Emergency Application — Lisa Richardson Henderson, Applicant v. Showcase Home Improvements, Inc., dba Kenneth Ferber, et al.

Supreme Court briefAug 26, 2026

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IN THE SUPREME COURT OF THE UNITED STATES

1 First Street, N.E.

Washington, DC 20543

No.

LISA RICHARDSON HENDERSON,

Petitioner,

Vv.

SHOWCASE HOME IMPROVEMENTS, INC.,

U.S. BANK TRUST NATIONAL ASSOCIATION,

AS TRUSTEE FOR PAD SERIES IV TRUST, et al.,

Respondents.

On Application Arising from the United States Court of Appeals

For the Fourth Circuit

EMERGENCY APPLICATION FOR STAY PENDING FILING AND

DISPOSITION OF PETITION FOR WRIT OF CERTIORARI

SUBMITTED BY:

LISA RICHARDSON HENDERSON

Petitioner, Pro Se

8753 Hayshed Lane

pe Columbia, Maryland 21045

RECEIVED Phone: 443-820-6573

AUS 28 7176 Email: LHenders@gmail.com

TABLE OF CONTENTS

Contents

INTRODUCTION .. sssxesvassazesescastncnevdeisanecscasaibasensecinannmcacsieanstessiacuuicaaneccnuevesuuuanaeess 3

I. JUDGMENTS AND ORDERS AT ISSUE ..........ccccccccccsseececesesescccsseessnssssssssessseseetseeeeeesees 6

I1.A. RELATED BANKRUPTCY APPEAL ...0.......eeccceesscceeseseeeesssceecesseeeeseseseeseesesaseeaeeees 6

I.B. FEDERAL CLAIMS FOR WHICH PRESERVATION IS SOUGHT .............::e00 7

I.C. PRE-JUDGMENT REPORTING OF ALLEGED MISCONDUCT .....0.. ccc eeeeeeeeeee: 7

I]. APPLICANT SOUGHT EMERGENCY RELIEF IN THE COURTS BELOW. ............. 8

III. AUTHORITY AND GOVERNING STANDARD..000... oes eeecccecceesesneeeeeeeeetseeeereeeeeessaeeeers 9

IV. THERE IS A REASONABLE PROBABILITY THAT FOUR JUSTICES WILL VOTE

TO GRANT CERTIORARI AND A FAIR PROSPECT OF REVERSAL OR VACATUR 10

A. The Petition Presents a Substantial Federal Procedural Question............::0::c0008 10

B. There Is a Fair Prospect of Reversal or Vacatur............::cseesessesseseeseeeceeeeeeceeeeesseeeeees 14

V. APPLICANT WILL SUFFER IRREPARABLE HARM ABSENT INTERIM RELIEF

VI. THE BALANCE OF EQUITIES FAVORS LIMITED, PRESERVATION-ORIENTED

RELIEF .. cgesamonsonsnennsnaansnaneansannatans sony toa tp Te ees ene ai SETAC TRUSSES GUGRGINGTOS «+= s +c eee eecssnnnecccnneentene 18

VII. THE PUBLIC INTEREST FAVORS PRESERVING MEANINGFUL SUPREME

COURT REVIEW ..|...... ccsssccsvesovssssvesvcssnsvsvceesvcssns cescovrancsuassasevansseoaneimenanwenanannccesesveasoreneexenens 19

VIII. THE REQUESTED RELIEF IS NARROWLY TAILORED.........0 ce eccccceeseeeeeneeees 19

IX. ALTERNATIVE REQUEST FOR A TEMPORARY ADMINISTRATIVE STAY ...20

CONCLUSION ........... cnsanssevusnsanmessansvneennanaceanmnansaesanvenensaassasavenenteneveesenasveneenaconenonmmonnnceens 20

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TABLE OF AUTHORITIES

Cases

Griggs v. Provident Consumer Discount Co., 459 U.S. 56, 58 (1982).....cccccccccessssesseeeseeees 15

Hollingsworth v. Perry, 558 U.S. 183, 190 (2010) (per curiam).........cecceceeecsseeeeceseeeensees 10

Statutes

28 U.S.C. § 2101 sccssesssvsssuvcrwnssnsnseyecetequsisie sans silieuisesssaedssoeiies RAR SURACUER REA SIRS 10, 20

Rules

Appellate Rule 12.1 oo... ccc cccccesscesssceessseceeseecesecerseesesaceeasessseesasceceaceeesecesecerseeeaceaes 14, 19

Fed. R. Civ. P. 62.1 ssssszsssssvcaesnscwaructenasansuesee copes siesta shy ces puecaessauagsiGcsieae ied pune hiaiiwabsseeoeeceenese 12

Federal Rule of Appellate Procedure 12.1 ..........ccccccccccccccecesesseccceccceceeceesceesevevsues 4, 5,11, 12

Federal Rule of Appellate Procedure 4(a)(4) ........cccccsecssssceesceeescecessceeesecessceess 3, 4, 6, 11, 18

Federal Rule of Civil Procedure 62.1 .i.ccccccccccscccssesesccccesessccceeececceceeceesenceccecsescecs 4,5, 11, 12

CC) 3, 13

Rule 4(a)(4)(A)................sayexswapepeasiounus ates aesadiseteeisaseadpaievsvpreereeceoeeseorceenerneresenenepesepensencsseseeens 13

Rule 4(8)(4)(B) @) sxcusssecasensesonansrecnonveveumacnens savceanar scetessiisctustccucahcdeveestsiigsba Deis suet osudisveises- 3, 13

Rule 59 sicaynssisscacernnennnsanteensnesnnenenannesunennmavn meconenmrnsngapiremrarketansennenedenennexennennonesseonenes 3, 13, 14

Rule 59 and a Rule 60 sssscsssssassssassesuccspevsceveveovanatscunsueseseususeUaiadvaphawaceensaeteaceceanceess +--+. 3,138

ALI 310\(0) een ee 12

Rule 60(b), implicated Rule 62.1 ..........cccccccccssccssccesssceessecssceeseceecsseceeasecetaceeseseaseetseerseeees 14

Rule 62.1 ssesucnnsswenunnnnncsnsasscvccss avs iauiwesesscapacesseveguas supesi Gave is 0s onenile SUING GaScURREN SUSUR EGR 12

Rules 59(€) and GO(D)..........ccccccccesssscessceseesesssscceesececenseceeeseceessecesseacecessrsusececsassensee 10, 11, 19

Rules 62.1 and 12.1 ........... .ccsmpascasevevssssveccmonecosnonereeonearernaronssenreorentseneenrevensnensepeermarenne 13, 14

Supreme Court Rule 23 sieccwinsasswanssvesineusnwvsevcsanccnsccicsastessasuhsaredseicsscsbekeiebeee.-. 10, 19, 20

Supreme Court Rules 22 and 28 .0........cccccscscccesssseceesscccesscceessceceeesssecceesssecesseceessececseceees 1,9

738

IN THE SUPREME COURT OF THE UNITED STATES

LISA RICHARDSON-HENDERSON,

Applicant,

SHOWCASE HOME IMPROVEMENTS, INC.,

U.S. BANK TRUST, N.A., et al.,

Respondents.

On Application Arising from the United States Court of Appeals

for the Fourth Circuit

Fourth Circuit No. 26-1077

District Court No. 1:25-cv-00695-ABA

EMERGENCY APPLICATION FOR STAY PENDING FILING AND

DISPOSITION OF PETITION FOR WRIT OF CERTIORARI

TO THE HONORABLE JOHN G. ROBERTS, JR., CHIEF JUSTICE OF THE UNITED

STATES AND CIRCUIT JUSTICE FOR THE FOURTH CIRCUIT:

Applicant Lisa Richardson Henderson, proceeding pro se, respectfully applies

pursuant to Supreme Court Rules 22 and 23 and 28 U.S.C. § 2101(f) for a limited stay

pending the timely filing and disposition of her Petition for a Writ of Certiorari seeking

review of the judgment of the United States Court of Appeals for the Fourth Circuit.

Applicant alternatively requests a temporary administrative stay sufficient to

preserve the status quo while this Application is considered.

This Application does not ask this Court to exercise direct appellate jurisdiction over

an independent Maryland state-court judgment, determine criminal liability, or

adjudicate the merits of a separate bankruptcy appeal pending in the Middle District of

North Carolina. Applicant seeks only such interim relief as is lawfully available to

preserve meaningful Supreme Court review of the federal judgment and to prevent the

federal controversy from becoming practically incapable of meaningful review before the

Court can act.

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INTRODUCTION

This Application arises from an unusual federal procedural circumstance concerning

the treatment of a substantive post-judgment motion submitted within the time period

addressed by Federal Rule of Appellate Procedure 4(a)(4), but received only minutes after

a Notice of Appeal.

On December 22, 2025, the United States District Court for the District of Maryland

entered a Memorandum Opinion and Order denying Applicant's Motion to Reopen. On

January 19, 2026—twenty-eight days later—Applicant submitted a Notice of

Appeal. Exactly seven minutes after submitting that Notice of Appeal, Applicant

submitted an Amended Motion for Reconsideration and Rebuttal expressly invoking

Federal Rule of Civil Procedure 59(e) and, alternatively, Rule 60(b). The District Court

received the post-judgment submission but returned it without docketing or presentation

to the District Judge because the Notice of Appeal had already been filed.

The threshold procedural question concerns Federal Rule of Appellate Procedure

4(a)(4). Rule 4(a)(4)(A) addresses specified timely post-judgment motions, including a

motion to alter or amend the judgment under Rule 59 and a Rule 60 motion filed within

the time allowed for filing a Rule 59 motion. Rule 4(a)(4)(B)(j), in turn, addresses the

effectiveness of a Notice of Appeal filed before disposition of such a qualifying motion.

Accordingly, the fact that Applicant submitted her Notice of Appeal seven minutes

before the post-judgment motion did not, standing alone, resolve the jurisdictional

question. A judicial determination was necessary concerning the character and timeliness

of the January 19 submission and whether it qualified under Rule 4(a)(4). Ifit did, Rule

A(a)(4)(B)(i) governed the effectiveness of the previously submitted Notice of Appeal.

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Returning the motion without docketing prevented that threshold determination from

being made.

The record presents an additional chronological concern. The District Court's

December 22, 2025, Order adjudicated Applicant's earlier Motion to Reopen. Applicant's

Amended Motion for Reconsideration and Rebuttal did not exist until January 19, 2026.

Nevertheless, the District Court's subsequent return of the January 19 submission stated

that the Motion for Reconsideration had been denied in the December 22, 2025, Order.

Thus, a post-judgment motion submitted twenty-eight days after the December 22 Order

was treated as though it had already been adjudicated by that earlier Order.

Alternatively, if Federal Rule of Appellate Procedure 4(a)(4) did not govern

the January 19 submission and the Notice of Appeal had already become

effective, the existence of the appeal still did not necessarily require the post-judgment

submission to be returned without judicial consideration. Federal Rule of Civil Procedure

62.1 establishes a procedure for addressing a motion that the District Court lacks

authority to grant because an appeal is pending. The District Court may defer

consideration, deny the motion, or state that it would grant the motion upon remand or

that the motion raises a substantial issue. Federal Rule of Appellate Procedure 12.1

supplies the corresponding appellate procedure following such an indicative ruling.

Applicant thereafter brought the District Court's treatment of the January 19

submission to the Fourth Circuit's attention through a Motion for Clarification,

Abeyance, and Limited Remand. In its June 30, 2026, [App. A] unpublished opinion, the

Fourth Circuit expressly described that request as relating to “the district court's

refusal to docket a motion to reconsider the denial of her motion to reopen.”

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The Court of Appeals denied clarification, abeyance, and limited remand. It separately

affirmed the December 22, 2025, [App. D] denial of Applicant's earlier Motion to Reopen

and expressly stated that the District Court's underlying dismissal of Applicant's

amended complaint was not before it.

Applicant subsequently sought emergency preservation relief in both federal courts

below. Following issuance of the Fourth Circuit's mandate on August 5, 2026, [App. C].

Applicant sought a stay and preservation of the status quo from the District Court. That

filing was returned on August 13, 2026. [App. F]. Applicant then sought recall and stay

of the mandate and temporary administrative relief from the Fourth Circuit. On

August 18, 2026, the Court of Appeals denied that relief. Applicant has therefore sought

interim relief in both federal courts below before presenting this Application to the Circuit

Justice.

Accordingly, Applicant's forthcoming Petition for a Writ of Certiorari will present a

federal procedural question concerning whether the January 19, 2026, postjudgment submission required judicial determination of its character,

timeliness, and effect under Federal Rule of Appellate Procedure 4(a)(4), and,

alternatively, whether Federal Rule of Civil Procedure 62.1 and Federal Rule

of Appellate Procedure 12.1 supplied the appropriate procedure if appellate

jurisdiction prevented the District Court from granting relief.

Applicant does not ask the Circuit Justice through this emergency Application to

adjudicate the merits of her underlying RICO, fraud, fraud-on-the-court, or Trust-related

allegations; exercise direct appellate jurisdiction over an independent Maryland state-

court judgment; determine criminal liability; or adjudicate the separate bankruptcy

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appeal pending in the Middle District of North Carolina. Applicant seeks only such

interim relief as is lawfully available to preserve the practical effectiveness of Supreme

Court review while her Petition for a Writ of Certiorari is filed and considered.

I. JUDGMENTS AND ORDERS AT ISSUE

The federal judgment for which Applicant seeks Supreme Court review arises from

the United States District Court for the District of Maryland, Civil Action No. 1:25-cv-

00695-ABA. [App. D].

On December 22, 2025, the District Court entered a Memorandum Opinion and Order

denying Applicant's Motion to Reopen and denying as moot her request for issuance of

summons.

Applicant sought appellate review in the United States Court of Appeals for the

Fourth Circuit. On June 30, 2026, the Fourth Circuit affirmed the December 22, 2025,

order. Applicant sought rehearing and rehearing en banc; that relief was denied on

July 28, 2026. [App. B]. The Fourth Circuit issued its mandate on August 5, 2026. [App.

C]. Applicant intends timely to seek a writ of certiorari.

IA. RELATED BANKRUPTCY APPEAL

Applicant respectfully advises the Court that issues concerning the June 2, 2023,

[App. J and App. J-1]. Order Annulling the Automatic Stay entered in In re Lisa

Richardson Henderson, Bankr. No. 17-11389 (Bankr. M.D.N.C.), and subsequent orders

denying relief from that order, are presently being pursued through a separate

bankruptcy appeal in the United States District Court for the Middle District of North

Carolina, Case No. 1:26-cv-00460.

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Applicant does not seek through this Application review, reversal, or modification of

those bankruptcy orders. The June 2, 2023, order is identified only to explain the

procedural history and continuing property consequences relevant to irreparable harm.

Applicant expressly preserves all challenges to the Bankruptcy Court's orders for

adjudication in the pending North Carolina bankruptcy appeal and any appellate review

arising from it. Nothing requested here is intended to interfere with that court's

jurisdiction.

I.B. FEDERAL CLAIMS FOR WHICH PRESERVATION IS SOUGHT

The underlying Greenbelt federal action included Applicant's civil allegations

concerning RICO, fraud, fraud on the court, and alleged interference with property and

rights associated with a private Trust. Applicant does not ask the Circuit Justice to

adjudicate the merits of those claims through this emergency Application.

The Fourth Circuit expressly stated that the District Court's underlying dismissal of

the amended complaint was not before it in Appeal No. 26-1077. Applicant therefore

relies on the underlying claims only to explain the practical significance of the returned

post-judgment filing and the threatened property consequences. The relief requested is

preservation-oriented: it seeks to prevent the federal controversy from becoming

practically ineffectual before this Court determines whether the procedural judgment

warrants review.

I.C. PRE-JUDGMENT REPORTING OF ALLEGED MISCONDUCT

Applicant's allegations concerning the underlying conduct did not originate after the

adverse state-court judgment. On December 9, 2022, before the February 17, 2023,

judgment affecting Applicant's residence and property interests, Applicant reported

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alleged misconduct involving Showcase Home Improvements, Inc., Kenneth Ferber, and

Dolores Ferber to the Office of the State's Attorney for Howard County, Maryland. [App.

K].

In a February 21, 2023, letter, Deputy State's Attorney Joshua J. Felsen stated that

the office had reviewed Applicant's voluminous submissions and follow-up emails, had

concluded its investigation concerning Showcase Home Improvements and the Ferber’s,

and had determined that further investigation and/or prosecution was not warranted.

Applicant does not claim a right to compel prosecution and does not ask this Court to

review prosecutorial discretion or determine criminal liability. The chronology is offered

only to show that the factual allegations later advanced in the federal civil litigation

predated the adverse judgment and were not first formulated in response to it. The

prosecutorial decision did not adjudicate Applicant's distinct federal civil claims.

II. APPLICANT SOUGHT EMERGENCY RELIEF IN THE COURTS BELOW

Applicant has sought preservation-oriented relief in both the District Court and the

Court of Appeals before presenting this Application to the Circuit Justice.

Following issuance of the Fourth Circuit's mandate on August 5, 2026, Applicant

submitted an Expedited Motion to Stay and Preserve the Status Quo Pending

Petition for Writ of Certiorari to the United States District Court for the District of

Maryland on August 10, 2026. [App. E]. Applicant expressly limited the requested relief

to matters within that court's lawful jurisdiction and alternatively requested temporary

administrative relief.

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On August 13, 2026, the District Court returned that filing without granting either

the requested stay or temporary administrative relief. [App. F].

Applicant thereafter sought emergency relief directly from the Fourth Circuit.

Applicant filed an Emergency Motion to Recall and Stay Mandate Pending Filing

and Disposition of Petition for Writ of Certiorari and Request for Temporary

Administrative Relief in Appeal No. 26-1077. [App. G].

On August 18, 2026, the Fourth Circuit entered an order stating that, “[u]pon

consideration of submissions relative to the motion to stay and recall the mandate and

for temporary administrative relief, the court denies the motion.” The Court of Appeals

supplied no further reasoning for its denial. [App. G.]

Applicant has therefore sought emergency preservation relief in both federal courts

below. Neither court afforded the requested interim relief. Relief is consequently

unavailable from the courts below, and Applicant now seeks relief from the Circuit

Justice pursuant to Supreme Court Rules 22 and 23 and 28 U.S.C. § 2101(f).

Ill. AUTHORITY AND GOVERNING STANDARD

A stay pending the filing and disposition of a petition for a writ of certiorari is

appropriate where the applicant demonstrates “(1) a reasonable probability that four

Justices will consider the issue sufficiently meritorious to grant certiorari; (2) a fair

prospect that a majority of the Court will vote to reverse the judgment below; and (3) a

likelihood that irreparable harm will result from the denial of a stay.” Hollingsworth v.

Perry, 558 U.S. 183, 190 (2010) (per curiam). In close cases, the Circuit Justice or Court

balances the equities and relative harms. Id.

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Under 28 U.S.C. § 2101(f), execution and enforcement of a final judgment subject to

review by this Court on writ of certiorari may be stayed for a reasonable time to permit

the aggrieved party to seek certiorari. Supreme Court Rule 23 likewise permits an

application to a Justice for a stay of enforcement of a judgment sought to be reviewed.

A stay pending certiorari requires, in substance, a reasonable probability that four

Justices will vote to grant certiorari, a fair prospect that a majority of the Court will

conclude that the judgment below was erroneous, and a likelihood of irreparable harm

absent interim relief; the balance of equities is also relevant. Applicant addresses each

consideration below.

Because the federal judgment itself denied relief rather than directing a sale or

transfer of property, Applicant does not ask this Court to transform § 2101(f) into direct

appellate control over a separate state-court judgment. Applicant instead requests only

relief within this Court's lawful authority sufficient to preserve the effectiveness of review

of the federal judgment and, alternatively, a temporary administrative stay while the

Court determines the proper scope of relief.

IV. THERE IS A REASONABLE PROBABILITY THAT FOUR JUSTICES WILL

VOTE TO GRANT CERTIORARI AND A FAIR PROSPECT OF REVERSAL OR

VACATUR

A. The Petition Presents a Substantial Federal Procedural Question

Whether a district court may refuse to docket and return a substantive post-judgment

motion invoking Rules 59(e) and 60(b), filed twenty-eight days after the challenged order

and seven minutes after a notice of appeal, without judicially determining whether the

motion qualified under Federal Rule of Appellate Procedure 4(a)(4) and affected the

effectiveness of the notice of appeal, or alternatively whether the procedures established

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Pad he)

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by Federal Rule of Civil Procedure 62.1 and Federal Rule of Appellate Procedure 12.1

applied.

The chronology makes the procedural question particularly concrete. Applicant's

Notice of Appeal and her substantive post-judgment motion were submitted on the same

day—January 19, 2026—and only seven minutes apart, with the Notice of Appeal

submitted first. The issue therefore is not whether Applicant attempted to reopen the

case months after appellate jurisdiction had attached. The post-judgment submission

followed the Notice of Appeal by only seven minutes, yet it was returned without

docketing or a judicial determination of its procedural effect. [App. H-1 and App. H-2].

The record also reflects a material chronological inconsistency concerning

the treatment of Applicant's January 19, 2026, submission. The District Court's

December 22, 2025, Order adjudicated Applicant's earlier Motion to Reopen. Applicant's

subsequent Amended Motion for Reconsideration and Rebuttal invoking Rules 59(e) and

60(b) was not submitted until January 19, 2026. Accordingly, the December 22, 2025,

Order could not have adjudicated a motion that had not yet been submitted.

The District Court's subsequent return of Applicant's January 19 submission stated

that the Motion for Reconsideration had been denied in the December 22, 2025, Order.

That statement presents an apparent chronological impossibility: Applicant did not

submit the Amended Motion for Reconsideration and Rebuttal until January 19, 2026—

twenty-eight days after entry of the order said to have denied it. [App. H-3 and H-4].

This distinction is material because the January 19 submission was not merely a

duplicate of the earlier Motion to Reopen. It expressly invoked Rules 59(e) and 60(b) and

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sought reconsideration of the December 22 disposition. Whether that submission was

timely, what rule governed it, what effect it had upon the Notice of Appeal submitted

seven minutes earlier, and whether the District Court retained authority to adjudicate it

or employ the indicative-ruling procedure were questions requiring judicial

determination—not resolution by treating the later filing as having already been denied

by the earlier order.

This procedural circumstance is not merely Applicant's characterization. The Fourth

Circuit's June 30, 2026, opinion expressly described Applicant's request for clarification,

abeyance, and limited remand as relating to “the district court's refusal to docket a motion

to reconsider the denial of her motion to reopen.” The Court of Appeals nevertheless

denied the requested clarification, abeyance, and limited remand. [App. A].

Federal Rule of Civil Procedure 62.1 addresses a motion for relief that a district court

lacks authority to grant because an appeal is pending. It permits the district court to

defer consideration, deny the motion, or state that it would grant the motion upon remand

or that the motion raises a substantial issue. Federal Rule of Appellate Procedure 12.1

supplies the corresponding appellate procedure following an indicative ruling.

The Advisory Committee confirms that Rule 62.1 was designed to formalize the

procedure traditionally employed when a Rule 60(b) motion is presented while an appeal

is pending. Fed. R. Civ. P. 62.1 advisory committee's note to 2009 adoption. Although the

district court may lack authority to grant relief without remand, it may entertain the

motion, deny it, defer consideration, or issue an indicative ruling.

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The timing also implicates Federal Rule of Appellate Procedure 4(a)(4). The

December 22, 2025, Order and Applicant's January 19, 2026 post-judgment submission

were twenty-eight days apart. Rule 4(a)(4)(A) provides that specified timely postjudgment motions—including a motion to alter or amend under Rule 59 and a Rule 60

motion filed within the time allowed for filing a Rule 59 motion—affect the time and

effectiveness of an appeal. And where a notice of appeal is filed after entry of judgment

but before disposition of such a qualifying motion, Rule 4(a)(4)(B)(i) provides that the

notice becomes effective when the order disposing of the last such remaining motion is

entered.

Thus, the mere fact that Applicant submitted her Notice of Appeal seven minutes

before submitting the post-judgment motion did not itself resolve the jurisdictional

question. Whether the January 19 filing qualified under Rule 4(a)(4), and what effect it

consequently had upon the previously submitted Notice of Appeal, depended upon the

character and timeliness of the post-judgment filing. Returning the motion without

docketing prevented a judicial determination of those threshold questions.

The question therefore concerns the administration of federal jurisdiction and the

operation of coordinated district-court and appellate procedures, rather than merely

disagreement with an individualized merits ruling.

The question has significance beyond this case. Post-judgment motions and notices of

appeal frequently arise within the same jurisdictional period. If a substantive postjudgment motion may be returned solely because a notice of appeal was submitted

moments earlier, without judicial determination whether Rule 4(a)(4) affects the notice's

effectiveness or whether Rules 62.1 and 12.1 provide the appropriate procedure, similarly

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situated litigants may be deprived of the very judicial determination necessary to

establish which court possesses authority to act. Guidance is therefore warranted to

ensure predictable administration of the coordinated district-court and appellate

procedures established by the Federal Rules.

B. There Is a Fair Prospect of Reversal or Vacatur

Applicant has a fair prospect of demonstrating error because the challenged

procedure prevented judicial determination of the character and effect of the post-

judgment filing.

Griggs v. Provident Consumer Discount Co., 459 U.S. 56, 58 (1982), establishes the

general principle that an effective notice of appeal transfers authority over matters

involved in the appeal to the court of appeals. Applicant does not contend that Griggs left

the District Court free to grant relief inconsistent with appellate jurisdiction. The

narrower question is whether the existence of the appeal justified refusing to docket and

returning a substantive post-judgment submission without judicial consideration at all.

Rules 62.1 and 12.1 provide a mechanism for addressing requests for relief that a

district court cannot grant because an appeal is pending. By returning Applicant's

submission rather than docketing it for judicial treatment, the procedure challenged here

prevented a determination whether the filing was timely or cognizable under Rule 59(e),

warranted consideration under Rule 60(b), implicated Rule 62.1, or otherwise affected

the respective jurisdiction of the District Court and Court of Appeals. It likewise

prevented development of an indicative ruling that could have activated Appellate Rule

12.1.

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The Fourth Circuit's opinion confirms both sides of the procedural posture: it

acknowledged the District Court's refusal to docket the later motion, yet it affirmed only

the December 22, 2025, denial of the earlier Motion to Reopen and stated that the

underlying dismissal of the amended complaint was not before it. Applicant therefore

does not ask the Circuit Justice to adjudicate the merits of claims the Court of Appeals

did not reach. The asserted error is that the treatment of the post-judgment submission

allegedly prevented operation of the procedures through which those matters could have

received further judicial consideration. [App. D].

V. APPLICANT WILL SUFFER IRREPARABLE HARM ABSENT INTERIM

RELIEF

The threatened property injury is further demonstrated by materially

different findings in the Maryland mechanics-lien proceedings. In an October 28,

2022, Order, the Circuit Court identified Showcase's signed contracts as totaling

$104,069.62 and separately stated that Showcase's Exhibit #2 appeared to allege “an

additional work order for $32,988.43 which there is no proof of.” The court also recognized

Applicant's payment of $60,310.36, noted that electrical work had failed inspection,

questioned whether the work Showcase claimed to have completed was in fact complete,

concluded that the amount actually owed was unclear, and denied Showcase's request for

a mechanic's lien without prejudice. [App. L].

In the subsequent proceeding, however, a different judge entered discovery sanctions

and a default judgment. The later Order found that Showcase's total work, “including

extras approved by Defendant,” was $136,583.05; found $91,145.90 due after credits;

entered judgment for $91,145.90 plus 10% post-judgment interest; established a final

mechanics lien against Applicant's residence in that amount; and directed that the

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property be sold unless the judgment was paid. [App. M.] The same Order prohibited

Applicant from introducing evidence opposing Showcase's complaint, judgment, or

mechanics lien, and from introducing or referencing documents, expert testimony, or

witness testimony. [App. M.]

Of particular relevance to preservation, the figures appearing in the two orders

present a notable numerical correspondence. The later Order's $136,583.05 figure

equals the $104,069.62 in signed contracts identified in the earlier Order, less the

separately identified $475.00 extra-work order, plus the $32,988.43 alleged additional

work order that the earlier court stated had “no proof of’:

$104,069.62 - $475.00 + $32,988.43 = $136,583.05. [App. M].

Applicant does not contend that this numerical correspondence, standing alone,

establishes how the later court calculated its award. Nor does Applicant ask this Court

to determine through this Application whether the later judgment improperly included

the disputed $32,988.43 amount. The correspondence is identified solely to demonstrate

the concrete and documented nature of the dispute underlying enforcement against

Applicant's residence and the importance of preserving meaningful review.

Applicant's current Chapter 13 proceeding does not eliminate the need for

interim relief. Although the automatic stay presently provides statutory protection

against certain enforcement activity, that protection is temporary and does not itself

adjudicate or extinguish the underlying Maryland judgment, mechanics hen, asserted

property rights, or the federal claims concerning the circumstances through which those

interests were allegedly obtained or enforced. The existence of the bankruptcy stay

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therefore postpones certain enforcement consequences; it does not resolve the underlying

controversy that gives rise to them.

Nor does the present Chapter 13 proceeding guarantee that the existing protection

will remain in place throughout the period necessary for Supreme Court review.

Bankruptcy protection is subject to the continued administration of the case and to relief

that may be sought under the Bankruptcy Code. Applicant's prior bankruptcy history

demonstrates the significance of that distinction: in the earlier North Carolina

proceeding, the Bankruptcy Court ultimately annulled the automatic stay retroactively,

permitting the Maryland proceeding to continue “from its inception.” Applicant

challenges matters relating to that order in the separate North Carolina bankruptcy

appeal and does not ask this Court to adjudicate that challenge here.

The present Chapter 13 proceeding does not eliminate the threatened

irreparable injury. Applicant’s current bankruptcy obligations materially increase over

the life of the plan. In approximately one year, the required monthly payment is

scheduled to increase to approximately $2,800, followed thereafter by payments

exceeding $4,208.53 per month. Applicant cannot sustain payments at those levels.

[App. I]. Unless the underlying property controversy can receive meaningful judicial

review before those obligations become unaffordable, Applicant faces a substantial risk

that the Chapter 13 case will no longer provide effective protection and that enforcement

consequences affecting her residence will resume.

The resulting harm is not merely monetary. If Applicant is unable to maintain the

required Chapter 13 payments, she faces the potential loss of the bankruptcy protection

that presently stands between her residence and enforcement of the Maryland judgment

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and mechanics lien. That judgment directs sale of the property unless satisfied. Loss of

the residence, alteration of title, or disposition of the property before this Court can act

would constitute an injury that could not readily be undone by a later ruling on the

federal procedural question.

Accordingly, the current bankruptcy does not eliminate the emergency; it temporarily

delays the threatened consequences while imposing an escalating payment structure that

Applicant contends she cannot sustain. The relevant question is therefore not whether

an automatic stay exists today, but whether meaningful Supreme Court review can occur

before that temporary protection becomes ineffective and the threatened property

consequences become irreversible.

Applicant does not contend that the financial burden of the Chapter 13 payments,

standing alone, constitutes irreparable injury. Rather, the escalating and ultimately

unaffordable payment obligations demonstrate the limited duration of the protection

presently preventing enforcement against the residence. The irreparable injury is the

resulting substantial risk of alteration or loss of Applicant’s property rights before the

federal procedural question presented for certiorari can receive meaningful review.

VI. THE BALANCE OF EQUITIES FAVORS LIMITED, PRESERVATION-

ORIENTED RELIEF

The requested relief is designed to preserve rather than finally alter existing legal

relationships. Applicant faces potentially irreversible consequences involving her

residence and property interests while seeking Supreme Court review.

By contrast, limited interim relief would not adjudicate ownership of property,

invalidate an independent state-court judgment, determine criminal liability, resolve the

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merits of Applicant's underlying civil claims, or decide the separate North Carolina

bankruptcy appeal.

The equities therefore favor only such narrow relief as the Circuit Justice concludes

is legally available and necessary to keep Supreme Court review meaningful.

VIL. THE PUBLIC INTEREST FAVORS PRESERVING MEANINGFUL

SUPREME COURT REVIEW

The public has an interest in orderly federal appellate procedure and in ensuring that

jurisdictional rules governing post-judgment motions operate predictably. The question

presented concerns the interaction among district-court authority, appellate jurisdiction,

Rules 59(e) and 60(b), Rule 62.1, and Appellate Rule 12.1.

A narrowly tailored stay would preserve the respective jurisdiction of the federal,

state, bankruptcy, and appellate courts while permitting this Court to determine whether

the federal procedural question warrants review.

VIII. THE REQUESTED RELIEF IS NARROWLY TAILORED

Applicant respectfully requests a stay, to the extent authorized by 28 U.S.C. § 2101(f),

Supreme Court Rule 23, and this Court's lawful authority, sufficient to preserve

meaningful Supreme Court review of the federal judgment and to prevent the federal

controversy from becoming practically incapable of meaningful relief while the Petition

for a Writ of Certiorari is filed and considered.

Applicant does not request through this Application that the Circuit Justice exercise

direct appellate jurisdiction over the Maryland state court, vacate or stay the June 2,

2023, bankruptcy order, adjudicate the pending North Carolina bankruptcy appeal,

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compel criminal prosecution, or decide the merits of the RICO, fraud, fraud-on-the-court,

or Trust-related allegations.

If the Court concludes that § 2101(f) does not authorize the broader preservation

Applicant seeks because the federal judgment itself does not command execution against

the property, Applicant requests whatever narrower interim relief is lawfully available

to preserve this Court's jurisdiction and the practical effectiveness of certiorari review.

IX. ALTERNATIVE REQUEST FOR A TEMPORARY ADMINISTRATIVE STAY

If the Circuit Justice determines that additional briefing or consideration is

appropriate before ruling on the requested stay, Applicant respectfully requests a

temporary administrative stay sufficient to preserve the status quo while this Application

is considered.

An administrative stay would not resolve the merits. It would provide a brief period

in which the Court can determine the lawful scope of interim relief without allowing the

request for Supreme Court review to become practically ineffective in the meantime.

CONCLUSION

For the foregoing reasons, Applicant respectfully requests that the Circuit Justice:

1. stay, to the extent authorized by 28 U.S.C. § 2101(f), Supreme Court Rule 23, or

other lawful authority, the effect and enforcement of the federal judgment sought

to be reviewed, and grant such preservation-oriented interim relief necessarily

incident to preserving this Court's ability to afford meaningful relief upon certiorari

review;

2. grant such additional, narrowly tailored preservation-oriented relief as is within

this Court's lawful authority and necessary to preserve the practical effectiveness

of Supreme Court review;

3. maintain any stay through disposition of the Petition for a Writ of Certiorari and, if

certiorari is granted, until further order of this Court;

493 4. alternatively, enter a temporary administrative stay while this Application is

494 considered; and

A495 5. grant such other relief as the Circuit Justice or Court deems just and appropriate.

496 Respectfully submitted,

497

498 Oy

499 Lisa Richardgon-He

500 Applicant, Pros

501 8753 Hayshed Lane

502 Columbia, Maryland 21045

503

om Date: Quiquil Aboors

506

507 APPENDIX

508 Appendix A — Opinion of the United States Court of Appeals for the Fourth Circuit, No.

509 26-1077, decided June 30, 2026.

510 Appendix B — Order of the United States Court of Appeals for the Fourth Circuit

511 Denying Petition for Rehearing and Rehearing En Banc, No. 26-1077,

512 July 28, 2026.

513 Appendix C — Mandate of the United States Court of Appeals for the Fourth Circuit,

514 No. 26-1077, issued August 5, 2026.

515 Appendix D— Memorandum Opinion and Order of the United States District Court for

516 the District of Maryland, Case No. 1:25-cv-00695-ABA, entered

517 December 22, 2025.

518 Appendix KE — Applicant's Expedited Motion to Stay and Preserve the Status Quo

519 Pending Petition for Writ of Certiorari, submitted to the United States

520 District Court for the District of Maryland on August 10, 2026.

521 Appendix F — District Court Return of Applicant's Expedited Motion to Stay and

522 Preserve the Status Quo, dated August 18, 2026.

523 Appendix G — Order of the United States Court of Appeals for the Fourth Circuit

524 Denying Applicant's Motion to Stay and Recall the Mandate and for

525 Temporary Administrative Relief, No. 26-1077, August 18, 2026.

526 Appendix H — January 19, 2026 Post-Judgment Filing Materials.

527 H-1 Filing/receipt record for Applicant's January 19, 2026, Notice of Appeal,

528 H-2 Filing/receipt record for Applicant's January 19, 2026, Amended Motion

529 for Reconsideration and Rebuttal.

530 H-3 Applicant's Amended Motion for Reconsideration and Rebuttal Invoking

531 Federal Rules of Civil Procedure 59(e) and 60(b),

532 H-4 District Court Return Document concerning the January 19, 2026,

533 Amended Motion for Reconsideration and Rebuttal

534 Appendix I — Limited Materials Concerning Applicant's Current Chapter 13

535 Proceeding

536 Appendix J —. June 2, 2023 Order Annulling the Automatic Stay, In re Lisa Richardson

537 Henderson, Bankruptcy No. 17-11389, United States Bankruptcy Court

538 for the Middle District of North Carolina.

539 J-1 June 2, 2023 Order Denying Any Further Relief From The Automatic

540 Stay, In re Lisa Richardson Henderson, Bankruptcy No. 17-11389,

541 United States Bankruptcy Court for the Middle District of North

542 Carolina.

543 Appendix K — Letter from the Office of the State's Attorney for Howard County,

544 Maryland, dated February 21, 2023.

545 Appendix L — Order Denying Plaintiff Showcase Home Improvements, Inc.'s Request

546 for Mechanics Lien, Circuit Court for Howard County, Maryland, dated

547 October 28, 2022.

548 Appendix M — Order Establishing Final Mechanics' Lien and Entering Judgment,

549 Circuit Court for Howard County, Maryland, arising from the

550 February 17, 2023, hearing, signed March 1, 2023, and entered April 4,

551 2023.

552

APPENDIX A

Opinion of the United States Court of Appeals for the

Fourth Circuit, No. 26-1077, decided June 30, 2026

Unpublished per curiam opinion affirming the District Court's December

22, 2025, denial of Applicant's Motion to Reopen. The opinion also

acknowledges Applicant's Motion for Clarification, Abeyance, and Limited

Remand “relating to the district court's refusal to docket a motion to

reconsider the denial of her motion to reopen,” and states that the

underlying dismissal of the amended complaint was not before the Court of

Appeals.

JSCA4 Appeal: 26-1077 Doc: 12 Filed: 06/30/2026 Pg: 1 of 2

UNPUBLISHED

UNITED STATES COURT OF APPEALS

FOR THE FOURTH CIRCUIT

No. 26-1077

LISA RICHARDSON HENDERSON,

Plaintiff - Appellant,

Vv.

SHOWCASE HOME IMPROVEMENTS, INC., d/b/a Kenneth Ferber; U. S. BANK

TRUST NATIONAL ASSOCIATION, as Trustee for Pad Series IV Trust,

Defendants - Appellees.

Appeal from the United States District Court for the District of Maryland, at Baltimore.

Adam B. Abelson, District Judge. (1:25-cv-00695-ABA)

Submitted: June 25, 2026 Decided: June 30, 2026

Before BENJAMIN and BERNER, Circuit Judges, and TRAXLER, Senior Circuit Judge.

Affirmed by unpublished per curiam opinion.

Lisa Richardson Henderson, Appellant Pro Se.

Unpublished opinions are not binding precedent in this circuit.

JSCA4 Appeal: 26-1077 Doc: 12 Filed: 06/30/2026 Pg: 2 of2

PER CURIAM:

Lisa Richardson Henderson appeals the district court’s order denying her motion to

reopen, in which she sought to file a second amended complaint following the district

court’s dismissal of her amended complaint pursuant to 28 U.S.C. § 1915(e)(2)(B).!

Because Richardson Henderson filed the motion to reopen more than 28 days after entry

of the dismissal order, it is properly considered a Fed. R. Civ. P. 60(b) motion.? See In re

Burnley, 988 F.2d 1, 2-3 (4th Cir. 1992). When “a plaintiff seeks to reopen a case under

Rule 60(b) in order to file an amended complaint, she must satisfy one of the Rule 60(b)

grounds before a court may consider her motion to amend.” Daulatzai, 97 F.4th at 178

(emphasis omitted). Upon review, we conclude that the district court did not abuse its

discretion by denying this motion. See Aikens v. Ingram, 652 F.3d 496, 501 (4th Cir. 2011)

(en banc) (stating standard of review). Accordingly, we affirm the district court’s order.

Richardson-Henderson v. Showcase Home Improvements, Inc., No. 1:25-cv-00695-ABA

(D. Md. Dec. 22, 2025). We dispense with oral argument because the facts and legal

contentions are adequately presented in the materials before this court and argument would

not aid the decisional process.

AFFIRMED

' Richardson Henderson has also filed a motion for clarification, abeyance, and a

limited remand, relating to the district court’s refusal to docket a motion to reconsider the

denial of her motion to reopen. We deny this motion.

* For this reason, the district court’s order dismissing the amended complaint is not

before us in this appeal. See Daulatzai v. Maryland, 97 F 4th 166, 178 (4th Cir. 2024);

Fed. R. App. P. 4(a)(4).

APPENDIX B

Order of the United States Court of Appeals for the Fourth

Circuit Denying Petition for Rehearing and Rehearing En

Banc, No. 26-1077, July 28, 2026

The Fourth Circuit denied Applicant's petition for panel rehearing and

rehearing en banc on July 28, 2026.

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This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.