Whether an individual who did not actually commit three qualifying predicate offenses can assert an actual innocence exception to procedural bars on habeas corpus relief under the Armed Career Criminal Act

by this case. Counsel also have a number of competing deadlines in cases before this Court and other federal courts, as well as personal obligations for the upcoming holidays. A 60-day extension would provide counsel with adequate time to prepare the petition for filing. Wherefore, Mr. Lairy respectfully requests that an order be entered extending the time to file a petition for a writ of certiorari to and including February 7, 2026. Dated: November 26, 2025 Respectfully submitted, O.%e Andrew T. Tutt Counsel of Record ARNOLD & PORTER KAYE SCHOLER LLP 601 Massachusetts Avenue, NW Washington, DC 20001 (202) 942-5000 Counsel for Applicant Michael Lairy