UNOPPOSED MOTION FOR ENLARGEMENT OF TIME (SECOND REQUEST)

ANDREW P. GORDON, District Judge.

Respondents, by and through counsel, Aaron D. Ford, 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 28, 2019, in which to file and serve their response to Hill's opposition to motion to dismiss.

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 has been one prior enlargement of Respondents' time to file said reply, and this motion is made in good faith and not for the purposes of delay.

DECLARATION OF COUNSEL

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.

2. By this motion, I am requesting a forty-five (45) day enlargement of time, to and including March 28, 2019, to respond to Hill's opposition to motion to dismiss. This is my second request for enlargement.

3. The response is currently due February 11, 2019.

4. Since my first enlargement, I have been involved in defending federal and state petitions, including Atkins v. Filson (2:02-cv-1348-JCM-PAL) (death penalty); Grow v. Dzurenda (3:17-cv-0637-MMD-WGC); Guzman v. Nevada Attorney General (3:17-cv-0515-HDM-CBC); Hidalgo v. LeGrand (3:16-cv-0618-MMD-WGC); Hidalgo v. Baca (3:18-cv-0153-MMD-CBC); McClain v. Williams (2:17cv-0753-RFB-NJK); McNair v. Baca (3:18-cv-0308-HDM-CBC); and numerous state habeas actions and extraditions. I was out of the office January 31 to February 1, 2019, and February 5-8, 2019, on annual leave and to work in other locations. In addition, I was recently promoted to Chief Deputy Attorney General, which has required addressing numerous new administrative functions. As such, I request a forty-five (45) day enlargement of time, to and including March 28, 2019, to respond to Hill's opposition to motion to dismiss.

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.

6. I contacted the assigned Federal Public Defender, Kimberly Sandberg, who has no objection to this enlargement.

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.