Whether a variance between oral and written jury instructions constitutes reversible error when the parties were aware of the discrepancy but did not formally correct the instructions in open court

No question identified. : Pursuant to Supreme Court Rules 13.5, 22, and 30.3, Jairo Arnaldo Jacome, Petitioner above named, respectfully requests a sixty (60) day extension of time, up to and including October 31, 2025, within which to file a petition for writ of certiorari from the judgment of the United States Court of Appeals for the Fourth Circuit. Mr. Jacome has not previously sought an extension of time from this Court. Petitioner is filing this Application at least ten days before the filing deadline, which is September 1, 2025. See S. Ct. R. 18.5. The jurisdiction of this Court will be invoked pursuant to 28 U.S.C. § 1254(1). In 2022, Mr. Jacome was convicted after a two week trial of various offenses, including conspiracy to conduct and participate in the affairs of the an enterprise through a pattern of racketeering activity (“RICO conspiracy”), a violation of 18 U.S.C. § 1962(d); murder in aid of racketeering, 18 U.S.C. § 1959(a)(1) (“VICAR murder”), and aid and abet, 18 U.S.C. § 2; and conspiracy to interfere with interstate commerce by extortion, a violation of 18 U.S.C. § 1951(a). The district court sentenced Mr. Jacome to life imprisonment. My. Jacome appealed to the Fourth Circuit Court of Appeals. Mr. Jacome claimed various errors, including that the district court had created a fatal variance via a difference between the oral and written jury instructions provided to the jury. The parties had noticed the district court’s error in the oral instructions and changed the 70-page set of written instructions that was provided to the jury during its deliberations. However, the jury was not returned to the courtroom to correct the error in open court. In a published decision, the Court of Appeals determined that under plain error review, Mr. Jacome was unable to establish a violation of his substantial rights. A copy of the Court of Appeals’ Opinion is attached as