Bradford v. Baker

Filing 197

ORDER Granting 196 Motion to Extend Time to reply to 195 Response to 194 Motion to Strike Replies due by 12/6/2022. Signed by Judge Richard F. Boulware, II on 11/29/2022. (Copies have been distributed pursuant to the NEF - LOE)

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AARON D. FORD
Attorney General
GERRI LYNN HARDCASTLE (Bar No. 13142)
Deputy Attorney General
State of Nevada
Office of the Attorney General
100 North Carson Street
Carson City, Nevada 89701-4717
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorney for Respondents

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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JULIUS BRADFORD,

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Case No. 2:13-cv-1784-RFB-EJY
MOTION FOR ENLARGEMENT OF TIME
TO FILE REPLY IN SUPPORT OF MOTION
TO STRIKE (FIRST REQUEST)

Petitioner,

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vs.

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WILLIAM GITTERE, et al.,

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Respondents.

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

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and Gerri Lynn Hardcastle, Deputy Attorney General, hereby move this Court for a seven-day

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enlargement of time, or up to and including Tuesday, December 6, 2022, to file and serve their reply in

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support of their motion to strike (ECF No. 194) Petitioner Julius Bradford’s (Bradford) motion to

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correct pleadings (ECF No. 193).

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This motion is based on the provisions of Rule 6(b)(1)(A) of the Federal Rules of Civil
Procedure and the attached Declaration of Counsel, as well as all other papers on file herein.
Respondents have not requested any previous enlargements of time to reply. Respondents make
this motion in good faith and not for the purpose of unnecessary delay.
RESPECTFULLY SUBMITTED this 28th day of November, 2022.
AARON D. FORD
Attorney General
By:

/s/ Gerri Lynn Hardcastle
GERRI LYNN HARDCASTLE (Bar No. 13142)
Deputy Attorney General
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AARON D. FORD
Attorney General
GERRI LYNN HARDCASTLE (Bar No. 13142)
Deputy Attorney General
State of Nevada
Office of the Attorney General
100 North Carson Street
Carson City, Nevada 89701-4717
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorney for Respondents

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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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CALVIN JOHNSON, et al.,

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DECLARATION OF COUNSEL (IN
SUPPORT OF MOTION FOR
ENLARGEMENT OF TIME TO REPLY IN
SUPPORT OF MOTION TO STRIKE (FIRST
REQUEST))

Respondents.
I, Gerri Lynn Hardcastle, hereby state, based on personal knowledge and/or information and

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Case No. 2:13-cv-01784-RFB-EJY

belief, that the assertions of this declaration are true:
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I am a Deputy Attorney General employed by the Attorney General’s Office of the State

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of Nevada in the Post-Conviction Division, and I make this declaration in support of Respondents’

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motion for enlargement of time.
2.

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Through this motion, I am requesting an enlargement of time of seven days, or up to and

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including Tuesday, December 6, 2022, to file Respondents’ reply in support of their motion to strike

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Bradford’s motion to correct pleadings. This is Respondents’ first request for an enlargement of time to

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reply.

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3.

My clients’ reply is currently due tomorrow, November 29, 2022.

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4.

I am unable to complete my clients’ reply today because I am currently out-of-town on

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annual leave and will not return to work until Wednesday, November 30, 2022. I have been out-of-

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town since Sunday, November 20, 2022, so I was unaware Bradford had filed his opposition to the

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///
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motion to strike until my Division Chief alerted me of the deadline earlier today. I have now read

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Bradford’s opposition, and I will be able to file the reply by next Tuesday, December 6, 2022.

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5.

I am moving for this enlargement of time in good faith and not for the purpose of unduly

delaying the ultimate disposition of this case.
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Pursuant to 28 U.S.C. § 1746, I hereby certify, under penalty of perjury, that the

foregoing is true and correct.
Executed on this 28th day of November, 2022.
By:

/s/ Gerri Lynn Hardcastle
GERRI LYNN HARDCASTLE (Bar No. 13142)
Deputy Attorney General

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IT IS SO ORDERED:

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__________________________
RICHARD F. BOULWARE, II
United States District Judge
DATED this 29th day of November, 2022.

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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 and that on this 28th day of

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November, 2022, I served a copy of the foregoing MOTION FOR ENLARGEMENT OF TIME TO

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FILE REPLY IN SUPPORT OF MOTION TO STRIKE (FIRST REQUEST by U.S. District

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Court CM/ECF electronic filing to:

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Jeremy C. Baron
Assistant Federal Public Defender
411 E. Bonneville Ave. Ste. 250
Las Vegas, Nevada 89101
[e-mail]

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/s/ Carrie L. Crago

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