Whether equitable tolling principles apply to statutory filing deadlines when a litigant experiences an extraordinary and unforeseeable family medical emergency

Arguments Supporting the Extension The requested extension is justified by several factors. First, on Thursday, November 6, 2025, I was required to take my mother to the emergency room due to a sudden and severe escalation of hip pain. My mother had previously sought medical attention for this condition, consulting with her physician in or around the summer of 2025. The physician, considering her age and symptoms, diagnosed the issue as bone-related and prescribed a calcium supplement regimen to be followed for one year, with a scheduled follow-up examination. My mother diligently adhered to this medical advice, taking the prescribed medication as directed, and experienced initial improvement in her symptoms. The emergency room visit revealed that her pain was attributable to two distinct underlying causes, which had not been previously identified. The attending physician recommended immediate surgical intervention, and the first surgery was performed on November 7, 2025, Following the procedure, it was explained that addressing both medical issues simultaneously would have posed significant risks, necessitating a second surgery in the coming weeks or months. This sequence of events was entirely unexpected, as my mother had actively sought treatment and complied with all medical recommendations. Up until the emergency, she had not exhibited any alarming symptoms beyond the initial pain. The need for multiple surgeries and the discovery of additional underlying causes were unforeseen, despite her diligence in managing her health. These developments required my immediate and sustained attention, directly impacting my ability to prepare and file the petition for writ of certiorari within the prescribed timeframe. I have acted diligently in all respects, but the extraordinary and unforeseeable nature of my mother's medical emergency has created circumstances beyond my control, necessitating this request for an extension. Second, the case involves complex questions regarding the collective application of equitable tolling to statutory deadlines (primarily focusing on the context of documented illness and pandemic-related disruptions). Third, Petitioner is continuing to research and analyze relevant legal authorities, including Supreme Court and circuit precedent, alongside ongoing efforts to assemble pertinent evidence to ensure the petition is comprehensive and persuasive. Fourth, the record is extensive and requires careful review to accurately present the factual and procedural history. Fifth, the issues raised are of exceptional importance to pro se litigants and the uniform Page 4 of 6 OCR_Page_