Whether a state supreme court's denial of review without substantive analysis violates a religious organization's First Amendment right to meaningful judicial review of constitutional claims

the questions for review. 5. In addition, undersigned counsel continues to face significant professional obligations that make it impracticable to complete the petition by the current deadline. Counsel must prepare for multiple trials—including a Cal/OSHA trial involving substantially the same parties and an October trial with pretrial deadlines throughout September and October, jury selection on October 1-2, and trial soon thereafter. Counsel is also scheduled to travel internationally from October 12-19, 2025, to teach continuing legal education programs in Rome and Athens. 6. Given these obligations and newly added counsel, additional time is necessary to ensure that the petition is thoroughly researched, carefully drafted, and fully protective of Applicants’ rights. This request is made in good faith and not for the purpose of delay. 7. The extension would not exceed the maximum 60-day extension authorized by Supreme Court Rule 13.5 and 28 U.S.C. § 2101(c). 8. Applicants have advised Respondents of this request. Respondents have indicated that they do not object, provided that Applicants agree to a reciprocal extension of Respondents’ deadline to file their brief in opposition. Specifically, Respondents note that, assuming a December 12, 2025, deadline for the petition, a substantial portion of their response period would fall during the end-of-year holidays, when much of their team will be unavailable. Applicants are amenable to this reciprocal accommodation. For these reasons, Applicants respectfully request that an order be entered extending the time in which to petition for a writ of certiorari by 60 days, to and including December 12, 2025. See Sup. Ct. R. 13.5. Dated: September 25, 2025 Respectfully submitted, ADVOCATES FOR FAITH & FREEDOM /s/ Robert Tyler Robert H. Tyler Counsel of Record Erin E. Mersino Joel Oster Julianne Fleischer 25026 Las Brisas Road Murrieta, CA 92562 (951) 326-4554 AMERICAN CENTER FOR LAW & JUSTICE Jay Alan Sekulow Stuart J. Roth Jordan A. Sekulow Walter M. Weber Christina Compagnone Abigail Southerland Nathan J. Moelker 201 Maryland Ave. NE Washington, DC 20002 EXHIBIT “A” SUPREME COURT Court of Appeal, Sixth Appellate District No. H051860 \ JUL 16 2025 §291092 Jorge Navarrete Clerk IN THE SUPREME COURT OF CALIFORNIA En Banc THE PEOPLE et al., Plaintiffs and Respondents, Vv. CALVARY CHAPEL SAN JOSE et al., Defendants and Appellants. The request for judicial notice is granted. The petition for review is denied. GUERRERO Chief Justice Deputy CERTIFICATE OF SERVICE Iam an employee in the County of Riverside. I am over the age of 18 years and not a party to the within entitled action; my business address is 25026 Las Brisas Road, Murrieta, California 92562. On September 25, 2025, I served a copy of the following document(s) described as: APPLICATION FOR AN EXTENSION OF TIME TO FILE A PETITION FOR WRIT OF CERTIORARI on the interested party(ies) in this action by-email or electronic service [C.C.P. § 1010.6; C.R.C 2.250-2.261]. The documents listed above were transmitted via e-mail to the e-mail addresses on the attached service list. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct and that I am an employee in the office of a member of the bar of this Court who directed this service. Zz Robert H. Tyler SERVICE LIST Melissa R. Kiniyalocts, Esq. Robin Wall, Esq. Xavier Brandwajn, Esq. Jamila Benkato, Esq. County Counsel, County of Santa Clara 70 West Hedding St., East Wing, Ninth FI. San Jose, CA 95110-1770 Jeffrey R. Rosen, Esq., District Attorney David Angel, Esq., Assistant Attorney 70 West Hedding Street, West