Guerrero v. Williams et al
ORDER Granting 89 Motion to Extend Time re Re: 87 Motion to Dismiss. Responses due by 2/19/2018. Signed by Judge Jennifer A. Dorsey on 1/8/2018. (Copies have been distributed pursuant to the NEF - ADR)
Case 2:13-cv-00328-JAD-CWH Document 89 Filed 01/05/18 Page 1 of 3
David K. Neidert, Esq.
Nevada State Bar No. 4342
316 California Ave. #420
Reno, NV 89509
Telephone: (775) 423-4455
Attorney for Petitioner
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
PABLO RAMON GUERRERO,
BRIAN E. WILLIAM, et al.
UNOPPOSED MOTION FOR
ECF No. 89
Petitioner, PABLO RAMON GUERRERO by and through counsel, DAVID K.
NEIDERT, respectfully asks this Court for a 45-day enlargement, up to and including February
19, 2018, in which to file the Response to the Motion to Dismiss.
This is the first request for an Enlargement made since the Respondents filed their
Motion to Dismiss. This request is based on the following declaration by undersigned counsel.
Respectfully submitted this 5th day of January, 2018.
/s/ David K. Neidert
Attorney at Law
Case 2:13-cv-00328-JAD-CWH Document 89 Filed 01/05/18 Page 2 of 3
Declaration by David K. Neidert
I, David K. Neidert, do declare under the pains and penalties of perjury that this
Declaration is true:
I am the attorney for the Petitioner in this case.
2. I was appointed as counsel for Mr. Guerrero on November 1, 2017. At the time I was
appointed to represent Mr. Guererro, I was preparing for jury trial in United States v.
Edward Smith, 3:cv-15-61-HDM-WGC, which was scheduled to commence on
December 11, 2017. As a result, I was concentrating my time on that endeavor.
3. The record I received includes the transcripts from an eight-day jury trial, two sentencing
hearings, and nine evidentiary hearings involving both Mr. Guerrero and his co-
defendants. Obviously, this totals thousands of pages of documents., all of which require
4. I have also recently accepted appointment as counsel in three other federal habeas corpus
cases, some of which have records similar in length to this case.
5. Today I spoke with Heather Procter, the Senior Deputy Attorney General assigned this
case. Ms. Procter graciously agreed to my request for an enlargement.
This is the first request for an Enlargement I have sought with respect to this motion and
it is not brought for purposes of delay or any other improper purpose.
Respectfully submitted this 5th day of January, 2017.
/s/ David K. Neidert
DAVID K. NEIDERT
Counsel for Petitioner
Good cause appearing, the unopposed
motion to extension [ECF No. 89] is
GRANTED. Plaintiff has until 2/19/18 to
respond to the motion to dismiss.
_ __ _ _ _
U.S. District Judge Jennifer Dorsey
e Jennifer D s
January 8, 2018
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