs, contrary to the sequencing requirements of FRAP 28, further compounding confusion and prejudice. B. Denial of Stay and Clarification Requests The Ninth Circuit has explicitly foreclosed any further requests for stay or clarification, despite unresolved jurisdictional motions involving judicial disqualification, change of venue, and record tampering, violations of labor rights and federal constitutional protections under the First, Fifth, and Fourteenth Amendments. Petitioners