Whether federal criminal statutes governing sexual abuse in Indian Country are unconstitutionally vague or overbroad in their application to specific types of conduct

No question identified. : To the Honorable Neil M. Gorsuch, Associate Justice of the Supreme Court of the United States and Circuit Justice for the Tenth Circuit: Petitioner Edgar Rene Garcia-Limon, by undersigned counsel, prays for a 30-day extension of time, up to and including November 19, 2025, in which to file a petition for a writ of certiorari. In support of this request, counsel states as follows: 1. On July 22, 2025, the United States Court of Appeals for the Tenth Circuit affirmed Mr. Garcia-Limon’s convictions for aggravated sexual abuse of a minor in Indian Country, in violation of 18 U.S.C. § 2251(c), 2246(2)(D), 1151, 1152, and abusive sexual contact in Indian Country, in violation of 18 U.S.C. §§ 2244(a)(5), 2246(3), 1151, 1152 (Attachment A.) 2. Mr. Garcia-Limon has ninety days from that date to file a petition for a writ of certiorari. Sup. Ct. R. 13.3. The petition is therefore due on October 20, 2025. This application is being filed at least ten days before that date, consistent with Supreme Court Rule 13.5. 3. The jurisdiction of this Court is invoked under 28 U.S.C. § 1254(1). 4, Since the Tenth Circuit Court of Appeals’ order and judgment in this case, undersigned counsel has filed a petition for certiorari in Adams v. United States, Sup. Ct. No. 25-5467 (filed Aug. 22, 2025); an opening brief in United States v. Estrada, 10th Cir. No. 25-8003 (filed Aug. 29, 2025); a reply brief in United States v. Robbins, 10th Cir. No. 24-7067 (filed Sept. 8, 2025); and a motion for reduction in sentence in United States v. Segura, D. Colo. No. 20-cr-293 (filed Sept. 29, 2025). Counsel also completed time-sensitive work on cases including United States v. Lopez, 10th Cir. No. 25-6037 (appeal dismissed Aug. 6, 2025); and United States v. Alvarado-Gomez, 10th Cir. Case No. 25-7012 (appeal dismissed Sept. 16, 2025). 5. In addition, counsel currently has a reply brief due on October 14, 2025, in United States v. Wiggins, 10th Cir. No. 25-8002; and an opening brief due on November 3, 2025, in United States v. Palma, 10th Cir. No. 25-7027. Counsel must also ptepare for oral argument on November 20, 2025, in United States v. Robbins, 10th Cir. No. 24-7067; and United States v. Cifuentes-Lopez, 10th Cir. No. 24-6177. 6. Given their own current caseloads, as well as the work undersigned counsel has put into this case as counsel of record, no other attorney in the Office of the Federal Public Defender is in a position to file the petition by its current due date. KOK For these reasons, Petitioner Edgar Rene Garcia-Limon respectfully requests that an order be entered extending the time in which to petition for a writ of certiorari by 30 days, to and including November 19, 2025. See Sup. Ct. R. 13.5. // // // Respectfully submitted, VIRGINIA L. GRADY Federal Public Defender KATHLEEN SHEN Assistant Federal Public Defender Counsel of Record for Petitioner 633 17th Street, Suite 1000 Denver, Colorado 80202 (303) 294-7002