Rocky Mountain Bank -v- Google, Inc.

Filing 201

Rocky Mountain Bank -v- Google, Inc.

Doc. 201 Att. 1

1 EDMUND G. BROWN JR. Attorney General of the State of California 2 DANE R. GILLETTE Chief Assistant Attorney General 3 GERALD A. ENGLER Senior Assistant Attorney General 4 PEGGY S. RUFFRA Supervising Deputy Attorney General 5 NANETTE WINAKER, State Bar No. 186025 Deputy Attorney General 455 Golden Gate Avenue, Suite 11000 6 San Francisco, CA 94102-7004 Telephone: [phone] Fax: [phone] Email: [e-mail] 8 9 Attorneys for Respondent 10 11 12 13 14 15 16 17 18 19 20 21 I, NANETTE WINAKER, declare under penalty of perjury: I am a Deputy Attorney General for the State of California and am responsible for the v. ROSEANNE CAMPBELL, Warden, Respondent. CARLOS CHICO, Petitioner, C 05-01282 MJJ DECLARATION OF NANETTE WINAKER IN SUPPORT OF APPLICATION FOR EXTENSION OF TIME TO FILE RESPONSE IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

22 preparation and filing of a response to this Court's Order to Show Cause in this habeas proceeding. 23 This Court's Order to Show Cause was filed May 16, 2007, and ordered respondent to file

24 an answer within 60 days or by July 15, 2007. On July 23, 2007, this Court granted my application 25 requesting an additional 60 days in which to file an answer; the current due date is September 13, 26 2007. I am unable to prepare and file a response by September 13, 2007, for the reasons set forth 27 below. 28 In the past 60 days, I have filed respondent's briefs in the California Courts of Appeal in
Dec of NW In Support Of Application For EOT

- Chico v. Campbell, Warden - C 05-01282 MJJ 1
Dockets.Justia.com

1 People v. Mazza (A115237), People v. Ray (A111688), and People v. Givens (A115487). I have 2 also filed a supplemental brief in People v. Tran (H030306). In addition, I was out-of-state and out 3 of the office between July 18, 2007 ­ July 24, 2007, and August 20, 2007 ­ August 24, 2007. 4 I am currently preparing a respondent's brief in People v. Bryant (A114925), and will be

5 out of the office on a prepaid vacation between September 12, 2007, and September 21, 2007. I 6 must also prepare an answer in a previously assigned case. See e.g., Saldana v. Scribner (C 067 02126 JW (PR)). 8 I have contacted petitioner's counsel, Benjamin Ramos, and he has stipulated to the

9 requested extension of time. 10 Accordingly, I request that the Court grant respondent an extension of sixty days, to and

11 including November 12, 2007, in which to file the response. 12 13 14 15 16 17 18 19 20 21 22 23 24 NW:er
20105581.wpd

Dated: September 24, 2007 Respectfully submitted, EDMUND G. BROWN JR. Attorney General of the State of California DANE R. GILLETTE Chief Assistant Attorney General GERALD A. ENGLER Senior Assistant Attorney General PEGGY S. RUFFRA Supervising Deputy Attorney General

/s/ Nanette Winaker NANETTE WINAKER Deputy Attorney General Attorneys for Respondent

25 26 27 28

SF2007401458

Dec of NW In Support Of Application For EOT

- Chico v. Campbell, Warden - C 05-01282 MJJ 2