Whether a local government's categorical ban on firearm possession in public parks violates the Second Amendment right to bear arms for self-defense

No question identified. : 1. The United States Court of Appeals for the Fourth Circuit rendered its decision on August 27, 2025. Exhibit 1. This Court has jurisdiction under 28 U.S.C. §1254(1). 2. Fairfax County, Virginia, prohibits possession of a firearm in its public parks, which consist of 23,632 acres of mostly wooded land. Plaintiffs, who have permits to carry handguns, are thereby prohibited from carrying firearms for selfdefense. The Fourth Circuit rejected plaintiffs’ Second Amendment challenge on the basis that four preschools exist on a tiny portion of the parklands. 3. In the court below, appellants were represented by Stephen P. Halbrook, Counsel of Record, and Earl N. Mayfield, III. Among other matters, Mr. Halbrook has a pre-existing briefing deadline in Wolford v. Lopez, No. 24-1046 (U.S.). Mr. Mayfield has a pre-existing commitment to file a complaint and preliminary injunction in the Southern District of Mississippi; a summary judgment reply in Davis v. United States, No. 1:24-cv-364 (Fed Cl.); a motion to dismiss in SWARG Opportunity Zone, LLC v. American Hindu Coalition, No. 125-cv-2812 (D.D.C.); and a motion to dismiss reply in Debebe v. St. Michael Church, No. 2025-CAB-5826 . (D.C. Sup. Ct.). 4. The firm Cooper & Kirk was retained on October 29, 2025, to assist in the preparation of this case. Counsel for Cooper & Kirk have several pre-existing obligations over the next month, including presenting argument in the Ninth Circuit on November 18, 2025, in Sanchez v. Bonta, No. 24-5566, and briefing deadlines in several cases, including in Calce v. City of New York, No. 25-861 (2d Cir.), Anderson v. Raoul, No. 25-2642 (7th Cir.), and Escher v. Noble, No. 25-cv10389 (D. Mass.). 5. Applicants thus request a modest extension for counsel to determine whether to file a petition for certiorari, and, if so, to prepare a petition that fully addresses the complex and far-reaching issues raised by the decision below and frames those issues in a manner that will be most helpful to this Court. WHEREFORE, for the foregoing reasons, Applicants request that an extension of time to and including December 26, 2025, be granted within which Applicants may file a petition for a writ of certiorari. Respectfully submitted, STEPHEN P. HALBROOK Counsel of Record 3925 Chain Bridge Road, Suite 403 Fairfax, VA 22030 (703) 352-7276 protell@aol.com October 30, 2025