Whether prison officials' deliberate indifference to systemic staffing deficiencies that substantially increase the risk of serious harm to inmates violates the Eighth Amendment, and whether such constitutional violations warrant equitable tolling of habeas corpus filing deadlines under 28 U.S.C. § 2244(d)(2)

No question identified. : U.S.C. §2244(d)(2). Respondents in the case at bar have successfully precluded, Petitioner’s attempts, ab initio, to raise the issues conclusively establishing Respondents’ both manufactured inculpatory evidence and withheld Brady’ materials in order to wrongfully convict Petitioner. Furthermore, Petitioner has experienced ongoing oppressive conditions due to the lack of officers in the South Carolina Department of Corrections (SCDC). SCDC has publicly acknowledged that they do not have adequate staff to properly run their prisons in accordance with federal guidelines. This admission establishes that the lack of personnel is a systemic issue and not an isolated incident, and is the reason that Petitioner’s screams for help went unanswered while he was being stabbed eight times. In the case of Farmer v. Brennan, 511 U.S. 825 (1994), this Court held that prison officials have a duty under the Eighth Amendment to protect inmates from harm. This duty includes providing adequate staffing levels to ensure the safety and security of prisoners. The Court further emphasized that deliberate indifference to a substantial risk of serious harm to inmates violates their constitutional rights. Because of this lack of adequate staff, Petitioner has severely limited opportunities to both seek assistance in the law library or even report to the prison mailroom for his legal mail since he is locked down all but 8 to 12 hours each week — which is the reason Petitioner was not able to file this motion at least 10 days prior to the deadline to file the petition for discretionary review in this Court. Therefore, Petitioner respectfully requests an extension of time to file his Writ of Certiorari because financial difficulties have precluded him from securing counsel, and the oppressive conditions of his confinement are also responsible for the delay in filing this 2 Brady g. Maryland, 373 U.S. 83 (1963). request just prior to the deadline to file the Petition for a Writ of Certiorari (and notably, after the Supreme Court Rule13.5’s 10-day extension window). WHEREFORE, Petitioner prays that this Court grants the relief requested; and for such other relief as this Court deems just and proper. Respectfully submitted, Clark D. Thomas, SC No.187845 Pro se Petitioner Ridgeland C.1. / Beaufort B-21 P.O. Box 2039 Ridgeland, SC 29936-2039 Z)opt / / , 2023 Ridgeland, S.C.