Whether the Third Circuit's prior appellate decision in favor of the petitioner warrants Supreme Court review given the unique circumstances of counsel's advanced age and disability

No question identified. : Summary Judgment. 3. Counsel for Petitioner plans to confer with previous counsel for Petitioner regarding the prior appeal decided in favor of Petitioner by the United States Court of Appeals for the Third Circuit. Prior counsel, age 91, resides in Massachusetts and is disabled. WHEREFORE, Plaintiff respectfully requests this Honorable Court to grant a sixty (60) day extension of time in which to file Petition for Writ of Certiorari to the United States Court of Appeals for the Third Circuit. Respectfully submitted: DURHAM & JAMES, P.C. Stephen A. Durham STEPHEN A. DURHAM, ESQUIRE Attorney for Appellant, Robert Holton 320 West Front Street Media, Pennsylvania 19063 Telephone No.: (610) 565-4750 Fax No.: (610) 565-4820 Email: I.D. No. 30086 PROOF OF SERVICE Thereby certify that I am this day serving the foregoing Motion to Extend Time to File a Petition for Writ of Certiorari upon the City of Philadelphia Law Department, Diana P. Cortes, City Solicitor, Adam R. Zurbriggen, Deputy City Solicitor, Civil Rights Unit, 1515 Arch Street, 14" Floor, Philadelphia, PA 19102-1595 via the ECF system of the Supreme Court of the United States and U.S. First Class Mail. Dated: December 28, 2023 /s/ Stephen A. Durham STEPHEN A. DURHAM, ESQUIRE Attorney for Appellant, Robert Holton 320 West Front Street Media, Pennsylvania 19063 Telephone No.: (610) 565-4750 Fax No.: (610) 565-4820 Email: I.D. No. 30086