Whether the Ex Post Facto Clause prohibits prosecuting a defendant under an expanded statutory definition of 'financial institution' that did not exist at the time of the alleged conduct

No question identified. : Pursuant to Supreme Court Rule 13.5, Petitioner Jessica Arong O’Brien respectfully requests a sixty (60) day extension, up to and including Monday, November 3, 2025, to file her petition for writ of certiorari from the Seventh Circuit’s June 4, 2025, Order (Docket #24-1207) (Ex. # A), which affirmed the Northern District of Illinois’ denial of her 28 U.S.C. § 2255 motion. Petitioner proceeds pro se. The following facts and circumstances demonstrate good cause under Supreme Court Rule 13.5 for granting this motion: 1. Extraordinary Record Volume and Procedural Complexity: Petitioner’s matter is built upon a uniquely voluminous and layered record, spanning an estimated 20,000+ pages and five separate federal court dockets, including criminal trial, direct appeal, post-conviction litigation, and governmental enforcement actions. The complexity and breadth of these records, as set forth in Petitioner’s docket summary below, demand extraordinary diligence and time for adequate review and synthesis: Proceeding/Docket Number of Docket Pages Filed (Known) Entries ND Illinois Criminal 426 12,000 + (est.) (1:17-cr-00239) 7th Cir. Direct Appeal 57 1,000+ (19-1004) ND Illinois Civil/§2255 73 3,000+ (est.) (1:22-ev-00083) 7 Cir. 28 U.S.C. § 2255 37 4,100+ (24-1207) Total: well over 20,000 pages, including hearing transcripts, trial exhibits, appellate motions, and supplemental and oversized briefs, all of which must be navigated and distilled by a single pro se litigant. 2. Case Complexity and Profound Legal Questions: This case presents unusually intricate legal and constitutional matters: e Ex Post Facto Clause and Retroactivity: Petitioner was convicted under 18 U.S.C. §1344 by application of a “financial institution” definition that was not enacted until 2009, two years after her real estate sale transactions in April of 2007. Congress only amended the law in 2009 to include entities like mortgage brokers and corporations. The government anchored jurisdiction on her buyer’s home equity line of credit (CHELOC”) as to Citibank N.A., but there was no proof of Petitioner’s involvement or knowledge of her buyer's HELOC, and other loans at issue were not from FDIC-insured entities. This raises not only a fundamental violation of the Ex Post Facto Clause (U.S. Const. Art. I, §9), but also defeats federal subject matter jurisdiction, as the government relied on statutory amendments to the definition of ‘financial institution’ that did not exist at the time of the alleged conduct and thus could not form the basis for a federal prosecution or conviction. ¢ Government Misrepresentation and Perjury: The prosecution obtained the Petitioner’s one-count of bank fraud and onecount of mail fraud conviction by misrepresenting the corporate relationship between CitiMortgage Inc. and Citibank, N.A., and falsely claiming Petitioner had previously dealt with Citibank. The prosecutor, with a history of prior misconduct, suborned perjury and relied on documents known to be false, as proven by public SEC filings and unrefuted evidence submitted by Petitioner, e.g., the lead litigator’s own email evidencing that he knew that the material testimony he elicited from the government's key witness was false. e Government’s Tampered Key Evidence: The HUD-1 Settlement Statement for Petitioner's Buyer’s HELOC presented to the trial jury was further altered that would have wrongfully implied Petitioner’s knowledge and involvement of the existence of this HELOC. It is the same HELOC that the government has anchored its federal subject matter jurisdiction and the precise transaction the district judge instructed the government it was required to prove at trial and therefore, was a material issue in this case. The government improperly took the first page of the HUD-1 settlement statement from the property sale between Petitioner and the buyer, a transaction that was fully funded by CitiMortgage, Inc., a non-FDIC-insured entity, and resulted in