Farnum v. LeGrand

Filing 69

ORDER Granting 68 Unopposed Motion to Extend Time (Second Request) Re: 53 Second Amended Petition for Writ of Habeas Corpus. Respondents' answer due 6/28/2019. Signed by Judge Andrew P. Gordon on 6/7/2019. (Copies have been distributed pursuant to the NEF - SLD)

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AARON D. FORD
Attorney General
JEFFREY M. CONNER (Bar. No. 11543)
Deputy 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 Respondents

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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JOHN MICHAEL FARNUM,

Case No. 2:13-cv-01304-APG-BNW

Petitioner,

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vs.

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ROBERT LeGRAND, et al.,

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UNOPPOSED MOTION FOR
ENLARGEMENT OF TIME (SECOND
REQUEST)

Respondents.

ORDER

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Respondents, by and through counsel, Aaron D. Ford, Attorney General of the State of Nevada,

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hereby respectfully move this Court for an order granting a twenty-one (21) day enlargement of time, to

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and including June 28, 2019, in which to file and serve their answer.

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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 has been one prior enlargement 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 7th day of June, 2019.
AARON D. FORD
Attorney General
By: /s/ Jeffrey M. Conner
JEFFREY M. CONNER (Bar. No. 11543)
Deputy Solicitor General

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AARON D. FORD
Attorney General
JEFFREY M. CONNER (Bar. No. 11543)
Deputy 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 Respondents

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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JOHN MICHAEL FARNUM,

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Case No. 2:13-cv-01304-APG-BNW

Petitioner,

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vs.

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ROBERT LeGRAND, et al.,

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DECLARATION OF COUNSEL

Respondents.

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

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1.

I am a Deputy Solicitor General employed by the Nevada Attorney General’s Office, and I

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make this declaration on behalf of Respondents’ motion for enlargement of time in the above-captioned

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matter.

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2.

Respondents’ answer to the remaining claims of the Mr. Farnum’s petition is currently due

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June 7, 2019. By this motion, I am requesting an enlargement of twenty-one (21) days, to and including

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June 28, 2019, to file Respondents’ answer. This is my second request for an enlargement of time regarding

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the answer.

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3.

Since Respondents initial request for an extension, I have remained exceedingly busy

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working on numerous state and federal matters. At current, in addition to working on this case and my other

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regular assignments within the Attorney General’s Office, I am in the process of preparing for an en banc

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argument in Ross v. Williams, No. 16-16533 (9th Cir.), which is scheduled for June 19, 2019. As a result

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of the foregoing, I need additional time to complete the answer to the petition while balancing that

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obligation with the need to adequately prepare for the argument in Ross. Accordingly, Respondents
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respectfully request that this Court issue an order granting them an enlargement of twenty-one (21) days,

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to and including June 28, 2019, to file the answer to the second-amended petition.

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4.

I informed opposing counsel, Lisa Rasmussen and Michael Schwarz, of my intention to

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seek an enlargement of time by e-mail. Both Mr. Schwarz and Ms. Rasmussen responded and indicated

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they have no objection to Respondents’ 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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By: /s/ Jeffrey M. Conner
JEFFREY M. CONNER (Bar. No. 11543)
Deputy Solicitor General

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ORDER

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IT IS SO ORDERED.

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Dated this ____ day of ___________________________, 2019

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DISTRICT COURT DISTRICT JUDGE
UNITED STATES JUDGE
Dated: June 7, 2019.

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