deepened a circuit split on whether a plea agreement is binding on federal prosecutors in districts other than the one in which it is entered. See United States v. Maxwell, 118 F. 4th 256 n.11 (2nd Cir. 2024) (“recogniz[ing] that circuits have been split on this issue’). 3. Undersinged counsel was just retained yesterday, on January 14, 2024. Due to case-related and other reasons, additional time is necessary and warranted for counsel to research the decisional conflicts, and prepare a clear, concise, and comprehensive petition for certiorari for the Court’s review. The press of other matters makes the submission of the petition difficult absent an extension, especially because Petitioner engaged undersigned counsel just this week to represent her in the Supreme Court. For example, Counsel is scheduled to commence a multi-defendant trial on March 3, 2025, United States v. Diego Sanudo Sanchez Chocron, Southern District of Florida, case number 24-cr-20155-RAR(s). In addition, counsel is due to file a reply brief in this Court in Elizabeth Peters Young v. United States, case number 24-571, shortly after the Goverment files its response on January 22, 2025. Therefore, because of the importance of this issue, and the need to draft a meaningful petition on such short notice, undersigned counsel is respectfully requesting an additional 45 days in the matter to file until April 10, 2025. 2 DOJ-OGR-00000030