Whether the Eleventh Circuit's summary judgment ruling improperly interpreted the constitutional issues presented by the Applicant

to present an effective petition. 5. The requested extension is the first such request in this matter. Good cause exists for the extension because of the change in counsel and the complexity of the constitutional issues presented. 6. Additional time is necessary to ensure that the petition is thoroughly researched, carefully drafted, and fully protective of Applicant’s rights. 7. This request is made in good faith and not for the purpose of delay. 8. The extension would not exceed the maximum 60-day extension authorized by Supreme Court Rule 13.5 and 28 U.S.C. § 2101(). 9. Applicant has advised counsel for Respondent of this request. Respondent does not oppose the application. For these reasons, Applicant respectfully requests that an order be entered extending the time in which to petition for a writ of certiorari by 60 days, to and including January 26, 2026. See Sup. Ct. R. 13.5. Respectfully submitted, /s/ Jay Alan Sekulow JAY ALAN SEKULOW JORDAN A. SEKULOW STUART J. ROTH CHRISTINA COMPAGNONE BENJAMIN P. SISNEY GEOFFREY R. SURTEES WALTER M. WEBER NATHAN J. MOELKER AMERICAN CENTER FOR LAw & JUSTICE 201 Maryland Ave. NE Washington, DC 20002 Telephone: 202-546-8890 Email: sekulow@aclj.org