Whether a military commission's prosecution of a Guantanamo Bay detainee for inchoate war crimes violates constitutional due process protections and the scope of military jurisdiction

in Petitioner’s case is confirmed by the fact that the CMCR sua sponte heard Petitioner’s case en banc three separate times. The United States also sought and obtained rehearing en banc twice in the D.C. Circuit. Over the course of fifteen years of appellate litigation, Petitioner’s conviction has been vacated twice in its entirety, and yielded at least twenty separate judicial opinions on several issues that are now ripe for review by this Court. Given the complexity and vastness of the appellate record, it is in the interests of justice to afford Petitioner’s counsel an additional sixty (60) days in which to determine which issue or issues are deserving of this Court’s attention. Furthermore, given that Petitioner is represented by government counsel, the extension will afford Petitioner sufficient time to secure the appropriations needed to ensure the petition is printed and delivered in conformity with this Court’s rules. CONCLUSION Applicant respectfully requests a sixty (60) day extension of time within which to file a petition for a writ of certiorari up to and including March 29, 2024. MICHEL PARADIS Counsel of Record AARON SHEPARD MILITARY COMMISSION DEFENSE ORGANIZATION 1620 Defense Pentagon Appellate Defense Division Washington, D.C. 20301 December 11, 2023 ATTACHMENT A Bahlul v. United States, Case No. 22-1097, Opinion (D.C. Cir., Jul. 25, 2023) USCA Case #22-1097 Document #2009385 Filed: 07/25/2023 United States Court of Appeals FOR THE DISTRICT OF COLUMBIA CIRCUIT Argued March 22, 2023 Decided July 25, 2023 No. 22-1097 ALI HAMZA AHMAD SULIMAN AL BAHLUL, PETITIONER Vv. UNITED STATES OF AMERICA, RESPONDENT Consolidated with 22-1173 On Petitions for Review from the United States Court of Military Commission Review Michel Paradis, Counsel, Office of the Chief Defense Counsel, argued the cause for petitioner. With him on the briefs were Todd E. Pierce and Alexandra Link. Eric L. Lewis was on the brief for amicus curiae Concerned Musicians in support of petitioner. John S. Summers, Andrew M. Erdlen, and Alexander J. Egervary were on the brief for amici curiae The Center for Vict