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No. 17-646


             un  the Supreme Court of the Oniteb *tates


                     TERANCE  MARTEz  GAMBLE,  PETITIONER

                                       V.

                           UNITED STATES OF AMERICA


                      ON PETITION FOR A WRIT OF CERTIORARI
                      TO THE UNITED STATES COURT OF APPEALS
                           FOR THE ELEVENTH  CIRCUIT


              MOTION FOR  LEAVE TO PARTICIPATE IN ORAL ARGUMENT
                         AND FOR EXPANDED  ARGUMENT


    Pursuant to Supreme Court Rules 28.4 and 28.7, the State of Texas, on behalf of a 36-

State coalition of amici (collectively, the amici States), respectfully requests that the Court

expand the time allotted for oral argument in order to allow the undersigned ten minutes

of argument time. This case implicates the States' core sovereign interests in combating

crime and punishing those who offend their laws. As set out in the amici States' brief, those

interests are parallel to, yet also distinct from, those of the United States. See Abbate v.

United States, 359 U.S. 187, 195 (1959); Bartkus v. Illinois, 359 U.S. 121, 132 (1959). Amici

States are uniquely positioned to represent and defend their interests before this Court.

    The United States does not oppose expanding the argument time to allow for ten

minutes of argument by the amici States and a corresponding additional ten minutes of

argument time for petitioner. Counsel for petitioner indicated that he opposes this motion.


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