Whether the Eighth Amendment prohibits the imposition of a death sentence where the defendant was represented by pro bono counsel during post-conviction proceedings and faced complex legal challenges

No question identified. : Criminal Appeals affirming the issues raised in his direct appeal. See attached Exhibit 1 (Opinion on Direct Appeal). The judgment of the Oklahoma Court of Criminal Appeals was entered on January 30, 2025. Petitioner’s motion for rehearing was considered, and denied on March 26, 2025. See attached Exhibit 2 (Order Denying Rehearing). Petitioner’s time in which to petition this Court for a Writ of Certiorari expires on Tuesday, June 24, 2025 (90 days calculated from March 26, 2025). Pursuant to United States Supreme Court Rule 13.5, this Application is being filed more than ten days before June 24, 2025. The jurisdiction of this Court is invoked pursuant to 28 U.S.C. § 1254(1). This case is a capital murder case out of Oklahoma where Petitioner has been sentenced to death. Although counsel had been retained to prepare the direct appeal to the Oklahoma Court of Criminal Appeals, Petitioner is now indigent and counsel is proceeding to this Court on a pro bono basis. Counsel requests an extension in this case because of the complex nature of the factual and legal disposition of the direct appeal, the fact that counsel is working pro bono at this point, and counsel’s obligations in other cases, including a Petition for Certiorari in this Court in Holt v. State, No. F-2023-533 (Okla. Crim. App.), due on or before July 2, 2025; and preparation of a brief in support of habeas petition in Calhoun y. Louthan, No. 25-cv-52-JDR-JFJ (N.D. Okla.), filed April 30, 2025. 11. Petitioner has not previously petitioned this Court for an extension of time in which to file a Petition for a Writ of Certiorari. 12. Counsel avers that this Application is made in good faith and not for purposes of delay. Wherefore, Petitioner requests respectfully that an Order issue establishing the due date for Petitioner’s Petition for a Writ of Certiorari as Monday, August 25, 2025. LIYE J fs. Hankins, Okla. Bar No. 15506 ABRI BUSINESS CENTER 24 N. Broadway Edmond, Oklahoma 73034 Telephone: 405.753.4150 Facsimile: 405.445.4956 Dated this 13" day of June, 2020. E-mail: COUNSEL FOR PETITIONER No. IN THE SUPREME COURT OF THE UNITED STATES OF AMERICA DANIEL RAUL SANTIAGO VASQUEZ, Petitioner, v. STATE OF OKLAHOMA, Respondent. CERTIFICATE OF SERVICE I, James L. Hankins, a member of the Bar of this Court, certify that I have this 13" day of June, 2025, served a copy of Petitioner’s Application for Extension of Time in which to File Petition for Writ of Certiorari to the Oklahoma Court of Criminal Appeals, by depositing the copy in the United States Mail, first-class postage prepaid, addressed to: Christina A. Burns Assistant Attorney General 313 NE 21* St. Oklahoma City, Oklahoma 73105 Phone: 405.521.3921 All parties required to be served have been served. Ye Jame¢L. Hankins