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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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,

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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

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v.
GLORIA HENRY,
Respondent-Appellee.
)

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I, ERIK G. BABCOCK, declare as follows:
1.

Ms. Campbell filed a pro se federal habeas petition in 2006. The court granted

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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 3, 2014.
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2.

I have exercised diligence but I am not able to file the traverse today.

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I have had an associate actively working on this case, researching issues and

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

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reviewing the record. .
4.

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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

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of time.

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file a traverse.

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I am requesting an extension of 90 days, to and including April 3, 2014 in which to

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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.

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I declare under penalty of perjury that the foregoing is true and correct. Executed this 4d
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day of October, 2013 at Oakland, California.
/S Erik Babcock
ERIK G. BABCOCK
Counsel for Petitioner

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SO ORDERED.

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DATED: January 10, 2014
Honorable Charles R. Breyer
UNITED STATES DISTRICT JUDGE

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

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