IN THE

SUPREME COURT OF THE UNITED STATES

__________________

No.
__________________
RICHARD GLOSSIP,
Petitioner,
vs.
STATE OF OKLAHOMA,
Respondent.

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.

JURISDICTION
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.
CONCLUSION
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.
Respectfully submitted,
Mark Olive, Esq.*
320 W. Jefferson Street
Tallahassee, FL 32301
850-224-0004
Donald R. Knight, Esq.
7852 S. Elati Street, Suite 201
Littleton, CO 80120
2

303-797-1645
Kathleen Lord. Esq.
1544 Race Street
Denver, CO 80206
303-321-7902.
* Counsel of Record
September 29, 2015
CERTIFICATE OF SERVICE
I CERTIFY the fore gong was served upon
Scott Pruitt
Jennifer Miller
Attorney General
313 NE 21st Street
Oklahoma City, Oklahoma 73105
jennifer.miller@oag.ok.gov
by e-mail on September 29, 2015.

_/s/_Olive__________________________