Whether a substitute trustee's deed executed during the pendency of a federal appeal violates due process and renders the foreclosure void under principles of appellate jurisdiction

No question identified. : UNSWORN DECLARATION UNDER 28 U.S.C. § 1746 I, Harriet Nicholson, declare under penalty of perjury under the laws of the United States of America that the following is true and correct: 1. Tam coming before this Court not out of ambition, but because I have no other choice. Thirteen years ago, I stood in a Texas courtroom pleading for protection from an unlawful eviction. Today, more than a decade later, I find myself in the same place—still trying to protect the very home that was legally returned to me years ago. My only Tequest is simple: to hold on to what the law has already said is mine. 2. Lam not asking for new rights or special treatment. I am asking for enforcement of an amended final judgment issued on September 16, 2020, which restored my title and declared the foreclosure void. That ruling was not symbolic. It was supposed to be final. And yet, I am again facing an eviction based on a deed executed while my federal appeal is still pending. 3. I suffered a stroke on December 9, 2023. Despite the toll it took on my body and spirit, I continued to advocate for myself—because no one else would. I have filed motions, researched legal doctrines, and kept this case alive with everything I have. I’ve done so because I believe that the law must protect those it has already vindicated. 4. This Court has the power—and I believe, the duty—to ensure that no person’s home is taken in the shadow of a federal appellate court. My home is not just real estate; itis my sanctuary, my history, my legacy. And I am not a tenant—I am the titleholder, as confirmed by a court of law. 5. The Constitution promises due process and equal protection, not just to the powerful or the well-represented, but to all of us. Especially to the vulnerable. Especially to those who, like me, already proved their case and won—yet are still forced to fight for the basic dignity of keeping a roof over their head. 6. I ask this Honorable Court to step in—not for charity, but for justice. To prevent the irreversible harm of losing my home. To preserve the rule of law. To say, once and for all, that final judgments matter. Respectfully submitted /s/ Harriet Nicholson EMERGENCY APPLICATION UNDER RULE 22 AND THE ALL WRITS ACT To the Honorable Justice Sonia Sotomayor, Circuit Justice for the Second Circuit: Pursuant to Supreme Court Rule 22 and the All Writs Act, 28 U.S.C. § 1651(a), Petitioner Harriet Nicholson respectfully submits this Emergency Application to preserve the appellate jurisdiction of the United States Court of Appeals for the Second Circuit in Case No. 24-586, and to enjoin an unconstitutional eviction based on an extrajudicial act committed during the pendency of appellate proceedings, in violation of Griggs v. Provident Consumer Disc. Co., 459 US. 56 (1982), In re Fogarty, 39 F 4th 62 (2d Cir. 2022), and Stop the Beach Renourishment, Inc. v. Fla. Dep’t of Envtl. Prot., 560 U.S. 702 (2010). I. RELIEF REQUESTED Petitioner respectfully requests: 1. A stay of execution of a July 9, 2025 judgment of possession issued by a Texas Justice of the Peace Court, which unlawfully classified Petitioner as a “tenant” of her homestead while her appeal was pending in the Second Circuit (Exhibit 2); 2. An order enjoining any further eviction proceedings or actions to dispossess Petitioner until the Second Circuit rules on her petition for panel rehearing, rehearing en banc, or a petition for writ of certiorari to this Court; 3. All further relief necessary to preserve the Second Circuit’s appellate jurisdiction and prevent a grave miscarriage of justice. Il. BACKGROUND This emergency application arises from an unlawful eviction judgment rendered while Petitioner’s federal civil rights appeal remained pending in the Second Circuit (Case No. 24586). On July 1, 2025, the Second Circuit affirmed the dismissal of Petitioner’s claims on res judicata grounds but granted judicial notice of dispositive facts, including: e The March 4, 2025 substi