Filed: Jan. 06, 2020
Latest Update: Jan. 06, 2020
Summary: UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE ANSWER TO FIRST AMENDED PETITION FOR WRIT OF HABEAS CORPUS (ECF NO. 41) (FIRST REQUEST) RICHARD F. BOULWARE, II , District Judge . Respondents move this Court for an enlargement of time of 30 days from the current due date of January 2, 2020, up to and including February 3, 2020, in which to file their Answer to the remaining claims in the First Amended Petition for Writ of Habeas Corpus (ECF No. 41). This Motion is made pursuant to Fed. R. C
Summary: UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE ANSWER TO FIRST AMENDED PETITION FOR WRIT OF HABEAS CORPUS (ECF NO. 41) (FIRST REQUEST) RICHARD F. BOULWARE, II , District Judge . Respondents move this Court for an enlargement of time of 30 days from the current due date of January 2, 2020, up to and including February 3, 2020, in which to file their Answer to the remaining claims in the First Amended Petition for Writ of Habeas Corpus (ECF No. 41). This Motion is made pursuant to Fed. R. Ci..
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UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE ANSWER TO FIRST AMENDED PETITION FOR WRIT OF HABEAS CORPUS (ECF NO. 41) (FIRST REQUEST)
RICHARD F. BOULWARE, II, District Judge.
Respondents move this Court for an enlargement of time of 30 days from the current due date of January 2, 2020, up to and including February 3, 2020, in which to file their Answer to the remaining claims in the First Amended Petition for Writ of Habeas Corpus (ECF No. 41). This Motion is made pursuant to Fed. R. Civ. P. 6(b) and Rule 6-1 of the Local Rules of Practice and is based upon the attached declaration of counsel. This is the first enlargement of time sought by Respondents to file this answer, and the request is brought in good faith and not for the purpose of delay.
DATED: January 2, 2020.
Submitted by:
AARON D. FORD
Attorney General
By: /s/ Jessica Perlick
Jessica Perlick (Bar. No. 13218)
Senior Deputy Attorney General
DECLARATION OF JESSICA PERLICK
STATE OF NEVADA
ss:
COUNTY OF CLARK
I, JESSICA PERLICK, being first duly sworn under oath, depose and state as follows:
1. I am an attorney licensed to practice law in all courts within the State of Nevada, and am employed as a Senior Deputy Attorney General in the Office of the Nevada Attorney General. I am assigned to represent Respondents in Justin James Edmisten v. Dwight Neven, et al., Case No. 2:15-cv-00952-RFB-NJK, and as such, have personal knowledge of the matters contained herein.
2. This Motion is made in good faith and not for the purpose of delay.
3. The Answer to the First Amended Petition is currently due January 2, 2020.
4. I am unable with due diligence to timely complete the Answer herein.
5. I was sick and out of the office for multiple days in December, which impacted a number of previously scheduled deadlines, including Ninth Circuit Court of Appeals briefing in Bolin v. Baker, 15-99004; Rogers v. Dzurenda, 19-17158; and Hogan v. Gittere, 18-99004; all of which are now due between now and the end of February. During the time I was in the office, I was also providing coverage for court appearances while others were on holiday leave, including hearings in Valentine v. State, C304810; Valentine v. State, A767205; Ferm v. Nevada Dep't of Parole and Probation, A789688; and State v. Sember, C334919. The combination of these factors greatly impacted my time and ability to complete the Answer, resulting in this request.
6. I have contacted counsel for the Petitioner, and he does not oppose this request for an extension.
7. Based on the foregoing, I respectfully request an enlargement of time of 30 days, up to and including February 3, 2020, to file the Answer to the First Amended Petition.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on this Thursday, January 2, 2020.
IT IS SO ORDERED.
