Bradley v. Attorney General of the State of Nevada

Filing 84

ORDER granting 83 Motion to Extend Time to Reply re: 76 Motion to Dismiss. Replies due by 7/27/2018. Signed by Judge Richard F. Boulware, II on 7/19/2018. (Copies have been distributed pursuant to the NEF - MMM)

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ADAM PAUL LAXALT
Attorney General
JEFFREY M. CONNER (Bar. No. 11543)
Assistant Solicitor General
State of Nevada
Office of the Attorney General
100 North Carson Street
Carson City, NV 89701-4717
[phone] (phone)
[phone] (fax)
[e-mail]
Attorneys for Respondent

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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CARL BRADLEY,

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Case No. 2:13-cv-01196-RFB-GWF

Petitioners,

MOTION FOR ENLARGEMENT OF TIME
(FIRST REQUEST)

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vs.

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ATTORNEY GENERAL OF THE STATE OF
NEVADA, et al.,

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Respondents.
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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 twenty-one (21) day enlargement

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of time, to and including July 27, 2018, in which to file and serve their reply.

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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 enlargement of Respondents’ time to file said reply, and this motion is
made in good faith and not for the purposes of delay.
RESPECTFULLY SUBMITTED this 5th day of July, 2018.
ADAM PAUL LAXALT
Attorney General
By: /s/ Jeffrey M. Conner
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JEFFREY M. CONNER (Bar. No. 11543)
Assistant Solicitor General
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ADAM PAUL LAXALT
Attorney General
JEFFREY M. CONNER (Bar. No. 11543)
Assistant Solicitor General
State of Nevada
Office of the Attorney General
100 North Carson Street
Carson City, NV 89701-4717
[phone] (phone)
[phone] (fax)
[e-mail]
Attorneys for Respondent

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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CARL BRADLEY,

Case No. 2:13-cv-01196-RFB-GWF

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Petitioners,

DECLARATION OF COUNSEL

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vs.

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ATTORNEY GENERAL OF THE STATE OF
NEVADA, et al.,

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Respondents.

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I, JEFFREY M. CONNER, declare under penalty of perjury:

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1.

I am an Assistant Solicitor General in the Office of the Attorney General of the State of

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

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above-captioned matter.

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2.

Respondents reply in support of the motion to dismiss is due July 6, 2018. By this motion,

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I am requesting an enlargement of twenty-one (21) days, to and including July 27, 2018. This is

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Respondents’ first request for an enlargement to file the reply.

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3.

Since Bradley filed his response to the motion to dismiss, I have been busy working on

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numerous other federal matters, including completing an answering brief in Redeker v. Neven, No. 17-

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16917 (9th Cir.), which is due on July 9, 2018. Additionally, I have numerous impending deadlines

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over the next two weeks in other federal habeas corpus matters, many of which have also been

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extended. In light of the foregoing, Respondents respectfully request that this Court issue an order

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granting them an enlargement of twenty-one (21) days to, and including, July 27, 2018, to file a reply in

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support of the motion to dismiss.

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4.

I contacted opposing counsel, Assistant Federal Defender Amelia Bizzaro, and she

indicated she has no objection to Respondents’ request for additional time.
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.

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By: /s/ Jeffrey M. Conner
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JEFFREY M. CONNER (Bar. No. 11543)
Assistant Solicitor General

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IT IS SO ORDERED:

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________________________________
RICHARD F. BOULWARE, II
UNITED STATES DISTRICT JUDGE
DATED this 19th day of July, 2018.

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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, State of Nevada, and that

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on the 5th day of July, 2018, I caused to be served a copy of the foregoing MOTION FOR

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ENLARGEMENT OF TIME (FIRST REQUEST), by U.S. District Court CM/ECF Electronic Filing

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to:

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Amelia L. Bizzaro
Assistant Federal Public Defender
411 East Bonneville Ave, Suite 250
Las Vegas, NV 89101

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_/s/ Amanda White__________
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