MOTION FOR ENLARGEMENT OF TIME FIRST REQUEST

AND ORDER THEREON

GLORIA M. NAVARRO, Chief District Judge.

Respondents, by and through counsel, Adam Paul Laxalt, Attorney General of the State of Nevada, hereby respectfully move this Court for an order granting a forty-five (45) day enlargement of time, to and including September 3, 2015, in which to file and serve their answer to the remaining claims of Wadsworth's petition.

This motion is based upon the provisions of Rule 6(b) of the Federal Rules of Civil Procedure and the attached Declaration of Counsel, as well as all other papers, documents, records, pleadings and other materials on file herein.

There have been no prior enlargements of Respondents' time to file said answer, and this motion is made in good faith and not for the purposes of delay.

IT IS SO ORDERED.

DECLARATION OF COUNSEL JEFFRY M. CONNER

I, JEFFREY M. CONNER, declare under penalty of perjury:

1. I am an Assistant Solicitor General employed by the Office of the Attorney General of the State of Nevada, and I make this declaration on behalf of Respondents' motion for enlargement of time in the above-captioned matter.

2. By this motion, I am requesting an enlargement of forty-five (45) days, to and including September 3, 2015, to file Respondents' answer to the remaining claims of Wadsworth's petition in compliance with this Court's order dated June 5, 2015. (ECF No. 50.) This is my first request for an enlargement with respect to this answer.

3. Since this Court ordered Respondents to answer Wadsworth's remaining claims, I have been busy working on other federal and state matters, including: Nevada v. Torres, Case No. 14A1064 (Supreme Court of the United States); Rudin v. Myles, 12-15362 (9th Cir.); Camp v. Neven, Case No. 13-15862 (9th Cir.); Elvik v. Baker, Case Nos. 13-17530 & 14-15126 (9th Cir.); Comstock v. Humphries, Case No. 14-15311 (9th Cir.); Gutierrez v. Williams, 2:10-cv-00109; Mack v. Baker, Case No. 3:12-cv-00104; Redeker v. Neven, 2:12-cv-00397; Chavez v. LaGrand, Case No. 3:13-cv-00548; Rico-Arreola v. Smith, Case No. 3:13-cv-00580; Lokken v. LeGrand, Case No. 3:13-cv-00608; Somee v. Hobbs, Case No. 2:13-cv-01190; Sahagun v. Williams, 2:14-cv-00539; and Bergna v. Baca, 15-EW-0014-1B (First Judicial District Court). Accordingly, Respondents respectfully request that this Court issue an order granting them an enlargement of forty-five (45) days, to and including September 3, 2015, to file their answer to Wadsworth's remaining claims.

4. I informed opposing counsel, Assistant Federal Defender Megan Hoffman, of my intention to seek an enlargement of time, and she indicated she has no objection to Respondents' request for additional time.

5. This motion for enlargement of time is made in good faith and not for the purpose of unduly delaying the ultimate disposition of this case

I declare under penalty of perjury that the foregoing is true and correct.