Opinion
2:13-cv-1784-RFB-EJY
11-29-2022
JULIUS BRADFORD, Petitioner, v. WILLIAM GITTERE, et al. Respondents.,
AARON D. FORD Attorney General GERRI LYNN HARDCASTLE (Bar No. 13142) Deputy Attorney General State of Nevada Attorney for Respondents
AARON D. FORD Attorney General GERRI LYNN HARDCASTLE (Bar No. 13142) Deputy Attorney General State of Nevada Attorney for Respondents
MOTION FOR ENLARGEMENT OF TIME TO FILE REPLY IN SUPPORT OF MOTION TO STRIKE (FIRST REQUEST)
RICHARD F. BOULWARE, II UNITED STATES DISTRICT JUDGE
Respondents, by and through counsel, Aaron D. Ford, Attorney General of the State of Nevada, and Gerri Lynn Hardcastle, Deputy Attorney General, hereby move this Court for a seven-day enlargement of time, or up to and including Tuesday, December 6, 2022, to file and serve their reply in support of their motion to strike (ECF No. 194) Petitioner Julius Bradford's (Bradford) motion to correct pleadings (ECF No. 193).
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.
JULIUS BRADFORD, Petitioner, v.
CALVIN JOHNSON, et al., Respondents
DECLARATION OF COUNSEL (IN SUPPORT OF MOTION FOR ENLARGEMENT OF TIME TO REPLY IN SUPPORT OF MOTION TO STRIKE (FIRST REQUEST))
I, Gerri Lynn Hardcastle, hereby state, based on personal knowledge and/or information and belief, that the assertions of this declaration are true:
1. I am a Deputy Attorney General employed by the Attorney General's Office of the State of Nevada in the Post-Conviction Division, and I make this declaration in support of Respondents' motion for enlargement of time.
2. Through this motion, I am requesting an enlargement of time of seven days, or up to and including Tuesday, December 6, 2022, to file Respondents' reply in support of their motion to strike Bradford's motion to correct pleadings. This is Respondents' first request for an enlargement of time to reply.
3. My clients' reply is currently due tomorrow, November 29, 2022.
4. I am unable to complete my clients' reply today because I am currently out-of-town on annual leave and will not return to work until Wednesday, November 30, 2022. I have been out-oftown since Sunday, November 20, 2022, so I was unaware Bradford had filed his opposition to the
motion to strike until my Division Chief alerted me of the deadline earlier today. I have now read Bradford's opposition, and I will be able to file the reply by next Tuesday, December 6, 2022.
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.
6. Pursuant to 28 U.S.C. § 1746, I hereby certify, under penalty of perjury, that the foregoing is true and correct.
IT IS SO ORDERED: