Lawrence Wilson Kingsley v. Ann Elizabeth Lange

APPLICATION FOR WRIT OF CERTIOARI Issues on Appeal

1. Should this case be allowed to conflict with both federal and state cases which hold that a nonparty cannot intervene in a case without adherence to FRCP 24 or corresponding state rules, and now, on the basis of this case, can any nonparty start filing papers in a case at will?

2. Should this case establish a new rule that it now OK to intervene in a case after it has been dismissed?

3. In the Supreme Court’s own words, has the court of last resort “so far departed from the accepted and usual course of judicial proceedings, or sanctioned such a departure by a lower court, as to call for an exercise of this Court’s supervisory power”?

4. Specifically, does the lack of due process and equal protection of the laws, in derogation of the appellant’s right to access to the court, raise a federal question that merits certiorari: A. Because this case upends a long tradition of federal and state cases which hold that issues cannot be raised for the first time on appeal. (As an unauthorized intervenor and an admitted nonparty, Crowell & Owens has asserted claims which were never part of the original litigation.) B. Because there was a rush to judgment before contrary evidence was considered—namely, that the factual basis of the Order of Abandonment was 2 r