Petition for Writ of Certiorari — Roger Jones, Jr., Petitioner v. United States
Supreme Court briefDec 9, 2017
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CASE NO. _________
IN THE SUPREME COURT OF THE UNITED STATES
UNITED STATES OF AMERICA,
Plaintiff/Respondent,
vs.
ROGER JONES, JR.,
Defendant/Petitioner.
___________________________________________________________________________________
MOTION FOR EXTENSION OF TIME TO FILE PETITION
COMES now the Petitioner, Roger Jones, Jr., by and through appointed counsel, Robert L.
Thomas, and pursuant to Supreme Court Rules 13 and 21, moves this Honorable Court for an Order
extending the time to file his Petition for Writ of Certiorari in this matter by one (1) day and in support
of which would respectfully state unto the Court as follows:
1.
This matter was originally before the Sixth Circuit Court of Appeals pursuant to an
appeal from the U.S. District Court for the Western District of Tennessee, Eastern Division, in USA v.
Roger Jones, Jr., Dkt. No. 15-cr-10072.
2.
On August 29, 2017, the Sixth Circuit rendered a decision affirming the district court's
decision denying the Petitioner's Motion to Suppress. Accordingly, the Petition for Writ of Certiorari
was due to to be filed on or before November 27, 2017.
3.
Counsel for the Petitioner recently learned that the Supreme Court has switched to an
electronic filing system. As such, counsel was required to register for the electronic filing system and
received his registration information on November 28, 2017.
4.
Counsel submits that his unfamiliarity with the Court's new electronic filing system is
what lead to the Petition being filed untimely, and said mistake was committed inadvertently. Counsel
further submits that neither party will be prejudiced as a result of the timing of the Petition’s filing.
Accordingly, counsel respectfully requests that the Court grant the Petitioner a one (1) day extension of
time in which to file the Petition for Writ of Certiorari in this cause and accept the filing thereof.
WHEREFORE, PREMISES CONSIDERED, the Petitioner respectfully requests that the
Court grant him a one (1) day extension of time in order to file the Petition for Writ of Certiorari for the
reasons set forth above.
Respectfully submitted,
/s/ Robert L. Thomas
Robert L. Thomas (#026629)
Attorney for Petitioner Roger Jones, Jr.
423 North Highland Ave.
Jackson, Tennessee 38301
(731) 422-6895
rthomas@rlthomaslaw.com
CASE NO. _____________
IN THE SUPREME COURT OF THE UNITED STATES
UNITED STATES OF AMERICA,
Plaintiff/Respondent,
vs.
ROGER JONES, JR.,
Defendant/Petitioner.
______________________________________________________________________________
PROOF OF SERVICE
______________________________________________________________________________
I, Robert L. Thomas, do hereby declare that on this date, November 28, 2017, as required
by Supreme Court Rule 29, I have served the enclosed MOTION FOR EXTENSION OF TIME
TO FILE PETITION on each party to the above proceeding or that party's counsel, and on every
other person required to be served, by depositing an envelope containing the above documents in
the United States mail properly addressed to each of them and with first-class postage prepaid to
the address(es) as follows:
Taylor M. Eskridge
Assistant United States Attorney
109 S. Highland Ave., Suite 300
Jackson, TN 38301
Solicitor General of the United States
Room 5614, Department of Justice
950 Pennsylvania Ave., N. W.
Washington, DC 20530-0001
I declare under penalty of perjury that the foregoing is true and correct on this the 28th
day of November, 2017.
Respectfully submitted,
/s/ Robert L. Thomas
Robert L. Thomas (#026629)
Attorney for Petitioner Roger Jones, Jr.
423 North Highland Avenue
Jackson, TN 38301
(731) 422-6895
rthomas@rlthomaslaw.com
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