Bradley v. Attorney General of the State of Nevada

Filing 37

ORDER Granting 36 Motion to Extend Time to File Amended Motion for Discovery until 2/12/2016. Signed by Judge Richard F. Boulware, II on 1/20/16. (Copies have been distributed pursuant to the NEF - MMM)

RENE L. VALLADARES
Federal Public Defender
Nevada State Bar No. 11479
MELANIE GAVISK
Assistant Federal Public Defender
Colorado State Bar No. 41380
411 E. Bonneville, Ste. 250
Las Vegas, Nevada 89101
[phone]
[phone] (Fax)
[e-mail]
Attorneys for Petitioner Carl Bradley
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
CARL BRADLEY,
Petitioner,
v.
ATTORNEY GENERAL OF THE STATE
OF NEVADA, et al.,

Case No. 2:13-cv-01196-APG-GWF
UNOPPOSED MOTION FOR
EXTENSION OF TIME TO FILE
AMENDED MOTION FOR
DISCOVERY

Respondents.

Carl Bradley moves this Court for an extension to time of 30 days from
January 13, 2016, until February 12, 2016, to file an Amended Motion for
Discovery. This motion is based upon the attached points and authorities and the
record in this case.

DECLARATION OF MELANIE GAVISK
1.

On September 30, 2015, this Court appointed the Federal Public

Defender to represent Mr. Bradley in this case. ECF 33. After the conflict check was
completed, I (Melanie Gavisk) entered my appearance as counsel for Mr. Bradley on
December 14, 2015. ECF 35. An amended motion for discovery is currently due on
January 13, 2013, per this Court’s November 10, 2015 order. ECF 34. For the
reasons described below, I request an additional 30 days, until February 12, 2016,
to file the amended discovery motion.
2.

In preparation for filing an amended discovery motion, I have collected

and reviewed the state court record and the record in this case. I have contacted
prior counsel for their files, but prior counsel have indicated they do not have files
for Mr. Bradley. Most recently, I contacted Jeffery Connor, the Deputy Attorney
General assigned to this case. He indicated to me that pursuant to this Court’s prior
order granting discovery, see ECF 10, the State may disclose additional materials to
Mr. Bradley.
3.

If the State discloses additional materials, that will impact what

materials, if any, Mr. Bradley requests in an amended discovery motion. Mr.
Bradley therefore requests an additional 30 days to filed an amended discovery
motion.

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4.

On January 12, 2016, I contacted Deputy Attorney General Jeffrey

Connor about this motion for an extension of time. Mr. Connor indicated he has no
opposition to this motion.
5.

I therefore ask this Court to grant my request for an extension of time

of 30 days to file the amended discovery motion and order the amended discovery
motion to be filed no later than February 12, 2016.
Dated this 13th day of January, 2016.

Respectfully submitted,
RENE L. VALLADARES
Federal Public Defender

/s/ Melanie Gavisk
MELANIE GAVISK
Assistant Federal Public Defender

IT IS SO ORDERED:

__________________________
RICHARD F. BOULWARE, II
United States District Judge
DATED this 20th day of January, 2016.

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CERTIFICATE OF SERVICE
The undersigned hereby certifies that he is an employee in the office of the
Federal Public Defender for the District of Nevada and is a person of such age and
discretion as to be competent to serve papers.
That on January 13, 2016, he served a true and accurate copy of the foregoing
to the United States District Court, who will e-serve the following addressee:
Jeffrey M. Connor
Deputy Attorney General
Nevada Attorney General’s Office
100 North Carson Street
Carson City, NV 89701

/s/ Adam Dunn

An Employee of the Federal Public
Defender, District of Nevada

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