Dixon v. Baker et al

Filing 99

ORDER granting ECF No. 95 Motion to Extend Time (second request). Respondents will have up to an including March 11, 2022, in which to file the response to the motion for evidentiary hearing (EFCF No. 90 ). Responses due by 3/11/2022. Signed by Judge Robert C. Jones on 3/1/2022. (Copies have been distributed pursuant to the NEF - HKL)

Case 3:13-cv-00248-RCJ-CSD Document 99 Filed 03/01/22 Page 1 of 3

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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TERRY D. DIXON,

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Petitioner,

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vs.

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RENEE BAKER, et al.,

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Respondents.

Case No. 3:13-cv-00248-RJC-CSD
ORDER GRANTING UNOPPOSED
MOTION FOR ENLARGEMENT OF
TIME TO FILE RESPONSE TO
MOTION FOR EVIDENTIARY
HEARING
(ECF NO. 90)

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(SECOND REQUEST)

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Respondents move this Court for an enlargement of time of 14 days from the current due date of

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February 25, 2022, up to an including March 11, 2022, in which to file their response to the motion for

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evidentiary hearing (ECF No. 90). This Motion is made pursuant to Fed. R. Civ. P. 6(b) and Rule 6-1 of

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the Local Rules of Practice and is based upon the attached declaration of counsel. This is the second

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enlargement of time sought by Respondents to file the response, and the request is brought in good faith

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and not for the purpose of delay.

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DATED February 25, 2022

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Submitted by:

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AARON D. FORD
Attorney General

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By: /s/ Jessica Perlick
Jessica Perlick (Bar. No. 13218)
Senior Deputy Attorney General

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Case 3:13-cv-00248-RCJ-CSD Document 99 Filed 03/01/22 Page 2 of 3

DECLARATION OF JESSICA PERLICK

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STATE OF NEVADA

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) ss:
COUNTY OF CLARK )

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I, JESSICA PERLICK, being first duly sworn under oath, deposes and states 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 Senior Deputy Attorney General in the Office of the Nevada Attorney General. I have

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been assigned to represent Respondents in Terry D. Dixon v. Renee Baker, et al., Case No. 3:13-cv-

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00248-RJC-CSD, and as such, have personal knowledge of the matters contained herein.

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2.

This motion is made in good faith and not for the purposes of delay.

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3.

The deadline to file the response to Dixon’s motion for evidentiary hearing (ECF No. 90)

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is February 25, 2022.
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I previously requested an extension for this response, as well as a reply in support of the

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motion to dismiss Dixon’s amended petition, to account for already-existing deadlines including a reply

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brief in Murray v. Howell, 21-15104, responses in Shue v. Johnson, 2:20-cv-02025; Guevara-Pontifes v.

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Baker, 3:20-cv-00652; and Palmer v. Gittere, 3:18-cv-00245; and an answering brief in Conners v.

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Hutchings, 21-15693; as well as the time needed to provide coverage during colleagues’ annual leave.

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5.

I have been unable with due diligence to complete the response herein. In my previous

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request, I referenced the need to prioritize an answer in Guy v. Baca, 2:11-cv-01809, which is

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unfortunately still in progress. In January I was dealing with a health issue that was impacting my work.

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Although I have since recovered, I am still working to catch up on outstanding deadlines that were

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impacted, including the answer in Guy.

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6.

Finally, in addition to working to catch up on everything impacted by the health issues in

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January, last week I had oral argument in Murray v. Howell, 21-15104, so I also spent significant time

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preparing for that.

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7.

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I have communicated with counsel for Dixon regarding this request, and she indicated that

she does not object to this extension.
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I am filing a separate request for additional time to file the reply in support of the motion

to dismiss (ECF No. 71), seeking the same 14-day extension.

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Case 3:13-cv-00248-RCJ-CSD Document 99 Filed 03/01/22 Page 3 of 3

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9.

For the foregoing reasons, I respectfully request an enlargement of time of 14 days, up to

and including March 11, 2022, in which to file the response to the motion for evidentiary hearing.
Executed on February 25, 2022.

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/s/ Jessica Perlick
Jessica Perlick (Bar No. 13218)

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IT IS SO ORDERED:

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_____________________________________________
UNITED STATES DISTRICT JUDGE
Dated: March 1, 2022.

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