MOTION FOR ENLARGEMENT OF TIME (FIRST REQUEST

RICHARD F. BOULWARE, II, 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-six (46) day enlargement of time, to and including June 17, 2019, in which to file and serve their response to Willing's 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.

There have been no prior enlargements 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

I, AMANDA C. SAGE, hereby state, 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 Division, 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-six (46) day enlargement of time, to and including June 17, 2019, to respond to Willing's amended petition. This is Respondents' first enlargement request.

3. The response is currently due May 2, 2019.

4. Since this Court ordered a response, I unexpectedly inherited several large matters due to staff reassignments and turnover. This included a motion to dismiss in Leonard v. Baker (death penalty, Case No. 2:99-cv-360, filed March 20, 2019), a motion to dismiss in Leonard's state postconviction action (filed 4/25/19), and a Ninth Circuit Answering Brief in Rosas v. Filson (Case No. 17-16839, filed April 12, 2019). As each matter had received enlargements under prior counsel, I had to turn my attention to those matters. Additionally, I researched and wrote a petition for writ of certiorari in Turner v. Baker (filed April 15, 2019); and researched and responded to miscellaneous pleadings in Snow v. Baker (death penalty, Case No. 15-99012, filed April 10, 2019); Alcaraz v. Williams, 2:13-cv-818 (filed 4/22/19); and Adkisson v. Neven, Case No. 2:14-cv-1934 (filed 4/23/19) Finally, I spent significant time reviewing resumes and conducting interviews for three vacant positions that we filled in the unit in March and April. I also conducted trainings for each of these new hires. Due to these responsibilities, I did not have adequate time to fully review and respond to Willing's petition.

5. Additionally, I will be out of the office on pre-arranged leave from April 26, 2019 through May 6, 2019. I unfortunately was not able to get to Willing's filing before my absence. An additional 46 days will allow me to properly review and respond to this petition on my return.

6. On April 25, 2019, I emailed Lisa Rasmussen, the appointed counsel representing Willing in this action, about my enlargement request. Ms. Rasmussen indicated she had no objection to Respondents' request for enlargement.

7. 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.

IT IS SO ORDERED.