Whether a pro se litigant's multiple petitions for certiorari from different circuit court judgments should be considered timely under the 90-day statutory filing period when received in close temporal proximity

No question identified. : PETITIONER’S CORRECTED APPLICATION FOR RELIEFCORRECTED MOTION FOR AN EXTENSION TO FILE PETITIONS FOR WRIT OF CERTIORARI IL INTRODUCTION July 1, 2025 Pursuant to 28 U.S.C.§2101(c), S.CtR.13.5, & S.Ct.R.30.2, Petitioner DAWUD C.S, GABRIEL (‘Gabriel’) motions the Court for an extension to file 28 U.S.C.$1254(1) Petitions for Writ of Certiorari, for the Court to review May 13, 2025, Judgment [Ex.1] of the Second (2nd) Cir. C.O.A. in the matter of Gabriel v. The A.R.B. of the U.S. Labor Dept., Case no.24-2130 (2nd Cir.2025). Gabriel requests the Court to extend the time until October 10, 2025, for Good Cause. Since Gabriel will exhibit Good Cause for an extension infra, the Court should grant Gabriel’s Relief Request. IL. RELEVANT PROCEDURAL HISTORY 1. On August 12, 2024, Gabriel filed a 49 Petition with the Clerk of the Second (2nd) Cir. C.O.A. in the matter of Gabriel _v. The A.R.B. of the U.S. Labor Dept., Case no.24-2130 (2nd Cir.2024). On August 12, 2024, Gabriel moved to proceed as a pauper in the matter of Gabriel v. The A.R.B. On March 17, 2025, the Clerk of the Second (2nd) Cir. C.O.A. entered an unlawful mandate, that unlawfully dismissed the appeal in the matter of Gabriel v. The A.R.B. of the U.S. Labor Dept., Case no.24-2130 (2nd Cir.2025) and unlawfully denied Gabriel’s August 12, 2024, Pauper Motion. On April 1, 2025, Gabriel filed a Mandate Recall Motion to vacate March 17, 2025, unlawful mandate by the Clerk of the Second (2nd) Cir. C.O.A. in the matter of Gabriel v. The A.R.B. of the _ Labor Dept., Case no.24-2130 (2nd Cir.2025), On May 17, 2025, Gabriel received the Clerk of the Second (2nd) Cir. C.0.A.’s May 13, 2025, unlawful judgment [Ex.1] by mail, which denied his April 1, 2025, Mandate Recall Motion, in the matter of Gabriel v. The A.R.B. of the U.S. Labor Dept.. Case _no.24-2130 (2nd Cir.2025). See Ex.1, Pg.1. Page 2 of 8 6. Gabriel now moves for the time to be extended until October 10, 2025, to file §1254(1) Petitions, for the Court to review May 13, 2025, Judgment [Ex.1] of the Second (2nd) Cir. C.O.A. in the matter of Gabriel v. The A.R.B. of the U.S. Labor Dept.. Case no.24-2130 (2nd Cir.2025). TI. LEGAL STANDARD A. Pro Se Standard “[P]ro se [papers]...we hold to less stringent standards than [papers] drafted by lawyers[.]” Haines v. Kerner, 404 U.S. 519, 520-21, 92 §.Ct. 594, 30 L.Ed.2d 652 (1972); Estelle v. Gamble, 429 US 97, 106, 97 S. Ct. 285, 50 L. Ed. 2d 251 (1976). A. 28 U.S.C.§1254(1) “Cases in the courts of appeals may be reviewed by the Supreme Court by the following methods...[b]y writ of certiorari granted upon the petition of any party to any civil or criminal case, before or after rendition of judgment or decree[.]” Federal Election Comm'n v. NRA Political Victory Fund, 513 US 88, 90, 115 S. Ct. 537. 130 L. Ed. 2d 439 (1994); Missouri v. Jenkins, 495 US 33, 45, 110 S. Ct, 1651, 109 L. Ed. 2d 31 (1990). B. 28 U.S.C.§2101(c) Extensions “[28 U.S.C. §] 2101 (c)...permits a Justice of this Court, "for good cause shown," to grant an extension of time for the filing of a petition for certiorari in a civil case for a period not exceeding 60 days. In civil cases, applications for extension of time must be presented during the original 90-day period.” Missouri v. Jenkins, 495 US 33. 81 n.12, 110 S. Ct. 1651, 109 L. Ed. 2d 31 (1990); S.CtR.30.2. C. Good Cause Standard “{W]here specific allegations before the court show reason to believe that the petitioner may, if the facts are fully developed, be able to demonstrate that he is...entitled to relief, it is the duty of the court to provide the necessary facilities and procedures for an adequate inquiry. Bracy v. Gramley, 520 US 899, 908-909, 117 S. Ct. 1793, 138 L. Ed. 2d 97 (1997); Harris v. Nelson, 394 US 286, 300, 89 S. Ct. 1082, 22 L. Ed. 2d 281 (1969). TV. DISCUSSION Under 28 U.S.C.§2101(c), Congress permits a §1254(1) Petition to be timely filed within ninety (90) days of a final order/judgment of an U.S. Court of A