Whether the Third Circuit improperly denied a certificate of appealability for a federal habeas corpus petition challenging a state criminal conviction

No question identified. : CASENO._ IN THE SUPREME COURT OF THE UNITED STATES October Term, 2024 WILLIAM HOUSMAN, Petitioner, v. SECRETARY, PENNSYLVANIA DEPARTMENT OF CORRECTIONS, ET AL., Respondent. APPLICATION FOR EXTENSION OF TIME TO FILE A PETITION FOR A WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT TO THE HONORABLE SAMUEL A. ALITO, Associate Justice of the Supreme Court of the United States and Circuit Justice for the United States Court of Appeals for the Third Circuit: 1. Pursuant to Rule 13.5 of the Rules of this Court, Petitioner William Housman, through undersigned counsel, respectfully moves for an extension of sixty (60) days to prepare and file a Petition for Writ of Certiorari to the United States Court of Appeals for the Third Circuit. 2. Petitioner seeks certiorari review of the Third Circuit’s order denying Petitioner’s request for a certificate of appealability (COA) of the district court’s denial of his petition writ of habeas corpus. The court issued an opinion denying the application for COA on June 10, 2025. A copy of the opinion and the order denying the application are attached. 3. Petitioner invokes the jurisdiction of this Court pursuant to 28 U.S.C. § 1254(1). Petitioner’s certiorari petition is currently due on September 8, 2025. See Sup. Ct. R. 13.3. In accordance with this Court’s rules, Petitioner makes this request at least ten (10) days in advance of the current due date. See Sup. Ct. R. 13.5. In support of his request, Petitioner respectfully submits as follows: 4. Petitioner’s case presents complex and important questions. Petitioner requests additional time to present them fully but concisely to this Court. Petitioner requests additional time to file in light of counsel’s competing case obligations that have prevented her from beginning work on Mr. Housman’s certiorari petition. Undersigned counsel is Assistant Chief of the Capital Habeas Unit for the Eastern District of Pennsylvania, and has had multiple briefs due in district courts, see, e.g., Nolen v. Quick, No. 22-cv-00272-R, (W.D. Okla. Jun 20, 2025), Marinelli v. Beard, No. 07-cv-00173-RDM-KS (M.D. Pa. Aug. 20, 2025), and an application for COA due in the Third Circuit, Bomar v. Harry, No. 24-9001 (3d Cir. July 24, 2025). Under these circumstances, undersigned counsel respectfully requests that the Court grant this Motion and extend the time in which to file the Petition for Writ of Certiorari by sixty (60) days, until November 7, 2025. 5. The granting of this request shall cause no prejudice to the Respondent, who does not object to this request. 3 6. This request is made in good faith and is not predicated on an intent to delay the resolution of this litigation. WHEREFORE, Petitioners pray that the Court allow a sixty (60) day extension for the preparation and filing of their Petition for Writ of Certiorari. Respectfully submitted, /s/ Katherine Ensler KATHERINE ENSLER* Assistant Chief, Capital Habeas Unit Federal Community Defender for the Eastern District of Pennsylvania 601 Walnut Street, Suite 545 West Philadelphia, PA 19106 (215) 928-0520 Counsel for Petitioner William Housman *Member of the Supreme Court Bar Dated: August 28, 2025 CASE NO. (CAPITAL CASE) IN THE SUPREME COURT OF THE UNITED STATES October Term, 2024 WILLIAM HOUSMAN, Petitioner, v. SECRETARY, PENNSYLVANIA DEPARTMENT OF CORRECTIONS, ET AL., Respondent. CERTIFICATE OF SERVICE I hereby certify that Iam a member in good standing of the bar of this Court and that on this 28‘ day of August, 2025 I served the foregoing by first class mail, postage prepaid, on the counsel identified below, pursuant to Rule 29.4(a) of the Rules of this Court: Jennifer A. Robinson Cumberland County Office of District Attorney 1 Courthouse Square, 2nd Floor, Suite 202 Carlisle, PA 17013 /s/ Katherine Ensler KATHERINE ENSLER Dated: August 28, 2025 TABLE OF APPENDICES