I have filed the following motion today with the United States Supreme Court, requesting an extension of time to file an application for writ of certiorari (basically a write of review over the decision of the Montana Supreme Court). I am filing this request because to date I am still having my ability to prepare such an application obstructed, primarily by my own attorney, William Hooks, who will not send me the legal documents I need to prepare the application...
It is just a question of whether the High Court will provide me the time to overcome these delays...
IN THE UNITED STATES SUPREME COURT
Ron Glick, ) Cause No.
Petitioner, ) Motion For Extension of Time To File an
) Application For Writ of Certiorari
State of Montana, )
Comes now Petitioner to move of the Court for an extension of time to file an application for writ of certiorari, and to wit:
The above-referenced cause was decided on or about February 19, 2009, by the Montana Supreme Court (attached hereafter as Exhibit A), yet the state court failed to address two of the principle arguments raised in the appeal and several lesser issues raised within the arguments it did address. Petitioner sought of his counsel, William Hooks, to file a motion for reconsideration, but said counsel delayed responding to such a request until early March, 2009, at which time he declared his intent to refuse to file such. Petitioner sought to seek an extension of time from the state court on or about March 12, 2009, but the state court issued a remittur on or about March 17, 2009, and applied this retroactively to Petitioner’s motion to reject its filing. Further, Petitioner’s attorney has failed to provide copies of records and transcripts requested by Petitioner necessary to file for writ of certiorari with this Court, making preparation and filing of an application within the time allowed impossible.
Based upon the foregoing, it is presently not possible for Petitioner to prepare a proper application for writ of certiorari and the interests of justice would best be served by this Court granting Petitioner a ninety (90) day extension to overcome the obstacles presently preventing Petitioner from making a timely filing.
WHEREFORE, Petitioner respectfully requests of the Court for a ninety (90) day extension of time to prepare and file an application for writ of certiorari.
Petitioner does hereby attest, under penalty of perjury, that the foregoing is true and correct to the best of his ability to present, and that this is respectfully submitted on the 15th day of April, 2009.