Bradford v. Baker

Filing 94

ORDER Granting 93 Third Motion to Extend Time Re: 67 Second Amended Petition for Writ of Habeas Corpus. Respondents' answer due 2/7/2019. Signed by Judge Richard F. Boulware, II on 11/14/2018. (Copies have been distributed pursuant to the NEF - SLD)

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ADAM PAUL LAXALT
Attorney General
Heidi Parry Stern (Bar. No. 8873)
Chief Deputy Attorney General
State of Nevada
Office of the Attorney General
555 E. Washington Ave., #3900
Las Vegas, NV 89101-1068
[phone] (phone)
[phone] (fax)
[e-mail]

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Attorneys 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-01784-RFB-GWF

Petitioner,

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vs.

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WILLIAM GITTERE, et al.

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MOTION FOR EXTENSION OF TIME TO
FILE ANSWER TO SECOND AMENDED
PETITION FOR WRIT OF HABEAS CORPUS

Respondents.

(ECF NO. 67)
(THIRD REQUEST)

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Respondents hereby request an extension of time of 90 days, up to and including February 7,

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2019, within which to file their answer to Petitioner Julius Bradford’s Second Amended Petition for Writ

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of Habeas Corpus. ECF No. 67. The current due date to file the answer is November 9, 2018. This motion

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is supported by the attached declaration of undersigned counsel.

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Respectfully submitted: November 9, 2018.
ADAM PAUL LAXALT
Attorney General
By: /s/ Heidi Parry Stern
Heidi Parry Stern
Chief Deputy Attorney General

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DECLARATION OF HEIDI PARRY STERN
STATE OF NEVADA )
) ss:
COUNTY OF CLARK )

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I, HEIDI PARRY STERN, 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 the State of Nevada; qualified and admitted to

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practice before this Court; employed as a Chief Deputy Attorney General in the Office of the Nevada

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Attorney General; and pursuant to this employment, I have been assigned to represent Respondents in

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Julius Bradford v. Timothy Filson, et al., 2:13-cv-01784-RFB-GWF, and as such, have personal

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knowledge of the matters contained herein.

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2.

This extension is necessary due to my preparation for oral argument in the Ninth Circuit

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in Robert Jones v. Jack Palmer, et al., Case No. 17-15575, which took place on October 9, 2018, and

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Alquandre H. Turner v. Renee Baker, Warden, et al., Case No. 17-72044, which will be taking place on

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November 16, 2018.

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3.

In addition, our office has been short staffed over the past few months due to the retirement

of one of the attorneys in our unit and the difficulty in finding a replacement for him.

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4.

That the answer is currently due to be filed on November 9, 2018.

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5.

Respondents request 90 days to file their answer, up to and including February 7, 2019.

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6.

I have contacted opposing counsel, and he has no objection to this request for extension.

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7.

This is Respondents’ third motion for extension of time to file their answer to the Second

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Amended Petition for Writ of Habeas Corpus.

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8.

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FURTHER DECLARANT SAYETH NAUGHT.

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DATED: this 9th day of November, 2018

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This motion for extension of time is made in good faith and not for the purpose of delay.

IT IS SO ORDERED:

/s/ Heidi Parry Stern
Heidi Parry Stern (Bar No. 8873)
Chief Deputy Attorney General

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________________________________
RICHARD F. BOULWARE, II
28 UNITED STATES DISTRICT JUDGE
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DATED this 14th day of November, 2018.
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CERTIFICATE OF SERVICE

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I hereby certify that I electronically filed the foregoing Motion for Extension of Time to File

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Answer to Second Amended Petition for Writ of Habeas Corpus (ECF No. 67) (Third Request) with the

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Clerk of the Court by using the CM/ECF system on November 9, 2018.

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The following participants in this case are registered electronic filing systems users and will be
served electronically:
Jeremy Baron, Esq.
Megan Hoffman, Esq.
Office of the Federal Public Defender
411 East Bonneville Ave., Suite 250
Las Vegas, NV 89101
[e-mail]
[e-mail]

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/s/ R. Carreau
An employee of the Office of the Attorney General

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