Bradford v. Baker
Filing
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ORDER Granting 99 Motion to Extend Time to File Exhibits in Support of 98 Answer to Amended Habeas Petition. Deadline: 4/1/2019. Signed by Judge Richard F. Boulware, II on 3/27/2019. (Copies have been distributed pursuant to the NEF - SLD)
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AARON D. FORD
Attorney General
Natasha M. Gebrael (Bar. No. 14367)
Deputy Attorney General
State of Nevada
Office of the Attorney General
555 E. Washington Ave., #3900
Las Vegas, NV 89101
(702) 486-2625 (phone)
(702) 486-2377 (fax)
NGebrael@ag.nv.gov
Attorneys for Respondents
UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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JULIUS BRADFORD,
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Petitioner,
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vs.
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WILLIAM GITTERE, et al.,
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Respondents.
Case No. 2:13-cv-01784-RFB-GWF
UNOPPOSED MOTION FOR
ENLARGEMENT OF TIME
TO FILE EXHIBITS IN SUPPORT OF
RESPONDENTS’ ANSWER TO
BRADFORD’S SECOND AMENDED
PETITION
(FIFTH REQUEST)
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Respondents move this Court for an enlargement of time of 7 days, up to and including April 1,
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2019, in which to file their Index of Exhibits in Support of Respondents’ Answer to Bradford’s Second
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Amended Petition for Writ of Habeas Corpus. This Motion is made pursuant to Fed. R. Civ. P. 6(b) and
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Rule 6-1 of the Local Rules of Practice and is based upon the attached affidavit of counsel.
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This is the fifth enlargement of time sought by Respondents and is brought in good faith and not
for the purpose of delay.
DATED March 25, 2019
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Submitted by:
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AARON D. FORD
Attorney General
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By: /s/ Natasha M. Gebrael
NATASHA M. GEBRAEL (Bar. No. 14367)
Deputy Attorney General
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Page 1 of 3
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DECLARATION OF NATASHA M. GEBRAEL
STATE OF NEVADA
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) ss:
COUNTY OF CLARK )
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I, NATASHA M. GEBRAEL, 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 Julius Bradford v. William Gittere, et al., Case No. 2:13-cv-01784-
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RFB-GWF, and as such, have personal knowledge of the matters contained herein.
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The Response to the Second Amended § 2254 Petition (ECF No. 67) is currently due on
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March 25, 2019. I timely filed my response, but am requesting a brief extension of time in which to file
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the accompanying Index of Exhibits.
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4.
I have been unable with due diligence to timely file the Index, which contains a total of
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580 exhibits. Due to the large number of exhibits, it is taking a significant amount of time to individually
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compress the exhibits to comply with the file-size restrictions, and break the total exhibits into the
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appropriate volume sizes. And, because one of our legal assistants was recently transferred to a new unit,
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the two remaining assistants are not only assisting me with the compression of the Index, but currently
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covering all administrative duties for our entire unit. In light of these concerns, I am requesting a brief
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enlargement of time in which to file the Index.
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5.
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has no objection.
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My office has contacted opposing counsel, Jeremy Baron, regarding this request, and he
Based on the foregoing, I respectfully request an enlargement of time of 7 days, up to and
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including April 1, 2019, to file the Index of Exhibits in support of Respondent’s Answer. This is my fifth
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request for an extension in this case, but the first request for extension in terms of the Index of Exhibits.
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I declare under penalty of perjury that the foregoing is true and correct.
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Executed on March 25, 2019.
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IT IS SO ORDERED:
/s/ Natasha M. Gebrael
NATASHA M. GEBRAEL (Bar No. 14367)
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________________________________
RICHARD F. BOULWARE, II
UNITED STATES DISTRICT JUDGE
DATED this
27th day of March, 2019.
Page 2 of 3
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CERTIFICATE OF SERVICE
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I hereby certify that I electronically filed the foregoing UNOPPOSED MOTION FOR
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ENLARGEMENT OF TIME TO FILE EXHIBITS IN SUPPORT OF RESPONDENTS’ ANSWER
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TO BRADFORD’S SECOND AMENDED PETITION with the Clerk of the Court by using the
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CM/ECF system on March 25, 2019.
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I certify that some of the participants in the case are not registered CM/ECF users. I have mailed
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the foregoing document by First-Class Mail, postage prepaid, or have dispatched it to a third party
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commercial carrier for delivery within 3 calendar days to the following non-CM/ECF participants:
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Jeremy Baron, Esq.
Megan Hoffman, Esq.
Federal Public Defender
411 East Bonneville, Suite 250
Las Vegas, NV 89101
jeremy_baron@fd.org
megan_hoffman@fd.org
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/s/_C. Ross____
An employee of the Office of the Attorney General
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