Campbell v. Henry

Filing 83

ORDER granting 82 MOTION for Extension of Time to File Traverse filed by Valerie E. Campbell. Extension to and including 4/3/2014 in which to file a taverse. Signed by Judge Charles R. Breyer on 1/10/2014. (beS, COURT STAFF) (Filed on 1/13/2014)

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1 2 3 4 5 6 ERIK G. BABCOCK, SBN 172517 LAW OFFICES OF ERIK BABCOCK 1212 Broadway, Suite 726 Oakland, CA 94612 (510) 452-8400 Tel. (510) 452-8405 Fax Attorney for Petitioner VALERIE CAMPBELL 7 8 9 IN THE UNITED STATES DISTRICT COURT 10 NORTHERN DISTRICT OF CALIFORNIA 11 12 VALERIE CAMPBELL, 13 No. CV-06-2225 CRB Petitioner-Appellant, APPLICATION FOR EXTENSION OF TIME TO FILE TRAVERSE AND FOR LATE FILING OF MOTION FOR EXTENSION OF TIME 14 15 16 17 v. GLORIA HENRY, Respondent-Appellee. ) 18 19 20 I, ERIK G. BABCOCK, declare as follows: 1. Ms. Campbell filed a pro se federal habeas petition in 2006. The court granted 21 respondent’s motion to dismiss on timeliness grounds. I was subsequently appointed 22 to represent her in the Ninth Circuit. The Ninth Circuit found her petition was timely 23 and remanded to this court. After several extensions, my traverse is due today, 24 January 3, 2014. 25 26 27 2. I have exercised diligence but I am not able to file the traverse today. 3. I have had an associate actively working on this case, researching issues and 28 APPLICATION FOR EXTENSION OF TIME Campbell v. Henry, No. 06cv2225 CRB 1 2 reviewing the record. . 4. 3 I have previously spoken with respondent’s counsel about this case and he indicated that he would have no objections to, or be prejudiced by, any requested extensions 4 of time. 5 6 6. file a traverse. 7 8 9 I am requesting an extension of 90 days, to and including April 3, 2014 in which to 7. My client is currently in state custody serving a sentence of 25 to life for murder, followed by two consecutive life sentences for two attempted murder convictions. 10 I declare under penalty of perjury that the foregoing is true and correct. Executed this 4d 11 12 day of October, 2013 at Oakland, California. /S Erik Babcock ERIK G. BABCOCK Counsel for Petitioner 13 14 15 SO ORDERED. 16 17 DATED: January 10, 2014 Honorable Charles R. Breyer UNITED STATES DISTRICT JUDGE 18 19 20 21 22 23 24 25 26 27 28 APPLICATION FOR EXTENSION OF TIME Campbell v. Henry, No. 06cv2225 CRB - 2 -

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