Whether the use of force against a handcuffed arrestee during a foot chase constitutes an objectively unreasonable seizure in violation of the Fourth Amendment's prohibition on excessive force

including the proper characterization of force used against a handcuffed arrestee, the interplay between disputed video evidence and Rule 12(b)(6) dismissal, and the application of qualified immunity, additional time is required to complete a fully developed petition for certiorari. The record is substantial and includes multiple briefs, bodyworn camera footage, and detailed qualified-immunity analysis 3. Counsel for Petitioner is presently responsible for extensive litigation in federal and state courts, including overlapping appellate deadlines, dispositivemotion filings, and ongoing discovery matters. These professional! obligations have limited the time available to prepare the petition for writ of certiorari. Additional time is therefore necessary to ensure that the constitutional questions are thoroughly and accurately presented. 4. Petitioner intends to ask this Court to grant review on important federal questions concerning (1) whether the force used constituted deadly force under 3 Exhibit C Order Denying Appellants Petition for Rehearing clearly established law, (2) whether the district court erred in resolving factual disputes and weighing video evidence at the Rule 12(b)(6) stage, and (3) whether the Fifth Circuit’s qualified-immunity analysis conflicts with the standards applied in other circuits. These issues carry national significance and warrant careful review before presentation to the Court. 5. For the foregoing reasons, Petitioner respectfully requests that this Court grant a sixty (60) day extension, to and including February 15, 2026, within which to file her petition for writ of certiorari. Respectfully submitted this 7th day of December 2025. /s/ Alfonso Bafidis Alfonso Bafidis SBN: 24122795 BAFIDIS LAW INJURY FIRM, P.L.L.C. P.O. Box 792, Helotes, Texas 78023 Telephone: 210-942-6633 E: Attorney for Petitioner Case 5:24-cv-00399-XR Document 26 Filed 11/15/24 Page1of1 EXHIBIT A IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION SAMANTHA LEE-ANN SEALEY, Plaintiff SA-24-CV-00399-XR -VsARTURO MANCIAS, SAN ANTONIO POLICE DEPARTMENT, CITY OF SAN ANTONIO, OR LPR LN LLLP LOO Defendants FINAL JUDGMENT This action was considered by the Honorable Xavier Rodriguez, and the following Judgment is rendered. It is hereby ORDERED, ADJUDGED, and DECREED that: Plaintiff Samantha Lee-Ann Sealey shall take nothing by her claims against Defendants Arturo Mancias and the City of San Antonio. Defendant San Antonio Police Department is DISMISSED from this action. Plaintiff's claims are DISMISSED WITH PREJUDICE. It is so ORDERED. SIGNED this 15th day of November, 2024. XAVIER RODRIGUEZ UNITED STATES DISTRICT JUDGE Case: 24-50998 Document: 69-1 Page:1 Date Filed: 08/19/2025 EXHIBIT B Gnited States Court of Appeals for the Fifth Circuit United States Court of Appeals Fifth Circuit FILED No. 24-50998 August 19, 2025 Summary Calendar Lyle W. Cayce Clerk SAMANTHA LEE-ANN SEALEY, versus ARTURO MANCIAS; CITY OF SAN ANTONIO, Defendants— Appellees. Appeal from the United States District Court for the Western District of Texas USDC No. 5:24-CV-399 Before DAVIS, GRAVES, and WILSON, Circuit Judges. PER CURIAM:* Samantha Lee-Ann Sealey paid a late-night visit to a 7-Eleven in San Antonio, Texas. A police officer with a warrant for Sealey’s arrest met her in the parking lot with handcuffs. When the officer turned his back, she made a break for it. In a foot chase, the officer drew close and Sealey fell face-first onto the pavement, her hands still cuffed behind her back. Sealey says that * This opinion is not designated for publication. See 5TH Cir. R. 47.5. Case: 24-50998 Document: 69-1 Page:2 Date Filed: 08/19/2025 No. 24-50998 she was shoved and brought claims under 42 U.S.C. § 1983 for violations of her Fourth Amendment rights. The district court concluded that the officer was entitled to qualified immunity and dismissed Sealey’s complaint for failure to state a claim. Sealey appeals. We AFFIRM