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West v. Williams, 2:15-cv-01504-LDG-NJK. (2017)

Court: District Court, D. Nevada Number: infdco20170202f53 Visitors: 13
Filed: Jan. 27, 2017
Latest Update: Jan. 27, 2017
Summary: MOTION FOR ENLARGEMENT OF ADAM PAUL LAXALT LLOYD D. GEORGE , 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 March 16, 2017, in which to file and serve their response to West's amended petition for writ of habeas corpus. This motion is based upon the provisions of Rule 6(b) of the Federal rules of civil Proced
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MOTION FOR ENLARGEMENT OF ADAM PAUL LAXALT

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 March 16, 2017, in which to file and serve their response to West's amended petition for writ of habeas corpus.

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 enlargement of Respondents' time to file said response, and this motion is made in good faith and not for the purposes of delay.

DECLARATION OF COUNSEL

STATE OF NEVADA :ss CARSON CITY )

I, HEATHER D. PROCTER, hereby states, based on personal knowledge and/or information and belief, that the assertions of this declaration are true:

1. I am a Senior Deputy Attorney General employed by the Attorney General's Office of the State of Nevada in the Bureau of Criminal Justice, Post-Conviction Unit, 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 a forty-five (45) day enlargement of time, to and including March 16, 2017, to respond to West's amended petition for writ of habeas corpus. This is my first request for enlargement.

3. The answer is currently due January 30, 2017.

4. Since this Court's order, I have been involved in defending federal and state petitions, including but not limited to Adams v. Filson (2:98-cv-1441-KJD-PAL) (death penalty); Atkins v. Filson (2:02-cv-1348-JCM-PAL) (death penalty); Blake v. Filson (3:09-cv-0327-RCJ-WGC) (death penalty); Crump v. Filson (2:07-cv-0492-APG-CWH) (death penalty); Duda v. Williams (2:16-cv-2108-JAD-VCF); Hammons v. Williams (2:14-cv-1902-JAD-GWF); Harlan v. Williams (2:15-cv-0799-JAD-PAL); Lisle v. Filson (2:03-cv-1005-JCM-CWH) (death penalty); Miranda-Rivas v. Wickham (3:16-cv-0663-MMD-VPC); Mosby v. Baker (3:14-cv-0251-MMD-WGC); Mosby v. Baker (2:13-cv-1625-JAD-GWF); Myers v. Filson (3:14-cv-0082-MMD-VPC); Robins v. Baker (2:99-cv-0412-LRH-PAL) (death penalty); Stubbs v. Baca (state court); Taylor v. Myles (3:13-cv-0035-MMD-VPC); and Winn v. Baker (3:13-cv-0669-LRH-WGC). In addition to time off during the Christmas and New Year's holidays, I was out of the office for a work conference January 11-13th. I will be out of the office February 7-20, 2017, on annual leave. I have also been training a new deputy in my division who started January 3, 2017. As such, I request a forty-five (45) day enlargement of time, to and including March 16, 2017, to answer West's second-amended petition.

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.

Pursuant to 28 U.S.C. § 1746, Declarant herein certifies, under penalty of perjury, that the foregoing is true and correct.

ORDER

IT IS SO ORDERED.

Source:  Leagle

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