1. Whether an order imposing circuit- and state-wide pre-filing injunctions conditioned
on purging monetary sanctions exceeds the All Writs Act, violates due process, and
conflicts with this Court's and the Fifth Circuit's precedents requiring injunctions to be
narrowly tailored and to preserve access to courts.

2. Whether a stay is warranted under Nken v. Holder, 556 U.S. 418 (2009), because
Applicant has a strong likelihood of success (or, at minimum, serious questions going to
the merits), faces irreparable harm absent a stay, and the balance of equities and
public interest favor interim relief.

Whether a pre-filing injunction conditioning court access on monetary sanctions violates due process and the right to access courts under the All Writs Act