should suffice.” Campos v. LeFevre, 825 F.2d 671, 676 (2d Cir.1987). But even that low bar is not met here. Our precedent follows the general rule that an untimely notice of appeal may not be construed as a motion for an extension of time. Pettibone v. Cupp, 666 F.2d 333, 335 (9th Cir.1981); see also Campbell v. White, 721 F.2d 644, 646 & n. 3 (8th Cir.1983) (gathering extra-circuit cases for the same proposition). We see no logical reason to treat motions for a COA as an exception to this well-established rule, and no circuit case to date has done so. But even if we were to consider such a possibility, Washington’s motion for a COA here did not indicate that it was intended to serve as a motion for an extension of time. See Bordallo v. Reyes, 763 F.2d 1098, 1101-02 (9th Cir.1985) (<HOLDING>). The motion for a COA does not mention
holding that a court must construe whether a motion however styled is appropriate for the relief requested recognizing appellant must raise issue on appeal that more relief than requested in motion was improperly granted in summaryjudgment order holding same with respect to motion styled simply second motion for summary judgment without containing amended in title holding that  109g2 does not apply when the creditor seeking relief in the first case received the requested relief holding that if appellant preserves legal sufficiency complaint in motion for new trial new trial is all the relief appellate court can give because that is all the relief appellant requested in trial court