Opinion
2:13-cv-01304-APG-BNW
04-18-2023
JOHN MICHAEL FARNUM, Petitioner, v. ROBERT LEGRAND, et al., R pcnnnripntc
AARON D. FORD Attorney General Katrina A. Lopez Deputy Attorney General
AARON D. FORD Attorney General
Katrina A. Lopez Deputy Attorney General
UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE RESPONSE TO OPENING BRIEF ON REMAND (ECF NO. 91)
(FIRST REQUEST)
Respondents move this Court for an enlargement of time of 62 days from the current due date of April 18, 2023, up to and including June 19, 2023, in which to file their Response to Farnum's Opening Brief on Remand. ECF No. 91. This Motion is made pursuant to Fed.R.Civ.P. 6(b) and Rule 6-1 of the Local Rules of Practice and is based upon the attached declaration of counsel.
This is the first enlargement of time sought by Respondents and is brought in good faith and not for the purpose of delay.
DECLARATION OF KATRINA A. LOPEZ
I, Katrina A. Lopez, being first duly sworn under oath, depose and state as follows:
1. I am an attorney licensed to practice law in all courts within the State of Nevada and am employed as a Deputy Attorney General in the Office of the Nevada Attorney General. I have been assigned to represent Respondents in John Michael Farnum v. Robert LeGrand, et al., Case No. 2:13-cv-01304-APG-BNW, and as such, have personal knowledge of the matters contained herein.
2. This Motion is made in good faith and not for the purpose of delay
3. The Response to Farnum's Opening Brief is currently due on Tuesday, April 18, 2023.
4. Respondents have been unable with due diligence to timely complete the Response.
5. In the past few months, Respondents filed a motion to dismiss filed February 2, 2023 (Jerry E. Johnson v. Calvin Johnson, et al., Case No. 2:22-cv-00642-JAD-DJA); a reply in support of a motion to dismiss filed February 9, 2023 (Corry Alexis Hawkins. v. Calvin Johnson, et al., Case No. 2: 20-cv-01852-CDS-VCF); an answer filed March 9, 2023 (Delbert Charles Cobb v. E.K. McDaniels, et al., Case No. 3:15-cv-00172-MMD-CSD); a response in support of answer filed March 23, 2023 (Christopher Ryan Martin v. Tom Lawson, et al., Case No. 2:22-cv-00850-APG-VCF); an answer filed March 24, 2023 (Cory O'Neal Brewer v. William Reubart, et al., Case No. 3:20-cv-00396-MMD-CLB);a response to motion to strike filed April 7, 2023 (Christopher Ryan Martin v. Tom Lawson, et al., Case No. 2:22-cv-00850-APG-VCF); and various responses in state post-conviction cases.
6. Additionally, Respondents are reshuffling cases to accommodate various deadlines due to losing 3 Senior Deputy Attorney Generals and 5 Deputy Attorney Generals within a 15-month period. As a result, Respondents need additional time to complete the Response.
7. Respondents communicated with counsel for Farnum regarding this extension and she does not object to this request.
8. Based on the foregoing, Respondents respectfully request an enlargement of time of 62 days from the current due date, April 18, 2023, up to and including June 19, 2023, to file our Response to Farnum's Opening Brief.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on April 18, 2023.
Katrina A. Lopez (Bar. No. 13394) Deputy Attorney General
IT IS SO ORDERED: