Robbins v. Howell, et al.

Filing 30

ORDER granting 29 Motion to Extend Time to File Response to 20 Amended Petition for Writ of Habeas Corpus. Attorney General of the State of Nevada answer due 2/3/2021; Jerry Howell answer due 2/3/2021. Signed by Judge Andrew P. Gordon on 1/5/2021. (Copies have been distributed pursuant to the NEF - HAM)

Case 2:19-cv-02153-APG-VCF Document 30 Filed 01/05/21 Page 1 of 4

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AARON D. FORD
Attorney General
Jaimie Stilz (Bar No. 13772)
Deputy Attorney General
State of Nevada
Office of the Attorney General
555 E. Washington Ave., Ste. 3900
Las Vegas, Nevada 89101-1068
[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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DANIEL ROBBINS,

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Petitioner,
vs.

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Case No. 2:19-cv-02153-APG-VCF
MOTION FOR ENLARGEMENT OF TIME
TO FILE RESPONSE TO FIRST AMENDED
PETITION FOR WRIT OF HABEAS
CORPUS (ECF NO. 20)

JERRY HOWELL, et al.,
(FOURTH REQUEST)
Respondent(s).

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Respondents move this Court for an enlargement of time of 30 days from the current due date of

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January 4, 2021, up to and including February 3, 2021, in which to file their Response to the First

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Amended Petition for Writ of Habeas Corpus (ECF No. 20). This Motion is made pursuant to Fed. R.Civ.

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P. 6(b) and Rule 6-1 of the Local Rules of Practice and is based upon the attached declaration of counsel.

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This is the fourth enlargement of time sought by Respondents, and the request is brought in good

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faith and not for the purpose of delay.
DATED: January 4, 2021.

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Submitted by:

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AARON D. FORD
Attorney General

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By:

/s/ Jaimie Stilz
Jaimie Stilz (Bar. No. 13772)
Deputy Attorney General

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Page 1 of 4

Case 2:19-cv-02153-APG-VCF Document 30 Filed 01/05/21 Page 2 of 4

DECLARATION OF JAIMIE STILZ

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STATE OF NEVADA

)
) ss:
COUNTY OF CLARK )

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I, JAIMIE STILZ, 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 am assigned to

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represent Respondents in Daniel Robbins v. Jerry Howell, et al., Case No. 2:19-cv-02153-APG-VCF, and

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as such, have personal knowledge of the matters contained herein.
2.

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This is my fourth request for an extension to file the Response to Petitioner’s First

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Amended Petition for Writ of Habeas Corpus (ECF No. 20), and the instant Motion is made in good faith

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and not for the purpose of delay.
3.

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The Response to the First Amended Petition for Writ of Habeas Corpus (ECF No. 20) is

currently due on January 4, 2021.
4.

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I am unable with due diligence to timely complete the Response herein. My office is still

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contending with the technological difficulties and issues ensuing from the COVID-19 pandemic,

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including still working from home as a result of the significant number of cases which are now once more

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on the rise again. Additionally, I am still attempting to manage severe on-going medical issues. Between

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these issues and the intervening holidays over the past several weeks, I have been diligently striving to

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resolve and/or work around these issues but they have significantly impacted my ability to complete the

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Response in a timely fashion, thus necessitating an extension.
5.

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In seeking this extension, I am taking into consideration additional obligations and

deadlines for both myself and my supervising senior colleague.
6.

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Based on the foregoing, I respectfully request an enlargement of time of 30 days, up to

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and including February 3, 2021, to file the Response to the First Amended Petition for Writ of Habeas

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Corpus (ECF No. 20).

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...

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...

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...

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Case 2:19-cv-02153-APG-VCF Document 30 Filed 01/05/21 Page 3 of 4

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I declare under penalty of perjury that the foregoing is true and correct.

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Executed on this 4th day of January, 2021.

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/s/ Jaimie Stilz
Jaimie Stilz (Bar No. 13772)
Deputy Attorney General

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IT IS SO ORDERED:
Dated:__________________
January 5, 2021
________________________
ANDREW P. GORDON
UNITED STATES DISTRICT JUDGE

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Case 2:19-cv-02153-APG-VCF Document 30 Filed 01/05/21 Page 4 of 4

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CERTIFICATE OF SERVICE

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I hereby certify that I am an employee of the Office of the Nevada Attorney General and that on

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this 4th day of January, 2021, I served a copy of the foregoing UNOPPOSED MOTION FOR

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ENLARGEMENT OF TIME TO FILE RESPONSE TO FIRST AMENDED PETITION FOR

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WRIT OF HABEAS CORPUS (ECF NO. 20), by U.S. District Court CM/ECF electronic filing, to:

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Lisa A. Rasmussen, Esq.
THE LAW OFFICES OF KRISTINA
WILDEVELD & ASSOCIATES
550 E. Charleston Blvd., Suite A
Las Vegas, NV 89104
[e-mail]

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/s/
Jaimie Stilz
An employee of the Office of the Attorney General

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