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Burgon v. Neven, 2:14-cv-01128-RFB-CWH. (2018)

Court: District Court, D. Nevada Number: infdco20180523f84 Visitors: 13
Filed: May 21, 2018
Latest Update: May 21, 2018
Summary: UNOPPOSED MOTION FOR EXTENSION OF TIME TO ANSWER REMAINING CLAIMS IN AMENDED PETITION FOR WRIT OF HABEAS CORPUS (ECF NO. 36) RICHARD F. BOULWARE, II , District Judge . Respondents hereby request an extension of time of an additional sixty (60 including July 20, 2018, within which to answer the remaining claims in the Amended Petition for Writ of Habeas Corpus. (ECF No. 36 This motion is based on the accompanying Declaration of Counsel. DECLARATION OF HEIDI PARRY STERN I, HEIDI PARRY STE
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UNOPPOSED MOTION FOR EXTENSION OF TIME TO ANSWER REMAINING CLAIMS IN AMENDED PETITION FOR WRIT OF HABEAS CORPUS (ECF NO. 36)

Respondents hereby request an extension of time of an additional sixty (60 including July 20, 2018, within which to answer the remaining claims in the Amended Petition for Writ of Habeas Corpus. (ECF No. 36

This motion is based on the accompanying Declaration of Counsel.

DECLARATION OF HEIDI PARRY STERN

I, HEIDI PARRY STERN, being first duly sworn under oath, depose and declare as follows

1. That I an attorney licensed to practice law in the State of Nevada; that I am qualified and admitted to practice before this Court; and that I am employed as a Deputy Attorney General in the Office of the Nevada Attorney General;

2. That, pursuant to my duties as a Chief Deputy Attorney General, I have been assigned to represent Respondents in the matter of Clay Burgon v. D.W. Neven, et al., 2:14-cv-01128-RFB-CWH and, as such, have personal knowledge of the matters contained herein;

3. That the Answer to the Remaining Claims of the Amended Petition for Writ of Habeas Corpus is due to be filed May 21, 2018.

4. This extension is necessary as I have been working to finalize supplemental briefing in the Ninth Circuit in the case of Marquez v. E.K. McDaniel, et al., Case No. 17-15154, which will be argued in front of the Ninth Circuit on June, 6, 2018. I have also been preparing, and will be filing next week, an Answering Brief in the Ninth Circuit in the capital case of Bolin v. Renee Baker, et al., Case No. 15-99004.

5. Respondents request 60 days to file their reply, up to and including July 20, 2018.

6. I have contacted opposing counsel, and she has no objection to this request for extension.

7. This is Respondents' first motion for enlargement of time to answer the remaining claims in the amended petition.

8. This Motion for enlargement of time is made in good faith and not for the purpose of delay.

Source:  Leagle

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