Bradley v. Attorney General of the State of Nevada

Filing 88

ORDER granting 86 Motion to Extend Time to Reply re: 76 Motion to Dismiss. Replies due by 8/1/2018. Signed by Judge Richard F. Boulware, II on 8/9/2018. (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
(SECOND 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 five (5) day enlargement of time,

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to and including August 1, 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 one 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 26th 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.

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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.
2.

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Respondents reply in support of the motion to dismiss is due July 27, 2018. By this

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motion, I am requesting an enlargement of five (5) days, to and including August 1, 2018. This is

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Respondents’ second request for an enlargement to file the reply.
3.

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While preparing the reply in this matter, I discovered that Bradley had inadvertently

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filed the wrong declaration in support of his opposition to the motion to dismiss. After informing

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opposing counsel of the discrepancy, Bradley filed a corrected image. ECF No. 85. In addition to the

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fact that I have numerous filing deadlines in various state and federal matters over the next few days, I

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need additional time to adequately review the declaration and complete the reply.

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Accordingly,

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Respondents respectfully request that this Court issue an order granting them an enlargement of five (5)

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days to, and including, August 1, 2018, to file a reply in support of the motion to dismiss.

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4.

Although opposing counsel, Assistant Federal Defender Amelia Bizzaro, is currently out

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of the office, her legal assistant, Jessica Pillsbury, informed me that they do not oppose Respondents’

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request for additional time.

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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

APPROVED:
DATED this 9th day of August, 2018.

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__________________________
RICHARD F. BOULWARE, II
United States District Judge

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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 26th day of July, 2018, I caused to be served a copy of the foregoing MOTION FOR

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

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Filing 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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