Bradford v. Baker

Filing 100

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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1 2 3 4 5 6 7 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 8 DISTRICT OF NEVADA 9 10 JULIUS BRADFORD, 11 Petitioner, 12 vs. 13 WILLIAM GITTERE, et al., 14 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) 15 16 Respondents move this Court for an enlargement of time of 7 days, up to and including April 1, 17 2019, in which to file their Index of Exhibits in Support of Respondents’ Answer to Bradford’s Second 18 Amended Petition for Writ of Habeas Corpus. This Motion is made pursuant to Fed. R. Civ. P. 6(b) and 19 Rule 6-1 of the Local Rules of Practice and is based upon the attached affidavit of counsel. 20 21 22 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 23 Submitted by: 24 AARON D. FORD Attorney General 25 26 27 By: /s/ Natasha M. Gebrael NATASHA M. GEBRAEL (Bar. No. 14367) Deputy Attorney General 28 Page 1 of 3 1 2 3 DECLARATION OF NATASHA M. GEBRAEL STATE OF NEVADA ) ) ss: COUNTY OF CLARK ) 4 I, NATASHA M. GEBRAEL, being first duly sworn under oath, depose and state as follows: 5 1. I am an attorney licensed to practice law in all courts within the State of Nevada, and am 6 employed as a Deputy Attorney General in the Office of the Nevada Attorney General. I have been 7 assigned to represent Respondents in Julius Bradford v. William Gittere, et al., Case No. 2:13-cv-01784- 8 RFB-GWF, and as such, have personal knowledge of the matters contained herein. 9 The Response to the Second Amended § 2254 Petition (ECF No. 67) is currently due on 10 March 25, 2019. I timely filed my response, but am requesting a brief extension of time in which to file 11 the accompanying Index of Exhibits. 12 4. I have been unable with due diligence to timely file the Index, which contains a total of 13 580 exhibits. Due to the large number of exhibits, it is taking a significant amount of time to individually 14 compress the exhibits to comply with the file-size restrictions, and break the total exhibits into the 15 appropriate volume sizes. And, because one of our legal assistants was recently transferred to a new unit, 16 the two remaining assistants are not only assisting me with the compression of the Index, but currently 17 covering all administrative duties for our entire unit. In light of these concerns, I am requesting a brief 18 enlargement of time in which to file the Index. 19 5. 20 has no objection. 21 6. 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 22 including April 1, 2019, to file the Index of Exhibits in support of Respondent’s Answer. This is my fifth 23 request for an extension in this case, but the first request for extension in terms of the Index of Exhibits. 24 I declare under penalty of perjury that the foregoing is true and correct. 25 Executed on March 25, 2019. 26 IT IS SO ORDERED: /s/ Natasha M. Gebrael NATASHA M. GEBRAEL (Bar No. 14367) 27 28 ________________________________ RICHARD F. BOULWARE, II UNITED STATES DISTRICT JUDGE DATED this 27th day of March, 2019. Page 2 of 3 1 CERTIFICATE OF SERVICE 2 I hereby certify that I electronically filed the foregoing UNOPPOSED MOTION FOR 3 ENLARGEMENT OF TIME TO FILE EXHIBITS IN SUPPORT OF RESPONDENTS’ ANSWER 4 TO BRADFORD’S SECOND AMENDED PETITION with the Clerk of the Court by using the 5 CM/ECF system on March 25, 2019. 6 I certify that some of the participants in the case are not registered CM/ECF users. I have mailed 7 the foregoing document by First-Class Mail, postage prepaid, or have dispatched it to a third party 8 commercial carrier for delivery within 3 calendar days to the following non-CM/ECF participants: 9 10 11 12 13 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 14 15 /s/_C. Ross____ An employee of the Office of the Attorney General 16 17 18 19 20 21 22 23 24 25 26 27 28 Page 3 of 3

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