Whether the Eleventh Circuit erred in applying a heightened pleading standard to employment discrimination claims in contravention of Bell Atlantic Corp. v. Twombly and Ashcroft v. Iqbal, and whether dismissal with prejudice of supplemental state law claims violated principles of supplemental jurisdiction

No question identified. : 2. This case involves important federal and constitutional questions. Applicant brought a civil action against Respondent for race discrimination under Title VII, race discrimination under the Florida Civil Rights Act, disability discrimination under the Florida Civil Rights Act, disability discrimination under the Americans with Disabilities Act, disability discrimination under the Rehabilitation Act, retaliation under the Florida Civil Rights Act, retaliation under the Americans with Disabilities Act, and retaliation under Title VII. Applicant began working for Respondent Broward County in March 1995 and was continuously employed for twenty-seven years until February 28, 2022 when she was wrongfully terminated. Applicant is a disabled individual of Chinese ancestry and was subjected to a pattern of severe and pervasive discrimination and harassment on account of her race and her disability by Respondent. Applicant filed a Charge of Discrimination against Respondent on March 28, 2022 before both the EEOC and the Florida Commission on Human Relations. On September 26, 2022, the Florida Commission on Human Relations made a determination that reasonable cause existed to believe an unlawful employment practice had occurred, namely retaliation and discrimination on the basis of race and disability. On May 31, 2023, the Department of Justice issued a notice of Right to Sue. 3. The Eleventh Circuit affirmed the District Court’s pre-answer dismissal with prejudice of Applicant’s Complaint in its entirety demanding a heightened pleading requirement in contravention of this Court’s precedent. The dismissal with prejudice included Applicant’s supplemental state law claims in contravention of this Court’s precedent. The important federal and constitutional issues involved include but are not limited to: whether the decision of the Eleventh Circuit affects the due process rights of litigants to have their claims heard on the merits; whether the decision of the Eleventh Circuit is in contravention of the precedent set forth in Muldrow v. City of St. Louis, 144 S. Ct. 967 (2024); whether the decision of the Eleventh Circuit is in contravention of the precedent set forth in Johnson v. City of Shelby, 574 U.S. 10 (2014); Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007), and Ashcroft v. Iqbal, 556 U.S. 662 (2009); and whether the Eleventh Circuit impermissibly dismissed the supplemental state law claims with prejudice in contravention of the precedent set forth in Royal Canin U.S. A., Inc. v. Wullschleger, 604 U.S. 22 (2025). 4, Applicant’s counsel, Alexandra C. Siskopoulos, was not the attorney of record in the United States Court of Appeals for the Eleventh Circuit and has been recently retained this week. As such, Applicant’s counsel needs additional time to review the entire record and fully brief the issues to be presented to this Honorable Court. Moreover, Applicant’s counsel has other substantial obligations. 5. In light of the foregoing, Applicant’s counsel respectfully requests an extension of time to familiarize herself with the relevant materials and to address the complex issues raised by the instant petition. Applicant’s counsel does not anticipate any further extension requests. WHEREFORE, for the foregoing reasons, Applicant requests that an extension of time of forty-two (42) days, to and including July 29, 2025, be granted within which Applicant may file a petition for writ of certiorari. June 4, 2025 Respectfully submitted, /s/ Alexandra C. Siskopoulos Alexandra C. Siskopoulos Counsel for Applicant Siskopoulos Law Firm, LLP 136 Madison Avenue 6th Floor #3007 New York, New York 10016 (646) 942-1798 acs@siskolegal.com