Whether a federal defender may obtain an extension of time to file a petition for writ of certiorari based on counsel's workload and case complexity
No question identified. : November 5th, 2025. See S.Ct. R. 13.5. The jurisdiction of this Court will be invoked under 28 U.S.C. § 1254(1). Mr. Brown asks this Court to extend the deadline because the issues in this case are complex, involving both detailed historical analysis and voluminous Circuit case law that reveals a number of potentially relevant Circuit splits. It will therefore require more time of counsel to prepare a well-researched and polished petition worthy of this Court’s time. As well, the undersigned counsel is responsible for a majority of the direct appeals and post-conviction proceedings for the Federal Defenders of the Middle District of Georgia, Inc., with several briefing deadlines between now and the current certiorari deadline. These further demands on counsel’s time may prevent counsel from preparing a competent and concise petition. Wherefore, since the time within which to file a petition for writ of certiorari in this case will expire on Wednesday, November 5th, 2025, unless extended, Mr. Brown requests that an order be entered extending his time to file a petition for writ of certiorari by sixty days, to and including Friday, December 5th, 2025. Respectfully submitted this 24th day of October, 2025. O2, — JONATHAN R. DODSON Assistant Federal Defender Fl. Bar No. 50177 *Counsel of Record Federal Defenders of the Middle District of Georgia, Inc. 440 Martin Luther King, Jr. Boulevard, Suite 400 Macon, Georgia 31201 Tel: (478) 743-4747 Fax: (478) 207-3419 E-mail: