Campbell v. Henry

Filing 75

ORDER granting 74 MOTION for Extension of Time to File Response/Reply filed by Valerie E. Campbell. Traverse due by 4/8/2013. Signed by Judge Charles R. Breyer on 1/9/2013. (beS, COURT STAFF) (Filed on 1/9/2013)

Case3:06-cv-02225-CRB Document74 Filed01/08/13 Page1 of 2

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ERIK G. BABCOCK, SBN 172517
LAW OFFICES OF ERIK BABCOCK
1212 Broadway, Suite 726
Oakland, CA 94612
[phone] Tel.
[phone] Fax
Attorney for Petitioner
VALERIE CAMPBELL

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IN THE UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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VALERIE CAMPBELL,

No. CV-06-2225 CRB

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ORDER
Petitioner-Appellant,

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v.

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APPLICATION FOR EXTENSION
OF TIME TO FILE TRAVERSE

GLORIA HENRY,

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Respondent-Appellee.
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I, ERIK G. BABCOCK, declare as follows:

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1.

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Ms. Campbell filed a pro se federal habeas petition in 2006. The court granted
respondent’s motion to dismiss on timeliness grounds. I was subsequently appointed

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to represent her in the Ninth Circuit. The Ninth Circuit found her petition was timely
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and remanded to this court. After several extensions, my traverse is due today,

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January 7, 2013.

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2.

I am requesting approximately 3 months in which to file a traverse. I have exercised
diligence but I am still not able to file the traverse by today, as currently scheduled.

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APPLICATION FOR EXTENSION OF TIM E
Campbell v. Henry, No. 06cv2225 CRB

Case3:06-cv-02225-CRB Document74 Filed01/08/13 Page2 of 2

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I have finished reviewing the record in this case. However, I have not been able to
finish my investigation and research. I am set for trial in a murder case in Hayward

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next Monday, January 14, 2013, in People v. Johnson, Alameda No. H52787. I am
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also set for trial in a serious child molest case on January 17, 2013, in People v.

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McCarthy, Alameda No., in which my client is facing many consecutive life

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sentences if convicted. I have been busy preparing for trial in these cases.

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I have previously spoken with respondent’s counsel about this case and understood
him to say that he would have no objection to, or be prejudiced by, any requested

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extensions.

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followed by two consecutive life sentences for two attempted murder convictions.

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My client is currently in state custody serving a sentence of 25 to life for murder,

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I therefore request approximately 3 months, to an including April 8, 2013.

I declare under penalty of perjury that the foregoing is true and correct. Executed this 7st

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day of January, 2013 at Oakland, California.
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/S Erik Babcock
ERIK G. BABCOCK
Counsel for Petitioner

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R NIA
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Signed: January 9, 2013

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APPLICATION FOR EXTENSION OF TIM E
Campbell v. Henry, No. 06cv2225 CRB

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