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.