1. Whether a stay is warranted where the Ninth Circuit dismissed a federal civil-rights appeal as "frivolous" under 28 U.S.C. § 1915(e)(2), despite the record containing substantial federal evidence—including docketed filings from the Southern District of New York PROMESA Title III proceedings—directly relevant to the issues raised in the appeal.

2. Whether a stay is warranted to preserve Applicant's access to appellate review where the Ninth Circuit's dismissal forecloses consideration of constitutional issues, whistleblower protections, and federal statutory obligations material to the underlying case.

Whether a federal appellate court can summarily dismiss a pro se civil rights appeal as frivolous under 28 U.S.C. § 1915(e)(2) without providing meaningful appellate review of constitutional due process claims