Whether prolonged pretrial detention without individualized bail hearings violates the constitutional right to due process and equal protection

also arises frequently (affecting hundreds of people making up 42% of the jail population in Allegheny County alone) and is tremendously important both because of the irreparable harm that unjustified detention inflicts (including loss of employment and housing, and interference with religious exercise), and because the right to physical liberty is among the most fundamental of all rights. 3. The extension of time is requested because undersigned counsel from Wilmer Cutler Pickering Hale and Dorr LLP have only recently been retained. Additional time is warranted to coordinate with applicants and their respective counsel. Counsel also have other filings that must be prepared in the weeks leading up to the current filing deadline here, including a summary-judgment motion due June 30 in Louisiana v. Biden, No. 2:25-ev-00071 (W.D. La.); a reply brief due July 9 in Hicks v. Social Security Administration, No. 24-5946 (6th Cir.); an amicus brief due July 18 in Fernandez v. United States, No. 24-556 (U.S.); a reply brief in support of a motion due on July 18 (pending approval for leave to file) in Hapress Scripts, Inc. v. Richmond, No. 25-cv-520 (E.D. Ark.); and a reply brief due July 21 in Rodriguez v. Pan American Health Organization, No. 24-7135 (D.C. Cir.). 4. Applicants therefore request a 30-day extension of time for filing a petition for a writ of certiorari in this case. June 24, 2025 ALEC G. KARAKATSANIS LEONARD J. LAURENCEAU SUMAYYA SALEH CIVIL RIGHTS CORPS 1601 Connecticut Avenue N.W., Suite 800 Washington, D.C. 20009 (202) 894-6132 Counsel for all applicants BRET GROTE DOLLY PRABHU JACLYN KURIN ABOLITIONIST LAW CENTER P.O. Box 8654 Pittsburgh, PA 15221 (414) 654-9070 Counsel for all applicants Respectfully submitted. /s/ Daniel S. Volchok DANIEL S. VOLCHOK Counsel of Record JEREMY W. BRINSTER ANNEKE DUNBAR-GRONKE WILMER CUTLER PICKERING HALE AND DORR LLP 2100 Pennsylvania Avenue N.W. Washington, D.C. 20037 (202) 663-6000 Counsel for applicant Dion Horton