Unopposed Motion for Enlargement of Time (First Request)

RICHARD F. BOULWARE, II, District Judge.

Petitioner, by and through counsel, M. Greg Mullanax, hereby respectfully move this court for an order granting a thirty (30) day enlargement of time, to and including February 1, 2017, in which to file and serve her reply to the State's answer to her amended 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.

This is the first request for an enlargement with respect to the reply to the State's answer to Rudin's first amended petition. This motion is made in good faith and not for the purpose of delay.

IT IS SO ORDERED.

DISTRICT OF NEVADA

I, M. Greg Mullanax, declare under penalty of perjury:

1. I am petitioner Margaret Rudin's attorney, and I make this declaration on behalf of Petitioner's motion for enlargement of time in the above-captioned matter.

2. By this motion, I am requesting an enlargement of thirty (30) days, to and including February 1, 2017, to file a response to the State's answer to petitioner's amended petition. This is my first request for an enlargement of time with respect to the reply to the State's answer.

3. Since the State filed its answer after two extensions of time, petitioner's reply is due right after the holiday season, which would require me to change my plans in order to comply with a deadline of January 2, 2017.

4. I communicated with opposing counsel, Jeffrey M. Conner. He indicated that he has no opposition to the 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.