Whether the Eleventh Circuit properly applied the Antiterrorism Effective Death Penalty Act of 1996 in affirming the denial of habeas corpus relief based on claims of ineffective assistance of counsel under Strickland v. Washington and prosecutorial misconduct in violation of the Due Process Clause

in the Pye case, the Eleventh Circuit’s misapplication of the AEDPA and continued noncompliance with this Court’s decision in Wilson v. Sellers, 138 S. Ct. 1188 (2018), presenting a split with the other circuits, is also presented in Petitioner’s case. This Court’s decision whether to grant certiorari on this issue in Pye will necessarily impact Mr. Pace’s case. Because that decision will come after Mr. Pace’s Petition is currently due in this Court, extending the time to file Mr. Pace’s Petition will best serve judicial economy. 4. Additionally, the Eleventh Circuit improperly applied the AEDPA to the federal constitutional issues in this case, including counsel’s ineffective assistance under Strickland v. Washington, 466 U.S. 668 (1984), and prosecutorial misconduct so extreme that one panel member wrote separately to express “disgust at how outrageous the prosecution’s conduct in closing argument was,” Pace, 2023 WL 3376683 at *41 (Rosenbaum, J., concurring); Darden v. Wainwright, 477 U.S. 168 (1986); Donnelly v. DeChristoforo, 416 U.S. 637 (1974). A Petition for Writ of Certiorari is essential, and counsel respectfully asks for additional time in which to properly winnow these issues for consideration by this Court. CONCLUSION Mr. Pace asks this Court to extend the deadline to file the Petition for Writ of Certiorari by sixty (60) days, up to and including December 8, 2023. September 14, 2023 Respectfully Submitted, GRETCHEN M. STORK FEDERAL DEFENDER PROGRAM 101 Marietta Street, NW Suite 1500 Atlanta, Georgia 30303 (404) 688-7530