Whether the Due Process Clause of the Fourteenth Amendment requires a state court to provide a full and fair opportunity for a client to litigate a motion to compel delivery of papers or money from an attorney under a state-created property right

No question identified. : I, APPLICATION FOR EXTENSION OF TIME 1. Pursuant to this Honorable Court’s Rule 13.5 and 28 U.S.C. § 2101(c), Applicant Freddie L. Byers, IIT: hereby requests a sixty (60) day extension of time within which to file a Petition for a Writ of certiorari, up to and including the end of the day on December 29, 2025.2 Il. JUDGMENT FOR WHICH REVIEW IS SOUGHT 2. The Judgment for which review is sought is in the following Indiana State Supreme Court, to wit: State of Indiana on the relation of Freddie L. Byers, III v. The St. Joseph County Indiana Superior Court, and the Honorable Christopher Fronk, as Judge thereof, and the Honorable Amy Rolfes, as Clerk thereof, No. 25S-OR-144,3 Order, dated July 21, 2025;4 that dismissed Applicant Byers’ Document, to wit: Petition for Writ of mandamus; requesting the Indiana Supreme Court to intervene in the Respondent Court, and force the rendering of a Final and Appealable Judgment 1 Hereinafter [“Applicant Byers”). 2 This is the next business day, as the actual sixtieth (60) day is December 28, 2025--a Sunday. As such this makes December 29, 2025 the sixtieth—and final day—for extension for the filing of a Petition for Writ of certiorari in this Honorable Court. See Rule 30.1 of the United States Supreme Court (In the computation of any period of time prescribed or allowed by these Rules, by order of the Court, or by an applicable statute, the day of the act, event, or default from which the designated period begins to run is not included. The last day of the period shall be included, unless it is a Saturday, Sunday, federal legal holiday listed in 5 U.S.C. § 6103, or day on which the Court building is closed by order of the Court or the Chief Justice, in which event the period shall extend until the end of the next day that is not a Saturday, Sunday, federal legal holiday, or day on which the Court building is closed). 3 Hereinafter [“OR-142’]. 4 Hereinafter [“Dismissal Order”]. Applicant Byers hereby attaches a true and correct copy of that Main Opinion hereto, and designates such as follows, to wit: [EXHIBIT B, p. 1]. Such is not Reported in the Official Reporter of Record for the Indiana Supreme Court, Court of Appeals, and Tax Court, to wit: Northeastern Reporter, 3d Series, at, to wit: State ex Rel Freddie L. Byers, III v. St. Joseph Superior Court, et al., No. 25S-OR-144, Unpublished Order (Ind. App. July 21, 2025). 1 by the Respondent Court therein, to wit: St. Joseph County Indiana Superior Court;5 the Honorable Christopher Fronk, as Judge thereof; concerning a Statutory Proceeding, to wit: Verified Motion for Order to Compel Delivery of Money or Papers;’ 5 Hereinafter (“Respondent Court”). 6 Hereinafter [“Respondent Court Judge”). 1 Hereinafter [“Motion to Compel”]. This Motion to Compel was invoked pursuant to the Statwtory Remedy provided for by the Indiana General Assembly in a duly enacted Statute by, to wit: Indiana Code § 33-43-1-9; intended to protect the Property Rights of Clients from their Attorneys. See Pigg v. State, 929 N.E.2d 799 (Ind. App. 2010), trans denied by Pigg v. State, 940 N.E.2d 826 (Ind. 2010); where the Court said in relevant part, to wit: Patently, Indiana Code section 33-43-1-9 protects the property rights of clients to the tangible product of their representation (i.e. the “papers”) and to the portion of money which they pay to attorneys which is ultimately not earned. The law prevents clients from having to file independent lawsuits in contract or quasi-contract in order to obtain what is rightfully theirs. Thus, by providing an opportunity for recourse in our courts, Indiana Code 33-43-1-9 has made the determination of whether to grant or deny a motion for delivery of papers or money from an attorney in a state action, making such a determination subject to due process considerations. “The Due Process Clause of the United States Constitution and the Due Course of Law Clause of the Indiana Constitution prohibit state action which