Whether an indigent plaintiff's inability to access digital technology constitutes a violation of First Amendment free speech and Fourteenth Amendment equal protection rights in the context of civil litigation procedure

No question identified. : 2. Therefore, again Latausha Simmons, proceeds in forma pauperis, factoring in the time for mailing and receiving a response from this Court, respectfully a sixty (60) to ninety (90) day extension of time within which to file her petition for writ of certiorari in this Court from the denial of rehearing by the Sixth Circuit Court of Appeals in case no. 22-2052. This application is submitted more than ten (10) days prior to the scheduled filing date for the Petition. See S. Ct. R. 13.5. The pertinent dates are: a: September 11, 2023, Issuance of written mandate denying rehearing en banc. A copy of the order is attached hereto as Exhibit A b: September 1, 2023, denial of rehearing denial of rehearing by the Sixth Circuit Court of Appeals A copy of the order is attached hereto as Exhibit B c: August 17, 2023, issuance of written order affirming denial of reinstatement of civil action (a federal action filed for violations of constitutional rights) dismissal of civil action for a dispute over deposition date and inability to afford zoom technology, a violation of First Amendment Rights and Fourteenth Amendment Rights. 3. This case involves the denial of who is indigent and similarly situated indigent individual(s)’ First Amendment Rights to Free Speech under the United States Constitution, concerning the constitutional rights to an in-person deposition, which Appellant was denied, but instead had a requirement forced upon and/or imposed to acquire Zoom technology for a deposition. In which, indigent individual(s) could not ascertain nor afford nor access. As a result, the unlawful penalizing of indigent individuals with a dismissal of a federal civil action, for being too poor to afford computer technology and/or access to computer technology, and/or being penalized for unlawfully imprisonment at the time a deposition was scheduled without notice and therefore unable to attend. 4. As such, this is a denial of Freedom of Speech under the First Amendment and Equal Protections to the Laws under the Fourteenth Amendment to the United States Constitution, as to all indigent individuals and is Public Interest that Requires Expeditious Determination. Wherein, indigent individuals cannot not be denied due process in pursuing a Section 1983 action for the violations of their federal constitutional rights, for being indigent and not being able to access or afford computer technology. 5. A plaintiff must be afforded plaintiff opportunity to be heard on question whether the failure to appear at scheduled deposition was willful or in bad faith.) Trupei v. City of Lighthouse Point, 506 so. 2d 19 (Fla. 4" D.C.A. 1987). 6. suffers from health issues, including but not limited to carpal tunnels in both wrists and other injuries, caused by excessive force from iaw enforcement. As a result, has caused delays and difficulties in drafting of her pleadings. Thus, she firmly believes these are compelling reasons to justify an extension of time is warranted. 7. As such, this case also involves, the exceptional public importance, i.e. nationwide police brutality with the use of excessive force, which is a violation of the Fourth Amendment to the U.S. Constitution. The right to be free from excessive force is a clearly established Fourth Amendment right.” Id. at 554-55 (citing Neague v. Cunkar, 258 F.3d 504, 507 (6th Cir. 2011)). 8. An extension will not cause prejudice to Respondents. 9. This Supreme Court’s letter dated October 31, 2023, postmarked November 1, 2023, was received by on November 8, 2023. Therefore, this motion for an extension of time.is being resubmitted by U.S. certified mail on November 9, 2023. For the foregoing reasons, the who is indigent, respectfully prays that this Court grant an extension of sixty (60) to ninety (90) days and including January 8, 2024, within which to file his petition for writ of certiorari. Respectfully submitted, this the 9th day of November, 2023. /s/LaTausha Simmons LaTausha