Whether an employment discrimination claim can proceed when a pro se plaintiff alleges workplace bias without meeting specific pleading requirements

No question identified. : 2 APPLICATION FOR EXTENSION OF TIME TO FILE A PETITION FOR A WRIT OF CERTIORARI To: United States Supreme Court Justice Sonia Sotomayor, Circuit Justice for the U.S. Court of Appeals for the Second Circuit: Under the U.S. Supreme Court's Rules 13.5 and 22, Applicant Mr. Mahfooz Ahmad ("Applicant") respectfully requests an extension of ninety two (92) days or (60) sixty days to file a petition for a writ of certiorari. BACKGROUND United States Court of Appeals for the Second Circuit issued decision in Ahmad v. Day, et al., Appeal No. 24-856, on August 07, 2025. Absent an extension, the petition for the Writ of Certiorari is due on November 5, 2025. Consistent with Rule 13.5, the instant application is filed more than ten (10) days before the petition for certiorari is currently due. This Court's jurisdiction is based on 28 U.S.C. § 1254(1). This application is jurisdictionally proper under 28 U.S.C. § 1254(1). The Supreme Court has repeatedly emphasized that the denial of certiorari ‘imports no expression of opinion upon the merits of the case.’ Teague v. Lane, 489 U.S. 288, 296 (1989). REQUEST Petitioner respectfully requests a 92-day extension, up to and including February 05, 2026, within which to prepare and file the petition for writ of certiorari. In the alternative, if the Court is not inclined to grant 92 days, Petitioner respectfully requests a 60day extension, up to and including January 05, 2026. 3 GROUNDS FOR EXTENSION This request is based on compelling personal circumstances. Petitioner’s wife is currently pregnant, with baby birth due date of November 10, 2025—just days after the current Writ of Certiorari due date. This period will require Petitioner’s full attention and presence to support his wife and newborn child. The petitioner is employed as a manager at Sip & Scoop Ice Cream, this further occupies my time and limits my ability to prepare a petition by the current due date. Petitioner respectfully submits that good cause exists for the requested extension of time request. Granting sufficient additional time will ensure that the petition is fully and properly prepared, without prejudice to the Respondents or undue burden on the Court. CONCLUSION For the foregoing reasons, Petitioner respectfully requests that the time to file the petition for writ of certiorari be extended to and including February 05, 2026, or, in the alternative, to January 05, 2026. Respectfully submitted, Mahfooz Ahmad 590 Main St, Monroe, Connecticut, 06468 T: +1 (475) 342-1915 E: Pro Se Petitioner /s/Mahfooz Ahmad Date: August 18, 2025 Case: 24-856, 08/07/2025, DktEntry: 90.1, Page 1 of 1 UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT At a Stated Term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 7T* day of August, two thousand twenty-five. Before: Eunice C. Lee, Beth Robinson, Maria Aratijo Kahn, Circuit Judges. Mahfooz Ahmad, ORDER Plaintiff Appellant, Docket No. 24-856 Vv. Colin Day, Courtney Dutter, ICIMS Inc., Beacon Hill Staffing Group, Vista Equity Partners Management, LLC, Navi Health Inc, Defendants Appellees. Appellant, pro se, moves the Court to recall the mandate and to consolidate Docket No. 24-856 with Docket No. 23-920. IT IS HEREBY ORDERED that the motion is DENIED. For the Court: Catherine O’Hagan Wolfe, Clerk of Court 5 CERTIFICATE OF SERVICE I Mahfooz Ahmad appellant declare under penalty of perjury that the foregoing is true and correct. Names of the parties served via mail and email are as below: Colin Day, Courtney Dutter, iCIMS Inc. Counsel of Record: Matthew R. Capobianco, Lisa Marie Griffith, Littler Mendelson, P.C. (Melville) 290 Broadhollow road suite 305, Melville, NY 11747 Navi Health Inc. Counsel of Record: Joseph Brent Crace, Jr. Robert w. Horton, Bass, Berry and Sims PLC. 150 Third Avenue South Suite 2800, Nashville, TN 37201 Beacon Hill Staffing G