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

Court: District Court, D. Nevada Number: infdco20180724947 Visitors: 5
Filed: Jul. 20, 2018
Latest Update: Jul. 20, 2018
Summary: UNOPPOSED MOTION FOR EXTENSION OF TIME TO ANSWER REMAINING CLAIMS IN AMENDED PETITION FOR WRIT OF HABEAS CORPUS (ECF NO. 36) (SECOND REQUEST) RICHARD F. BOULWARE, II , District Judge . Respondents hereby move this Court for an extension of time of an additional sixty (60) days, up to and including September 18, 2018, within which to answer the remaining claims in the Amended Petition for Writ of Habeas Corpus. (ECF No. 36). This Motion is made pursuant to Fed. R. Civ. P. 6(b) and Rule 6-1 o
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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) (SECOND REQUEST)

Respondents hereby move this Court for an extension of time of an additional sixty (60) days, up to and including September 18, 2018, within which to answer the remaining claims in the Amended Petition for Writ of Habeas Corpus. (ECF No. 36). 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 second enlargement of time sought by Respondents and is brought in good faith and not for the purpose of delay.

DECLARATION OF HEIDI PARRY STERN

STATE OF NEVADA ss: COUNTY OF CLARK

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

1. I am an attorney licensed to practice law in the State of Nevada; qualified and admitted to practice before this Court; employed as a Chief Deputy Attorney General in the Office of the Nevada Attorney General; and pursuant to this employment, I have been assigned to represent Respondents in 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;

2. That the Answer to the Remaining Claims in the Amended Petition for Writ of Habeas Corpus is due to be filed July 20, 2018.

3. This extension is necessary due to my recently increased workload, occasioned by the retirement of one of the attorneys in our unit, as well as several upcoming deadlines in the Ninth Circuit, including unanticipated supplemental briefing in a death penalty appeal.

4. Respondents request 60 days to file their answer, up to and including September 18, 2018.

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

6. This is Respondents' second motion for enlargement of time to answer the remaining claims in the Amended Petition for Writ of Habeas Corpus.

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

FURTHER DECLARANT SAYETH NAUGHT.

APPROVED:

Source:  Leagle

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