Robbins v. Howell, et al.

Filing 34

ORDER granting 33 Motion to Extend Time to Respond Re: 20 Amended Petition for Writ of Habeas Corpus. Attorney General of the State of Nevada answer due 2/22/2021. Jerry Howell answer due 2/22/2021. Signed by Judge Andrew P. Gordon on 2/18/2021. (Copies have been distributed pursuant to the NEF - HAM)

Case 2:19-cv-02153-APG-VCF Document 34 Filed 02/18/21 Page 1 of 4

1
2
3
4
5
6
7

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

8

UNITED STATES DISTRICT COURT

9

DISTRICT OF NEVADA

10
11
12
13
14
15

Case No. 2:19-cv-02153-APG-VCF

DANIEL ROBBINS,
Petitioner,
vs.
JERRY HOWELL, et al.,

MOTION FOR ENLARGEMENT OF TIME
TO FILE RESPONSE TO FIRST AMENDED
PETITION FOR WRIT OF HABEAS
CORPUS (ECF NO. 20)
(SIXTH REQUEST)

Respondent(s).

16

Respondents move this Court for an enlargement of time of 5 days from the current due date of

17

February 17, 2021, up to and including February 22, 2021, in which to file their Response to the First

18

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

19

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

20

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

21
22

faith and not for the purpose of delay.
DATED: February 17, 2021.

23

Submitted by:

24

AARON D. FORD
Attorney General

25
26
27

By:

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

28

Page 1 of 4

Case 2:19-cv-02153-APG-VCF Document 34 Filed 02/18/21 Page 2 of 4

DECLARATION OF JAIMIE STILZ

1
2
3

STATE OF NEVADA

)
) ss:
COUNTY OF CLARK )

4

I, JAIMIE STILZ, 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 am assigned to

7

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

8

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

9

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

10

Petition for Writ of Habeas Corpus (ECF No. 20), and the instant Motion is made in good faith and not

11

for the purpose of delay.
3.

12
13

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

currently due on February 17, 2021.
4.

14

I am unable with due diligence to timely complete the Response herein. I am still in the

15

process of finalizing the Response. I have been facing and am currently still attempting to resolve severe

16

on-going medical issues, including emergency medical treatment this past weekend. I am also still dealing

17

with the continuing impact from COVID-19 and working from home. I have been diligently striving to

18

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

19

Response in a timely fashion,
5.

20
21

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

deadlines for both myself and my supervising senior colleague.

22

6.

I have spoken to counsel for Mr. Robbins, and she does not oppose this request.

23

7.

Based on the foregoing, I respectfully request an enlargement of time of 5 days, up to and

24

including February 22, 2021, to file the Response to the First Amended Petition for Writ of Habeas

25

Corpus (ECF No. 20).

26

...

27

...

28

...

Page 2 of 4

Case 2:19-cv-02153-APG-VCF Document 34 Filed 02/18/21 Page 3 of 4

1

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

2

Executed on this 17th day of February, 2021.

3

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

4
5
6
7
8
9

IT IS SO ORDERED:
February 18, 2021
Dated:__________________
________________________
ANDREW P. GORDON
UNITED STATES DISTRICT JUDGE

10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

Page 3 of 4

Case 2:19-cv-02153-APG-VCF Document 34 Filed 02/18/21 Page 4 of 4

1

CERTIFICATE OF SERVICE

2

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

3

this 17th day of February, 2021, I served a copy of the foregoing UNOPPOSED MOTION FOR

4

ENLARGEMENT OF TIME TO FILE RESPONSE TO FIRST AMENDED PETITION FOR

5

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

6
7
8
9

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

10
11
12

/s/ C. Martinez
An employee of the Office of the Attorney General

13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

Page 4 of 4