Habeas Corpus - September 2011 Second Circuit Orders

No COA's during September.  I believe this means that, for the first time since I started tracking orders in the Second Circuit on a monthly basis, the court did not grant a single COA during a month.

This comes on the heels of the month with the highest number of COA's.

I guess it all averages out in the end.  And what's the average?  I'd say probably between 2 and 3 COA's per month.