Whether the Fourteenth Amendment's due process protections require a jury trial in state probate court proceedings involving title disputes when fundamental property rights are at stake

No question identified. : Commissioner Attorney Charles A. Russell Pro Se, P.O. Box 2124 Concord, NH 03302 Giovanni Verani, Pro Se, Berkshire Hathaway HS, Verani Realty 1 Verani Way Londonderry, NH 03053 Attorney John F. Bisson, for John Poirier Counsel of Record for Respondent 722 Chestnut Street Manchester, NH 03104 Attorney Timothy E. Britain, for David P. Masciarelli, Christy N. Masciarelli and Granite State Mortgage Corporation Counsel of Record for Respondent 2 Capital Plaza 5" Floor Concord, NH 03301 July 8, 2025 To the Honorable Ketanji Brown Jackson, as Circuit Justice for the United States Court of Appeals for the First Circuit: Application For Extension Of Time And Jurisdiction Pursuant to this Court’s Rules 13.5, 22, and 30, Karyn M. Kelley ET AL respectfully requests that the time to file its Petition for Writ of Certiorari in this matter be extended for 60 days up to and including September 19, 2025. The State of New Hampshire Supreme Court issued its order on April 24, 2025 (attached as Exhibit A) and denied a motion for rehearing or reconsideration on March 25, 2025 (attached as Exhibit B). Absent an extension of time, the Petition for Writ of Certiorari would be due on July 22, 2025. filed this Application more than ten days before that date. See S. Ct. R. 13.5. This Court would have jurisdiction over the judgment under 28 U.S.C. 1254(1). Respondent takes no position on the request. Judgment For Which Review Is Sought The judgment for which review is sought is Karyn M. Kelley ET AL v. Mary E. Feeney ET AL No. 2024-0369, dated April 24, 2025 (attached as Exhibit A). The Supreme Court of the State of New Hampshire denied Applicant’s motion for rehearing or reconsideration on March 25, 2025 (attached as Exhibit B). Background This case was filed on February 2, 2023 in the Hillsborough Probate Court, Southern District, which holds jurisdiction for Title dispute to Quiet Title to Real Property under New Hampshire RSA 498:5-a. Hillsborough Probate Court, Southem District has jurisdiction over the subject matter of this action pursuant to New Hampshire RSA 498:5a to decide disputes in title. Upon motion for a trial by Jury, pursuant to NH RSA 547:II-d, the Probate Court will transfer to Superior Court to hold the Jury Trial, which the Court that holds jurisdiction is Hillsborough Superior Court, Southern District. Many Respondents filed motions for a Jury Trial with the Hillsborough Probate Court, Southern District. On or about May 4, 2023 Hillsborough Probate Court, Southern District Granted a Jury Trial in this matter. Subsequently, many Respondents filed motions to transfer to Hillsborough Superior Court, Northern District, which lacked jurisdiction, subject matter jurisdiction and venue to decide a dispute in title in the Town of Merrimack. The Town of Merrimack is served by the Hillsborough Probate Court, Southern District and the Hillsborough Superior Court, Southern District. The Hillsborough Probate Court, Southern District by err transferred the Probate Complaint to Hillsborough Superior Court, Northern District. Hillsborough Superior Court, Northern District accepted the Hillsborough Probate Court, Southern District Transfer and docketed the Complaint. Subsequently, many Respondents filed motions to consolidate the transferred Probate Complaint to a (12) year old tried to conclusion closed case. Hillsborough Superior Court, Northern District consolidated the Probate Complaint to the (12) year old tried to conclusion closed case in err, which dismissed the Probate Complaint without Hearing, Granted Jury Trial that violated the 14" Amendment, due process moreover, the right to a Jury Trial. Hillsborough Superior Court, Northern District lacked jurisdiction, subject matter jurisdiction and venue whereby the trial court denied due process. The questions to be reviewed under Writ of Certiorari are important questions that were determined adversely by the Supreme Court of the State of New Hampshire. Reason