UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY TO ANSWER

(SECOND REQUEST)

ANDREW P. GORDON, District Judge.

Petitioner Priscella Saintal, by counsel, moves this Court for the entry of Order extending the time within which she must file her Reply to Respondents' Answer by 30 days from May 21, 2018 to and including June 20, 2018. Saintal's request is based on the record in this case and the attached Points and Authorities. The state, by Senior Deputy Attorney General Victor-Hugo Schulze II, does not object to this request.

POINTS AND AUTHORITIES

1. Undersigned counsel filed her appearance on August 22, 2017, to represent Ms. Saintal (ECF No. 43).

2. This is Saintal's second request for an extension of time. This motion is not filed for the purposes of delay but in the interests of justice, as well as in the interests of Saintal.

3. Counsel's schedule and circumstances beyond her control have precluded her from meeting the current deadline of May 21, 2018. There are several issues counsel should discuss with Saintal before filing the Reply; counsel is in the process of setting up a meeting with Saintal. In addition, counsel is filing a petition next week, has a hearing the following week, and will file at least two other pleadings next week. Counsel is also preparing for oral argument in June.

4. Senior Deputy Attorney General Victor-Hugo Schulze II has no objection regarding her requested extension. This lack of objection does not constitute a waiver of any procedural defenses.

5. The requested extension is necessary for counsel to complete her review of the case and to draft and file the Reply to Answer. For these reasons, as well as the record in this case, Saintal respectfully asks this Court to grant her request to extend the time for filing an opposition by 30 days until June 20, 2018.

ORDER

IT IS SO ORDERED.