Wadsworth v. Williams et al

Filing 53

ORDER Granting 52 Motion to Extend Time to Answer/Respond. Attorney General of the State of Nevada answer due 9/3/2015; Brian Williams answer due 9/3/2015. Signed by Chief Judge Gloria M. Navarro on 7/23/15. (Copies have been distributed pursuant to the NEF - MMM)

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ADAM PAUL LAXALT
Attorney General
JEFFREY M. CONNER
Assistant Solicitor General
Office of the Attorney General
100 North Carson Street
Carson City, Nevada 89701-4717
[phone]
[e-mail]
Attorney for Respondents

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IN THE UNITED STATES DISTRICT COURT

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FOR THE DISTRICT OF NEVADA

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MICHAEL B. WADSWORTH,

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Petitioner,

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vs.
BRIAN E. WILLIAMS, et al.,

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Respondents.

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Case No. 2:13-cv-00401-GMN-GWF
MOTION FOR
ENLARGEMENT OF TIME
(FIRST REQUEST)

AND ORDER THEREON

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Respondents, by and through counsel, Adam Paul Laxalt, Attorney General of the State of

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Nevada, hereby respectfully move this Court for an order granting a forty-five (45) day enlargement of

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time, to and including September 3, 2015, in which to file and serve their answer to the remaining claims

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of Wadsworth’s petition.

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This motion is based upon the provisions of Rule 6(b) of the Federal Rules of Civil Procedure

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and the attached Declaration of Counsel, as well as all other papers, documents, records, pleadings and

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other materials on file herein.

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There have been no prior enlargements of Respondents’ time to file said answer, and this
motion is made in good faith and not for the purposes of delay.
RESPECTFULLY SUBMITTED this 20th day of July, 2015.

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ADAM PAUL LAXALT
Attorney General

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By:
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/s/ Jeffrey M. Conner
JEFFREY M. CONNER
Assistant Solicitor General

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IT IS SO ORDERED.

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________________________________
Gloria M. Navarro, Chief Judge
United States District Court

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DATED: 07/23/2015.

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ADAM PAUL LAXALT
Attorney General
JEFFREY M. CONNER
Assistant Solicitor General
Office of the Attorney General
100 North Carson Street
Carson City, Nevada 89701-4717
[phone]
[e-mail]
Attorney for Respondents

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IN THE UNITED STATES DISTRICT COURT

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FOR THE DISTRICT OF NEVADA

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MICHAEL B. WADSWORTH,

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Petitioner,
vs.
BRIAN E. WILLIAMS, et al.,

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Respondents.

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Case No. 2:13-cv-00401-GMN-GWF
DECLARATION OF COUNSEL
JEFFRY M. CONNER

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I, JEFFREY M. CONNER, declare under penalty of perjury:
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I am an Assistant Solicitor General employed by the Office of the Attorney General of the

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State of Nevada, and I make this declaration on behalf of Respondents’ motion for enlargement of time in

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the above-captioned matter.

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2.

By this motion, I am requesting an enlargement of forty-five (45) days, to and including

September 3, 2015, to file Respondents’ answer to the remaining claims of Wadsworth’s petition in
compliance with this Court’s order dated June 5, 2015. (ECF No. 50.) This is my first request for an

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enlargement with respect to this answer.
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Since this Court ordered Respondents to answer Wadsworth’s remaining claims, I have

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been busy working on other federal and state matters, including: Nevada v. Torres, Case No. 14A1064

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(Supreme Court of the United States); Rudin v. Myles, 12-15362 (9th Cir.); Camp v. Neven, Case No. 13-3-

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15862 (9th Cir.); Elvik v. Baker, Case Nos. 13-17530 & 14-15126 (9th Cir.); Comstock v. Humphries,
Case No. 14-15311 (9th Cir.); Gutierrez v. Williams, 2:10-cv-00109; Mack v. Baker, Case No. 3:12-cv-

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00104; Redeker v. Neven, 2:12-cv-00397; Chavez v. LaGrand, Case No. 3:13-cv-00548; Rico-Arreola

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v. Smith, Case No. 3:13-cv-00580; Lokken v. LeGrand, Case No. 3:13-cv-00608; Somee v. Hobbs, Case

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No. 2:13-cv-01190; Sahagun v. Williams, 2:14-cv-00539; and Bergna v. Baca, 15-EW-0014-1B (First

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Judicial District Court). Accordingly, Respondents respectfully request that this Court issue an order

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granting them an enlargement of forty-five (45) days, to and including September 3, 2015, to file their
answer to Wadsworth’s remaining claims.

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4.

I informed opposing counsel, Assistant Federal Defender Megan Hoffman, of my

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intention to seek an enlargement of time, and she indicated she has no objection to Respondents’

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request for additional time.

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5.

This motion for enlargement of time is made in good faith and not for the purpose of

unduly delaying the ultimate disposition of this case
I declare under penalty of perjury that the foregoing is true and correct.

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/s/ Jeffrey M. Conner
JEFFREY M. CONNER

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CERTIFICATE OF SERVICE

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I certify that I am an employee of the Office of the Attorney General and that on this 20th day of

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July, 2015, I served a copy of the foregoing MOTION FOR ENLARGEMENT OF TIME (FIRST

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REQUEST), by U.S. District Court CM/ECF electronic filing to:

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MEGAN C. HOFFMAN
Assistant Federal Public Defender
411 East Bonneville Avenue, Suite 250
Las Vegas, Nevada 89101
/s/ Bonnie L. Hunt

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