Whether a federal inmate may obtain an extension of time to file a petition for a writ of certiorari based on limited communication opportunities and counsel's competing professional obligations

No question identified. : December 8, 2023, more than ten days prior to the date on which the time for filing the petition is to expire. 2. Applicant has good cause for an extension of time. Mr. Allen is currently an inmate at a federal correctional institution, and his opportunities to communicate with counsel are limited. An extension of time will allow for necessary communication regarding Mr. Allen’s petition for a writ of certiorari. In addition, this case involves nuanced and novel questions of statutory interpretation. And counsel for Applicants have extensive professional obligations over the coming months, including a merits brief due December 13 in Bissonnette v. LePage Bakeries Part St., LLC (No. 23-51), a reply brief in support of certiorari due December 20 in Raitzloff v. United States (No. 23-310), a reply brief in support of a motion to dismiss due January 5 in Beny v. University of Michigan (E.D. Mich. No. 22-12021), a motion for summary judgment due January 25 in KalshiEx LLC v. Commodity Futures Trading Commission (D.D.C. No. 23-03257), and a reply brief due January 31 in Riely v. Waterman (CA7 No. 23-1253). In light of these competing commitments, the quality of the petition would greatly benefit from an extension of time. WHEREFORE, Applicants respectfully request that an order be entered extending the time to file a petition for a writ of certiorari for 60 days, to and including February 24, 2024. Dated: December 8, 2023 Respectfully submitted, /s/ Amanda K. Rice DUSTIN M. KOENIG AMANDA K. RICE JONES DAY Counsel of Record 325 John H. McConnell Blvd. JONES DAY Suite 600 150 W. Jefferson Ave., Suite 2100 Columbus, OH 43215 Detroit, MI 48226 (614) 281-3972 (318) 230-7926 arice@jonesday.com Counsel for Applicant Ranito Allen