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SUPREME COURT OF THE UNITED STATES
STATE OF OKLAHOMA,
ON PETITION FOR A WRIT OF CERTIORARI TO THE
OKLAHOMA COURT OF CRIMINAL APPEALS
APPLICATION FOR A STAY OF EXECUTION
PENDING DISPOSITION OF PETITION FOR A WRIT
OF CERTIORARI TO THE OKLAHOMA COURT OF CRIMINAL APPEALS
TO: THE HONORABLE SONIA SOTOMAYOR, ASSOCIATE JUSTICE, UNITED
STATES SUPREME COURT
Petitioner Richard Glossip, a condemned prisoner in the State of Oklahoma, requests that
this Court stay his execution currently scheduled for 3:00 p.m. on Wednesday, September 29,
2015, until further order of this Court, in order to permit the consideration and disposition of his
petition for writ of certiorari.
Mr. Glossip invokes this Court's jurisdiction to stay his execution under 28 U.S.C. section
2101, and Rule 23 of the Rules of the Supreme Court of the United States.
REASONS FOR GRANTING A STAY
For a Circuit Justice to grant a stay of execution, a petitioner must show: 1) irreparable
injury if no stay is granted; 2) A "reasonable probability that four (4) members of the Court will
consider the issue [presented] sufficiently meritorious to grant certiorari," Graves v. Burnes, 405
U.S. 1201 (1972) (Powell, Circuit Justice), or a reasonable probability that a plurality of the
Court would grant relief on an original habeas petition; and, 3) a likelihood of success on the
merits. See Barefoot v Estelle, 463 U.S. 880, 893 (1983); see also Fare v. Michael C., 439 U.S.
1310 (1978) (Rehnquist, Circuit Justice). Petitioner meets these standards, as set forth in the
petition for writ of certiorari filed this day.
If no stay is granted, Mr. Glossip will suffer the most irreparable injury known to the law.
His petition illustrates why he is likely to prevail.
Wherefore, Mr. Glossip respectfully requests an Order staying his execution pending
consideration of his petition for writ of certiorari to the Oklahoma Court of Criminal Appeals.
Mark Olive, Esq.*
320 W. Jefferson Street
Tallahassee, FL 32301
Donald R. Knight, Esq.
7852 S. Elati Street, Suite 201
Littleton, CO 80120
Kathleen Lord. Esq.
1544 Race Street
Denver, CO 80206
* Counsel of Record
September 29, 2015
CERTIFICATE OF SERVICE
I CERTIFY the fore gong was served upon
313 NE 21st Street
Oklahoma City, Oklahoma 73105
by e-mail on September 29, 2015.