Farnum v. LeGrand

Filing 93

ORDER Granting 92 Motion to Extend Time for extension of time to file response to 91 Opening Brief. Responses due by 6/19/2023. Signed by Judge Andrew P. Gordon on 4/18/2023. (Copies have been distributed pursuant to the NEF - LOE)

Case 2:13-cv-01304-APG-BNW Document 93 Filed 04/18/23 Page 1 of 3
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AARON D. FORD
Attorney General
Katrina A. Lopez (Bar. No. 13394)
Deputy Attorney General
State of Nevada
Office of the Attorney General
555 E. Washington Ave., Ste. 3900
Las Vegas, NV 89101
[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,

UNOPPOSED MOTION FOR
ENLARGEMENT OF TIME
TO FILE RESPONSE TO OPENING BRIEF
ON REMAND (ECF NO. 91)

vs.

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ROBERT LEGRAND, et al.,

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Respondents.

(FIRST REQUEST)

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Respondents move this Court for an enlargement of time of 62 days from the current due date of

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April 18, 2023, up to and including June 19, 2023, in which to file their Response to Farnum’s Opening

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Brief on Remand. ECF No. 91. This Motion is made pursuant to FED. R. CIV. P. 6(b) and Rule 6-1 of the

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Local Rules of Practice and is based upon the attached declaration of counsel.

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This is the first enlargement of time sought by Respondents and is brought in good faith and not
for the purpose of delay.
DATED April 18, 2023

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Submitted by:

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AARON D. FORD
Attorney General

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By:

/s/ Katrina A. Lopez
Katrina A. Lopez
Deputy Attorney General

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Case 2:13-cv-01304-APG-BNW Document 93 Filed 04/18/23 Page 2 of 3
DECLARATION OF KATRINA A. LOPEZ

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I, Katrina A. Lopez, being first duly sworn under oath, depose and state as follows:

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1.

I am an attorney licensed to practice law in all courts within the State of Nevada and am

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employed as a Deputy Attorney General in the Office of the Nevada Attorney General. I have been

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assigned to represent Respondents in John Michael Farnum v. Robert LeGrand, et al., Case No. 2:13-

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cv-01304-APG-BNW, and as such, have personal knowledge of the matters contained herein.

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2.

This Motion is made in good faith and not for the purpose of delay

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3.

The Response to Farnum’s Opening Brief is currently due on Tuesday, April 18, 2023.

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4.

Respondents have been unable with due diligence to timely complete the Response.

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5.

In the past few months, Respondents filed a motion to dismiss filed February 2, 2023

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(Jerry E. Johnson v. Calvin Johnson, et al., Case No. 2:22-cv-00642-JAD-DJA); a reply in support of a

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motion to dismiss filed February 9, 2023 (Corry Alexis Hawkins. v. Calvin Johnson, et al., Case No. 2:

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20-cv-01852-CDS-VCF); an answer filed March 9, 2023 (Delbert Charles Cobb v. E.K. McDaniels, et

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al., Case No. 3:15-cv-00172-MMD-CSD); a response in support of answer filed March 23, 2023

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(Christopher Ryan Martin v. Tom Lawson, et al., Case No. 2:22-cv-00850-APG-VCF); an answer filed

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March 24, 2023 (Cory O’Neal Brewer v. William Reubart, et al., Case No. 3:20-cv-00396-MMD-CLB);a

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response to motion to strike filed April 7, 2023 (Christopher Ryan Martin v. Tom Lawson, et al., Case

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No. 2:22-cv-00850-APG-VCF); and various responses in state post-conviction cases.
6.

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Additionally, Respondents are reshuffling cases to accommodate various deadlines due

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to losing 3 Senior Deputy Attorney Generals and 5 Deputy Attorney Generals within a 15-month period.

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As a result, Respondents need additional time to complete the Response.
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Respondents communicated with counsel for Farnum regarding this extension and she

does not object to this request.
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Based on the foregoing, Respondents respectfully request an enlargement of time of 62

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days from the current due date, April 18, 2023, up to and including June 19, 2023, to file our Response

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to Farnum’s Opening Brief.

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///

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///

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Case 2:13-cv-01304-APG-BNW Document 93 Filed 04/18/23 Page 3 of 3
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I declare under penalty of perjury that the foregoing is true and correct.

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Executed on April 18, 2023.

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/s/ Katrina A. Lopez
Katrina A. Lopez (Bar. No. 13394)
Deputy Attorney General

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IT IS SO ORDERED:

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________________________________
UNITED STATES DISTRICT COURT
April 18, 2023
Dated: __________________________

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