Turner v. Foulk et al

Filing 16

Order by Hon. Vince Chhabria granting 15 Motion for Extension of Time to File Response/Reply.(knm, COURT STAFF) (Filed on 7/3/2014)

ORIGINAL
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ORIGINAL

Robert J. Beles Bar No. 41993
Paul McCarthy Bar No. 139497
One Kaiser Plaza, Suite 2300
Oakland, California 94612-3642
Tel No. [phone]
Fax. No. [phone]
Attorneys for Petitioner

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United States District Court

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San Francisco Courthouse

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Northen District of California

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No. 3:13-cv-05718-VC

VINCENT TURNER,

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v.

Petitioner,

FRED FOULK, Warden, High Desert State
Prison

MOTION AND DECLARATION OF GOOD
CAUSE FOR EXTENSION OF TIME TO
FILE TRAVERSE AND REPLY
MEMORANDUM

Respondent,
PEOPLE OF THE STATE OF CALIFORNIA,
Real Party in Interest.

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MOTION AND DECLARATION OF GOOD CAUSE FOR
EXTENSION OF TIME TO FILE TRAVERSE AND REPLY MEMORANDUM
I, Paul McCarthy, declare under penalty of perjury as follows:
1. I am the attorney for petitioner in this case.
2. Respondent’s Answer was filed on June 5, 2014. Utilizing the deadline set forth in
the Order to Show Cause, the Traverse is due on July 5, 2014.
3. Counsel requests an extension of 30 days, so that the traverse and reply will be due
on Monday, August 4, 2014.
4. Petitioner has not previously requested any extensions of time to file the traverse and

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Motion and Declaration of Good Cause for Extension
of Time to File Traverse and Reply Memorandum

ORIGINAL
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ORIGINAL

reply memorandum.

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5. Within the last 30 days, I prepared and filed two federal petitions for writ of habeas

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corpus (Moran and Gonzalez). I also filed a traverse for Fernandez and an opening brief in the

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First Appellate District (Jimenez). Because of the work on these items, I will be unable to

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prepare and file the traverse and reply memorandum by the due date.

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6. On June 27, 2014, my office contacted Margo Yu, the listed attorney of record for
respondent. Ms. Yu indicated that she had no objection to the request.
I declare under penalty of perjury that the facts stated in this declaration are true and
correct. Executed in Oakland, California, on Friday, June 27, 2014.

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Paul McCarthy
Attorney for Petitioner

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Date: July 3, 2014

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NO

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Motion and Declaration of Good Cause for Extension
of Time to File Traverse and Reply Memorandum

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